The doctrine of Separation of Power that was envisioned by the constitution
makers and then incorporated as one of the basic structures of the Indian
Constitution, provides very clearly for the independence of Judiciary. It is the
Judiciary through its courts of laws that upholds the democracy of this nation
and keeps the other organs of the state machinery accountable for their actions.
However, over the years the meaning and scope of this independence of the
judiciary have been much discussed and deliberated upon, raising questions as to
whether such independence is absolute or if it suggests an insubordination of
the executive and legislature. One such branch of discussion grew around the
powers of appointments of judges of High Courts and Supreme Court. Judges are an
integral part of the judiciary and a transparent, clear and democratic system
dealing with the appointment of Judges is necessary for the continuance of an
efficient judicial system which upholds the trust of the people, guards the
constitutional values and democracy and balances the other organs while keeping
them in check.
Article 217(1) of the Indian Constitution provides that every judge of a High
Court shall be appointed by the President by warrant under his hand and seal on
consultation with the Chief Justice of India, the Chief Justice of the concerned
High Court and the Governor of the concerned state. Through this article, the
power of appointing the judges is placed upon the President of India and thus,
the executive. The first judges transfer case, which took place in 1981 was one
of the first instances where this balance between executive's power to appoint
judges and the potential effect it could have on the independence of the
judiciary was discussed.
The case set a precedent for the evolving the system of appointment of the
judges and putting in place a 'Collegium System' was discussed. Subsequently
the second and third judges transfer case put into effect the Collegium system
and also modified it to address the loopholes in the system. The fourth and the
most recent judges transfer case of 2015 abolished the National Judicial
Appointment Commission that was introduced for the selection of candidates for
the post of a Judge of a High Court.
The other side of the argument remains however, that the collegium system while
keeping a check on the influence of the executive on the judiciary, is itself a
non-transparent and ambiguous process and is not in consonance with the very
democratic value it seeks to protect. This paper discussed the stages of
development of the present system of Appointment of the Judges through the four
judges transfer cases in its relation to constitutional democracy. The article
seeks to understand the tussle between the executive and judiciary and potential
impacts of both on the judicial system as a whole.
Judges Transfer Cases
The appointment of judges has been seen to be closely connected with the
independence of judiciary. Three major judgements in the last two decades of the
twentieth century took cognizance of the same and worked on evolving a system of
appointment and transfer of judges.
S.P Gupta v Union of India
The case of SP Gupta v Union of India is the first judges transfer case, that
took place in 1981. This case set the precedent for incorporation of a Collegium
System that was subsequently developed. The case developed through a bunch of
petitions that were filed across different high courts in India primarily
against the issue of appointments and reappointments of additional judges, which
the petitions alleged directly affected the independence of judiciary in India.
Some key issues that were challenged were the non-extension of the term of an
additional judge, the order of the Union Law minister directing Chief Ministers
directing appointment of additional judges in other states, as well as the
appointment of additional judges in the Supreme Court.
Judgement of the Case:
In the Judgement of the Case, it was held the while the non-extension of the
term of the additional judge, Justice S.N. Kumar was valid, it pointed out in
the difference in the use and implementation of Article 224(1) by the executive
and the interpretation of the article itself. Article 224(1) provides that
President of India can appoint additional judges in High Courts when there is an
increase in the business of the courts and that such appointments cannot exceed
a time period of 2 years. These appointments are also subject to the conditions
for appointment of a judge as provided under Article 217.
The court saw the interpretation of the article as, those appointments of judges
which were temporary for reasons of dealing with increased work load in certain
high courts for a limited period of time. The appointments of additional judges
were to be so as to clear off the arrears of the court within two years. The
nature of appointments was temporary, and the additional judges were expected to
go back to the bar after serving their term. This was under the presumption that
the government would appoint a sufficient number of judges in the higher
judiciary, which would be able to deal with the work load in the courts in
ordinary course of nature and therefore, the appointment of additional judges
required would only be for a limited period of time.
However, the implementation of the Article, by appointing and re-appointing
additional judges had led to a practice that the appointment as a additional
judge would subsequently lead to an appointment for the permanent post of judge
and the appointees had a right to form a legitimate expectation to be
subsequently considered for the posts of permanent judges. There was also a
strict emphasis on how appointments for additional judges cannot be made when
there were vacancies in the posts of permanent judges.
In the judgement, there has been an overall disapproval of the practice of
appointments of temporary judges, as it left a possibility of misuse of power
for the appointed judges would ideally have to return to the bar. In case of an
ideal implementation of judge, the additional judges would have served for a
temporary term and would therefore have a lesser chance of misusing their
position after they returned to the bar, but because there has been a continuous
practice of extension of the terms of the additional judges, the scope of misuse
The meaning and Nature of Consultation
A long and essential part of the Judgement discussed the meaning and nature of
the term 'consultation' as used under Article 217(1).
The article reads as follows:
- Every Judge of a High Court shall be appointed by the President by
warrant under his hand and seal after consultation with the Chief Justice of
India, the Governor of the State, and, in the case of appointment of a Judge
other than the Chief Justice, the Chief Justice of the High Court, and shall
hold office, in the case of an additional or acting Judge, as provided in
article 224, and in any other case, until he attains the age of sixty two
Here, the word 'consultation' subjected, to some extent, the power of the
executive power held by the president to appoint judges, to the
constitutional functionaries i.e., the Chief Justice of India, the Chief
Justice of the High Court and the Governor of the state. The meaning of
consultation was seen to be full and effective consideration by the
constitutional functionaries based upon full and identical material and not
on irrelevant consideration. However, according to the judgement such
consultation did not mean that the opinion the Chief Justice was to be given
primacy, nor were the opinions provided were binding upon the president.
The judgement saw the power of the appointment of judges to be vested in the
President and by his virtue in the Union government. While the dangers of
vesting of power in a 'single person' were realized, the judgement believed
that the process of consultation of the constitutional functionaries, serves
to an extent as a safeguard, but at the same time clearly pointed that such
a mechanism did not mean that the opinion of the Chief Justice of India
enjoyed a primacy in the process of consultation and that the end decision
was still upon the president.
The judgement however very clearly highlights that the inclusion of the
provision of consultation indicates that the constitution makers wanted to
keep a safeguard against the power of the President while appointing judges,
as a means of ensuring independence of the judiciary. Further, the judgement
points how simply consultation does not provide an adequate safeguards and
suggests the formation of a 'collegium' which would recommend candidates for
appointment to the president. This collegium would have wider and broader
scope of interests in making consultations to the president. The collegium
would consist of those, who are expected to have the knowledge as to the
persons fit for appointment and would allow for recommendations of
candidates that would make for independent judges, investing into the
judicial proceedings meaning and significance for the deprived sections of
The instances of other nations like Australia and New Zealand were also
provided here, both of which had been leaning seriously towards the
formation of a Judicial Commission for appointments in the higher judiciary
and emphasized that the Indian government must also focus on the same.
The judgment also emphasized on formation of the collegium to decrease the
influence of the executive in the appointments in higher judiciary so as to
maintain the independence of the judiciary. While the power of appointments
was vested in the President, and was executive in nature, it was not
absolute, and had to be performed with safeguards, which then were the
constitutional functionaries, and that would be the ideal role of the
collegium as well, if so formed.
Significance of the Judgement The judgement was quite significant in so as far as setting the precedent
for the introduction of a collegium system. Th judgement presided over
certain important questions of law, and in the context of independence of
judiciary it provided the understanding of the word 'consultation' as used
in Article 217(1). The judgment provided that the process of consultation
was a necessary safeguard in the practice of appointment and transfers of
judges. There were detailed deliberations on the question of Independence of
Judiciary in the context of appointments and transfers of judges. The
judgement on the same question provided that while, the independence of
judiciary was of utmost importance.
Supreme Court Advocates-on-Record Association v Union of India This case arose out of writ petition filed in the form of a PIL by Advocate
Subhash Sharma and the Supreme Court Advocates on Record Association for
relief by filling the vacancies for permanent judges in high courts as well
as the Supreme Court. A nine-judge bench was subsequently formed to look
into the question of justiciability of fixing the number of judges as well
question re-taken up to look into whether the CJI's opinion should enjoy
primacy while appointing judges under Article 217(1), which was rejected in
the S.P Gupta case.
Judgement of the Case:
The judgment overruled the view held in the S.P Gupta case which placed primacy
over the President in the appointment of judges. The judgement held that the
consultation with the CJI should be given primacy in matters of appointment of
judges in the higher judiciary. Moreover, the judgment also emphasized that the
consultation with CJI must also include the opinions of two most senior judges
of the Supreme Court so as to ensure that the CJI is not providing an individual
opinion but one that was formed collectively by the persons serving at the Apex
court of law.
The judgment interpreted the word consultation to mean 'concurrence' of the
opinion of the CJI. While the opinion of the CJI was still not absolutely
binding upon the President, dissent from such consultation was only permitted
under specified circumstances and not based on the individual opinion of the
president. By this, the judgment reduced the role of the President in the
appointment of judges. The concurrence in the collective opinion of the CJI and
the senior judges was seen to be more important as these judges were better
equipped to fully assess the appointment or non-appointment of judges and their
suitability in the higher judiciary.
The procedure provided that in case of appointments where the opinion of the CJI
differed from that of the senior judges so consulted, and where the opinion of
the latter was for non-appointment of the recommendation by the CJI to which the
executive agreed, then non-appointment would stand valid. Similarly, in case of
appointment of judges in the High Courts, where the opinions of the CJI and the
CJ of the high court conflicted, non-appointment for valid reasons based on
relevant material was acceptable.
Significance of the Judgement
The judgement plays a significant role in as far as the establishment of the
Collegium System is concerned. In 1990, the Constitution (Sixty Seventh
Amendment) Bill, 1990 was introduced in the parliament which made a provision
for the constitution of a high-level judicial appointments commission known as
the National Judicial Commission, which could be formed by the president.
The bill provided that the CJI would serve as the chairperson of such
commission, and for any appointments in the Supreme the commission would consist
of the CJI and two most senior judges of the Supreme court. For appointments in
the High Court, the commission would consist of the CJI, serving as the
Chairperson, the Chief Minister of the State, next senior most judge of the
Supreme Court, the Chief Justice of the High Court and the next senior most
judge of the High Court.
This bill provided that the commission was to make recommendations to the
president for appointments of judges, and for the transfer of judges as well.
The commission would serve to be more transparent and to remove arbitrariness
from the process of appointments and transfers of the judges.
However, when the bill was not passed in the parliament, the court took it upon
themselves to resolve the problems arising out of the outdated model of
appointments that was in practice. There had been several instances, including
the said amendment bill, the 121st report of the Law Commission and even
international practices, which all provided for the formation of an appointments
commission so as to decrease the influence of the executive and to maintain the
independence of the judiciary. But despite this, when there was no significant
change seen the process, the judgement introduced the system of Collegium, which
was to make recommendations to the president.
Thus, by the way of the judgement, the collegium system became a result of
Judicial Pronouncement. The collegium system was seen to provide a far more
credible and transparent process for recommendations, appointments and transfers
of judges in the higher judiciary. The system however did not provide a broader
representation as was imagined by Jt. Bhagwati in the S.P Gupta case, and kept
the membership limited to senior judges.
In Re Special Reference 1 of 1998
Exercising his power under Article 143 to consult the supreme court of India,
the president of India, made a reference to the Supreme Court in the respect to
three issues, which were as follows:
- The issue of consultation by the CJI and other senior judges of the
supreme court by the president in the matter of appointments and transfers
of judges in the higher judiciary.
- Judicial review of transfer of judges
- The relevance of seniority of judges while making recommendations
It was clearly put down by the Attorney General that the Union of India is
not seeking a review of reconsideration of the 1993 judgement in this regard,
and has restricted itself to the questions posed in the reference.
The reference so provided to the question posed served not just as replies to
the reference but also laid down certain more clarifications in regards to the
Collegium System. These included:
- The opinion of the CJI, which has primacy in the process of consultation
and reflects the opinion of the judiciary, has to be formed collectively on
the basis of consultation with the collegium, comprising of the CJI and the
four senior most Judges of the Supreme Court. The Judge, who is to succeed
the CJI should also be included, if he is not one of the four senior most
- Views of the senior most Judges of the Supreme Court, who come from the
same High Courts where the persons to be recommended are working as Judges,
must be obtained in writing, if they are not part of the collegium.
- The recommendation of the collegium and the views of the member, along
with the views obtained of any other judge for the purposes of appointment
should be conveyed by the CJI to the government of India.
- The substance of the opinions of all those consulted by the CJI,
particularly of any non-judges should be stated in the memorandum and should
be conveyed to the Government of India.
- The collegium system should in ordinary course of things make
recommendations on the basis of consensus of the opinions of the members.
However, no one would be appointed in the case the CJI dissents.
- In case two or more members of the collegium dissent the CJI should not
continue with the recommendation of such person to the president.
- In case of non-appointment of a candidate recommended, the materials and
information so conveyed by the Government of India for the same must be
placed before the collegium, original or reconstituted. Further, it is upon
the collegium, to decide whether the recommendation should be withdrawn or
reiterated. Reiteration is possible only when it is decided unanimously by
- It is upon the discretion of the CJI to bring to the knowledge of the
person recommended, the reasons for non-appointment, which have been
provided by the Government of India. The CJI may also ask for a response
from such person, and if made, the response is to be considered by the
collegium before withdrawing or reiterating the recommendation.
- The predominant consideration while recommendation should be merit.
However, the inter-seniority of the Judges in their High Courts and their
combined seniority on an All-India basis should also be given weight.
- Cogent and good reasons should be recorded for recommending a person of
outstanding merit regardless of his lower seniority.
- While recommending one of many persons almost an equal degree of merit,
the factor of the High Courts not represented on the Supreme Court, may be
considered by the collegium.
- The Judges passed over can be reconsidered unless strong reasons had
been recorded for non-appointment to an extent that such person is never to
- The recommendations made by the CJI without following the norms and
requirements, are not binding on the government.
Significance of the Case
Through this, the working of the collegium system was further refined and
polished further. This case dealt with all the questions related to the working
and administration of the collegium system. As a result of this, there was an
increase in the number of judges in the collegium, who were to be consulted by
the President for the appointment of judges. The collegium, resultantly, came to
be constituted of the Chief Justice of India and four other senior-most judges
of the Supreme Court.
It was also held that the presence of the Chief Justice in the collegium does
not mean that only his advice will be taken into consideration but that everyone
in the collegium will be consulted by the President equally i.e., plurality of
opinions in the consultation process was seen to be a necessary part of the
collegium system in order to ensure that it was not merely the individual
opinion of the CJI.
Supreme Court Advocates-on-Record Association v Union of India (2015)
This case is also known as the 'Fourth Judges Case'. It became significant after
a judgement on the National Judicial Appointments Commission (NJAC). The NJAC
was established by the National Judicial Appointments Act of 2014, which was
held to be unconstitutional and thus, void by the Supreme Court.
This Commission was formed to recommend the names of candidates for the
appointment of judges in the Supreme Court and the High Courts within the
collegium system. The five-judge bench, in this case, held the commission
unconstitutional, stating that lack of proper parliamentary procedure while
enacting the 99th Constitutional Amendment Act, 2015, which established the
The Court also held the Amendment Act unconstitutional. The majority opinion
held that it affected the independence of the judiciary as the commission was
established by the legislature and so the appointment procedure of the judges
would not be transparent.
The National Judicial Appointments Commission
The commission was constituted in order to help the President with the
appointment and transfers of judges in the Supreme Court and High Courts. The
constitution of the commission was envisioned to be as follows:
Significance of the Judgment
- The Chief Justice of India to serve as the chairman of the commission.
- Two senior-most judges from the Supreme Court.
- The Union Minister of Law and Justice.
- The other members to be two eminent persons who were selected by a
committee consisting of the Prime Minister, the Chief Justice of India, and
the leader of the opposition party as members.
The constitutional bench of the Apex court declared the NJAC to be
unconstitutional for violating the basic structure of the constitution. The
amendments so brought as a result, thus were set aside. The judgement held that
the primacy of the judiciary in the process of appointments cannot be
compromised. Further, the composition which once again increased the role of the
executive, and reduced the representation of judiciary, stood to affect the
independence of the judiciary.
The Present System of Appointments
Through the Judges Transfer Cases, presently remains in place the collegium
system for appointments and transfers of judges in the higher judiciary. The
collegium presently is constituted as follows:
Appointment of the Chief Justice of India and other Supreme Court Judges
- In case of appointment of judges in the Supreme Court: The CJI along
with the four senior most judges
- In case of appointments in the High Court, the CJI along with the two
senior most judges
The Chief Justice of India is appointment by the President under Article 126 of
the Constitution. The recommendation for the appointment of the next CJI is
generally made by the outgoing CJI and a practice of appointing the CJI on the
basis of seniority has been generally followed.
For appointing any person as a judge in the Supreme Court, the CJI initiates the
procedure for recommendation. The CJI in consultation with the collegium
provides recommendations for the post and these are conveyed to the Union Law
Minister which is then conveyed to the Prime and Minister and the President for
advisement. In the collegium so formed, the opinion of the succeeding CJI must
also be obtained, if such person is not one of the four senior most judges.
Further, the opinions of those senior most judges must be obtained who hail from
the same high courts as the recommended persons.
For Appointment of the Chief Justice of High Courts
The appointment of the Chief Justice of a High Court follows the policy of
having Chief Justices from outside the respective States. The Collegium takes
the call on such elevation. High Court judges are recommended by a Collegium
comprising the CJI and two senior-most judges. The proposal, however, is
initiated by the outgoing Chief Justice of the High Court concerned in
consultation with two senior-most judges of the concerned court. The
recommendation is then sent to the Chief Minister, who advises the Governor to
send the proposal to the Union Law Minister.
Advantages of the Collegium System
The collegium system ensures independence of judiciary. By reducing the role of
executive in the process of appointment and placing primacy with the Judiciary,
the system ensures that the influence of politics and legislature is kept at
bay. This allows the judges to work without the pressure and influence of any
other material and give judgements based on relevant and material facts.
It must also be seen that the Collegium consists of the judges of the Supreme
Court itself and also consults the judges of the High Courts as and when
required. Since these members are appointed as judges themselves, they have a
better grasp at judging the suitability of a person for the concerned post.
Issues present in the Present System
The present system was evolved by means of judicial pronouncements, with the aim
of maintaining the independence of judiciary in India. However, over the course
of time this system has also developed its own set of issues, the biggest of
which has been the lack of democratic processes in the appointment of judges.
The issues in the present system are dealt with in detail in following points:
A system of Secrecy
While the system lays down that judiciary enjoys primacy in the process of
appointments and it is not simply the CJI whose opinion is being considered, but
that of a whole collegium, the actual process of recommendations still remains,
to the larger extent, a process completed in secrecy. There are no guidelines
per say, to determine the 'suitability' of a person for being recommended.
Further the process remains a 'close door mechanism', with its proceeding closed
to the public, with no clarity as to how the collegium takes its decision. There
are no minutes of the meetings provided, there is no official secretariat
present during the meeting, which keeps the entire process of the collegium a
secret. Scope for Favoritism and Nepotism
There are no fixed criteria for testing a candidate for the concerned post. The
decision is left more or less on the collegium with no guidelines for the
proceedings. Such a system thus allows a great scope for the collegium members
to practice favoritism and nepotism. This also leads to the building of an
ambiguous and non-transparent process.
Lack of Checks and Balances
The reduced role of the executive from the collegium system might act as a
safeguard for the independence of the judiciary, but it also strikes a blow to
the system of checks and balances that is ideally supposed to be created between
the three organs.
Moreover, the system holds no means of placing accountability. The decisions of
the collegium are not under the executive or public scrutiny till much later,
which means any decision of the collegium cannot be questioned from the get-go
and reduces the changes of the administrative body from being held accountable
for its decisions.
The problem of Representation
The system of collegium, as ideally imagined by Jt. Bhagwati was to create a
credible body of people with broad representation, so as to make recommendations
of such nature that would allow justice to be served better. However, the
collegium system so incorporated did not keep this view in mind and created a
narrow body of individuals only from the higher and superior judiciary. In
practicality, such a body does not provide adequate representation to women, or
members of other communities, like the transgender community. Such unusual
representation, while not new in the system of judiciary, goes a long way to
affect the inclusion of both persons of other genders and communities and their
Independence of the Judiciary in its relation to Constitutional Democracy
Constitutional Democracy in Other Organs of the Government
The major significance of the four judges transfer cases was the establishment
of the collegium system. The entire of point of contention, and the reasoning
behind the establishment of the system boiled down to the independence of the
judiciary. The collegium reduced the influence of the executive in the process
of appointments and transfers.
The appointment of judges in a system which kept at bay, political and other
influences, allowed the judges to freely perform their functions without feeling
that their growth was dependent upon another. The freedom and independence of
the judges would thus allow them to make truly fair and equal decisions, free of
all sorts of political, and executive influences.
However, this independence of the judiciary has been maintained at the expense
of transparency and democracy. A democracy vests its power in its people, which
forms the rule of the people. In a system of constitutional democracy, the
vesting of such power, the derivation of rights and privileges of the people
flow from the constitution of the nation. The people chose their
representatives, and decide their rules, by means of the power vested in them by
These representatives are elected directly in the parliament and state
legislative assemblies, both of which function as law making bodies. Thus the
representatives so elected by the people are directly involved in the law-making
process, by means of which the same people will be governed.
Lack of Representation of People in Judicial Appointments
The appointment of judges and their functioning however, it governed and guided
purely by the provisions of the constitution and nothing else. The common people
are not involved in any stage of appointment of judges, and the judges are not
representatives of the people. This means that on one hand, there is little to
no scope for dirty politics in the judicial appointments, as has been developed
for elections in the nation, the other side remains where the common people and
their opinions and concerns are not adequately represented. Furthermore, India
as a nation is a constitutional democracy, but in the judiciary, it is not the
people's rule that persists.
The system of collegium has brought into existence a system that is inclusive of
only the members of the judiciary, keeps the process of appointments of judges
limited primarily within the judiciary, govern themselves without any
accountability to the people, while the other two organs and their process
remain completely open to scrutiny of the eyes of the people. The system of
judicial appointments has been formed in a way that any and all external sources
are kept ay bay and only play a minimal role.
The broader picture that is thus painted, is one that keeps out everyone from
its processes and functions. The common people get no say in the whole process
where their concerns have no guarantee of being recognized or heard. It remains
upon the judges so appointed to take cognizance of matter, or to work towards
the greater good of the people, but they are not responsible or answerable to
the people if they act otherwise.
The matter boils down to maintaining a balance between ensuring the independence
of the judiciary, keeping it free from any political or executive pressures and
influences while appointing the judges so as to allow them to exercise their
functions properly and in accordance with the law, without owing any
consideration to other irrelevant material or facts. Such circumstances, where
the judiciary is completely independent and free in its functioning, the judges
can truly achieve their purpose and serve just, fair and equitable judgements.
A free and independent judiciary is necessary to uphold the trust of the people
in the justice system of India. It is also the judiciary that is entrusted with
uphold the democratic principles of the nation, to keep in check the other
organs of the government and to hold them responsible where they do wrongs. The
judiciary not only interprets the constitution but also guards it, and upholds
the basic constitutional values in the nation.
However, this independence is ensured and maintained on a double-edged sword. A
system free from all influences, including the very people is seeks to serve
justice to, leaves behind a large scope for arbitrariness and ambiguity.
Judiciary is that organ that holds the other accountable, keeps a check on their
power and balances them out but the judiciary itself cannot be held accountable
for its action, in so far as the appointments is concerned. The judiciary is not
answerable to the public and thus, systemically excludes the common people from
its official processes, leaving a case of lack of proper representation.
The four judges transfer cases had rightly recognized the threat to the
judiciary and consequently the democracy if the appointments were left to be a
completely executive process. The possibility of these appointments soon turning
into a tool for the executive to interfere in the judicial proceedings was very
much real. The benches in all these cases had highlighted the importance of
maintaining the independence of the judiciary and through it ensuring the
continuance of a democracy in the nation.
The judgements, through judicial pronouncements thus sought to create a system
which ensured that such independence in maintained, by reducing the role of the
executive, and by limiting the processes primarily to the members of the
In the present times, it can be said, that these judgements essentially were the
basis on which the independence of the judiciary continues even today allowing
the organ to perform its functions, to quite an extent, it its truest and
realest sense. Any compromise on the Independence of Judiciary can have an
almost permanent effect upon the nature of democracy in India and thus, it is
one of the most basic principles of the constitution, that must in all
importance be upheld.
This system however cannot justify its ambiguity and non-transparency in the
name of the same independence. There are essential changes needed in the
collegium system to make it more transparent, efficient and more importantly, a
little reflective of the very democratic principles, that it seeks to protect.
- Suggested by PN Bhagwati in SP Gupta v UOI (1981)
- S.P Gupta v Union of India AIR 1982 SC 149
- Jt. Bhagwati in SP Gupta v. UOI (1981)
- Supreme Court Advocates-on-Record Association (1993) 4 SCC 441
- In re Special Reference 1 of 1998 (1998) 7 SCC 739
- Supreme Court Advocates-on-Record Association (2015) 6 SCC 408
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