Article 141 of Indian Constitution mandates that the law declared by the Supreme Court is binding on all courts in India. It ensures consistent legal interpretation and upholds the authority of the Supreme Court and supports uniform application of laws nationwide. It also ties into the Court’s power of judicial review and reinforces its role as the final interpreter of the Constitution. Explore other important Constitutional Articles.

Article 141 of Indian Constitution

Law declared by Supreme Court to be binding on all courts

The law declared by the Supreme Court shall be binding on all courts within the territory of India.

Note: “The information on Article 141 of Indian Constitution provided above has been sourced from the official website, i.e., Indian Code. While the content has been presented here for reference, no modifications have been made to the original laws and orders.”

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Article 141 of Indian Constitution plays an important role in establishing the principle of judicial precedent within the Indian legal system. It lays down that “the law declared by the Supreme Court shall be binding on all courts within the territory of India.” Article 141 of Constitution fosters consistency and uniformity in the interpretation and application of laws nationwide.

Binding Authority of Supreme Court Judgments

The main objective of Article 141 of Indian Constitution is to affirm the authority of the Supreme Court as the Apex judicial body in India. By mandating that its decisions are binding on all subordinate courts. Article 141 of Constitution bolsters the doctrine of precedent and hierarchical structure of the judiciary. As a result, the lower courts are obligated to comply with the legal interpretations and principles set out by the Supreme Court.

Doctrine of Stare Decisis 

The Doctrine of Stare Decisis in India is enshrined in Article 141 of Indian Constitution. The Latin term stare decisis means "to stand by decisions and not to disturb what is settled." This principle highlights the importance of legal precedents in guiding the resolution of cases with similar facts and legal questions.

Article 141 of Indian Constitution Scope and Exceptions

Article 141 of Indian Constitution requires that all Courts follow the rulings of Supreme Court, only the ratio decidendi (the underlying legal reasoning for the decision) is considered binding. The following are notable exceptions:

• Obiter dicta

Obiter dictum is a Latin term meaning "something said in passing." It refers to the Comments or observations made by judges that are not important to the decision are not binding. These statements are not legally binding but may carry persuasive value in future cases.

• Per incuriam

Per incuriam is a Latin term meaning "through lack of care." Judgments delivered without due consideration of relevant legal provisions are not authoritative. Such decisions are not considered binding and have no legal force.

• Sub silentio

Sub silentio is a Latin term meaning "in silence." It refers to a situation where a court applies a rule or principle of law without explicitly acknowledging or considering the relevant legal arguments or statutes. This typically occurs when the court does not address or discuss the legal point in its judgment.

• Legislative override

Legislative Provisions refer to laws passed by the Parliament, which holds supreme legislative authority. Parliament retains the power to nullify Supreme Court precedents by enacting new laws. Legislation can either explicitly or implicitly abrogate a judicial precedent, thereby altering its legal impact.

Article 141 of Indian Constitution Significance in the Indian Judiciary

By embedding the doctrine of precedent, often referred to by its Latin term stare decisis, into constitutional law through Article 141 of Indian Constitution, the Indian legal system promotes stability, uniformity and predictability. It enhances judicial accountability and guards against arbitrary rulings. The framework also streamlines legal proceedings by providing consistent guidelines for subordinate courts and reducing redundancy in judicial reasoning for similar legal questions.

Supreme Court Rulings Are Binding on All Courts

Article 141 of Indian Constitution lays down a foundational doctrine of the Indian judiciary: the law declared by the Supreme Court is binding on all courts across the country. Originally introduced as Article 117 in the 1948 Draft Constitution, it was incorporated as Article 141 in the final version adopted in 1950. It is important to preserve consistency & uphold hierarchical structure of Indian judicial system.

Article 141 of Indian Constitution allows adaptability. The Supreme Court may overrule its earlier decisions and lower courts can differentiate cases on factual grounds. Judgments made per incuriam or without substantive reasoning are not binding.

Article 141 of Constitution and the doctrine of stare decisis both uphold the authority of judicial precedents but they function at different levels within the legal system. While closely related, they differ in scope and application.

• Similar but Distinct

Article 141 of Indian Constitution is a constitutional mandate that binds all courts to the law declared by the Supreme Court. Stare decisis, on the other hand, is a broader common law principle guiding the adherence to precedents across all judicial tiers.

• Binding Scope

Under Article 141 of Indian Constitution, only the ratio decidendi of Supreme Court judgments is binding. Obiter dicta and decisions made per incuriam do not carry the same authoritative weight.

• Adaptability

Both Article 141 of Indian Constitution and stare decisis promote consistency but permits for legal evolution. The Supreme Court may overrule its own precedents and courts can distinguish cases based on differing facts or evolving legal standards.

Article 141 of Indian Constitution Case Laws

Article 141 of Indian Constitution establishes the binding nature of Supreme Court decisions on all courts within India. The following case laws highlight the application and interpretation of this principle and explains its scope and exceptions:

• Mohd. Ahmed Khan v. Shah Bano Begum (1985):
  The Supreme Court in Mohd Ahmed Khan v. Shah Bano Begum ruled that its interpretation of religious scriptures is to be treated as binding precedent under Article 141 of Indian Constitution.
• State of U.P. v. Synthetics & Chemicals Ltd. (1991):
  It was held that a judgment lacking legal reasoning or analysis of issues does not qualify as a binding law under Article 141 of Constitution.
• Suganthi Suresh Kumar v. Jagadeesan (2002):
  The Court highlighted that High Courts cannot disregard or overrule Supreme Court rulings merely because certain legal points were not discussed in those judgments as per Article 141 of Indian Constitution.
• Pandurang Kalu Patil v. State of Maharashtra (2002):
  The Supreme Court clarified that decisions of High Courts remain authoritative unless specifically overruled by the Supreme Court.
• Paramjit Kaur v. State of Punjab (2021):
  In this case, the Supreme Court broadened the interpretation and scope of its binding authority under Article 141 of Indian Constitution.
• Bilkis Yakub Rasool v. Union of India (2024)
  The case held that Radheshyam Bhagwandas Shah v. State of Gujarat (2022) was per incuriam as it contradicted larger bench rulings.
• Islam v. Gopal Dubey (1994)
  A smaller bench declined to follow a larger bench decision on grounds of per incuriam.
• Haris v. Jahfar (2020)
  The Kerala High Court held that Union of India v. Chitra Lekha Chakroborthy was per incuriam and sub silentio, as it failed to consider Section 22 of the Administrative Tribunals Act, 1985 and key provisions from the Civil Procedure Code and Limitation Act.
• South Central Railway Employees Cooperative Credit Society Employees’ Union v. B. Yashoda Bai, (2015)
  The Supreme Court overturned an Andhra Pradesh High Court ruling for wrongly refusing to follow a Supreme Court decision that was not per incuriam. High Courts cannot sidestep Supreme Court precedents under Article 141 of Indian Constitution on grounds like alternative arguments not being presented.

Article 141 of Indian Constitution Significance

The importance of Article 141 of Indian Constitution under Part V lies in its role in maintaining consistency, authority and coherence within the judicial system of India. It ensures that the decisions of the Supreme Court are followed uniformly by all subordinate courts. It promotes stability and trust in the legal process. The important aspects are:

• Promotes Legal Uniformity: Article 141 of Constitution ensures that the same legal principles are applied across all jurisdictions in India and avoids contradictory judgments.
• Doctrine of Precedent: Article 141 of the Indian Constitution establishes the principle of stare decisis—lower courts are bound by the decisions of higher courts especially the Supreme Court.
• Strengthens Judicial Discipline: Article 141 of Indian Constitution encourages consistency in judicial decision-making and respect for the hierarchy of courts.
• Supreme Court as Final Interpreter: It bolsters the role of the Supreme Court as the ultimate authority on constitutional and legal matters.
• Facilitates Judicial Review: It upholds the power of the Supreme Court to declare laws unconstitutional with such rulings binding on all other courts.

Conclusion

Article 141 of Indian Constitution mandates that Supreme Court decisions are binding on all courts across India. The provision promotes uniformity, consistency and predictability in how laws are interpreted and applied nationwide. It strengthens the doctrine of judicial precedent and plays an important role in ensuring a fair and efficient legal system in India.