Source: Supreme Court  

Why in News? 

The Supreme Court recently overturned a High Court Division Bench order for lacking proper reasoning. The Division Bench had merely affirmed the single-judge decision without providing detailed explanations for its concurrence. The Supreme Court noted that a decision without reasoned judgment cannot be legally sustained. 

• Justices Hima Kohli and Sandeep Mehta held in matter of State Project Director, UP Education for All Project Board & Ors. v. Saroj Maurya & Ors   

What was the Background of State Project Director, UP Education for All Project Board & Ors. v. Saroj Maurya & Ors. Case? 

• The State of Uttar Pradesh filed an appeal against a judgment dated 18th April 2022, passed by the Division Bench of the High Court of Judicature at Allahabad. 
• The Division Bench's judgment was in response to an intra-court appeal against a common judgment dated 21st December 2021, passed by a Single Judge in a batch of writ petitions. 
• The State of Uttar Pradesh had issued various Government Orders, including one dated 11^th December 2020, which were brought to the attention of the Division Bench. 
• The Division Bench's judgment primarily recorded the cases of the writ petitioners and respondents, along with the findings of the Single Judge. 
• The State contended that the Division Bench did not adequately consider or address the Government Orders and Circulars issued by the appellants. 
• During the pendency of the matter, the Supreme Court had issued a stay order on 2^nd September 2022, which was subsequently made absolute on 2^nd May 2023. 
• The stay order allowed the State to make appointments with teachers, subject to final orders in the appeal. 
• The State argued that the Division Bench had not applied its mind to the submissions made by both sides and had simply upheld the Single Judge's order without proper reasoning. 
• The case involved issues related to teacher appointments in Uttar Pradesh, with subsequent developments occurring after the initial judgments were passed. 
• The matter raised questions about the adequacy of judicial reasoning and the consideration of relevant government orders in administrative decision-making. 

What were the Court’s Observations? 

• The Supreme Court noted that the Division Bench of the High Court, in its impugned judgment, merely placed on record the cases of the writ petitioners and respondents, followed by the findings of the learned Single Judge. 
• The Supreme Court observed that the Division Bench failed to express its own view on the issues raised before it. 
  • It was also found that the Division Bench's judgment concluded with a mere observation of agreement with the approach and view of the learned Single Judge, without furnishing any reasons, therefore. 
• The Court emphasized that in the absence of any reasoning in the impugned judgment, the same cannot be sustained. 
• Relying on the precedent set in CCT v. Shukla & Bros. (2010), the Supreme Court reiterated the principle that reason is the very life of law and that giving reasons furthers the cause of justice while avoiding uncertainty. 
• The Court observed that the concept of a reasoned judgment has become an indispensable part of the basic rule of law and is a mandatory requirement of procedural law. 
• The Supreme Court held that clarity of thoughts leads to clarity of vision, and proper reasoning is the foundation of a just and fair decision. 
• The Court noted that a reasoned judgment serves multiple purposes: to clarify the court's own thoughts, communicate reasons to concerned parties, and provide a basis for consideration by appellate/higher courts. 
• The Supreme Court observed that the absence of reasons in a judgment leads to frustration of these objectives and introduces an element of uncertainty and dissatisfaction. 
• The Court held that there is an unqualified obligation upon courts to record reasons, even in the absence of explicit statutory provisions requiring the same. 
• The Court noted that subsequent developments, including further Government Orders and Circulars issued by the appellants, ought to have been taken into consideration by the Division Bench.

What is a Judgment?

About: 

• A judgment is the official pronouncement of the court's decision on the matters in dispute between parties in a lawsuit. 
• A judgment usually includes:  
  • The court's findings of fact. 
  • The court's conclusions of law. 
  • The decision or ruling on the case. 
  • Any orders for relief or remedies granted. 

Types:

• Final Judgment: Resolves all issues in the case, subject only to appeal. 
• Interlocutory Judgment: Decides some issues while leaving others to be determined later. 
• Default Judgment: Entered against a party who fails to appear or respond to a lawsuit. 
• Summary Judgment: Decided without a full trial when there are no material facts in dispute.

Essential Elements:

• A judgment is binding on the parties involved and can be enforced by law. 
• Precedential value: Judgments, especially from higher courts, may serve as precedents for future cases with similar facts or legal issues. 
• Judgments are typically written in formal, precise legal language to avoid ambiguity. 
• A judgment may be enforced through various means, such as seizure of assets or garnishment of wages. 
• Judgments can usually be appealed to a higher court within specified time limits. 
• Judgments are officially recorded and become part of the public record.

Legal Provision: 

• Section 2 of Code of Civil Procedure, 1908 (CPC) gives the definition of decree, order and judgment. 
• Section 2(9) of CPC lays down the definition of judgment. 
• “Judgment” means the statement given by the Judge on the grounds of a decree or order. 
• Judgment provides reasons for passing a decree or order. 
• Section 33 of the CPC provides that the Court shall, after the case has been heard, pronounce the judgment and on such judgment decree shall follow. 
• Order XX Rule 1 of CPC provides that judgment must be pronounced in open Court either at once or as soon thereafter as may be practicable. 
• The Proviso to Order XX Rule 1 provides that where the judgment cannot be pronounced at once it must be pronounced within 30 days from the date on which hearing of case was concluded and this period should not extend beyond 60 days from the date on which hearing of case was concluded (in case of exceptional circumstances and due notice of the date fixed must be given to the parties or their pleaders). 
• Order XX Rule 2 of CPC provides that the Judge shall pronounce the judgment written but not pronounced by his predecessor. 
• Order XX Rule 3 of CPC provides that the judgment shall be dated and signed by the Judge in open Court and once signed it shall not altered or amended except as provided under Section 152 of CPC or on review. 
• Order XX Rule 4 of CPC provides that Courts other than Courts of Small Causes must contain: 
  • Concise statement of the case 
  • Points for determination 
  • Decision thereon 
  • Reasons for such decision 
• Judgment delivered by Court of Small Causes need not contain more than points for determination and decision thereon. 
• In the case of Gajraj Singh v. Deohu (1951), the Court held that the judgment must be intelligible and must show that the judge has applied his mind.