Supreme Court Sets Aside High Court Judgment for Delayed Reasoning in Murder Case

Date of the Judgment: April 19, 2022

Citation: 2022 INSC 402

Judges: M. R. Shah, J., B.V. Nagarathna, J.

Can a High Court pronounce an order without providing the reasons for it? The Supreme Court of India recently addressed this critical question regarding judicial procedure. This case arose from a murder case where the High Court of Judicature at Allahabad acquitted the accused but issued a detailed judgment five months after the order. The Supreme Court, in this judgment, has set aside the High Court order due to this delay in providing the reasoning. The judgment was delivered by a two-judge bench comprising Justice M. R. Shah and Justice B.V. Nagarathna.

Case Background

The case involves an appeal against a judgment by the High Court of Judicature at Allahabad. The High Court had acquitted the accused in a murder case. The original complainant, feeling aggrieved, appealed to the Supreme Court. The core issue was that the High Court had announced the operative part of its order on March 30, 2019, acquitting the accused, but the detailed reasoned judgment was only made available approximately five months later. This delay led the Supreme Court to examine the validity of such a practice.

Timeline

Course of Proceedings

The High Court of Judicature at Allahabad heard the appeals and on March 30, 2019, delivered an operative order acquitting the accused. However, the reasoned judgment was provided approximately five months later. The original complainant then appealed to the Supreme Court of India, challenging this practice of delayed reasoned judgments.

Legal Framework

The Supreme Court referred to previous judgments to emphasize the importance of delivering reasoned judgments promptly. The Court cited the following cases:

• State of Punjab & Ors. versus Jagdev Singh Talwandi, (1984) 1 SCC 596: This case highlighted the difficulties caused by High Courts pronouncing final orders without reasoned judgments.

• Anil Rai versus State of Bihar, (2001) 7 SCC 318: This case provided guidelines for the pronouncement of judgments, emphasizing that judgments should ideally be delivered within two months of the conclusion of arguments.

• Balaji Baliram Mupade & Anr. versus The State of Maharashtra, Civil Appeal No.3564 of 2020: This recent decision of the Supreme Court deprecated the practice of pronouncing final orders without a reasoned judgment.

The Court also referred to the following cases:

• Zahira Habibulla H. Sheikh & Ors. v. State of Gujarat & Ors. [AIR 2004 SC 3467]: This case also emphasized the need for reasoned judgments.

• Mangat Ram v. State of Haryana (2008) 7 SCC 96: This case further reiterated the importance of reasoned judgments.

• Ajay Singh & Anr. Etc. v. State of Chhattisgarh & Anr. [AIR 2017 SC 310]: This case reinforced the principle of delivering reasoned judgments.

The Supreme Court emphasized that the practice of pronouncing final orders without a reasoned judgment undermines the judicial process and creates difficulties for the aggrieved party seeking further legal recourse.

Arguments

Appellant’s Arguments (Original Complainant):

• The appellant argued that the High Court’s practice of pronouncing the operative order without a reasoned judgment is against established legal principles.

• They relied on the Supreme Court’s decision in Balaji Baliram Mupade & Anr. versus The State of Maharashtra, which deprecated such a practice.

• The appellant contended that the delay in providing the reasoned judgment deprived them of the opportunity to seek further legal redressal effectively.

State’s Arguments:

• The State supported the appellant’s arguments and highlighted the need for reasoned judgments to maintain judicial discipline.

Respondents’ Arguments (Accused):

• The respondents did not make any specific arguments as the case was decided on the procedural aspect of delayed judgment.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was:

1. Whether the High Court’s practice of pronouncing the operative part of the order without a reasoned judgment and delivering the reasoned judgment after a significant delay is sustainable under the law.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court relied on the following authorities:

Judgment

The Supreme Court set aside the impugned judgment and order passed by the High Court of Judicature at Allahabad. The Court did not delve into the merits of the case. The matter was remanded back to the High Court to decide the appeals afresh in accordance with the law. The Supreme Court requested the High Court to dispose of the appeals within six months. The accused were allowed to remain on bail pending the fresh decision by the High Court.

How each authority was viewed by the Court?

• State of Punjab & Ors. versus Jagdev Singh Talwandi, (1984) 1 SCC 596:* The Supreme Court relied on this case to highlight the difficulties caused by the practice of pronouncing final orders without reasoned judgments.
• Anil Rai versus State of Bihar, (2001) 7 SCC 318:* The Supreme Court used this case to reinforce the guidelines for timely pronouncement of judgments.
• Balaji Baliram Mupade & Anr. versus The State of Maharashtra, Civil Appeal No.3564 of 2020:* The Supreme Court heavily relied on this recent decision, which deprecated the practice of pronouncing final orders without reasoned judgments, to set aside the High Court’s judgment.
• Zahira Habibulla H. Sheikh & Ors. v. State of Gujarat & Ors. [AIR 2004 SC 3467]:* The Supreme Court used this case to further support the view that reasoned judgments are necessary.
• Mangat Ram v. State of Haryana (2008) 7 SCC 96:* The Supreme Court relied on this case to reiterate the importance of reasoned judgments.
• Ajay Singh & Anr. Etc. v. State of Chhattisgarh & Anr. [AIR 2017 SC 310]:* The Supreme Court used this case to reinforce the principle that judgments should be reasoned.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the need to maintain judicial discipline and ensure transparency in the judicial process. The Court emphasized that reasoned judgments are essential for several reasons:

• Accountability: Reasoned judgments ensure that the judiciary is accountable for its decisions.

• Transparency: They provide transparency in the decision-making process, allowing the public to understand the basis of the judgment.

• Opportunity for Appeal: They enable the aggrieved party to seek further legal recourse effectively.

• Judicial Discipline: Prompt delivery of reasoned judgments is a key aspect of judicial discipline.

The Court’s reasoning was primarily based on legal principles and precedents, with no consideration of the factual aspects of the case.

Logical Reasoning

Key Takeaways

• High Courts must pronounce reasoned judgments promptly after concluding arguments.

• Pronouncing only the operative part of the order without a reasoned judgment is not sustainable.

• Delayed reasoned judgments undermine judicial discipline and the right to appeal.

• The Supreme Court has reiterated the importance of reasoned judgments for maintaining transparency and accountability in the judicial process.

Directions

The Supreme Court directed the High Court to decide the appeals afresh in accordance with the law and on its own merits, preferably within a period of six months from the date of the receipt of the order. The accused were allowed to remain on bail during the pendency of the appeals before the High Court.

Development of Law

The ratio decidendi of this case is that a High Court cannot pronounce the operative part of the order without a reasoned judgment and that such a practice is unsustainable. This judgment reinforces the existing legal principle that reasoned judgments must be delivered promptly to maintain judicial discipline, transparency, and the right to appeal. There is no change in the previous position of law, but rather a reiteration of the existing legal principle.

Conclusion

In conclusion, the Supreme Court’s decision in Indrajeet Yadav vs. Santosh Singh and Anr. reaffirms the critical importance of reasoned judgments in the Indian judicial system. The Court set aside the High Court’s judgment due to the delay in providing a reasoned judgment, emphasizing that such delays undermine the judicial process. This judgment serves as a reminder to all High Courts to ensure that reasoned judgments are delivered promptly to maintain judicial discipline and uphold the principles of justice.