Reconciling Inconsistent Supreme Court Decisions: Guidance for High Courts

In a recent judgment, the Supreme Court of India addressed the approach High Courts should adopt when confronted with seemingly inconsistent decisions from the apex court. The bench, comprising Justices JB Pardiwala and R Mahadevan, emphasized that High Courts should not selectively follow one Supreme Court decision while disregarding another. Instead, they are mandated to make earnest efforts to reconcile both judgments, ensuring that the jurisprudence is harmonized and that both decisions are respected.

The court underscored the importance of contextual interpretation, advising that each judgment must be read in light of the specific facts and circumstances that led to its pronouncement. This approach ensures that the general expressions within a judgment are not misapplied beyond their intended scope. The bench recommended adopting the perspective of Lord Halsbury from the case of Quinn v. Leathern, 1901 AC 495 at p.506, which was reiterated by the Privy Council in Punjab Cooperative Bank Ltd. v. Commissioner of Income Tax, Lahore, AIR 1940 PC 230:

"Every judgment must be read as applicable to the particular facts proved or assumed to be proved, since the generality of the expressions, which may be found there, are not intended to be expositions of the whole law, but governed or qualified by the particular facts of the case in which such expressions are to be found."

This principle serves as a guiding beacon for High Courts, ensuring that the application of Supreme Court judgments remains faithful to the context in which they were delivered.

However, the Supreme Court also acknowledged that there may be instances where reconciling conflicting decisions is challenging. In such scenarios, the High Courts are advised to follow the precedent that aligns more closely with the facts of the case before them. This nuanced approach allows for a more tailored application of legal principles, ensuring that justice is administered effectively.

This recent guidance marks a departure from earlier directives. Previously, in the case of Union Territory of Ladakh v. Jammu and Kashmir National Conference, the Supreme Court had observed that when faced with conflicting judgments by benches of equal strength, High Courts should follow the earlier decision. The court had stated:

"When faced with conflicting judgments by Benches of equal strength of this Court, it is the earlier one which is to be followed by the High Courts, as held by a 5-Judge Bench in National Insurance Company Limited v. Pranay Sethi, (2017) 16 SCC 6805. The High Courts, of course, will do so with careful regard to the facts and circumstances of the case before it."

The evolution in the Supreme Court's stance reflects a more flexible and context-sensitive approach. By encouraging High Courts to reconcile conflicting decisions and consider the specific facts of each case, the apex court aims to promote a more nuanced and just application of legal principles. This methodology not only respects the integrity of past judgments but also ensures that the law evolves in a manner that is both coherent and adaptable to varying circumstances.

In conclusion, the Supreme Court's recent guidance empowers High Courts to engage in a thoughtful analysis when confronted with inconsistent precedents. By striving to reconcile such decisions and focusing on the factual alignment with the case at hand, High Courts can uphold the principles of justice while maintaining the consistency and harmony of legal jurisprudence.