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Supreme Court’s

The Supreme Court of India, citing a decision from April 2022, has made a significant legal development by highlighting the binding nature of decisions made by a Constitution bench on benches of lesser strength. This action highlights the strict adherence to judicial precedents, which is essential to the Indian legal system, as well as the hierarchical judicial structure.

Background of the Case

The Supreme Court’s ruling on April 7, 2022, concerning the ownership of land confiscated from proprietors under the Haryana Village Common Lands (Regulation) Act, 1961, was the source of the conflict. Panchayats could only administer and control such land, not claim ownership, according to the Court’s ruling. This decision deviated from the Punjab and Haryana High Court’s earlier full-bench ruling, which had explained Section 2(g) of the Act.

Due to its disregard for a significant precedent established by the Supreme Court’s Constitution bench in the 1966 Bhagat Ram case, the April 2022 ruling drew criticism. The law about these types of land conflicts was settled by the 1966 ruling, which was rendered by a bench of five judges. Justices B. R. Gavai and Sandeep Mehta’s bench recently ruled to recall the April 2022 decision, emphasizing the need for consistency and deference to higher court decisions.

The Importance of Judicial Precedents

India adheres to the common law system, which is based on judicial precedent, or stare decisis. To preserve uniformity and stability in the legal system, this idea guarantees that rulings rendered by higher courts are binding on subordinate courts. The idea behind the principle is that similar situations should be resolved similarly, which promotes predictability and fairness in legal proceedings.

The Supreme Court’s Constitution bench, which usually consists of five or more justices, decides important legal cases with broad ramifications. All other Supreme Court benches, which typically have fewer judges, are expected to follow the rulings of these benches. Because of this hierarchical structure, rulings that have been thoroughly considered by a bigger panel of judges are guaranteed to be given more weight.

The April 2022 Verdict and Its Recall

The Supreme Court of India ruled in April 2022 that panchayats in Haryana were allowed to administer and govern land that they had purchased from owners, but they were not allowed to claim ownership. Legal discussions were triggered by this decision since it appeared to go against the rules established in the 1966 Bhagat Ram case.

A Constitution bench’s Bhagat Ram ruling had established precise rules regarding the vesting of land and the degree of ownership and control by panchayats. The two-judge bench unintentionally produced a legal anomaly by not reconciling the 2022 verdict with this well-established norm. The April 2022 verdict was recalled as a result of this misalignment, which also generated a review petition.

Justices Gavai and Mehta stressed in the recall ruling that the bench that handed down the April 2022 decision ought to have followed the Bhagat Ram precedent or offered a strong justification for departing from it. The two-judge bench’s failure to do so constituted a “material error, manifest on the face of the order,” which supported the recall.

Implications of the Recall Judgment

A major precedent is established by the Supreme Court’s decision to recall the April 2022 ruling and bring back the appeal for an additional hearing. It highlights the need for lower benches to follow the decisions made by higher benches in the Constitution and confirms the hierarchical integrity of court precedents. This ruling strengthens the Indian legal system’s judicial accountability and uniformity foundation.


The fact that the April 2022 ruling was recalled by the Supreme Court is evidence of the strong legal systems‘ procedures in India that protect justice equity and uniformity. The Court has enhanced the concept of stare decisis and rectified a judicial oversight by reiterating the binding nature of bench decisions under the Constitution. The judiciary’s position as a defender of legal continuity and integrity is reaffirmed by this move, which guarantees that the law will always be fair and predictable.

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