Category: Supreme Court of India

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Five instances where judges considered the use of criminal contempt for criticism of their integrity

PraptiPatelRecently, a Delhi High Court judge initiated contempt proceedings against a legal news magazine that published a report which claimed that a nightclub in the capital was allowed to remain open beyond the licensed closing time because the judge’s son had an interest in the club.

‘Criminal contempt’, defined under Section 2(c) of the Contempt of Courts Act, 1971 as a criminal offence, is the act of communicating, either through spoken or written words or other visible representations, something that, among other things,

scandalises, or tends to scandalise, or lowers, or tends to lower, the authority of any court. Under Section 12 of the Act, criminal contempt can be punished with simple imprisonment up to six months or a fine up to Rupees Two thousand or both.

The somewhat old-fashioned rationale behind this power is that in order for the judiciary to carry out its functions, it was essential for the courts to be perceived as fair and unbiased. Let us look at five instances where courts have used this power to penalise communication in the media that has been critical of the integrity of judges.

1. Perspective Publications v. State of Maharashtra (1968)

Blitz, a weekly newspaper, had lost a suit in which a firm of architects claimed damages of Rs. 3 lakhs from them. Justice Tarkunde of the Bombay High Court had passed the decree. Later, an article that appeared in a publication brought out by Perspective Publications and written by its editor, alleged that the judgment had been decided in favour of the firm because Justice Tarkunde’s father, brother, and other relatives were partners and had a large pecuniary interest in the firm. They were found guilty of contempt of court and sentenced to a month of simple imprisonment and a fine of Rs. 1000. “The publication of a disparaging statement”, Justice Mukherjee held “will be an injury to the public if it tends to create an apprehension in the minds of the people regarding the integrity, ability, or fairness of the judge or to deter actual and prospective litigants from placing complete reliance upon the court’s administration of justice or if it is likely to cause embarrassment in the mind of the judge himself in the discharge of his judicial duties.”

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2. In Re S. Mulgaokar (1978)

A letter was circulated among judges of the Supreme Court and the High Courts on drafting a code of ethics for judges. The Indian Express published the details of the letter and also commented on the character of the judges, specifically referring to some who lacked ‘moral courage’. The suit was dismissed and the article was not held to amount to contempt of court. Justice Krishna Iyer laid down six principles to determine if the publication of some matter amounts to contempt of court.

3. Court On Its Own Motion v. M.K. Tayal and Others (2007)

yksabharwalMid-Day published an article with a cartoon which alleged that Justice Y.K. Sabharwal, a former Chief Justice of India had headed a Supreme Court bench which passed certain orders in the matter of sealing off commercial establishments in residential areas even though the sons of the Chief Justice had a vested interest in those commercial establishments. The article cast aspersions on the soundness of the judgement and imputed that the sons had benefitted from it. Following the publication, senior advocate R.K. Anand had submitted a copy of the paper to the Court and accused the newspaper of scandalising the judge and the Court. The Court took suo moto cognizance of the matter and the newspaper’s editor, publisher, resident editor, and cartoonist were held guilty of contempt of court. “The manner in which the entire incidence has been projected”, the Court held, “gives the impression as if the Supreme Court permitted itself to be led into fulfilling an ulterior motive of one of its members. It tends to erode the confidence of the general public in the institution itself.”

4. Dr. Subramanian Swamy v. Arun Shourie (1990)

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Justice Kuldip Singh, then a judge of the Supreme Court, was appointed the chairman of a commission of inquiry to probe into allegations of corruption against Ramakrishna Hegde, the former Chief Minister of Karnataka. When the commission released its report, it refuted all the allegations. The Indian Express published an article titled “If Shame Had Survived”, criticising the report for being “deferential” to the Chief Minister and accusing Justice Singh of “inventing theories and probabilities” to argue against the allegations. The article also highlighted how Justice Singh had failed to include the evidence of the key witness in the case and said that “If there had been any sense of honour or shame, a Judge would never have done any of this.” Subramanian Swamy filed a contempt petition against Arun Shourie, who was the editor of the newspaper, contending that the editorial was a scandalous statement in respect of a sitting judge of the Supreme Court. Even though the Court took suo moto cognizance of the matter, the petitions were dismissed, partly because the law was amended during the course of the proceedings to include truth as a defence and partly because Justice Singh, as member of a commission of inquiry, was not a court for the purposes of the contempt law.

5. Shri Surya Prakash Khatri & Another v. Smt. Madhu Trehan and Others, 2001

A fortnightly magazine called Wah India published an article listing fourteen judges of the Delhi High Court and evaluated them on parameters of punctuality, knowledge of the law, integrity, quality of judgments, manners in court, and receptiveness to arguments. The evaluation was apparently based on a survey that took in the opinions of fifty “senior lawyers”. The Delhi High Court issued a notice against the magazine’s Editor-in-Chief and directed the Delhi police to ensure that copies of the allegedly offensive issue were withdrawn from newsstands and the shops that sold it. Copies of the issue that had not been circulated were thus seized and confiscated. The Court held that prima facie contempt had been committed by the respondents because the ranking of the judges amounted to scandalising the judiciary. The Court also refused the apologies that were tendered by the accused.

The law on criminal contempt of court in India has been invoked against the press several times because of perceived insults to the judiciary. In Germany, France, Belgium, Austria, and Italy, however, there is no concept of criminal contempt of court and the only options that the judges have are in their personal capacity: either file a criminal complaint or institute an action for libel. In the United Kingdom, even though the criminal offence was only abolished in 2013, the last successful prosecution happened in 1931. Various Indian judgments on the issue have been quick to point out that “scandalising the judiciary” amounts to contempt under the statute but isn’t it time that the judiciary made a conscious move to give a more liberal interpretation to the law? Healthy debate and criticism are necessary in a democracy and there is no reason the judiciary should be above it.

(Prapti Patel is a student of the Indian Law Society’s Law College in Pune.)

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Supreme Court of India

Jaya’s plea before the Supreme Court shines light on appellate courts’ powers

JitenMehraThe Karnataka High Court recently refused to release Jayalalithaa on bail after her conviction under the provisions of the Prevention of Corruption Act, 1988. Sentenced to imprisonment for four years and a fine of Rs. 100 crores, Jayalalithaa was immediately disqualified from the membership of the Tamil Nadu legislature and had to step down as Chief Minister of the state. With the Supreme Court set to hear her plea any day now, let us briefly examine appellate court’s powers of ordering that a sentence or a conviction be suspended pending appeal.

Power to suspend a sentence versus power to suspend the conviction

Pending the disposal of an appeal or a revision, appellate and revisional courts have powers to (i) suspend the execution of a sentence and release the appellant on bail or (ii) suspend the conviction itself and release the appellant on bail. In the case of appellate courts, these powers reside in Section 389(1) of the Code of Criminal Procedure, 1973 (“CrPC”). The important distinction between these powers is that a suspension of the execution the sentence pending an appeal does not erase the conviction or suspend any disqualification that arose from the conviction. A suspension of the conviction on the other hand, has the legal effect of staying any disqualifications under any law because of the  conviction. For example, a person is disqualified from being a member of Parliament or the Legislative Assembly or Legislative Council of a state under Section 8(3) of the Representation of People Act, 1951 if he or she has been convicted and sentenced for any offence for not less than two years. If an appellate court has stayed the conviction under Section 389(1), it has the effect of staying such a disqualification. Not so, if the order merely suspends the execution of the sentence.

Power to suspend conviction – exercise with caution

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The Supreme Court has held that the power to suspend the conviction must be exercised only in exceptional cases where a failure to stay the conviction would lead to injustice and irreversible consequences. In Navjot Singh Sidhu v. State of Punjab, the Court held that the person seeking a stay of the conviction should specifically draw the attention of the appellate court to the consequences that may arise if the conviction is not stayed. A person convicted cannot obtain an order of stay of conviction without that. In State of Tamil Nadu v. A. Jaganathan and in K.C. Sareen, the Court has even held that a conviction on a corruption charge against a public servant should not be suspended even if the sentence of imprisonment is suspended.

Time taken to hear an appeal – a factor when considering suspension of sentence

In either case, the appellate court has to record reasons in writing. The Supreme Court has noted some of the factors that can be taken into account while dealing with suspension of sentence. In Angana and Another v. State of Rajasthan, for example, Court held that the fact that the appellant did not misuse bail during trial could be considered. The time that it would take to hear and adjudicate an appeal is another factor. In fact, in K.C. Sareen v.  C.B.I, Chandigarh, the Court held that when a court admits an appeal, it should normally suspend the sentence of imprisonment until the disposal of the appeal, because unless an appeal is heard soon after it is filed, a refusal to do so would render the very appeal otiose. The fact that a person has already undergone a substantial portion of the sentence awarded, either under trial or as a convict must also weigh in favour of the appellant.

It remains to be seen whether the Supreme Court will release Jayalalitha on bail after suspension of sentence or is impressed enough to order suspension of her conviction as well.

(Jiten Mehra is an advocate practising in Delhi.)

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Supreme Court of India

Supreme Court correctly holds National Tax Tribunal unconstitutional but should ordinary law be tested against basic structure and constitutional convention?

GautamBhatia_SupremeCourtofIndiajpgIn a landmark judgment last week – Madras Bar Association v. Union of India – a Constitution Bench of the Supreme Court held unconstitutional, the National Tax Tribunal Act, 2005. The majority opinion runs into 230 pages and deals with a host of complicated statutory and constitutional provisions. Briefly, the National Tax Tribunal Act provided for the constitution of a National Tax Tribunal (“NTT”), which had the power to adjudicate appeals from various appellate tribunals (constituted under the Income Tax Act, the Customs Act, and the Central Excise Act), where such appeals involved a substantial question of law. Before this, such appeals were heard by the jurisdictional high courts. The idea behind the NTT was to create a single forum for the hearing of tax appeals, in order to provide the uniformity and consistency that was lacking in the law because of the conflicting decisions of the various high courts.

The petitioners challenged the NTT Act on four grounds: first, that the reasons for setting up the NTT were fallacious, since there were no problems of consistency in the present jurisprudence of the high courts; secondly, deciding upon a substantial question of law was a “core judicial appellate function”, which could not be transferred to a quasi-judicial authority that lacked the basic features of a superior court; thirdly, that the enabling constitutional provision, Article 323B, inserted into the Constitution via the 42nd Amendment, violated the basic features of the Constitution (such as the rule of law, the separation of powers, and the independence of the judiciary); and fourthly, certain specific provisions of the NTT Act undermined the independence of the judiciary, and were therefore liable to be struck down. In short, the Court accepted the second and fourth contentions, while upholding the validity of Article 323B.

Chief Justice R.M. Lodha and Justices Khehar, Chelameshwar, Sikri, and Nariman comprised the bench.
Chief Justice R.M. Lodha and Justices Khehar, Chelameshwar, Sikri, and Nariman comprised the bench.

Examining the line of Tribunals Cases – Sampath Kumar, Chandra Kumar and Union of India v. Madras Bar Association, the Court concluded that it was settled law that judicial review in general – and the High Courts’ power to exercise judicial superintendence over the courts and tribunals in their respective jurisdictions in particular – was part of the basic structure of the Constitution. While the Parliament was competent to enact a law transferring the jurisdiction of the High Court with respect to specific subjects to other courts or tribunals, what it could not do was to transfer the constitutionally-vested power of the High Courts elsewhere. The NTT Act – the Court found – transferred only jurisdiction, and not the High Courts’ powers of superintendence under Articles 226 and 227 of the Constitution. Accordingly, the Court held that the NTT Act did not violate the basic structure.

We may pause here to notice a controversial assumption that the Court only touches upon: that ordinary legislation is subject to a basic structure challenge. From the inception of the basic structure doctrine, it has been a contested issue whether that doctrine applies only to constitutional amendments, or to ordinary laws as well. For instance, in Union of India v. R. Gandhi, a judgment handed down by a coordinate bench just four years ago, it had been found that ordinary laws could be challenged only upon the touchstone of the Constitution, and not the basic structure. In holding otherwise, without referring to prior doctrine, the Court further muddied an already confused area of law.

Transfer of adjudicatory functions and guarantees of judicial independence

The Court then turned to the issue of transfer of adjudicatory functions. In what is perhaps the most interesting part of the judgment, it noted cases from across commonwealth jurisdictions – Canada, England, and the Privy Council – to hold that in constitutions based on the “Westminster model of governance”, there was a clear demarcation of functions between the executive and the judiciary, with the two being kept independent of each other. This independence was guaranteed through provisions regulating the appointment and security of the tenure of judges. Consequently, adjudicatory powers could be transferred from traditional courts only if the forums that they were being transferred to had analogous guarantees of independence. This was the only way in which the scheme of separation of powers could be maintained. Constitutionally, this proposition was supported by the L. Chandra Kumar judgment, and its insistence that the transfer of jurisdiction must be to a forum that embodies the salient features of the court from which the transfer is taking place.

Facebook Images-470x246Having established this, the Court then turned to the specific provisions of the NTT Act. It found that the establishment of a central tribunal (with no regional benches), the power of the central government to determine the constitution of benches and the transfer of members, the provision allowing “technical members” and “accountant members” to be appointed to the tribunal (to adjudicate substantial questions of law), the provision of a direct appeal to the Supreme Court (thus bypassing the jurisdictional High Courts) – all pointed to the fact that while the composition of the NTT was supposed to be on the same parameters as that of the judges of high courts (since, effectively, the NTT was acting as a substitute for the High Court), in practice, this was not so. Consequently, the Court held, in paragraph 90:

“Sections 5, 6, 7, 8 and 13 of the NTT Act have been held by us (to the extent indicated hereinabove) to be illegal and unconstitutional on the basis of the parameters laid down by decisions of constitutional benches of this Court and on the basis of recognized constitutional conventions referable to constitutions framed on the Westminster model. In the absence of the aforesaid provisions which have been held to be unconstitutional, the remaining provisions have been rendered otiose and worthless, and as such, the provisions of the NTT Act, as a whole, are hereby set aside.”

 What is curious about this paragraph is its reliance upon constitutional conventions to strike down legislation. This is surely a first! Constitutional conventions are – as the term suggests – conventions, that is, practices that have acquired strong normative and binding force because of a long period of consistent adherence. To hold a convention to be legally enforceable is a category mistake – what distinguishes constitutional provisions from constitutional conventions is precisely their legal standing. As the reasoning above demonstrates, the Court had no need to resort to conventions: the reasoning in the Tribunals Cases was enough for it to hold that a transfer of jurisdiction must be to a forum with the relevant trappings of a court. In the alternative, if it was of a mind to invoke the Westminster constitutional model, it could simply have held that the independence of the judiciary was a structural feature of a Westminster Constitution (as, incidentally, was held in some of the cases that the Court cited from abroad, none of which relied upon conventions). Structural analysis, that is, inferring constitutional obligations not directly from the constitutional text, but by way of necessary implications from its overall scheme and structure – is an accepted form of constitutional adjudication, widely prevalent in the United States, and – although controversial, most famously in Kesavananda Bharati – used in India as well, on occasion (see, for instance, the Delhi High Court’s finding of the word “sex” in Article 15 including “sexual orientation”). In holding constitutional conventions to be legally enforceable, the Court has – with respect – created an entirely unnecessary minefield for the future.

In a brief and pithy concurring opinion, Justice Nariman decided the case on the narrow ground that the legislature was not permitted to divest superior courts of record from the core judicial function of deciding substantial questions of law. He relied upon Chandra Kumar, which had clearly held that “tribunals are competent to hear matters where the vires of statutory provisions are questioned. However, in discharging this duty, they cannot act as substitutes for the High Courts and the Supreme Court which have, under our constitutional set-up, been specifically entrusted with such an obligation. Their function in this respect is only supplementary and all such decisions of the Tribunals will be subject to scrutiny before a Division Bench of the respective High Courts.” In supplanting the scrutiny of the High Court, the Act bypassed its constitutionally guaranteed power under Article 227, as well as falling foul of Chandra Kumar.

Madras Bar Association v. Union of India is correctly decided. Its holding, that the adjudication of substantial questions of law cannot be transferred to tribunals that lack the substantive trappings of the High Court, is clearly consistent with Chandra Kumar, Article 227 of the Constitution, and the structural foundations of the Westminster Model. In simultaneously holding that ordinary laws can be subjected to a basic structure challenge, and that constitutional conventions can be used to strike down an otherwise validly enacted law, the Supreme Court has, however, ventured into uncertain territory. It remains to be seen what implications this will have for the future.

(Gautam Bhatia blogs at Indian Constitutional Law and Philosophy.)

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Supreme Court of India Uncategorized

Pre-BALCO arbitration agreements with foreign seat: SC decision does little to improve clarity on Part 1 exclusion

SindhuSivakumar_DraftingForArbitrationA few months ago (May 28, 2014), in Reliance Industries Limited and Another v. Union of India, the Supreme Court of India elaborated on the law laid by it in relation to the jurisdiction of Indian courts over foreign-seated arbitrations in the 2012 decision in Bharat Aluminium v. Kaiser Aluminium, (2012) 9 SCC 552.

Without getting into the substantive details, the dispute and arbitration arose out of two production-sharing contracts between the parties. While Indian law governed the agreement, the arbitration clause provided for arbitration seated in London and English law expressly governed the arbitration clause (or agreement). Over the course of arbitration proceedings, the Union of India challenged the arbitrability of four issues. This was resisted by Reliance, and ultimately, the three-member arbitral tribunal decided in favour of Reliance through an award on September 12, 2012. This award of the tribunal (on arbitrability) was challenged under Section 34 of the Indian Arbitration and Conciliation Act, 1996 (“Act”) by the Union of India before the Delhi High Court.

Surprisingly, the Delhi High Court accepted its jurisdiction to hear the Section 34 set-aside application even though the award in question was passed in a foreign-seated arbitration. The reasoning of the High Court in accepting jurisdiction is suspect; the High Court seemed to suggest that the law of the seat only governed the conduct of arbitration, not the issues of arbitrability or public policy, which are also subject to the law of the contract, that is, Indian law. The High Court also took into account the fact that the parties had not expressly excluded Part 1 of the Act. Since the arbitration agreement pre-dated the Bharat Aluminium decision (it was a 1994 agreement), the fact that Part 1 was not excluded, was taken to imply that Indian courts had the jurisdiction to set aside the foreign award under Section 34 (following the logic of the Supreme Court in Bhatia International v. Bulk Trading S.A., (2002) 4 SCC 105).

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Reliance filed an appeal before the Supreme Court, and the Supreme Court overruled the Delhi High Court’s judgment on its jurisdiction to hear the Section 34 application. The Supreme Court essentially went back to the post-Bhatia, pre-Bharat Aluminium line of cases that dealt with what constituted an effective ‘exclusion’ of Part 1 of the Act under Bhatia International. One of these cases was Yograj Infrastructure Limited v. Ssang Yong Engineering and Construction Company Limited, (2011) 9 SCC 735, where the Supreme Court had held that the choice of a foreign seat (in this case, Singapore) amounted to an ‘implied exclusion’ of the Part 1 of the Indian Act, and that accordingly, Indian courts had no jurisdiction in such foreign seated arbitrations. Another pre-BALCO decision the Supreme Court referred to in Reliance was Videocon Industries v. Union of India, (2011) 6 SCC 161, in which the Supreme Court had held that a foreign law governing the arbitration agreement (as well as a foreign seat) amounted to an exclusion of Part I of the Indian Act. In the present case, as there was a choice of an English seat and because English law was the law governing the arbitration agreement, Part 1 was clearly excluded. Further, the Supreme Court also made it clear that the law of the seat did not just govern the conduct of the arbitration; it meant that the courts at the seat had exclusive supervisory jurisdiction to hear challenges to awards based on arbitrability and public policy. Further, the Supreme Court reiterated its ruling in Enercon that recognised the separability principle.

All in all, this decision of the Supreme Court is very much in line with the recent ‘pro-arbitration’ trend in the Indian courts. The ‘pro arbitration’ trend is reflective of a larger strategy of the present Indian government to convert India into a global arbitration hub (2014 BJP Manifesto). On the flip side, this decision does not do much to clarify the position on pre-BALCO (that is, before September 6, 2012) arbitration agreements that provide for a foreign seat: on the one hand, you have the Yograj decision which seemed to (correctly) indicate that the providing for a foreign seat was enough to exclude the application of Part 1 and Section 34, and on the other, the Videocon decision, which relied on the presence of a foreign law governing the arbitration agreement to imply the exclusion of Part 1. The Reliance case could have been the perfect opportunity for the Supreme Court to clarify that a foreign seat alone is sufficient to exclude Part 1; unfortunately, the Supreme Court did not bite.

(Sindhu Sivakumar is part of the faculty on myLaw.net.)

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Supreme Court of India

An incredible number of cases are pending before our judges. How many vacancies need to be filled? How many more judges do we need?

SmritiParsheera_SumathiChandrashekaran_JusticeReformCourts in India are faced with a huge backlog of cases, leaving parties embroiled in legal battles for years, often decades, at a stretch. Many factors contribute to this problem, including procedural inefficiencies, new laws passed without any litigation impact assessment, and poor court and case management systems.

One reason however, comes to mind before any of these other reasons – the apparent inadequacy of the present judicial workforce to handle the large numbers of pending cases. While we can use the available data on the backlog of cases to estimate the number of cases that each judge would have to handle if this backlog were to be cleared in the current year, (see the first figure below) it is crucial to highlight the limitations of the available data.

We don’t really know the magnitude of the problem

Without a uniform system for indexing and categorising cases, different states have devised their own methods for recording data. As the Law Commission of India observed in July this year, some states count each interlocutory application as a separate case while others do not. Similarly, while some states exclude data on traffic and motor challan cases, most others do not. There is therefore, doubt about the accuracy of pendency figures.

An incredible number of cases pending before each judge

Pending-workload-of-our-judges-at-the-end-of-2013

Working within these limitations, we can see that the number of cases pending for each judge is staggeringly high. High court judges, whose potential workload is over three times that of their counterparts in the Supreme Court and at the subordinate courts, seem to be in the worst position.

Many posts lie vacant

These numbers are based on the number of judges who are actually working, and not the sanctioned strength, which is the number of judges that are, on paper, expected to be in office. These two figures often tend to vary significantly. For example, at the end of 2013, 29 per cent of the posts in the High Courts and 22 per cent of the posts in subordinate courts were lying vacant.

Percentage-of-Vacancies-in-the-Judiciary-in-2013

On the bright side, the numbers show a steady increase in the sanctioned strength of judges over the years, particularly in subordinate courts, where it has gone up by over 30 per cent in the last eight years.

Percentage-of-Judges-Sanctioned-Since-2006

Who is responsible for filling these vacancies?

Recent debate surrounding the National Judicial Appointments Commission (“NJAC”) has focused extensively on appointments to the higher judiciary, that is, the Supreme Court and the High Courts. At present, because of the Supreme Court’s interpretation of Articles 124 and 217 of the Constitution, it is the judiciary that plays a decisive role in such appointments.

The proposed constitutional amendment and NJAC law will change this, creating NJAC as a permanent body  to recommend appointments to the President. There will also be a timeline within which the central government has to inform the NJAC of imminent vacancies, though there is no such timeline timeline for the NJAC to complete its selection and make recommendations to the President.

Legal Research AdvertisementThe Governor appoints judges and judicial officers for subordinate courts in consultation with the High Court. The State Public Service Commission also has to be consulted for judicial officers below the rank of district judges. Rules made by different states provide for the actual recruitment process – whether through promotion or competitive examination.

In 2006, the Supreme Court in Malik Mazhar Sultan identified unfilled vacancies as a key reason for the pendency problem and directed states and High Courts to evolve a fixed schedule to fill vacancies in subordinate courts. After that, the Supreme Court itself devised a detailed time schedule for the states. The High Courts were asked to oversee this process, which included timelines for the determination of vacancies, issuing advertisements, conducting examinations and interviews, declaring results, and issuing final appointment orders. Seven years on, the Supreme Court is still struggling to ensure compliance with those directions.

How many judges do we need?

In 1987, the Law Commission recommended that there should be at least 50 judges for every million Indians. For today’s population of 1200 million therefore, India would need about 60,000 judges, that is, triple the current number of sanctioned judges.

In July this year, the Law Commission changed its opinion about the judge-population ratio, observing that it was not based on any objective criteria and that it did not capture state-specific needs. Instead, it proposed calculating the additional number of judges required to deal with the backlog of cases by using the current rate at which judges dispose of cases. By any reasonable metric however, the current sanctioned strength is far less than what is required.

Any real solution to these problems requires effective cooperation between the judiciary and the central and state governments. The judiciary should urgently take the initiative in filling vacancies and the government should create additional courts and extend infrastructure support to them.

(Sumathi Chandrashekaran and Smriti Parsheera are lawyers working in the area of public policy.)

(Images by Rachit Gupta.)