The Supreme Court on Monday expunged critical observations made by the Madhya Pradesh High Court against a special trial court judge, ruling that the “hasty conclusion” accusing the judicial officer of “intellectual dishonesty” was “totally unwarranted.”
A bench comprising Chief Justice Surya Kant and Justice Joymalya Bagchi set aside the High Court’s adverse remarks, noting that the findings were “uncalled for” and “out of context.”
The primary legal issue before the Supreme Court was whether the Madhya Pradesh High Court was justified in making personal and professional remarks against a Special Judge and a Public Prosecutor while reversing a conviction in a sexual assault case. The High Court had accused the judge of “intellectual dishonesty” for allegedly overlooking evidence that suggested the victim was a consenting adult.
Background of the Case
The matter originated from a trial conducted under the Protection of Children from Sexual Offences (POCSO) Act. The Special Court judge had convicted an individual in a sexual assault case, leading to the accused serving over three years in prison.
Upon appeal, the Madhya Pradesh High Court reversed the conviction. In its judgment dated December 17, 2025, the High Court criticized the Special Judge and the Public Prosecutor for what it termed a “major lapse” that resulted in “injustice to the accused.” The High Court observed that the victim was a consenting adult and that the conviction was unsustainable.
The High Court went further to state:
“This is a sign of intellectual dishonesty on the part of the special judge. Registry is requested to issue a show cause notice to the concerned special judge and the public prosecutor, calling for their explanation.”
Aggrieved by these remarks and the subsequent show cause notice, both the Special Judge and the Public Prosecutor approached the Supreme Court in separate appeals.
The Supreme Court’s Analysis
The Supreme Court bench examined the High Court’s rationale and the statutory framework regarding age determination. The bench found that the High Court’s findings ignored the procedural mandates of the law.
Chief Justice Surya Kant, delivering the order, stated:
“We are satisfied that observations of the high court are totally uncalled for, out of context, being contrary to Section 94 (method of determining age) of the Juvenile Justice Act, 2015.”
The apex court observed that the High Court had reached a “hasty conclusion” regarding the judicial officer’s integrity. The bench emphasized that while a superior court has the authority to reverse a judgment on merits, it should refrain from making disparaging personal remarks against lower court judges unless there is clear evidence of malice or corruption.
The Decision
The Supreme Court allowed the appeals and ordered the immediate removal of the disparaging remarks from the record.
“Impugned judgment so far as it pertains to the appellants (judge and prosecutor) is set aside,” the CJI directed.
By expunging the remarks, the Supreme Court effectively stayed the show cause notices issued by the High Court Registry, protecting the judicial and professional records of the trial judge and the prosecutor.
