(SCC p. 177, para 2):
Of course, if a government or a public
authority takes up a technical plea, the
Court has to decide it and if the plea is well
founded, it has to be upheld by the court,
but what we feel is that such a plea should
not ordinarily be taken up by a government
or a public authority, unless of course the
claim is not wellfounded and by reason of
delay in filing it, the evidence for the
purpose of resisting such a claim has
become unavailable...."
9. In a three Judge Bench judgment of Bhag Singh &
Ors. v. Union Territory of Chandigarh through LAC,
Chandigarh [(1985) 3 SCC 737]: the Hon'ble Supreme
Court held: (SCC p. 741, para 3)
"3... The State Government must do what
is fair and just to the citizen and should
not, as far as possible, except in cases
where tax or revenue is received or
recovered without protest or where the
State Government would otherwise be
irretrievably be prejudiced, take up a
technical plea to defeat the legitimate and
just claim of the citizen."
10. Unwarranted litigation by governments and
statutory authorities basically stem from the two
general baseless assumptions by their officers. They
are:
(i) All claims against the government/
statutory authorities should be viewed as
illegal and should be resisted and fought up
to the highest court of the land.
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(ii) If taking a decision on an issue could be
avoided, then it is prudent not to decide the
issue and let the aggrieved party approach
the Court and secures a decision.
The reluctance to take decisions, or tendency to
challenge all orders against them, is not the policy of
the governments or statutory authorities, but is
attributable to some officers who are responsible for
taking decisions and/or officers in charge of litigation.
Their reluctance arises from an instinctive tendency to
protect themselves against any future accusations of
wrong decision making, or worse, of improper motives
for any decision making. Unless their insecurity and
fear is addressed, officers will continue to pass on the
responsibility of decision making to courts and
Tribunals."
10. In Mahanadi Coalfields Ltd. and Another vs. Mathias Oram and
Others, (2010) 11 SCC 269, the Hon'ble Supreme Court has observed
as under:-
"10. The counter argument goes like this. It is very
often the process of development that most starkly
confirms the fears ex pressed by Dr. Ambedkar about
our democracy. A blinkered vision of development,
complete apathy towards those who are highly
adversely affected by the development process and a
cynical unconcern for the enforcement of the laws lead
to a situation where the rights and benefits promised
and guaranteed under the constitution hardly ever
reach the most marginalized citizens.
11. This is not to say that the relevant laws are perfect
and very sympathetic towards the dispossessed. There
are various studies that detail the impact of
dispossession from their lands on tribal people. It is
pointed out that even when laws relating to land
acquisition and resettlement are implemented perfectly
and comprehensively (and that happens rarely!),
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uncomfortable questions remain. For a people whose
lives and livelihoods are intrinsically connected to the
land, the economic and cultural shift to a market
economy can be traumatic."
11. In Gurgaon Gramin Bank vs. Khazani and Another, (2012) 8 SCC
781, the Hon'ble Supreme Court considered the approach of the
Government to litigate and observed as under:-
"2. Number of litigations in our country is on the rise,
for small and trivial matters, people and sometimes
Central and State Governments and their
instrumentalities Banks, nationalized or private, come
to courts may be due to ego clash or to save the
Officers' skin. Judicial system is over- burdened,
naturally causes delay in adjudication of disputes.
Mediation centres opened in various parts of our
country have, to some extent, eased the burden of the
courts but we are still in the tunnel and the light is far
away. On more than one occasion, this court has
reminded the Central Government, State Governments
and other instrumentalities as well as to the various
banking institutions to take earnest efforts to resolve
the disputes at their end. At times, some give and take
attitude should be adopted or both will sink. Unless,
serious questions of law of general importance arise
for consideration or a question which affects large
number of persons or the stakes are very high, courts
jurisdiction cannot be invoked for resolution of small
and trivial matters. We are really disturbed by the
manner in which those types of matters are being
brought to courts even at the level of Supreme Court
of India and this case falls in that category."
12. In Punjab State Power Corporation Ltd., Patiala and Others vs.
Atma Singh Grewal, (2014) 13 SCC 666, the Hon'ble Supreme Court
has noted the facts that the Courts are burdened with unnecessary
litigation primarily for the reason that the Government or Public Sector
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Undertakings etc. decide to litigate even when there is no merit in the
claim. It would be apposite to refer to the relevant observations, which
read thus:-
"8. It is not the first time that the Court had to express
its anguish. We would like to observe that the mindset
of the Government agencies/undertakings in filing
unnecessarily appeals was taken note of by the Law
Commission of India way back in 1973, in its 54th
report. Taking cognizance of the aforesaid report of
the Law Commission as well as National Litigation
Policy for the States which was evolved at an All India
Law Ministers Conference in the year 1972, this Court
had to emphasize that there should not be
unnecessary litigation or appeals. It was so done in
the case of Mundrika Prasad Singh v. State of Bihar,
1979 4 SCC 701. We would also like to reproduce the
following words of wisdom expressed by Justice V.R.
Krishna Iyer, who spoke for the Bench, in Dilbagh Rai
Jarry v. Union of India and Ors., 1974 3 SCC 554.
25........5...... But it must be remembered
that the State is no ordinary party trying to
win a case against one of its own citizens
by hook or by crook; for the State's interest
is to meet honest claims, vindicate a
substantial defence and never to score a
technical point or overreach a weaker party
to avoid a just liability or secure an unfair
advantage, simply because legal devices
provide such an opportunity. The State is a
virtuous litigant and looks with unconcern
on immoral forensic successes so that if on
the merits the case is weak, government
shows a willingness to settle the dispute
regardless of prestige and other lesser
motivations which move private parties to
fight in court. The lay out on litigation costs
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and executive time by the State and its
agencies is so staggering these days
because of the large amount of litigation in
which it is involved that a positive and
wholesome policy of cutting back on the
volume of law suits by the twin methods of
not being tempted into forensic show
downs where a reasonable adjustment is
feasible and ever offering to extinguish a
pending proceeding on just terms, giving
the legal mentors of government some
initiative and authority in this behalf.
9. In its 126th Report (1988), the Law Commission of
India adversely commented upon the reckless manner
in which appeals are filed routinely. We quote
hereunder the relevant passage therefrom:
2.5. The litigation is thus sometimes
engendered by failing to perform duty as if
discharging a trust. Power inheres a kind of
trust. The State enjoys the power to deal
with public property. That power has to be
discharged like a trust keeping in view the
interests of the cesti que trust. Failure on
this front has been more often commented
upon by the court which, if it was taken in
the spirit in which it was made, would have
long back energised the Government and
the public sector to draw up its litigation
policy. When entirely frivolous litigation
reaches the doorsteps of the Supreme
Court, one feels exasperated by the
inaction and the policy to do nothingness
evidenced by blindly following litigation
from court to court. Dismissing a Special
Leave Petition by the State of Punjab, the
Court observed that the deserved defeat of
the State in the courts below demonstrates
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the gross indifference of the administration
towards litigative diligence. The court then
suggested effective remedial measures. It
may be extracted:
4. We would like to emphasize that
Government must be made accountable by
parliamentary Social audit for wasteful
litigative expenditure inflicted on the
community by inaction. A statutory notice
of the proposed action under Section 80
Code of Civil Procedure is intended to alert
the state to negotiate a just settlement or
at least have the courtesy to tell the
potential outsider why the claim is being
resisted. Now Section 80 has become a
ritual because the administration is often
unresponsive and hardly lives up to the
parliament's expectation in continuing
Section 80 in the Code despite the Central
Law Commission's recommendations for its
deletion. An opportunity for setting the
dispute through arbitration was thrown
away by sheer inaction. A litigative policy
for the State involves settlement of
governmental disputes with citizens in a
sense of conciliation rather than in a
fighting mood. Indeed, it should be a
directive on the part of the State to
empower its law officer to take steps to
compose disputes rather than continue
them in court. We are constrained to make
these observations because much of the
litigation in which governments are involved
adds to the case load accumulation in
courts for which there is public criticism.
We hope that a more responsive spirit will
be brought to bear upon governmental
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litigation so as to avoid waste of public
money and promote expeditious work in
courts of cases which deserve to be
attended to.
Nearly a decade has passed since the observations but
not a leaf has turned, not a step has been taken, and
the Law Commission is asked to deal with the
problem.
2.6. A little care, a touch of humanism, a
dossier of constitutional philosophy and
awareness of futility of public litigation
would considerably improve the situation
which today is distressing. More often it is
found that utterly unsustainable
contentions are taken on behalf of
Government and public sector
undertakings.
10. Even when Courts have, time and again, lamented
about the frivolous appeals filed by the Government
authorities, it has no effect on the bureaucratic
psyche. It is not that there is no realisation at the level
of policy makers to curtail unwanted Government
litigation and there are deliberations in this behalf from
time to time. Few years ago only, the Central
Government formulated National Litigation Policy,
2010 with the "vision/mission" to transform the
Government into an efficient and responsible litigant.
This policy formulated by the Central Government is
based on the recognition that it was its primary
responsibility to protect the rights of citizens, and to
respect their fundamental rights and in the process it
should become "responsible litigant". The policy even
defines the expression 'responsible litigant' as under:
Responsible litigant" means-
(i) That litigation will not be resorted to
for the sake of litigating.
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(ii) That false pleas and technical points
will not be taken and shall be
discouraged.
(iii) Ensuring that the correct facts and
all relevant documents will be placed
before the Court.
(iv) That nothing will be suppressed
from the Court and there will not
attempt to mislead any court or
tribunal.
2. That Government must cease to be a compulsive
litigant. The philosophy that matters should be left to
the courts for ultimate decision has to be discarded.
The easy approach, "Let the Court decide", must be
eschewed and condemned.
3. The purpose underlying this policy is also to reduce
government litigation in courts so that valuable court
time would be spent in resolving other pending cases
so as to achieve the goal in the national legal mission
to reduce average pendency time from 15 years to 3
years. Litigators on behalf of the Government have to
keep in mind the principles incorporated in the
national mission for judicial reforms which includes
identifying bottlenecks which the Government and its
agencies may be concerned with and also removing
unnecessary government cases. Prioritisation in
litigation has to be achieved with particular emphasis
on welfare legislation, social reform, weaker sections
and senior citizens and other categories requiring
assistance must be given utmost priority.
11. This policy recognises the fact that its success will
depend upon its strict implementation. Pertinently
there is even a provision of accountability on the part
of the officers who have to take requisite steps in this
behalf. The policy also contains the provision for filing
of appeals indicating as to under what circumstances
appeal should be filed. In so far as service matters are
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concerned, this provision lays down that further
proceedings will not be filed in service matters merely
because the order of the Administrative Tribunal
affects a number of employees. Also, appeals will not
be filed to espouse the cause of one section of
employees against another.
12. The aforesaid litigation policy was seen as a silver
living to club unnecessary and uncalled for litigation by
this Court in the matter of Urban Improvement Trust,
Bikaner v. Mohan Lal, 2010 1 SCC 512in the following
manner:
"11. The Central Government is now
attempting to deal with this issue by
formulating realistic and practical norms for
defending cases filed against the
Government and for filing appeals and
revisions against adverse decisions, thereby
eliminating unnecessary litigation. But it is
not sufficient if the Central Government
alone undertakes such an exercise. The
State Governments and the statutory
authorities, who have more litigations than
the Central Government, should also make
genuine efforts to eliminate unnecessary
litigations. Vexatious and unnecessary
litigations have been clogging the wheels of
justice for too long, making it difficult for
courts and tribunals to provide easy and
speedy access to justice to bona fide and
needy litigants."
13. Alas, in spite of the Government's own policy and
reprimand from this Court, on numerous occasions,
there is no significant positive effect on various
Government officials who continue to take decision to
file frivolous and vexatious appeals. It imposes
unnecessary burden on the Courts. The opposite party
which has succeeded in the Court below is also made
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to incur avoidable expenditure. Further, it causes delay
in allowing the successful litigant to reap the fruits of
the judgment rendered by the Court below
14. No doubt, when a case is decided in favour of a
party, the Court can award cost as well in his favour.
It is stressed by this Court that such cost should be in
real and compensatory terms and not merely symbolic.
There can be exemplary costs as well when the appeal
is completely devoid of any merit. [See Rameshwari
Devi and Ors. v. Nirmala Devi and Ors., 2011 8 SCC
249]. However, the moot question is as to whether
imposition of costs alone will prove deterrent? We
don't think so. We are of the firm opinion that
imposition of cost on the State/PSU's alone is not
going to make much difference as the officers taking
such irresponsible decisions to file appeals are not
personally affected because of the reason that cost, if
imposed, comes from the government's coffers. Time
has, therefore, come to take next step viz. recovery of
cost from such officers who take such frivolous
decisions of filing appeals, even after knowing well
that these are totally vexatious and uncalled for
appeals. We clarify that such an order of recovery of
cost from the concerned officer be passed only in
those cases where appeal is found to be ex-facie
frivolous and the decision to file the appeal is also
found to be palpably irrational and uncalled for.
13. In Subrata Roy Sahara vs. Union of India and Others, (2014) 8
SCC 470, it has been observed by the Hon'ble Supreme Court that the
State and its agencies litigate endlessly just because lack of responsibility
to take decision. It was observed as under:-
"This abuse of the judicial process is not limited to any
particular class of litigants. The State and its agencies
litigate endlessly up to the highest Court just because
of the lack of responsibility to take decisions. So much
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so that we have started to entertain the impression
that all administrative and executive decision-making
are being left to courts just for that reason. In private
litigation as well, the litigant concerned would continue
to approach the higher Court, despite the fact that he
had lost in every court hithertobefore. The effort is not
to discourage a litigant in whose perception his cause
is fair and legitimate. The effort is only to introduce
consequences if the litigant's perception was incorrect
and if his cause is found to be not fair and legitimate,
he must pay for the same. In the present setting of
the adjudicatory process, a litigant no matter how
irresponsible he is, suffers no consequences. Every
litigant, therefore, likes to take a chance even when
counsel's advice is otherwise."
14. Similar reiteration of law can be found in a judgment of the Hon'ble
Supreme Court in Rajendra Shankar Shukla and Others vs. State of
Chhattisgarh and Others, (2015) 10 SCC 400, wherein again while
referring to the earlier decision in Hymanshu's case (supra), the Hon'ble
Supreme Court has held in para 32 as under:
"32. Further, this Court has frowned upon the practice
of the Government to raise technical pleas to defeat
the rights of the citizens in Madras Port Trust vs.
Hymanshu International (1979) 4 SCC 176, wherein it
was opined that it is about time that governments and
public authorities adopt the practice of not relying
upon technical pleas for the purpose of defeating
legitimate claims of citizens and do what is fair and
just to the citizens. Para 2 from the said case reads
thus :- (SCC p.177)
"2. We do not think that this is a fit case
where we should proceed to determine
whether the claim of the respondent was
barred by Section 110 of the Madras Port
Trust Act (2 of 1905). The plea of limitation
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based on this section is one which the court
always looks upon with disfavour and it is
unfortunate that a public authority like the
Port Trust should, in all morality and justice,
take up such a plea to defeat a just claim of
the citizen. It is high time that governments
and public authorities adopt the practice of
not relying upon technical pleas for the
purpose of defeating legitimate claims of
citizens and do what is fair and just to the
citizens. Of course, if a government or a
public authority takes up a technical plea, the
Court has to decide it and if the plea is well-
founded, it has to be upheld by the court, but
what we feel is that such a plea should not
ordinarily be taken up by a government or a
public authority, unless of course the claim is
not wellfounded and by reason of delay in
filing it, the evidence for the purpose of
resisting such a claim has become
unavailable. Here, it js obvious that the claim
of the respondent was a just claim supported
as it was by the recommendation of the
Assistant Collector of Customs and hence in
the exercise of our discretion under Article
136 of the Constitution, we do not see any
reason why we should proceed to hear this
appeal and adjudicate upon the plea of the
appellant based on Section 110 of the Madras
Port Trust Act (2 of 1905)."
15. In Bhusawal Municipal Council vs. Nivrutti Ramchandra Phalak
and Others, (2015) 14 SCC 327, the Hon'ble Supreme Court considered
the plight of farmers effected by land acquisition and creation of
compulsive situation to avoid luxurious litigation instituted or the
circumstances created by the State. It shall be apposite to refer to the
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relevant observations as contained in paras 16 to 17 of the judgment,
which read as under:-
"16. The judicial process of the court cannot subvert
justice for the reason that the court exercises its
jurisdiction only in furtherance of justice. The
State/authority often drags poor uprooted claimants
even for payment of a paltry amount upto this Court,
wasting the public money in such luxury litigation
without realising that poor citizens cannot afford the
exorbitant costs of litigation and, unfortunately, no
superior officer of the State is accountable for such
unreasonable conduct. It would be apt to quote the
well known words of Justice Brennan:
"Nothing rankles more in the human heart
than a brooding sense of injustice. Illness we
can put up with. But injustice makes us want
to pull things down. When only the rich can
enjoy the law, as a doubtful luxury, and the
poor, who need it most, cannot have it
because its expense puts it beyond their
reach, the threat to the continued existence of
free democracy is not imaginary but very real,
because democracy's very life depends upon
making the machinery of justice so effective
that every citizen shall believe in and benefit
by its impartiality and fairness."
17. The fundamental right of a farmer to cultivate his
land is a part of right to livelihood "Agricultural land is
the foundation for a sense of security and freedom
from fear. Assured possession is a lasting source for
peace and prosperity." India being predominantly an
agricultural society, there is a "strong linkage between
the land and the person's status in the social system."
"10.....A blinkered vision of development, complete
apathy towards those who are highly adversely
affected by the development process and a cynical
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unconcern for the enforcement or the laws lead to a
situation where the rights and benefits promised and
guaranteed under the Constitution hardly ever reach
the most marginalised citizens. For people whose lives
and livelihoods are intrinsically connected to the land.
the economic and cultural shift to a market economy
can be traumatic."
(Vide: Mahanadi Coal Fields Ltd. & Anr. v. Mathias
Oram & Ors., 2010 11 SCC 269; and Narmada Bachao
Andolan v. State of Madhya Pradesh & Anr., 2011
AIR(SC) 1989) 18. A farmer's life is a tale of
continuous experimentation and struggle for existence.
Mere words or a visual can never convey what it
means to live a life as an Indian farmer. Unless one
experiences their struggle, that headache he will never
know how it feels. The risks faced by the farming
community are many; they relate to natural calamities
such as drought and floods; high fluctuation in the
prices of input as well as output, over which he has no
control whatsoever; a credit system which never
extends a helping hand to the neediest; domination by
middlemen who enjoy the fruits of a farmer's hard
work; spurious inputs, and the recent phenomenon of
labour shortages, which can be conveniently added to
his tale of woes. Of late, there have been many cases
of desperate farmers ending their lives in different
parts of the country. The Principles of Economics
provides for the producer of a commodity to determine
his prices but an Indian farmer perhaps is the only
exception to this principle of economics, for even
getting a decent price for their produce is difficult for
them."
16. Time and again, the Courts have been expressing their displeasure at the
Governments'/public sector undertakings' compulsive litigation habit, but a
solution to this alarming trend is a distant dream. The judiciary is now
imposing costs upon the Government/Public Sector undertaking not only
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when it pursues cases which can be avoided, but also when it forces the
public to do so. The precise time, effort and other resources go down the
drain in vain.
17. This situation is best described by the Hon'ble Delhi High Court in
National Textile Corporation vs. Kunj Behari Lal, (2011) 167 Comp
Cas 29 (Delhi), wherein it was observed as under:-
"18. Present petition is most bogus and frivolous one
and has been filed just to squander public money and
to harass a common man who committed blunder by
giving his property on rent to the mighty public
undertaking. It is a well-known fact that courts across
the country are saddled with large number of cases.
Public Sector undertakings indulgences further burden
them. Time and again, courts have been expressing
their displeasure at the Governments/Public Sector
undertakings compulsive litigation habit but a solution
to this alarming trend is a distant dream. The judiciary
is now imposing costs upon Government/Public Sector
undertakings not only when it pursue cases which can
be avoided but also when it forces the public to do so.
19. Public Sector undertakings spent more money on
contesting cases than the amount they might have to
pay with regard to the premises which have been
taken on rent by them. In addition there to, precious
time, effort and other resources go down the drain in
vain. Public Sector undertakings are possibly an apt
example of being penny wise, pound foolish. Rise in
frivolous litigation is also due to the fact that Public
Sector undertakings though having large number of
legal personnel under their employment, do not
examine the cases properly and force poor litigants to
approach the court.
20. Frivolous litigation clogs the wheels of justice
making it difficult for courts to provide easy and
speedy justice to the genuine litigants. Public Sector
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undertakings should not indulge in mindless litigation
and unnecessary waste the time and public
exchequer's money. A strong message is required to
be sent to those litigants (whether Government or
Private) who are in the habit of challenging each and
every order of the trial court even if the same is based
on sound reasoning and also to those litigants who go
on filling frivolous applications one after another."
18. We have no hesitation to conclude that public money is being wasted
because of adamant behaviour of the Officers of the State due to the
litigious attitude adopted by these Officers in pursuing avoidable litigation
and trying to justify their action/inaction which is otherwise not at all
justifiable.
19. Merely because the Officers of the State Government do not have to pay
for the litigation from their own pocket, they cannot be permitted to file
frivolous petitions as observed by the Hon'ble Supreme Court in Special
Leave Petition (Civil) Nos. 20070 and 30326 of 2023 in case titled as
Special Land Acquisition Officer vs. Vithal Rao, decided on 6th
September, 2023 which reads as under:-
"1. Delay condoned.
2. We deprecate the practice of filing such a frivolous
petition after the award passed by the Reference Court
has attained finality before this Court. The landowners
were, thereafter, required to file execution
proceedings before the competent authority. The
Executing Court passed an order directing payment to
the landowners.
3. The petitioner-State did not stop at that and they
further challenged that order before the High Court.
The High Court by the impugned order directed the
petitioner(s) to make the payment of compensation.
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4. Even the High Court's order directing payment to
the landowners is now challenged by way of special
leave petition.
5. Merely because the officers of the State
Government, do not have to pay for the litigation from
their own pocket, they cannot be permitted to file such
frivolous petitions and harass the landowners, who
have already lost their valuable land.
6. The special leave petitions are, therefore, dismissed
with cost quantified at Rs.5,00,000/- (Rupees Five
Lakhs Only) to be paid within four weeks from the
date of this order. The cost of Rs.2,50,000/- (Rupees
Two Lakhs Fifty Thousand Only) shall be deposited in
the Supreme Court Advocates-on-Record Association
to be used for the purpose of Library and the cost of
Rs.2,50,000/- (Rupees Two Lakhs Fifty Thousand
Only) shall be deposited with the Supreme Court Bar
Association Advocates Welfare Fund."
20. The officials of the State Government have been totally oblivious to the
fact that the State defined within the ambit of Article 12 of the Constitution
of India, is not an ordinary party trying to win a case against one of its
own citizens by hook or crook. The State interest is to meet honest claims,
vindicate or substantial defence and never to score a technical point or
overreach a weaker party to avoid a just liability or secure an unfair
advantage, simply because legal devices provide such opportunity.
21. It is high time that we restrain the State and its agencies from litigating
endlessly just because of lack of responsibility to take decisions by its
Officers and direct that henceforth all the litigations on the appellate or
revisional side at the behest of the State shall be initiated only after
following the Jharkhand State Litigation Policy and certificate to this effect
shall be appended with the appeal/second appeal/revision petition,
including petition under Article 227 of the Constitution of India, or else,
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such litigation would ordinarily not be entertained, unless an affidavit of
the Department Head or the Secretary concerned, as the case may be, is
filed setting out therein cogent reasons as to why the provisions of the
Litigation Policy have not been adhered to, or else, the Courts may be
constrained to follow the course of action as adopted by the Hon'ble
Supreme Court while deciding S.L.P. (C) No. 3398 of 2024 titled as State
of Rajasthan and Others vs. Gopal Bijawat, on 16th February, 2024,
wherein it was held as under:-
"The respondent was reinstated by the Labour Court
in the year 2001 and the writ petition filed by the
State of Rajasthan was dismissed. Thereafter,
continuously the respondent has been compelled to
file repeated litigation in order to get the fruits of the
award of the Labour Court. The State of Rajasthan
has now come up in Special Leave Petition against the
orders passed by the learned Single Judge and the
Division Bench directing for implementation of the
said award.
It is unfortunate that the State of Rajasthan has been
harassing the poor litigant, a part-time labourer, who
was extended benefits by the Labour Court in the
year 2001, i.e. for the last 22 years he has been
litigating. This is totally a frivolous petition. It is,
accordingly, dismissed with costs of Rs.10,00,000/-
(Rupees ten lakhs only) to be paid to the respondent
within four weeks from today and file proof of such
payment before this Court within six weeks."
22. The instant civil review is most bogus and frivolous, where public money
has been squandered and the respondent-company has been harassed. It
is a well-known fact that the Courts across the country are saddled with
large number of cases and the petitioners unfortunately have indulged in
further burdening the Court.
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23. Accordingly, the present civil review is dismissed with a cost of
Rs.1,00,000/- (Rupees One Lakh) to be deposited by all the petitioners
out of their own pocket within a period of four weeks with the Jharkhand
State Legal Services Authority (JHALSA), Ranchi.
24. Pending interlocutory application stands disposed of.
25. For compliance to come up on 20.01.2026.
(TARLOK SINGH CHAUHAN, C.J.)
(RAJESH SHANKAR, J.)
16.12.2025
Satish/Vikas
Uploaded on 17.12.2025
