Judicial Integrity and Accountability: A Supreme Court Perspective

Facts of the Case

1. Nature of the Dispute:
   The appellant, an Additional District and Sessions Judge in Delhi, challenged the adverse remarks made against him by the Delhi High Court in connection with his handling of a bail matter.
2. Judicial Background:
   • The appellant had denied anticipatory bail to an accused in a theft case and issued sharp directions and observations regarding police conduct.
   • The High Court, on a petition by the Investigating Officer (IO) and Station House Officer (SHO), expunged the appellant’s remarks, labeling his actions as unwarranted and “judicial misadventure.”
3. Appellant’s Grievance:
   • The adverse remarks (paragraphs 13 and 14 of the High Court’s judgment) could damage his unblemished judicial career.

Contentions of the Parties

Appellant (Sonu Agnihotri):

1. His observations on police procedural lapses were necessary for ensuring accountability and upholding judicial duty.
2. The High Court’s remarks were unwarranted, stigmatizing, and detrimental to his career.
3. Criticized the reliance on now-repealed Rule 6 of the High Court Rules, which discouraged judicial officers from commenting on police conduct.

Respondents (Chandra Shekhar & Ors.):

1. Judicial officers should avoid overreach and maintain restraint in making adverse remarks, especially when not integral to the case’s decision.
2. Highlighted principles from previous judgments emphasizing judicial restraint.

Principles Enunciated

1. Judicial Restraint and Dignity:
   Observations on individuals or institutions by judges should be necessary for case resolution and made with sobriety, avoiding stigmatization.
2. Supervisory Role of High Courts:
   High Courts possess supervisory powers but must exercise them with care to maintain judicial independence and fairness for subordinate judges.
3. Expunging Remarks:
   Personal adverse remarks against judicial officers in judgments can undermine their dignity and careers, violating principles of natural justice.

Final Order

1. The Supreme Court allowed the appeal, directing the expunging of adverse remarks in paragraphs 13 and 14 of the High Court’s judgment.
2. The Court emphasized that while judicial independence allows accountability, such matters should ideally be handled on the administrative side, ensuring fair opportunity for the concerned officer.

Impact on Public Law and Order

This judgment reinforces the balance between judicial accountability and independence. It upholds the dignity of subordinate judicial officers, encouraging fair criticism without undermining their integrity. This ensures trust in the judiciary while promoting restrained and responsible adjudication.

Citation: Sonu Agnihotri vs. Chandra Shekhar & Ors., 2024 INSC 888.