The Supreme Court has underscored that while courts may sometimes decide cases on a single decisive point of law, the ideal practice is to address all issues raised by the parties in appeals or petitions to ensure comprehensive adjudication and clarity in the record. A bench of Justices S. Ravindra Bhat and Bela M. Trivedi articulated this principle while hearing an appeal arising out of a dispute concerning the interpretation of contractual obligations under a joint development agreement. The Court observed that appellate courts often limit their reasoning to a singular legal point that determines the outcome, but emphasised that such an approach can leave other important questions unanswered, leading to avoidable litigation in future and uncertainty in the law.
In its detailed judgment, the Supreme Court noted that courts are generally justified in deciding cases on a determinative issue where it clearly governs the result, but identified circumstances where addressing additional issues raised by the parties would add value to the judicial record and aid future cases. The bench explained that answering all substantial questions of law and fact presented in the pleadings, even where one such issue may be sufficient for the result, fosters clarity and prevents piecemeal litigation. The Court highlighted that comprehensive reasoning enhances the quality of judicial decisions and contributes to the development of jurisprudence, particularly in complex matters involving multiple legal facets.
The case before the Supreme Court involved an appeal against the judgment of a High Court that had ruled on specific grounds without examining all contentions raised by the appellant regarding alleged breaches in a joint development agreement. The appellant contended that the High Court’s limited approach resulted in an incomplete adjudication of its grievances. In examining this contention, the Supreme Court explained that while courts have discretion to focus on a single determinative issue, the better practice is to engage with all contested questions if they are substantial and material to the controversy between the parties.
The Supreme Court also clarified that a court’s obligation to address every issue is not absolute in every case and recognised practical constraints such as judicial time and the nature of the controversy. Nonetheless, the bench stated that when multiple issues have been specifically raised and argued, it would generally be preferable for courts to deal with them in the judgment unless doing so would be wholly unnecessary in the context of the decision. The Court’s ruling suggested that a more holistic adjudicatory approach aids litigants by providing them with reasoned answers on all points of contention, reducing uncertainty and enhancing the predictability of legal outcomes.
In its reasoning, the Supreme Court highlighted the broader adjudicatory function of courts, which includes not only resolving the dispute at hand but also providing reasoned guidance on legal questions for the benefit of the litigants and the wider legal community. It observed that judgments addressing multiple issues may serve as precedents with greater clarity, reducing the likelihood of future disputes over legal points that were left unanswered. The Court emphasised that the ideal of answering every issue raised, where feasible, supports the interests of justice and contributes to the integrity of the judicial process.
Accordingly, in disposing of the appeal, the Supreme Court remanded certain aspects of the matter to the High Court for reconsideration, directing that the additional issues raised by the appellant be examined and adjudicated upon in light of the evidence and legal submissions. The Supreme Court’s observations serve as a guiding principle for judicial practice, advocating for thorough and comprehensive judgments that engage with the full spectrum of contested contentions in a case rather than relying solely on a single point to determine the result.
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