Article 141 of Indian Constitution, Interpretation, Significance

Article 141 of Indian Constitution provides that the law declared by the Supreme Court shall be binding on all courts within the territory of India. This provision ensures uniformity in legal interpretation and affirms the authority of the Supreme Court as the apex judicial body. It promotes consistency in the application of laws across the country and is closely linked to the Court’s power of judicial review, reinforcing its position as the final interpreter of the Constitution.

Article 141 of Indian Constitution

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

Article 141 of Indian Constitution Interpretation

Article 141 of Indian Constitution establishes the principle of judicial precedent within the Indian legal framework. It provides that “the law declared by the Supreme Court shall be binding on all courts within the territory of India,thereby ensuring consistency and uniformity in the interpretation and application of laws across the nation.

Binding Authority of Supreme Court Judgments

The primary purpose of Article 141 of Indian Constitution is to affirm the Supreme Court’s position as the apex judicial authority in India. By mandating that its pronouncements are binding on all subordinate courts, it reinforces the doctrine of precedent and the hierarchical structure of the judiciary. Consequently, lower courts are bound to follow the legal interpretations and principles laid down by the Supreme Court, ensuring coherence in judicial decision-making throughout the country.

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Doctrine of Stare Decisis

The Doctrine of Stare Decisis in India finds its constitutional foundation in Article 141 of the Indian Constitution. The Latin expression stare decisis translates to “to stand by decisions and not to disturb what is settled.” This principle underscores the importance of legal precedents in ensuring stability and predictability in the law. It guides courts to follow established rulings when deciding cases involving similar facts and legal issues, thereby promoting consistency and judicial discipline.

Article 141 of Indian Constitution Scope

Article 141 of Indian Constitution mandates that all courts in the country follow the rulings of the Supreme Court. However, only the ratio decidendi, the core legal reasoning forming the basis of the decision, is binding. Certain well-recognised exceptions limit the binding nature of Supreme Court rulings:

1. Obiter dicta: An obiter dictum (Latin for “something said in passing”) refers to remarks, observations, or opinions expressed by a judge that are not essential to the decision of the case. While such statements are not legally binding, they may hold persuasive value in future cases.

2. Per incuriam: Per incuriam (Latin for “through lack of care”) describes a judgment delivered without due consideration of relevant statutory provisions or binding precedents. Such decisions lack authoritative weight and are not treated as binding law.

3. Sub silentio: Sub silentio (Latin for “under silence”) applies when a legal principle is assumed or applied without the court consciously addressing it. In such cases, the precedent is considered to have been established without deliberate judicial consideration and is not binding.

4. Legislative override: Parliament, as the supreme legislative authority, may override a judicial precedent by enacting new legislation. This can be done explicitly or implicitly, effectively altering or nullifying the legal impact of a Supreme Court decision.

Article 141 of Indian Constitution Significance

By embedding the doctrine of precedent commonly known by its Latin term stare decisis into constitutional law through Article 141 of the Indian Constitution, the legal system promotes stability, uniformity, and predictability. This principle strengthens judicial accountability and safeguards against arbitrary decision-making. It also streamlines legal proceedings by offering consistent interpretative guidelines to subordinate courts, thereby reducing duplication in judicial reasoning for cases involving similar legal issues.

Article 141 of Indian Constitution Challenges

Article 141 of Indian Constitution incorporates a degree of adaptability within the doctrine of precedent. The Supreme Court retains the authority to overrule its earlier decisions, and lower courts may distinguish cases on the basis of factual differences.

While Article 141 and the Doctrine of Stare Decisis both reinforce the authority of judicial precedents, they operate at different levels. Article 141 is a constitutional directive mandating that all courts follow the law declared by the Supreme Court. Stare decisis, by contrast, is a broader common law principle that guides courts at all levels to adhere to established precedents.

1. Binding Scope

Under Article 141, only the ratio decidendi, the core legal reasoning of a Supreme Court judgment, is binding. Obiter dicta and judgments delivered per incuriam do not carry the same authoritative force.

2.  Adaptability

Both Article 141 and stare decisis promote consistency in the legal system while allowing for legal development. The Supreme Court can overturn its own precedents, and courts may distinguish cases where facts or legal standards differ from earlier rulings.

Article 141 of Indian Constitution Cases

Article 141 of Indian Constitution establishes that the law declared by the Supreme Court is binding on all courts within India. Judicial pronouncements have further clarified its scope, operation, and exceptions. Key decisions include:

1. Mohd. Ahmed Khan v. Shah Bano Begum (1985): The Supreme Court held that its interpretation of religious scriptures is to be treated as binding precedent under Article 141.

2. State of U.P. v. Synthetics & Chemicals Ltd. (1991): The Court ruled that a judgment lacking legal reasoning or substantive analysis of issues does not constitute binding law under Article 141.

3. Suganthi Suresh Kumar v. Jagadeesan (2002): It was reaffirmed that High Courts cannot disregard or overrule Supreme Court decisions on the ground that certain legal points were not discussed.

4. Pandurang Kalu Patil v. State of Maharashtra (2002): The Court clarified that High Court rulings remain binding within their jurisdiction unless expressly overruled by the Supreme Court.

5. Paramjit Kaur v. State of Punjab (2021): The Supreme Court expanded the interpretation of its binding authority under Article 141. 

6. Bilkis Yakub Rasool v. Union of India (2024): The Court held that Radheshyam Bhagwandas Shah v. State of Gujarat (2022) was per incuriam as it contradicted larger bench decisions.

7. Islam v. Gopal Dubey (1994): A smaller bench declined to follow a larger bench decision on grounds of per incuriam.

8. Haris v. Jahfar (2020): The Kerala High Court held that Union of India v. Chitra Lekha Chakroborthy was per incuriam and sub silentio for failing to consider Section 22 of the Administrative Tribunals Act, 1985 and relevant provisions of the CPC and Limitation Act.

South Central Railway Employees Cooperative Credit Society Employee’s Union v. B. Yashoda Bai (2015): The Supreme Court set aside an Andhra Pradesh High Court ruling that had refused to follow a Supreme Court precedent on the ground that certain arguments were not presented. The Court reiterated that High Courts cannot sidestep binding precedents unless they fall within recognized exceptions such as per incuriam.