The High Court of Madhya Pradesh has ruled that a complainant who files a grievance against a member of the District Judiciary regarding a judicial decision is merely a “messenger” and does not possess a legal right to demand that the High Court take administrative action. The court held that the decision to act upon such a complaint is the exclusive prerogative of the High Court. Consequently, the court dismissed a writ petition that challenged an unreasoned administrative order closing a complaint against a judge, imposing exemplary costs on the petitioner for filing a frivolous plea intended to pressure the judiciary.
Background of the Case
The petitioner, Rajneesh Chaturvedi, had filed a writ petition after the High Court, on its administrative side, directed that a complaint he filed against a Judicial Magistrate First Class be “filed” (closed as non-actionable) without providing any reasons.
The petitioner was prosecuted and convicted for an offence under Section 332 of the Indian Penal Code (voluntarily causing hurt to deter a public servant from his duty) by Ms. Khalida Tanveer, the then Judicial Magistrate First Class, Umariya. The judgment of conviction and sentence was passed on December 10, 2022. An appeal against this conviction is currently pending before the Court of Sessions at Umariya.
While the appeal was pending, on February 9, 2024, the petitioner submitted a complaint to the Registrar (Vigilance) of the High Court against the judicial officer. In his complaint, the petitioner alleged that the trial judge had assured him that he need not produce defence witnesses as the prosecution’s evidence was insufficient for a conviction. He claimed the judge told him that two prosecution witnesses had turned hostile and a third could not be cross-examined. The petitioner stated he was led to believe he would be acquitted and expressed surprise at his conviction, suggesting the judge was not conducting her court “honestly and fairly.”
This complaint was examined on the administrative side of the High Court, and upon perusal by the Lord Chief Justice, an order was passed to “file” the complaint. Aggrieved by this unreasoned administrative order dated May 18, 2024, the petitioner filed the present writ petition.
Arguments of the Petitioner
Appearing for the petitioner, Senior Advocate Shri Narinder Pal Singh Ruprah, assisted by Ms. Muskan Anand, argued that the High Court’s administrative order ought to have been a reasoned one. The core contention was that the order, which rejected the complaint, must be a “speaking order” that reflects the application of mind by the Chief Justice.
To support this argument, reliance was placed on the Supreme Court’s judgment in M/s Kranti Associates Pvt. Ltd. and another Vs. Masood Ahmed Khan and others (2010) 9 SCC 496. The petitioner’s counsel highlighted the Supreme Court’s observation that the distinction between administrative and quasi-judicial orders has blurred over time, and that an order by any authority affecting the rights of parties “must speak.” It was argued that reasons are an “indispensable component of a decision-making process” for judicial, quasi-judicial, and even administrative bodies.
Further, the petitioner cited Mohinder Singh Gill and another Vs. The Chief Election Commissioner, New Delhi and others (1978) 1 SCC 405, to argue that public orders must be construed objectively based on the language used in the order itself, not on subsequent explanations.
Court’s Analysis and Observations
The Division Bench, comprising Justice Atul Sreedharan and Justice Amit Seth, began its analysis by distinguishing the factual matrix of the cited Supreme Court precedents from the case at hand. The Court noted that while the cited judgments correctly establish that judicial, quasi-judicial, and administrative orders should be speaking orders, not every unreasoned administrative order is subject to challenge.
The Court laid down a crucial distinction, stating: “It is only those administrative orders, which give rise to a cause of action either by way of infringement of a statutory right or a constitutional right or any other legal right on account of which he has suffered an adversity by such an administrative order.” The Court clarified that to challenge a non-speaking administrative order, the petitioner must demonstrate a violation of a legal or constitutional right that gives rise to an “actionable claim.”
Defining the role of a complainant, the Court held that the authority to examine allegations against a District Judiciary judge is the “exclusively prerogative of the High Court.” It observed: “The complainant is not a person aggrieved when he or she intimates the High Court to act against the erring Judge for his judicial decision and the role of the complainant comes to an end with the complaint being preferred before the High Court.” The Court explicitly stated that whether to act against a judge on the administrative side is “not a legal right vested in the complainant, but the prerogative of the High Court under article 227.”
The Bench examined the petitioner’s complaint and found its contents to be “absolutely unverified, preposterous and fanciful.” It noted that the allegations of assurances from the judge lacked any specific details regarding time, date, or place.
The Court inferred the petitioner’s true motive, observing: “The actual reason appears to be to get a finding on the factual aspects relating to the case of the petitioner from this Court on the administrative side and use the same to influence the proceedings before the appellate Court, which is the Sessions Court at Umariya before whom the appeal is pending.”
Citing Haryana Financial Corporation and another Vs. Jagdamba Oil Mills and another (2002) 3 SCC 496, the Court cautioned against applying precedents like “Euclid’s theorems,” emphasizing that the ratio of a judgment cannot be understood in isolation from its facts.
In a scathing critique, the Court described the petitioner’s actions as an “attempt to overawe the District Judiciary by making frivolous and outrageous allegations.” The judgment included a powerful observation on the predicament of trial court judges:
“As it is, the Judges of the District Judiciary of Madhya Pradesh find themselves between the devil and the deep sea. On one side it has the High Court, literally breathing down their neck, instilling in them an unwarranted fear of action on the administrative side for their judicial orders resulting in acquittals and granting bails, and on the other hand of this spectrum, the district judiciary judges have to face such frivolous complaints from unscrupulous litigants who exploit the mindset of the High Court in order to bring pressure to bear upon the judges of the district judiciary. This is most deplorable and needs to be dealt with a heavy hand.”
Decision of the Court
Finding the petition to be a misuse of the judicial process, the High Court dismissed it. Furthermore, it imposed “exemplary cost of Rs.50,000/-” upon the petitioner, Rajneesh Chaturvedi. The petitioner was directed to deposit this amount in the account of the M.P. State Legal Services Authority within ten days, failing which it would be recovered as arrears of revenue.
