Recently, the Madhya Pradesh High Court dismissed a plea challenging an administrative order passed by the Chief Justice, holding that the complainant has no legal right to demand a reasoned order when the complaint concerns a judge’s judicial conduct. The Court further observed that such frivolous complaints are an attempt to overawe the judiciary and must be discouraged with a heavy hand.
Brief Facts:
The petitioner, having been convicted under Section 332 of the IPC by a Judicial Magistrate, filed an appeal which is currently pending. During the pendency of the appeal, he lodged a complaint before the High Court against the presiding Magistrate, alleging that she had assured him of acquittal and discouraged him from presenting a defence. He claimed that no prosecution witness had implicated him and accused the Magistrate of giving him misleading assurances throughout the trial. Surprised by his conviction, the petitioner sought administrative action against the judge.
The High Court, however, filed the complaint without passing a reasoned order, prompting the petitioner to challenge the same on the ground that even administrative orders must be speaking and reasoned.
Contentions of the Petitioner:
The counsel for the petitioner argued that the order passed by the Chief Justice in filing the complaint, though administrative in nature, adversely affects the petitioner’s rights and hence must contain reasons. Placing reliance on Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan and Mohinder Singh Gill v. Chief Election Commissioner, he asserted that administrative, quasi-judicial, and judicial authorities are all obligated to pass reasoned orders when their decisions impact legal or constitutional rights.
He further contended that in the present case, the non-speaking order violated the petitioner’s rights and was liable to be set aside, urging the Court to remand the matter for reconsideration through a reasoned order.
Observations of the Court:
The High Court rejected the petitioner’s argument, noting, “It is not every administrative order which is deficient in reasoning that can be challenged. It is only those administrative orders, which give rise to a cause of action either by way of infringement of a statutory right or a constitutional right...” The Court clarified that once a complaint is filed before the High Court against a judicial officer, the complainant’s role ends. The power to take cognizance of such complaints lies solely with the High Court under Article 227, and no legal right exists in favour of the complainant to demand administrative action or a reasoned rejection.
On examining the complaint, the Court found the allegations "unverified, preposterous and fanciful", lacking any reference to specific time, date, or place where the alleged assurances were made by the judge. The Court strongly condemned the intent behind the complaint, “The actual reason appears to be to get a finding on the factual aspects relating to the case of the petitioner from this Court on the administrative side and use the same to influence the proceedings before the appellate Court...” The Court warned against such tactics which are intended to pressure judicial officers and called the attempt “deplorable,” adding, “The Judges of the District Judiciary of Madhya Pradesh find themselves between the devil and the deep sea... This is most deplorable and needs to be dealt with a heavy hand.”
Citing Haryana Financial Corporation v. Jagdamba Oil Mills, the Court reiterated that precedents cannot be applied blindly and must be contextually interpreted based on factual similarity.
The decision of the Court:
Dismissing the petition, the Court imposed an exemplary cost of ₹50,000 on the petitioner, to be deposited with the Madhya Pradesh State Legal Services Authority within ten days. It warned that failure to do so would result in recovery as arrears of revenue. The Court concluded that such baseless allegations against judicial officers are an attempt to influence ongoing judicial proceedings and shall not be entertained.
Case Title: Rajneesh Chaturvedi vs. High Court Of Madhya Pradesh And Others
Case No.: Writ Petition No. 18528 Of 2025
Coram: Justice Atul Sreedharan
Advocate for Petitioner: Adv. Narinder Pal Singh Ruprah (Senior Advocate), Muskan Anad
Advocate for Respondent: Advs. Rajvardhan Dutt Pararha
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