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The Supreme Court of India delivered a series of significant judgments in 2024 through its Constitution Benches, addressing crucial socio-legal issues with nationwide ramifications. A total of twelve Constitution Bench judgments were delivered, comprising three 9-judge benches, three 7-judge benches, and six 5-judge benches. These decisions significantly impacted various aspects of Indian law and governance, ranging from electoral reforms and legislative privileges to taxation and the rights of minority communities. The sheer volume and importance of these rulings solidify 2024 as a pivotal year for judicial pronouncements in India. The consistent involvement of Chief Justice of India DY Chandrachud across multiple benches underscores his leadership and the Court's proactive approach to resolving long-standing legal ambiguities.
One of the most impactful decisions was the invalidation of the Electoral Bonds Scheme. The 5-judge bench, in Association for Democratic Reforms & Anr. v. Union of India & Ors., determined that the anonymity afforded by electoral bonds violated the right to information enshrined in Article 19(1)(a) of the Constitution. This ruling addressed concerns about transparency and accountability in political funding, tackling issues of potential corruption and undue influence. The Court considered the non-disclosure of information regarding voluntary contributions to political parties, analyzing its compatibility with the principles of free and fair elections. The decision overturned a system perceived by many as facilitating opaque funding practices, potentially impacting the dynamics of political campaigning and party financing in the future. The dissenting opinions, if any, would be valuable to further understand the nuances of the ruling and potential implications for future amendments to the political financing system.
Another landmark judgment addressed the automatic vacation of High Court stay orders. The 2018 Asian Resurfacing judgment, mandating the automatic expiry of stay orders after six months, was overturned in High Court Bar Association Allahabad v. State Of Uttar Pradesh & Ors. The 5-judge bench argued against imposing time-bound schedules on courts, emphasizing that each court’s caseload and circumstances vary. This ruling acknowledged the practical challenges faced by overburdened courts and prioritizes judicial discretion in managing cases. This decision aimed to enhance judicial efficiency while respecting the autonomy of constitutional courts in managing their individual workloads and priorities. The Court likely weighed the potential for injustice caused by arbitrarily imposed deadlines against the need for timely resolution of legal disputes, aiming to strike a balance between these competing concerns.
The 7-judge bench in Sita Soren vs Union Of India overturned the 1998 PV Narasimha Rao judgment concerning legislative privileges. The Court held that legislative immunity under Articles 105(2) and 194(2) does not extend to bribery. The court's assertion that the crime of bribery is complete upon acceptance of the bribe, regardless of subsequent legislative action, clarified the scope of immunity enjoyed by legislators. This decision aims to combat corruption within legislative bodies, establishing a clear legal precedent against accepting bribes, even if no legislative act is undertaken as a result of the bribe. This represents a significant shift in judicial interpretation, potentially strengthening mechanisms for prosecuting corruption among public officials. The detailed analysis of the paradoxical situation created by the earlier judgment demonstrates the Court's concern for upholding legal consistency and ensuring the integrity of the legislative process.
The 9-judge bench case, Mineral Area Development Authority v. M/S Steel Authority Of India & Ors, addressed the crucial question of state power to tax mineral rights. The 8:1 majority ruling affirmed the states' right to levy taxes on mineral rights, despite the existence of the Mines and Minerals (Development and Regulation) Act 1957. This decision had significant financial ramifications for both state governments and mining companies, impacting revenue distribution and potentially leading to adjustments in mining operations and taxation policies. The differing opinions of the judges in the 9-judge bench highlight the complex interplay between state and central government powers within a federal framework. The decision's retrospective application, up to April 1, 2005, demonstrates the Court’s intention to address past injustices and ensure fiscal accountability. This judgment could potentially lead to significant financial adjustments and re-negotiations within the mining sector.
The permissibility of sub-classification within Scheduled Castes for reservations was addressed by a 7-judge bench in State Of Punjab And Ors. v Davinder Singh And Ors. The 6:1 majority decision allowed sub-classification to grant separate quotas for more backward groups within the SC category, but clarified that this should not lead to 100% reservation for any sub-class and must be justified by empirical data. This ruling attempts to balance the objective of affirmative action with the need to ensure equitable distribution of benefits among various groups within the already reserved category. The dissenting opinion emphasized the limitations imposed by Article 341 on the state's power to alter the Presidential list of Scheduled Castes. The implications of this decision will undoubtedly shape future reservation policies and their implementation across various states. The majority's suggestion to identify a ‘creamy layer’ within SC and ST quotas might also add a new layer of complexity to future reservation discussions.
The constitutional validity of Section 6A of the Citizenship Act 1955, which recognizes the Assam Accord, was upheld by a 4:1 majority in Re: Section 6A Citizenship Act 1955. The Court acknowledged the political and humanitarian context, and the complexity of addressing illegal immigration, considering the balancing act between protecting the local population and addressing humanitarian needs, within a constitutional framework. The majority view deemed the March 25, 1971, cut-off date rational, placing it within the historical context of the Bangladesh War. The dissenting opinion highlights the potential for a law, valid at its enactment, to become flawed over time due to changing circumstances. The court's rationale touches upon the sensitive issue of citizenship and national identity, emphasizing the reconciliation of national interest with the welfare of migrant populations.
The 9-judge bench in State of U.P. v. M/S Lalta Prasad Vaish ruled on the states' power to regulate industrial alcohol under the term 'intoxicating liquor.' The 8:1 majority concluded that the term encompasses industrial alcohol, even if not directly fit for human consumption, expanding the scope of state regulatory powers. The dissenting opinion provided a narrower interpretation of the term “intoxicating liquor”, emphasizing the importance of the product’s intended use. The judgment significantly impacts the states’ ability to regulate alcohol production and distribution, potentially influencing taxation policies and regulations within the liquor industry. This decision could impact the alcohol manufacturing, distribution, and taxation framework of states, prompting potential review of existing laws and regulations.
The 9-judge bench case, Property Owners Association v. State of Maharashtra, addressed whether all private property constitutes 'material resources of the community' subject to equitable redistribution under Article 39(b). The 7:2 majority decision clarified that not all private property falls under this purview; only those that qualify as 'material resources' and 'of the community' are subject to equitable redistribution under Article 39(b). The Court established important distinctions between personal and community resources. The dissenting opinions emphasized the socio-economic context of Article 39(b) and the persisting inequalities. This decision may significantly impact future debates surrounding land reforms and resource allocation, specifying the applicability of the Directive Principles of State Policy to privately owned property.
In M/S. Bajaj Alliance General Insurance Co. Ltd. v. Rambha Devi & Ors, a 5-judge bench clarified that LMV license holders can drive transport vehicles under 7500 kg without additional endorsements, provided the gross weight remains below the limit. The absence of evidence linking LMV license holders to higher accident rates played a role in the decision. This judgment may simplify licensing requirements and potentially reduce administrative burden. The court likely considered the practical implications of requiring additional endorsements and weighed the costs against potential safety concerns, concluding that a more streamlined approach was warranted.
The ruling in Tej Prakash Pathak And Ors. v. Rajasthan High Court And Ors emphasized the importance of stability in recruitment processes. A 5-judge bench held that eligibility criteria cannot be altered mid-process unless the rules explicitly permit it, ensuring fairness and transparency in public appointments. This decision reinforces principles of procedural fairness in the hiring process by preventing unexpected changes that might disadvantage candidates. The Court addressed the potential for arbitrariness and injustice if rules can be changed during an ongoing selection process.
The 7-judge bench in Aligarh Muslim University Through Its Registrar Faizan Mustafa v. Naresh Agarwal addressed the minority status of Aligarh Muslim University (AMU). The 4:3 majority overturned a previous judgment that barred institutions incorporated by statute from claiming minority status, referring the specific question of AMU’s minority status to a regular bench. The differing opinions reveal varying interpretations of the term 'establishment' and the necessary criteria for an institution to be considered a minority institution under Article 30. This leaves the question of AMU's minority status to a regular bench, requiring further examination of its establishment and administration. This decision, with its extensive discussion of the legal and historical context, emphasizes the complexity of defining minority status in the context of educational institutions.
Finally, the 5-judge bench in Central Organisation For Railways Electrification v. M/S ECI Spic Smo MCML (JV) A Joint Venture Company invalidated clauses in public-private contracts allowing PSUs to unilaterally appoint arbitrators. While PSUs can maintain panels, they cannot compel the selection of an arbitrator from that panel, upholding principles of fairness and ensuring both sides have an equal say in the selection of an arbitrator. This ruling prevents potential conflicts of interest and enhances the impartiality of the arbitration process. The partial dissent highlighted the importance of party autonomy in contract law and the need for courts to respect agreed-upon arbitration processes within limits of fairness and equity.
Source: 2024 Round-Up| Constitution Bench Decisions Of Supreme Court