In what could be a termed as a massive shift for precedential value of a Judgment, the Supreme Court recently emphasized the critical importance of explicitly stating the intended purpose and scope of a judgment within the judgment itself. In a significant observation, the Court elaborated that not every judicial pronouncement automatically qualifies as a binding precedent under Article 141 of the Constitution. This distinction is crucial as it directly impacts how lower courts interpret and apply these judgments. Therefore, the Court stressed that each judgment must clearly specify whether its primary purpose is to resolve a specific dispute between the parties involved or to establish a broader legal precedent under Article 141.
The Court provided a comprehensive explanation, noting that beyond its routine case disposal duties under Article 136 of the Constitution, it also delivers landmark decisions that serve as binding precedents under Section 141 of the Constitution. This dual role often creates interpretative challenges for High Courts and Trial Courts, which frequently struggle to differentiate between decisions meant solely for dispute resolution and those intended to establish precedential value. The Court acknowledged that this ambiguity can lead to confusion in the judicial system and potentially inconsistent application of legal principles. Therefore, to eliminate such uncertainty and ensure proper implementation of its decisions, the Court emphasized the paramount importance of explicitly stating whether a particular judgment is designed to merely resolve the dispute between the parties or to set a broader legal precedent for future cases.
In regards to the specific merits of this specific case, observation of the Court reflects that the precedents cited by the Appellant were not intended to establish binding legal authority under Article 141. Rather, these judgments were specifically focused on resolving particular disputes between the parties involved in those cases. Consequently, these decisions cannot be universally applied as binding precedents to all related cases without careful consideration of their specific context and intended scope.
CIVIL APPEAL NO. 3705 OF 2024.
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