In a significant ruling, the Supreme Court of India has set aside the judgment of the Division Bench of the Allahabad High Court due to a lack of reasoning and has remanded the matter back for a fresh hearing. The case, Civil Appeal No. 3465 of 2023, was brought before the apex court by the State Project Director, UP Education for All Project Board & Others (Appellants) against Saroj Maurya & Others (Respondents).
Background of the Case
The appeal challenged the judgment dated April 18, 2022, passed by the Division Bench of the Allahabad High Court, which had upheld an earlier decision by a Single Judge dated December 21, 2021. The Single Judge’s ruling pertained to a batch of writ petitions concerning the recruitment process and appointments in the UP Education for All Project Board.
The appellants, represented by Ms. Garima Prashad, Senior Additional Advocate General, argued that the Division Bench failed to provide any independent reasoning or analysis, merely concurring with the Single Judge’s findings without addressing the substantive issues raised by both sides. The appeal noted that several Government Orders (G.Os.) issued by the State of Uttar Pradesh, including a crucial G.O. dated December 11, 2020, were not considered by the High Court, leading to a lack of application of mind in its decision-making process.
Legal Issues Involved
The Supreme Court addressed the critical issue of judicial reasoning in the High Court’s judgment. The Court emphasized that every litigant has a legitimate expectation of knowing the reasons behind the rejection or acceptance of their claims. The absence of such reasoning impairs the ability of the parties to challenge the decision effectively on appeal. It further noted that reasoned judgments ensure transparency and enhance public confidence in the judicial process.
The Supreme Court referred to its earlier ruling in CCT v. Shukla & Bros. (2010) 4 SCC 785, underscoring the necessity of reasoned judgments. The Court observed:
“Failure to give reasons amounts to a denial of justice… Reasons are the real live links to the administration of justice.”
Observations of the Court
The Supreme Court made several important observations regarding the necessity of reasoned judgments:
– Transparency and Accountability: The Court noted that reasoned judgments provide clarity to the litigants and facilitate a fair appeal process. It stated that “reason is the very life of law” and emphasized that a reasoned judgment avoids uncertainty and dissatisfaction among the litigants.
– Judicial Obligation: The Court reiterated that an unqualified obligation exists on all courts to provide reasoned judgments. The absence of reasons can lead to “uncertainty, dissatisfaction, and entirely different dimensions to the questions of law raised before the higher/appellate courts.”
Decision of the Court
After considering the submissions of both parties, the Supreme Court, in its judgment delivered by Justice Hima Kohli and Justice Sandeep Mehta, concluded that the judgment of the Division Bench of the Allahabad High Court could not be sustained due to its lack of reasoning. The Court held:
“In the absence of any reasoning in the impugned judgment, the same cannot be sustained.”
The Supreme Court quashed and set aside the impugned judgment of the High Court and remanded the case back to the Division Bench for fresh consideration. The Court directed the High Court to conduct a new hearing, allowing both parties to present their arguments afresh, including any subsequent developments in the case.
The Court ordered the parties to appear before the Roster Bench of the High Court on September 20, 2024, and requested the High Court to expedite the hearing of the appeal. Until the High Court disposes of the appeal, the interim orders passed by the Supreme Court will continue to operate. The Supreme Court also granted liberty to the respondents and intervenors to seek modification or vacation of these interim orders, if necessary.
Case Details
– Case Title: State Project Director, UP Education for All Project Board & Ors. vs. Saroj Maurya & Ors.
– Case Number: Civil Appeal No. 3465 of 2023
– Bench: Justice Hima Kohli and Justice Sandeep Mehta
– Appellants’ Counsel: Ms. Garima Prashad (Senior Additional Advocate General), Mr. Krishnanand Pandeya, Mr. Divyanshu Sahay, Mr. Yash Kirti Kumar Bharti
– Respondents’ Counsel: Mr. Sanjoy Ghose (Senior Advocate), Ms. Mayuri Raghuvanshi, Mr. Vyom Raghuvanshi, Ms. Akanksha Rathore, Mr. Mohnish Nirwan, and others
