🚨SUPREME COURT VS HIGH COURT⚖️

Subhodeep Chattopadhyay
Aug 7
15 min read

Updated: Aug 11

Supreme Court's Shikhar Chemicals Ruling: A Critical Analysis of Judicial Supervision vs High Court Autonomy ⚖️

A deep dive into the constitutional implications of the Supreme Court's administrative directives in M/s. Shikhar Chemicals v. State of Uttar Pradesh, 2025.

Introduction 📖

The balance between judicial supervision and constitutional autonomy represents one of the most delicate aspects of India's federal judicial structure. On August 4, 2025, the Supreme Court's judgment in M/s. Shikhar Chemicals v. The State of Uttar Pradesh & Anr., 2025 has sparked significant constitutional debate by issuing unprecedented administrative directives to the Chief Justice of Allahabad High Court. This landmark case raises fundamental questions about the boundaries of Supreme Court authority and the preservation of High Court autonomy within India's federal framework. Hon'ble Supreme Court has a penchant for considering itself to be more supreme than what it actually is and consider High Courts to be lesser high than what it constitutionally is.

Case Background: The Shikhar Chemicals Dispute 🏭

The Commercial Dispute That Started It All

The case originated from a seemingly straightforward commercial dispute between M/s. Shikhar Chemicals and M/s. Lalita Textile Concern. The facts reveal a typical business disagreement that unfortunately spiraled into criminal proceedings:

Key Facts:

Transaction Period: April-July 2019
Total Yarn Supply Value: ₹52,34,385/-
Amount Paid: ₹47,75,000/- via RTGS
Outstanding Balance: ₹4,59,385/-
Interest Claimed: ₹7,23,711/- at 8% per Yarn Committee regulations

The Legal Journey 🛤️

The complainant (Lalita Textile) initially attempted recovery through conventional means including phone calls, GST notices, and legal notices, which were either returned undelivered or refused. When police declined to register an FIR citing the matter as a civil dispute, the complainant filed a private complaint under Section 406 IPC (Criminal Breach of Trust).

The Additional Chief Judicial Magistrate-I, Kanpur Nagar, after conducting a Section 202 Cr.P.C. inquiry, issued process under Section 406 IPC. This decision was challenged before the Allahabad High Court.

The Controversial High Court Decision ⚠️

Justice Prashant Kumar of the Allahabad High Court upheld the magistrate's order on May 5, 2025, with reasoning that has since been severely criticized:

High Court's Rationale:

Civil remedies would be "too burdensome" for the complainant
The matter warranted criminal proceedings under Section 406 IPC
The commercial dispute could be treated as criminal breach of trust

This decision fundamentally misapplied established legal principles regarding the distinction between civil and criminal liability in commercial transactions.

Supreme Court's Response and Directions 📋

Legal Analysis by the Supreme Court

The Supreme Court, in its August 4, 2025 judgment, categorically rejected the High Court's reasoning. The Court relied on established precedents:

State of Gujarat v. Jaswantlal Nathalal (1968) - Clarifying that sale transactions don't constitute "entrustment" under Section 405 IPC
Delhi Race Club v. State of U.P. (2024) - Reinforcing the distinction between civil and criminal liability

Deep Analysis: Delhi Race Club v. State of U.P. (2024) - The Civil-Criminal Liability Watershed 📊

The Foundational Precedent on Commercial Disputes

The Supreme Court's landmark judgment in Delhi Race Club (1940) Ltd. v. State of Uttar Pradesh [(2024) 10 SCC 690] represents a watershed moment in distinguishing between civil and criminal liability in commercial transactions. This case provides the doctrinal foundation that the Supreme Court relied upon in Shikhar Chemicals to quash the criminal proceedings.

Key Legal Principles from Delhi Race Club

1. The Entrustment Doctrine

The Supreme Court emphasized that "for criminal breach of trust, the property must have been entrusted to the accused or he must have dominion over it." This fundamental principle distinguishes criminal breach of trust from ordinary commercial disputes.

2. Sale vs. Entrustment Distinction

The Court held that "without entrustment of property, there cannot be any criminal breach of trust. Thus, prosecution of cases on charge of criminal breach of trust, for failure to pay the consideration amount in case of sale of goods is flawed to the core."

Comprehensive Legal Framework: Civil vs. Criminal Liability

Legal Element	Civil Liability (Contract/Tort)	Criminal Liability (Section 406 IPC)	Delhi Race Club Analysis
Property Relationship	Sale/Purchase transaction	Entrustment with dominion	"Entrustment is a crucial element that distinguishes criminal breach of trust from cheating"
Mens Rea Requirement	Breach of contract intent	Dishonest intention at entrustment	"This intention, which is the gist of the offence"
Timing of Intent	At time of breach	At time of entrustment	"Criminal breach of trust necessitates evidence of property being entrusted to someone who then misappropriates it"
Property Control	No dominion required	Must have dominion over property	Property must be under accused's control
Remedy Available	Damages/Specific performance	Imprisonment/Fine	"There can be civil remedy for the non-payment"

The Entrustment Test: A Legal Litmus

The Delhi Race Club judgment established a clear entrustment test for determining criminal liability:

Essential Elements for Criminal Breach of Trust:

Property Entrustment: Actual transfer of property with trust
Dominion Establishment: Accused must have control over the property
Dishonest Intent: Specific intention to misappropriate at the time of entrustment
Misappropriation Act: Actual conversion or disposal contrary to terms

Commercial Sale Characteristics:

Quid Pro Quo Transaction: Exchange of goods for consideration
No Trust Element: Simple contractual relationship
Payment Obligation: Civil remedy for non-payment
No Dominion Transfer: Seller retains ownership until payment

Application to Shikhar Chemicals: The Legal Parallel

The factual matrix in Shikhar Chemicals mirrors the commercial dispute pattern identified in Delhi Race Club:

Factual Element	Shikhar Chemicals Facts	Delhi Race Club Principle	Legal Conclusion
Transaction Nature	Yarn supply against payment	Commercial sale transaction	Civil dispute, not criminal
Property Relationship	Sale of yarn for consideration	No entrustment involved	Section 406 IPC inapplicable
Outstanding Amount	₹4,59,385/- unpaid balance	Contract breach, not misappropriation	Civil remedy available
Interest Claim	₹7,23,711/- at 8%	Commercial claim	Contractual dispute

The Supreme Court's Criticism of Judicial Misapplication

The Supreme Court's critique of the Allahabad High Court's reasoning gains constitutional significance when viewed through the Delhi Race Club lens:

High Court's Flawed Logic:

"Civil remedies too burdensome" - Contradicts established legal remedies
Criminal proceedings justified - Ignores entrustment requirement
Commercial dispute criminalized - Violates civil-criminal distinction

Constitutional Implications:

Abuse of Criminal Process: Using criminal law for civil disputes
Judicial Overreach: Expanding criminal liability beyond statutory scope
Legal Certainty Erosion: Undermining predictable legal framework

Broader Impact on Commercial Law

The Delhi Race Club principle, as applied in Shikhar Chemicals, has far-reaching implications:

For Business Transactions:

Contractual Security: Commercial disputes remain civil matters
Criminal Law Boundaries: Clear demarcation prevents misuse
Legal Predictability: Businesses can rely on established frameworks

For Judicial Decision-Making:

Precedential Binding: Courts must follow established distinctions
Legal Reasoning: Proper application of criminal law principles
Constitutional Compliance: Respecting separation between civil and criminal law

The Unprecedented Administrative Directives 🚨

The Supreme Court issued four specific directions that have raised constitutional eyebrows:

Paragraph 23: Requested the Chief Justice to reassign the case to another judge Paragraph 24: Directed immediate withdrawal of the case from the concerned judge Paragraph 25: Instructed placement of the judge in a Division Bench with a senior judge Paragraph 26: Prohibited the judge from handling criminal matters indefinitely

Constitutional Implications: A Federal Crisis? 🏛️

High Courts as Constitutional Entities

Under India's Constitution, High Courts enjoy significant autonomy:

Article 214: Establishes High Courts for states
Article 215: Designates them as courts of record with inherent powers
Article 229: Grants Chief Justice exclusive administrative control

The Doctrine of Judicial Federalism

Key Supreme Court precedents have consistently upheld High Court autonomy:

State of Rajasthan v. Prakash Chand (1998): Affirmed Chief Justice's sole authority over roster management Asok Pande v. Supreme Court of India (2018): Reinforced administrative independence of High Courts

Deep Dive: State of Rajasthan v. Prakash Chand (1998) - The Bedrock of High Court Autonomy 🏛️

Case Background and Constitutional Questions

The landmark case of State of Rajasthan v. Prakash Chand [(1998) 1 SCC 1] represents one of the most significant judgments on judicial independence and High Court autonomy in Indian jurisprudence. The case arose from a complex situation involving judicial interference and raised fundamental questions about the administrative powers of Chief Justices.

Key Constitutional Principles Established

The Supreme Court, in a comprehensive judgment, laid down several foundational principles:

1. Chief Justice as Master of the Roster

The Court held that immunity from any civil or criminal action or a charge of contempt of court is essential for maintaining independence of the judiciary and for the strength of the administration of justice. This principle extends to administrative functions, making the Chief Justice the ultimate authority in roster management.

2. Administrative Autonomy Framework

Constitutional Provision	Prakash Chand Interpretation	Practical Application
Article 229	Chief Justice has exclusive administrative control	Cannot be interfered with by external authorities
Article 215	High Courts are courts of record with inherent powers	Administrative decisions are part of inherent jurisdiction
Article 214	High Courts are constitutional courts	Independence extends to all administrative functions
Judicial Independence	Part of basic structure of Constitution	No external interference in internal administration

3. Separation of Powers Principle

The judgment emphasized that judicial administration, particularly roster management, falls within the exclusive domain of the Chief Justice. Any external interference, even from coordinate constitutional authorities, violates the separation of powers doctrine.

Prakash Chand vs. Shikhar Chemicals: A Comparative Analysis

Aspect	Prakash Chand Principle	Shikhar Chemicals Application	Constitutional Conflict
Roster Authority	Exclusive with Chief Justice	Supreme Court issued roster directions	Direct violation of established principle
Case Assignment	Chief Justice's sole discretion	Supreme Court mandated reassignment	Undermined administrative autonomy
Judicial Independence	Protected from external interference	Administrative directives imposed externally	Compromised independence doctrine
Constitutional Hierarchy	Coordinate relationship maintained	Subordinate relationship implied	Federal balance disturbed

The Prakash Chand Precedent: Binding Authority

The Prakash Chand judgment established binding precedents on:

Administrative Immunity: Chief Justices enjoy immunity in administrative decisions
Roster Exclusivity: No external authority can interfere in case assignments
Judicial Independence: Administrative autonomy is integral to judicial independence
Constitutional Separation: Clear demarcation between administrative and judicial review functions

Constitutional Violation Analysis

The Shikhar Chemicals directives violate Prakash Chand principles in multiple ways:

Direct Contraventions:

Roster Interference: Directing case reassignment violates Chief Justice's exclusive authority
Administrative Control: Imposing specific administrative arrangements undermines autonomy
Jurisdictional Overreach: Exceeding supervisory powers established in Prakash Chand

Systemic Implications:

Precedential Erosion: Ignoring binding constitutional precedent
Federal Disruption: Disturbing the coordinate relationship between courts
Independence Compromise: Threatening the basic structure principle of judicial independence

Article 141: The Binding Law Principle 📚

While Article 141 makes Supreme Court's "law declared" binding, administrative directives fall outside this scope. As established in Indian Express Newspapers v. Union of India (1985), only the ratio decidendi constitutes binding precedent.

The Per Incuriam Doctrine: A Critical Analysis ❌

Understanding Per Incuriam

The doctrine of "per incuriam," literally meaning "through lack of care," refers to a judgment rendered without reference to a statutory provision or earlier binding judgment that would have been relevant to the decision. In India, this doctrine is enforced when a judgment has overlooked a statutory provision or legal precedent central to the legal issue in question.

Key Elements of Per Incuriam

The doctrine applies when courts:

Ignore binding statutory provisions without proper consideration
Overlook relevant precedential authority from superior courts
Fail to apply established legal principles in their reasoning
Act in ignorance of their own previous decisions or those of coordinate benches

Application to Shikhar Chemicals Case

The Supreme Court's administrative directives in Shikhar Chemicals may constitute a per incuriam decision based on several critical factors:

Per Incuriam Element	Application to Shikhar Chemicals	Constitutional Impact
Ignored Statutory Provision	Article 229 - Chief Justice's administrative control	Violated constitutional separation of powers
Overlooked Binding Precedent	State of Rajasthan v. Prakash Chand (1998)	Contradicted established roster autonomy principle
Lack of Jurisdictional Basis	No constitutional authority for administrative directives	Exceeded supervisory jurisdiction under Articles 136, 142
Absence of Proper Reasoning	No constitutional analysis provided for administrative interference	Failed to justify departure from federal principles

Legal Implications of Per Incuriam Classification

A judgment classified as per incuriam lacks binding force and cannot be considered valid precedent, thus serving as an exception to the doctrine of stare decisis. If the Shikhar Chemicals directives are indeed per incuriam:

No Binding Authority: The administrative directives would lack precedential value
Constitutional Restoration: High Court autonomy principles would remain intact
Federal Balance: The coordinate relationship between Supreme Court and High Courts would be preserved
Future Protection: Similar administrative overreach would be prevented

Analyzing the Constitutional Crisis 🔍

The Per Incuriam Challenge to Constitutional Order

The classification of the Shikhar Chemicals directives as per incuriam has profound constitutional implications. Per incuriam refers to a judgment rendered "through lack of care," specifically when courts ignore relevant statutory provisions or binding precedents. A decision made per incuriam is mistaken, ignores binding authority or statute, and thus has no binding force.

Constitutional Deficiencies in Shikhar Chemicals

The Supreme Court's administrative directives exhibit classic per incuriam characteristics:

1. Statutory Ignorance

The Court failed to engage with Article 229, which grants Chief Justices exclusive administrative control. This constitutional provision was neither analyzed nor distinguished in the judgment.

2. Precedential Oversight

The established principles from Prakash Chand regarding roster autonomy were completely ignored, despite being directly relevant and binding.

3. Jurisdictional Confusion

The Court provided no constitutional basis for extending its supervisory jurisdiction under Articles 136 and 142 to administrative matters, conflating legal review with administrative control.

The Constitutional Framework: High Court Independence 🏛️

The constitutional scheme provides robust protections for High Court independence that the Shikhar Chemicals directives blatantly violate:

Article 235: Administrative Control

This article vests administrative control over district courts in High Courts, not the Supreme Court. The constitutional design deliberately separates administrative functions from appellate review.

Supreme Court's Own Precedents on Independence

The Supreme Court has previously emphasized that "Independence of judiciary is not only independence from the Executive pressure but also from pressure of superior courts… A High Court judge is not a subordinate of the Supreme Court."

In Tirupati Balaji Developers Pvt Ltd v. State of Bihar (2004), the Court held: "Under the constitutional scheme as framed for the judiciary, the Supreme Court and the High Court both are courts of record. The High Court is not a court 'subordinate' to the Supreme Court."

Master of the Roster Principle

Multiple Supreme Court precedents have consistently held:

State of Rajasthan v. Prakash Chand (1998): Chief Justice has exclusive prerogative over bench constitution and case allocation
Shanti Bhushan v. Supreme Court of India (2018): Reaffirmed Chief Justice's administrative autonomy
State of Karnataka v. B Krishna Bhat (2001): Similar principle applied by Karnataka High Court

Institutional Disrespect and Judicial Restraint Concerns 😠

The Shikhar Chemicals order exhibits concerning language that borders on institutional disrespect:

Problematic Judicial Language:

Calling the order "one of the worst"
Questioning whether decisions were made due to "extraneous considerations or sheer ignorance"
Describing judicial reasoning as "a mockery of justice"

Such language undermines judicial dignity and creates a culture of fear rather than learning within the judiciary. The Supreme Court, as the apex court, should exemplify judicial restraint rather than engage in public castigation.

Judicial Independence vs. Accountability

The case presents a classic tension between two fundamental principles:

Judicial Independence: Protected under the basic structure doctrine (S.P. Gupta v. Union of India, 1981) Judicial Accountability: Necessary for maintaining public confidence in the judiciary

Federal Balance at Risk ⚖️

The Supreme Court's administrative interference threatens the federal judicial structure by:

Centralizing judicial control
Undermining Chief Justice's roster powers
Creating precedent for future interventions
Eroding coordinate relationship between Supreme Court and High Courts

The Stare Decisis Exception

The principle of Per Incuriam is an established exception to the doctrine of Stare Decisis, where judgments are the result of omission of particular statute or law and hence cannot be considered valid. This provides a constitutional mechanism to restore proper judicial federalism by:

Nullifying Administrative Overreach: Rendering the directives non-binding
Preserving Constitutional Order: Maintaining separation of powers
Protecting Future Autonomy: Preventing similar interventions
Restoring Federal Balance: Ensuring coordinate court relationships

Alternative Approaches to Judicial Reform 💡

Instead of direct administrative intervention and public humiliation, several constructive alternatives exist that respect constitutional boundaries:

1. Constitutional Mechanisms for Judicial Accountability 📋

Existing Constitutional Framework:

Chief Justice of High Court: Primary administrative authority for internal corrections
Chief Justice of India: Administrative oversight and guidance
Collegium System: Institutional mechanism for addressing persistent judicial issues
Friendly Intervention: Informal guidance from Supreme Court ("friendly call from Tilak Marg")

Graduated Response System:

Issue Severity	Appropriate Response	Constitutional Authority	Dignity Preservation
Single Error	Appellate correction only	Supreme Court (judicial)	Full judicial dignity maintained
Pattern of Errors	Chief Justice consultation	High Court CJ + Supreme Court CJ	Internal administrative handling
Serious Concerns	Collegium referral	Collegium system	Institutional process respect
Misconduct	Formal disciplinary action	Constitutional authorities	Due process protection

2. Enhanced Training Programs 📚

Specialized workshops on criminal law application
Regular judicial education seminars focusing on civil-criminal distinctions
Peer learning initiatives between High Courts
Delhi Race Club principle workshops for commercial law clarity

3. Institutional Reforms 🏢

Strengthened appellate review mechanisms with constructive feedback
Systematic case law databases accessible to all judges
Judicial performance evaluation systems based on legal reasoning quality
Constitutional training on judicial independence and federalism

4. Collaborative Solutions 🤝

Inter-court consultation mechanisms for complex legal issues
Regular judicial conferences addressing common legal challenges
Best practices sharing platforms between Supreme Court and High Courts
Mentorship programs pairing senior and junior judges across court hierarchies

5. Dignified Correction Mechanisms ⚖️

Constructive Appellate Review:

Instead of public humiliation, the Supreme Court can:

Correct legal errors without personal attacks
Provide legal guidance for future similar cases
Reference binding precedents for clarification
Maintain institutional respect while ensuring legal accuracy

Private Judicial Guidance:

Direct communication with Chief Justice of concerned High Court
Institutional consultation on recurring legal issues
Confidential feedback mechanisms for judicial improvement
Preservation of judicial dignity while ensuring accountability

International Perspectives 🌍

Federal judicial systems worldwide maintain similar balances:

United States: Circuit courts maintain independence from Supreme Court administration

Canada: Provincial superior courts retain administrative autonomy

The Way Forward: Recommendations 🛣️

For the Supreme Court

Exercise restraint in administrative matters
Focus on legal precedent-setting rather than case management
Respect constitutional boundaries of High Court autonomy

For High Courts

Implement robust internal review mechanisms
Enhance judicial training programs
Strengthen case law research capabilities

For the Judicial System Overall

Develop clear guidelines for inter-court relationships
Establish formal protocols for addressing judicial errors
Create institutional safeguards for federal balance

Impact on Legal Practice 👨‍💼

For Criminal Law Practice

The Delhi Race Club principle, reinforced in Shikhar Chemicals, creates clear guidelines for criminal law practitioners:

Criminal Proceedings Checklist:

Entrustment Verification: Is there actual transfer of property with trust?
Dominion Assessment: Does accused have control over the property?
Intent Timing: Was dishonest intention present at entrustment?
Commercial Distinction: Is this a sale transaction or entrustment?

For Commercial Law Practice

The judgment provides crucial protection for business transactions:

Commercial Dispute Framework:

Contractual Security: Payment disputes remain civil matters
Criminal Protection: Clear boundaries against misuse of criminal law
Remedy Predictability: Established civil law remedies remain primary

For Lawyers

Increased scrutiny of High Court criminal law applications
Greater emphasis on civil vs. criminal distinction arguments
Enhanced importance of constitutional law expertise
Delhi Race Club Citation: Mandatory reference in commercial criminal cases

For Litigants

Potential delays in case reassignments due to administrative directives
Uncertainty in judicial decision-making following constitutional overreach
Possible forum shopping implications
Commercial Protection: Clear distinction prevents criminal harassment

Long-term Constitutional Consequences 📊

The Shikhar Chemicals case may have lasting implications:

Positive Outcomes

Clarified boundaries between civil and criminal law
Highlighted importance of proper legal reasoning
Demonstrated Supreme Court's commitment to legal accuracy

Concerning Precedents

Administrative overreach into High Court functions
Potential erosion of judicial federalism
Risk of increased centralization

Conclusion: Preserving Constitutional Balance ⚖️

The Supreme Court's intervention in the Shikhar Chemicals case presents a constitutional paradox: while the legal correction was necessary and justified, the administrative overreach and public humiliation of a sitting High Court judge violates fundamental principles of judicial independence and federalism.

The Dual Nature of the Constitutional Crisis

Justified Legal Intervention ✅

Supreme Court correctly identified the Allahabad High Court's misapplication of criminal law
Delhi Race Club principles were properly applied to distinguish civil and criminal liability
The legal reasoning protecting commercial transactions from criminal harassment was sound
Constitutional mandate to ensure legal accuracy was fulfilled

Unjustified Administrative Overreach ❌

Direct interference in Chief Justice's roster management violated Article 229
Public humiliation contradicted the Court's own precedent in C.S. Karnan
Administrative directives exceeded constitutional boundaries under Articles 136, 142
Per incuriam classification applicable due to ignorance of binding precedents

The Dangerous Precedent: Weaponizing Appellate Jurisdiction ⚠️

The most concerning aspect of Shikhar Chemicals is the creation of a precedent where "every High Court order can be questioned before the Supreme Court and every bad order has a risk of public humiliation." This represents a fundamental shift from:

Legal correction → Administrative control
Institutional respect → Public castigation
Constitutional federalism → Judicial centralization
Dignified disagreement → Humiliating subordination

Constitutional Remedies and Future Safeguards 🛡️

Immediate Constitutional Response:

Per Incuriam Classification: Legal community should treat administrative directives as non-binding
Chief Justice Autonomy: High Court Chief Justices should assert constitutional prerogatives
Bar Council Intervention: Professional bodies should defend judicial dignity
Academic Critique: Legal scholars should highlight constitutional violations

Long-term Institutional Reforms:

Clear Jurisdictional Boundaries: Define limits of Supreme Court administrative intervention
Dignified Correction Protocols: Establish respectful mechanisms for addressing judicial errors
Constitutional Training: Enhance understanding of federal judicial relationships
Institutional Dialogue: Foster communication between Supreme Court and High Courts

The Path Forward: Maturity in Judicial Relationships 🤝

The legal community consensus recognizes that "the Shikhar Chemicals judgment can be justified on legal grounds, but lacks maturity when it comes to mutual respect of the Supreme Court and the High Courts." The path forward requires:

Supreme Court Leadership:

Exercise judicial restraint in administrative matters
Distinguish between judicial error and judicial misconduct
Preserve institutional dignity while ensuring legal accuracy
Respect constitutional boundaries of High Court autonomy

High Court Resilience:

Maintain constitutional independence despite external pressure
Strengthen internal mechanisms for legal accuracy
Assert administrative autonomy where constitutionally protected
Foster culture of continuous legal learning

Professional Community Responsibility:

Defend constitutional principles of judicial independence
Critique institutional overreach regardless of court hierarchy
Promote dignified discourse in legal proceedings
Preserve federal balance through professional advocacy

Key Takeaways:

✅ Supreme Court correctly identified legal error regarding civil-criminal distinction

✅ Delhi Race Club and Prakash Chand principles provide clear constitutional framework

❌ Administrative directives exceeded constitutional boundaries and violated judicial federalism

❌ Public humiliation created dangerous precedent for future judicial relationships

⚖️ Constitutional balance requires both legal accuracy and institutional respect 🛡️ Per incuriam doctrine provides mechanism to preserve federal judicial structure

The future of India's federal judicial system depends not merely on legal accuracy but on the wisdom to exercise power within constitutional boundaries while preserving the dignity and independence that form the bedrock of judicial authority. The Shikhar Chemicals case serves as both a necessary legal correction and a cautionary tale about the limits of institutional power in a constitutional democracy.

This analysis is based on publicly available court documents, constitutional provisions, and established legal precedents. The constitutional concerns raised reflect the fundamental principles of judicial independence and federal balance essential to India's democratic framework.

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