In a significant ruling reaffirming the administrative supremacy of the Chief Justice within the High Court, a Division Bench of the Gujarat High Court has expunged strictures passed by a single-judge against the court registry regarding delays in the installation of CCTV cameras on the court premises. The Bench comprising Justice AS Supehia and Justice RT Vachhani held that puisne judges cannot encroach upon the administrative domain of the Chief Justice, including matters relating to the functioning and regulation of the registry.
The case, titled High Court of Gujarat v. Babubhai Sampatbhai Pateliya & Ors., arose from orders passed by Justice Sandeep N Bhatt, who had censured the registry over delays in executing a 2023 directive mandating CCTV installation within the High Court campus.
Background of the Controversy
The controversy traces back to an order dated August 18, 2025, passed by Justice Sandeep N Bhatt. In his order, the single-judge expressed sharp criticism over the failure of the High Court registry to comply with an earlier direction for the installation of CCTV cameras across the High Court premises, including its registry.
Justice Bhatt had observed that despite a 2023 order directing compliance by January 2024, no tangible progress had been made. He remarked that this failure created opacity in court administration, making it harder to trace alleged irregularities. He insisted that CCTV cameras be installed in “every corner of the Registry covering every table, corridors, and important places of the High Court campus”, so as to enhance transparency.
The single-judge did not stop at directing compliance but went on to censure registry officials, suggesting that the delay was not just bureaucratic inefficiency but an attempt to “mislead concerned persons” and push the issue “under the carpet.” He even equated the registry’s approach with government-style “red tapism.”
Unsurprisingly, these strictures against the registry led to a challenge before a Division Bench by the present Registrar (IT) of the Gujarat High Court.
Division Bench Decision: Upholding Chief Justice’s Authority
Hearing the appeal, the Division Bench comprising Justice AS Supehia and Justice RT Vachhani categorically ruled in favor of the registry, setting aside the order of the single-judge.
The Court observed that:
- Administrative Control Lies Exclusively with the Chief Justice
- The Bench held that while the concerns of Justice Bhatt regarding transparency were commendable, his judicial authority did not extend to administrative matters of the registry.
- Administrative control, regulation, and functioning of the registry are matters that fall exclusively under the domain of the Chief Justice.
- Puisne Judges Cannot Encroach on Administrative Supremacy
- The Court emphasized that puisne judges cannot override the Chief Justice’s administrative prerogative unless such authority has been specifically delegated or assigned to them by the Chief Justice.
- Beyond the Roster Jurisdiction
- The single-judge had amalgamated writ petitions belonging to different jurisdictions and rosters, thereby traveling beyond his judicial domain.
- Faith in Chief Justice for Administrative Standards
- The Bench stressed that the majesty, grandeur, and repute of the High Court depends on the proper functioning of its registry and departments, which can only be ensured by reposing full faith in the Chief Justice’s authority.
Accordingly, the Division Bench expunged the strictures passed by the single-judge against the registry and stayed any further monitoring by Justice Bhatt in relation to CCTV installation.
Observations of the Division Bench
The Court made several noteworthy observations:
- “The puisne Judges cannot encroach on the supremacy of the Chief Justice, when it comes to administrative control, regulation and functions of the Registry and its staff, unless it is specifically delegated or assigned.”
- “Though we commend the concern expressed by the learned single-judge relating to transparency, with due respect, we hold that the learned single-judge in his judicial capacity lacks the authority to command the registry in any way.”
- “The Hon’ble the Chief Justice is already apprised of the status of installation of CCTV cameras in the Registry of the High Court, and the same is under active implementation.”
These remarks collectively reasserted the institutional principle of judicial hierarchy within the High Court.
Justice Bhatt’s Earlier Observations
In his strongly worded order, Justice Bhatt had remarked that:
- The delay in CCTV installation suggested negligence and lack of seriousness on part of the registry.
- Transparency in court functioning was non-negotiable, and CCTV surveillance was vital to trace any alleged wrongdoing within the High Court premises.
- His order was being misunderstood as “renegade” by registry officials, who were treating the issue as a “storm in a teacup.”
Justice Bhatt had further criticized past registrars, noting that some had deliberately stalled the implementation process.
Division Bench’s Intervention in Context
The ruling of the Division Bench comes against the backdrop of earlier tensions between Justice Bhatt and the court registry. Notably, in February 2025, Justice Bhatt had passed another strongly worded order against then Registrar (SCMS & ICT) AT Ukrani, questioning how Ukrani had remained posted in the registry for over six years despite controversies and misunderstandings. That episode had prompted the Chief Justice to alter Justice Bhatt’s roster.
Thus, the present ruling also signifies the need to maintain balance between judicial independence of individual judges and the collective administrative authority vested in the Chief Justice.
Broader Legal and Administrative Implications
This decision has important implications not just for the Gujarat High Court but for all High Courts across India:
- Reaffirmation of Chief Justice’s Administrative Supremacy
- The ruling underscores that matters relating to staff, registry, and administrative control are outside the judicial powers of puisne judges.
- Clear Separation of Judicial and Administrative Functions
- Judges, while exercising judicial authority, must refrain from entering into administrative domains unless specifically empowered.
- Transparency vs. Hierarchy
- While transparency in functioning is vital, the proper forum for ensuring such measures is through administrative channels headed by the Chief Justice, not unilateral judicial orders by puisne judges.
- Strengthened Registry Autonomy
- The order shields registry staff from unwarranted judicial censures, reinforcing the principle that accountability must flow through the Chief Justice.
Conclusion
The Gujarat High Court’s decision in High Court of Gujarat v. Babubhai Sampatbhai Pateliya & Ors. is a vital reaffirmation of judicial discipline and institutional balance. By expunging the strictures of Justice Sandeep N Bhatt and staying his further monitoring of CCTV installation, the Division Bench has clarified that administrative control lies solely with the Chief Justice of the High Court.
While transparency and accountability in court administration remain pressing concerns, such objectives must be pursued within the framework of judicial hierarchy. The ruling thus strikes a careful balance: acknowledging the importance of transparency but refusing to compromise on the institutional authority of the Chief Justice.
As High Courts continue to modernize with measures like CCTV surveillance and digitization, this judgment ensures that reforms are carried out within proper administrative channels, preserving both efficiency and judicial integrity.
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