LI Network
Published on: January 4, 2024 at 21:36 IST
The recent Supreme Court judgment emphasized the significance of maintaining judicial discipline, highlighting that when a coordinate Bench of the same High Court issues a decision, it is to be adhered to and considered binding on subsequent benches.
The Court underscored the importance of the rule of ‘Judicial Discipline and Propriety’ and the Doctrine of precedents, promoting consistency and certainty in judicial decisions.
In a case presided over by Justices Vikram Nath and Rajesh Bindal, involving a civil suit initiated in 1995 for possession declaration and injunction, the Court analyzed the intricacies of prior litigation.
The appellant filed the suit based on the dismissal of a 1976 suit by the respondents for her ejectment. Despite the 1976 suit’s dismissal at all levels up to the High Court in 1990, subsequent issues arose regarding the extent of the property under dispute.
During the 1995 suit proceedings, the respondents contended ownership of 8 cents of land, distinct from the prior suit. The Trial Court decreed in favor of the appellant for the area containing her house, while dismissing the claim over the remaining property.
The High Court initially ruled in favor of the appellant but later restored the Trial Court’s decree in a subsequent appeal, leading to the matter reaching the Supreme Court.
The Supreme Court stressed the High Court’s consistent recording of the suit property comprising 8 cents of land in its earlier judgment. Any interpretation deviating from this clear judgment would signify judicial indiscipline, according to the Court.
Additionally, the Court referenced the doctrine of merger, asserting that judgments from prior litigation are absorbed into earlier conclusive judgments, prohibiting contradictory positions by lower courts.
The Supreme Court concluded that the Trial Court and subsequent High Court actions in the second round of litigation contradicted the established judicial discipline by opposing the earlier High Court judgment.
Consequently, the appeal was allowed, and the contested judgment was overturned in light of these violations of judicial discipline.
