Allahabad High Court Upholds Doctrine of Finality in Landmark Judgement Review

LI Network

Published on: December 06, 2023 at 12:30 IST

The Allahabad High Court, presided over by Justices Saumitra Dayal Singh and Shiv Shanker Prasad, emphasized the paramount importance of the doctrine of finality of adjudication in the legal system.

The Court, while declining to quash an 11-year-old judgment in review, asserted that the sanctity attached to judgments that have achieved finality outweighs concerns regarding their accuracy or correctness.

The bench, in its pronouncement, stated, “The doctrine of finality of adjudication often eclipses or overpowers concerns or considerations that otherwise exist in favor of accuracy or correctness of judgments.”

The case in question originated in 2013 when the writ Court directed the State Government to ensure non-practising allowances for Medical Officers, including Ayurvedic, Allopathic, and Homeopathic Medical Officers, governed by 1953 Rules. The Supreme Court, in 2014, dismissed a Special Leave Petition against this order.

Subsequently, a dispute arose over the payment of non-practising allowance to private respondents practicing Ayurvedic medicine without the required qualifications. Despite multiple rounds of litigation, the High Court’s order in favor of the private respondents was upheld by the Supreme Court in 2021.

The Court noted that the applicants raised objections long after the judgment’s finality, alleging non-compliance with certain rules. However, the Court observed that the State failed to present this argument during previous rounds of litigation, casting doubt on the sincerity of the objections raised.

While acknowledging the Court’s authority to condone delays, the bench maintained that no compelling reasons were presented to disturb the finality achieved by the judgment. The Court held, “Archival judgments are not to be dug out to test their correctness or to correct any error of law that may be claimed to exist in them.”

In conclusion, the Allahabad High Court dismissed the review application, affirming the doctrine of finality and emphasizing that the accuracy or correctness of judgments should not undermine the stability and functionality of the legal system.

Case Title: Dr. Arvind Kumar And 3 Others v. State Of U.P. And 4 Others

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