In a strongly worded judgment, the Supreme Court has criticized the growing trend of inconsistent rulings by coordinate benches, calling it a serious threat to judicial discipline and public trust. The Court observed that such inconsistencies reduce litigation to a “punter’s game” and open the doors to forum shopping and judicial caprice.
This significant ruling came in the case Renuka v. State of Karnataka and Anr. [2025 LiveLaw (SC) 511], where the apex court, comprising Justice PS Narasimha and Justice Joymalya Bagchi, set aside a Karnataka High Court order that had quashed domestic violence proceedings against the complainant’s husband while ignoring an earlier ruling by a coordinate bench that had allowed proceedings against similarly placed in-laws.
Background: Two Conflicting High Court Orders
The case arose out of a complaint filed by a woman, Renuka, alleging domestic violence by her husband and in-laws. Initially, the Karnataka High Court refused to quash the proceedings against some of the in-laws. However, in a later proceeding, a coordinate bench of the same High Court quashed the case against the husband, without referring to or distinguishing the earlier decision involving the in-laws.
Aggrieved by the contradictory rulings, the complainant approached the Supreme Court seeking justice and uniformity in adjudication.
Supreme Court’s Ruling: Precedent Must Be Respected
Delivering the judgment authored by Justice Joymalya Bagchi, the Supreme Court highlighted the principle of “stare decisis”, which mandates courts to follow precedent to maintain uniformity and predictability in the legal system.
The Court emphasized:
“Consistency in judicial outcomes is the hallmark of a responsible judiciary. Inconsistent decisions coming out from different benches shake public trust and reduce litigation to a punter’s game.”
The Bench underlined that coordinate benches — those composed of judges of equal strength — are bound to either follow earlier rulings or provide detailed reasons for deviating from them. Failing to do so, the Court held, results in an erosion of judicial propriety and undermines legal certainty.
Failure to Acknowledge Precedent Amounts to Judicial Arbitrariness
In the present case, the subsequent bench of the High Court did not even acknowledge the earlier judgment refusing to quash proceedings against the in-laws, let alone provide any reasoning for arriving at a different conclusion with respect to the husband. This led to an illogical situation where the husband — the primary accused — was exonerated while the in-laws continued to face trial for the same set of allegations.
The Supreme Court called this judicial inconsistency “arbitrary and capricious”, holding that:
“It was incumbent on the Judge while quashing the proceeding against the respondent husband to refer to the earlier decision of the co-ordinate bench and distinguish the reasons therein to arrive at a different conclusion. Failure to do so infracts judicial propriety and discipline.”
The apex court concluded that such erratic rulings lead to sharp practices like forum shopping and ultimately damage public confidence in the judiciary.
Appeal Allowed, Proceedings Revived
Allowing the appeal, the Supreme Court set aside the Karnataka High Court’s order and revived criminal proceedings against the respondent-husband. The decision ensures that all accused will face trial together and be subjected to the same legal standards, upholding the principle of equality before law.
Legal Significance of the Judgment
This decision is a powerful reaffirmation of core judicial values:
- Judicial Discipline: The ruling underscores the obligation of coordinate benches to respect earlier decisions or explain deviations. Without this discipline, chaos and unpredictability dominate.
- Public Confidence in Judiciary: Uniformity in rulings helps maintain credibility, while conflicting judgments create confusion and diminish faith in the justice delivery system.
- Forum Shopping Discouraged: Inconsistency gives litigants incentives to “shop” for favorable benches, undermining the sanctity of impartial adjudication.
- Strengthens Stare Decisis: The judgment strengthens the doctrine of precedent, a cornerstone of common law systems, ensuring legal stability and predictability.
Quotes from the Judgment
Several powerful observations were made by the Court:
- “Inconsistent decisions coming out from different benches shake public trust and reduce litigation to a punter’s game.”
- “It gives rise to various insidious sharp practices like forum shopping, spoiling the clear stream of justice.”
- “Impugned order suffers from the vice of judicial caprice and arbitrariness and is liable to be set aside.”
These remarks are not just critical of the Karnataka High Court’s handling of the case but also serve as a cautionary guideline for all High Courts and subordinate courts across the country.
Case Details
- Case Title: Renuka v. State of Karnataka and Anr.
- Citation: 2025 LiveLaw (SC) 511
- Bench: Justice PS Narasimha and Justice Joymalya Bagchi
- Date of Judgment: 1 May 2025
Conclusion
The Supreme Court’s ruling in Renuka v. State of Karnataka is a stark reminder of the importance of judicial consistency and adherence to precedent. In a legal system that relies heavily on prior rulings to guide future conduct, arbitrary deviations not only create injustice in individual cases but also erode the entire edifice of legal certainty.
The judgment is a call for greater judicial accountability, reinforcing that justice must not only be done but must be seen to be done uniformly. For litigants, it reaffirms the hope that the legal system is governed by reasoned principles rather than randomness. For the judiciary, it is a stern reminder that judicial discipline is the bedrock of justice.
