Relief Beyond Pleadings: Supreme Court Sets Boundaries for Division Benches.


31 October 2025
The Supreme Court of India, in the recent case of The Director, Bharathidasan Institute of Management & Another v. Dr. C.N.S. Ramnath Babu & Others (Civil Appeal Nos. of 2025), has again reiterated the settled position that an appellate court cannot expand the scope of an appeal by granting relief to a respondent in the absence of a cross-appeal or cross-objection.

A Bench comprising Justice Ahsanuddin Amanullah and Justice Satish Chandra Sharma allowed the appeals preferred by the Director and Chairman of Bharathidasan Institute of Management, modifying the order of the Madras High Court, Madurai Bench. The Division Bench of the High Court had upheld the quashing of the termination of Dr. C.N.S. Ramnath Babu but went further to direct his reinstatement with all consequential benefits—a direction which the Supreme Court found legally unsustainable.

 

 

The Court further observed that although judicial discretion permits limited intervention to achieve the cause of justice, the grant of additional relief to a respondent who has not filed any cross-appeal can be granted only in exceptional cases. In the instant case, no cross-appeal or plea for reinstatement having been preferred by the writ petitioner, the Division Bench could not have enlarged the scope of the appeal to that extent.

The Bench observed that the proper course was that laid down by the Single Judge: quashing of the order of termination and directing the matter to be placed before the Board of Governors for fresh consideration after giving the opportunity of hearing to the petitioner. Reinstatement, the Court held, would not be the appropriate remedy in these circumstances. The Court reasoned that if the employee ultimately succeeded, monetary compensation would suffice to redress his grievance, avoiding administrative complexities and further disputes.

The Supreme Court, accordingly, set aside the direction for reinstatement and restored the order of the Single Judge. In the process, the judgment pronounces valuable reaffirmation of procedural discipline in appellate adjudication and ensures that the boundaries of appellate jurisdiction are not transgressed under the guise of equitable relief.