The Supreme Court has repeatedly emphasized the need for promptness and transparency in the delivery of judgments. In its landmark decision in Balaji Baliram Mupade v. State of Maharashtra (2021), the Court underscored the importance of judicial discipline, particularly with regard to the timely delivery of reasoned judgments. Delays in providing detailed reasons for judgments not only hinder the opportunity for parties to seek further judicial review, but they also breach the constitutional guarantee of speedy justice under Article 21.

In its recent observations, the Court noted with regret that despite these strong reminders, many High Courts, including the Gujarat High Court in the present case, continue to ignore these directives. The Court's frustration with this persistent negligence was evident as it observed that such conduct undermines the judiciary's credibility and affects the administration of justice. Judges are expected to uphold the highest standards of professionalism and integrity, which includes ensuring that their orders are clear, timely, and available to the parties concerned.

The present civil appeal before the Supreme Court arose from a judgment issued by the Gujarat High Court in March 2023. The appellant had filed a petition challenging an order passed by the Deputy Collector in 2015. The case was heard on March 1, 2023, and the appellant's counsel was under the impression that the judgment had been reserved, as no detailed order was pronounced immediately. However, more than a year later, in April 2024, the appellant's counsel received a soft copy of a reasoned order, which was dated March 1, 2023, despite the fact that the reasons had not been made available until that time.

This delay raised serious ethical concerns. The appellant alleged that the reasoned order was ante-dated to give the impression that it had been delivered on March 1, 2023, when, in fact, it had only been prepared and issued in April 2024. A report from the Registrar General of the High Court confirmed this allegation, further revealing that the reasoned order had been dictated by the judge to his personal secretary in April 2024, over a year after the hearing. This practice of backdating judicial orders not only violates established judicial norms but also creates a sense of mistrust among litigants regarding the fairness of the judicial process.

The Supreme Court's observations highlighted that when a judgment is pronounced in open court, the parties involved are entitled to rely on the operative portion of the order as the final judgment. The signing of the order is typically a formality unless there are exceptional circumstances requiring amendments or alterations. In this case, however, the lack of clarity regarding the dismissal of the petition and the delayed delivery of the reasoned judgment led to a breakdown of trust between the parties and the judicial system.

The Court pointed out that when a judge issues an oral order, it should be followed by an immediate or prompt delivery of the written reasons to ensure transparency and avoid any suspicion of delay or manipulation. The practice of delaying judgments, even after an oral order has been made, not only causes inconvenience to the litigants but also compromises the credibility of the judiciary. As the Supreme Court has stressed in Anil Rai v. State of Bihar (2001), delays in the delivery of judgments can amount to a violation of the right to life and liberty under Article 21, as they prevent parties from seeking further legal recourse in a timely manner.

Despite the pressures faced by judges in managing a heavy docket of cases, the Court emphasized that such delays should not become an excuse for neglecting the fundamental principles of judicial accountability. It urged judges to adopt practices that ensure timely pronouncement of judgments, either by dictating the judgment in open court or by reserving the judgment with a clear timeline for its delivery. In cases where judgments are reserved, the Court recommended that reasoned orders should be made available within a reasonable time frame—preferably within five days of the judgment's delivery—to avoid the creation of doubts in the minds of the litigants.

The Court also stressed the importance of learning from mistakes and improving the system. While the judicial process is inherently complex and burdened with a high volume of cases, it is essential for judges to exercise care and caution, keeping in mind the larger impact their decisions have on the administration of justice and public confidence in the legal system.

The Supreme Court's ruling in this case is a clear message to the High Courts across the country that the principles of promptness, transparency, and judicial discipline must be upheld at all costs. While acknowledging the immense pressure faced by judges, the Court emphasized that justice must not only be done but must also be seen to be done, as famously stated by Lord Hewart. The improper conduct of one judge can tarnish the reputation of the entire judiciary, and it is vital for judges to remain committed to upholding the oath of office and ensuring that their actions are beyond reproach.

In this case, the Court ultimately set aside the order passed by the Gujarat High Court, reviving the appellant’s petition for fresh consideration. This decision serves as a reminder that while judges may err, it is the responsibility of the judiciary as a whole to correct those errors and take steps to prevent their recurrence. As the legal system evolves, it is imperative that judges continue to adapt to changing demands while upholding the highest standards of fairness and professionalism.