In a significant procedural development aimed at strengthening the accuracy and credibility of court records, the Supreme Court of India has issued clear directions to its Registry not to clear or list any petitions that contain black-and-white photographs. The apex court has further mandated that Advocates-on-Record (AoRs) must ensure that all photographs filed along with petitions are in proper colour format and supported by relevant distance dimensions and conceptual plans. Until such compliance is ensured, the matter will remain categorised under “defects not cured” and will not be taken up for listing.
This direction was passed by a bench comprising Justice Surya Kant (now Chief Justice of India), Justice SVN Bhatti, and Justice Joymalya Bagchi in the case of Dinamati Gomes v. State of Goa, SLP(C) No. 7944/2024. The order reiterates the Court’s commitment to maintaining procedural discipline and ensuring that all visual evidence presented is clear, authentic, and reliable.
Why the Supreme Court Rejected Black-and-White Photographs
The Supreme Court observed that black-and-white photographs often fail to capture essential visual details that may be crucial for adjudication. Colour photographs provide clarity regarding environmental conditions, physical structures, distances, and contextual elements, which can be decisive in cases involving land disputes, environmental matters, construction violations, and infrastructure-related litigation.
By refusing to entertain petitions with monochrome images, the Court seeks to prevent ambiguity, misrepresentation, or misinterpretation of factual evidence. The directive ensures that judges have access to precise visual documentation, promoting fairness and accuracy in decision-making.
Registry Instructed Not to Clear Non-Compliant Paper-Books
The Supreme Court has categorically instructed its Registry to not clear any paper-book for listing if it contains black-and-white photographs. The order specifies that such matters will be kept in the list of “defects not cured” until the required compliance is fulfilled.
The bench stated that unless properly coloured photographs, along with distance dimensions and a conceptual plan, are appended, no such material shall be allowed to be placed on record. This places a responsibility not only on litigants but also on Advocates-on-Record to diligently verify compliance before filing.
This move is expected to significantly enhance the quality of documentation being placed before the Supreme Court and reduce procedural delays caused by incomplete or improperly filed records.
Mandatory Submission of Hard Copies for E-Filed Photographs
Another important aspect of the Supreme Court’s direction concerns petitions filed electronically. The Court clarified that even if coloured photographs are submitted via e-mail or e-filing, AoRs must simultaneously file hard copies of the same coloured photographs.
This dual requirement ensures that there is both a digital and physical record of the visual evidence, safeguarding the integrity of case files and reducing the risk of tampering, distortion, or loss of crucial material.
The decision aligns with the Supreme Court’s broader policy of blending technological efficiency with traditional procedural safeguards.
Background: September 2024 Order on Black-and-White Photographs
It is noteworthy that this is not the first time the Supreme Court has taken a firm stance on this issue. In September 2024, a bench led by Justice Surya Kant had already restrained the Registry from accepting black-and-white photographs produced by parties without the Court’s specific permission.
The recent order reinforces this earlier direction and institutionalises the practice as a mandatory procedural requirement, leaving little room for discretion or deviation.
Implications for Advocates-on-Record (AoRs)
The responsibility of compliance now squarely rests on AoRs, who act as the primary interface between litigants and the Supreme Court. They must ensure:
- All photographs filed are in clear, coloured format
- Images include distance dimensions
- A supporting conceptual plan accompanies the photographs
- Hard copies are filed even when e-filing is used
- No black-and-white images are appended without court permission
Failure to adhere to these directives could result in delays in listing, procedural setbacks, or even dismissal due to non-compliance.
This move encourages higher professional diligence and reinforces the importance of precision in legal documentation.
Strengthening Judicial Efficiency and Transparency
The Supreme Court’s directive highlights its intent to streamline judicial processes while enhancing transparency and accuracy. By insisting on high-quality visual documentation, the Court ensures that disputes are resolved on the basis of clear, verifiable, and complete evidence.
This also helps in reducing judicial confusion, unnecessary adjournments, and repetitive clarifications due to unclear photographic evidence, thereby contributing to faster resolution of cases.
Case Details
Case Title: Dinamati Gomes v. State of Goa
Case Number: SLP(C) No. 7944/2024
Citation: 2025 LiveLaw (SC) 1136
Bench: Justice Surya Kant (CJI), Justice SVN Bhatti, Justice Joymalya Bagchi
The Court observed that unless compliance is complete, the matter will continue to remain in the defect category, reinforcing strict procedural discipline.
Legal and Procedural Significance
This directive marks an important milestone in the evolving procedural landscape of the Indian judiciary. It reflects the Supreme Court’s proactive role in ensuring that technical aspects of filing do not compromise the quality of justice delivered.
From environmental litigation to civil disputes, where photographic evidence plays a decisive role, the insistence on coloured visuals signifies a shift towards more reliable and detailed legal documentation.
Moreover, the focus on conceptual plans and dimensions ensures that the photographic evidence is not merely illustrative but analytically useful for judicial assessment.
Conclusion
The Supreme Court’s directive to reject petitions filed with black-and-white photographs and mandate colour photographs marks a crucial reform in judicial filing procedures. By placing the onus on Advocates-on-Record and strictly instructing the Registry to ensure compliance, the apex court has reinforced the importance of clarity, accuracy, and procedural integrity.
This decision not only enhances the quality of legal records but also contributes to efficient case management and fair adjudication. As the judiciary continues to adopt technology-driven reforms, such procedural mandates ensure that the balance between efficiency and reliability remains intact.
For advocates and litigants alike, this ruling serves as a reminder that even seemingly minor procedural requirements can have a significant impact on the progress and outcome of legal proceedings.
With this firm stance, the Supreme Court of India has once again demonstrated its commitment to maintaining high standards in the administration of justice, ensuring that every petition presented before it meets the threshold of clarity, completeness, and authenticity.
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