Upholding an unwavering commitment to the constitutional values, 51st CJI, Justice Sanjiv Khanna, retires

“Freedom to express and speak is the most important condition for political democracy. Law and policies are not democratic unless they have been made and subjected to democratic process including questioning and criticism.”¹

– Justice Sanjiv Khanna

For decades, Justice Sanjiv Khanna has stood as a pillar of integrity within the legal community with an unwavering commitment to constitutional values. Often described by his colleagues as independent-minded, principled, and “no-nonsense,” Justice Khanna approached the bench with quiet confidence and an eye for detail that few could rival.² As Chief Justice Sanjiv Khanna culminates his distinguished judicial career , the legal community accords him a respectful and solemn farewell.

Early Life and Education

Born on 14-05-1960 into a family steeped in legal tradition, Justice Sanjiv Khanna inherited not just a profession but also the morality encompassed within it. His father, Justice Devraj Khanna, served as a lawyer and later a judge of the Delhi High Court, while his mother, Saroj Khanna, was a lecturer at Lady Shri Ram College.³

Justice Khanna completed his schooling from Delhi’s prestigious Modern School, Barakhamba Road. He graduated from University of Delhi in 1980 and later studied Law from the Campus Law Centre, University of Delhi.⁴

While his journey to the highest judicial office in the country might seem destined in hindsight, it was not always the career his family had envisioned for him.

• Did You Know? Justice Sanjiv Khanna’s parents wanted him to become a Chartered Accountant

However, destiny had other plans, when Justice Sanjiv Khanna was drawn not just to the law, but also towards a towering figure within, as he found his inspiration in his uncle, the legendary Justice H.R. Khanna.⁵

• Did You Know? Justice Sanjiv Khanna is the nephew of a former Judge of the Supreme Court of India, Justice Hans Raj Khanna, who propounded the Basic Structure Doctrine in 1973 and famously delivered the lone dissenting judgement in the ADM Jabalpur case,⁶ popularly known as the Habeas Corpus case, in 1976. Justice H. R. Khanna was superseded to the office of the Chief Justice of India by M. H. Beg.

From an Advocate to a Supreme Court Judge⁷

Justice Sanjiv Khanna enrolled as an Advocate with the Bar Council of Delhi in 1983. He began his practice in the District Courts at Tis Hazari in Delhi and soon shifted his practiced to Delhi High Court.

His area of practice was wide and varied from writ petitions in public law matters, direct tax appeals, income tax prosecutions, arbitration cases, commercial suits, environment and pollution laws matters, besides medical negligence cases before consumer forums and company law cases before the Company Law Board.

His expertise and integrity earned him the position of Senior Standing Counsel for the Income Tax Department for seven years. Subsequently, he served as Senior Standing Counsel (Civil) for the Government of the National Capital Territory of Delhi. Additionally, he was appointed as an Additional Public Prosecutor in the High Court of Delhi and served as amicus curiae in numerous criminal and public interest cases.

• Did You Know? Justice Sanjiv Khanna never headed any High Court as Chief Justice and was a Judge of the Delhi High Court prior to his elevation to SC.

On 24-06-2005 he was elevated as an Additional Judge of the Delhi High Court and became a Permanent Judge of the Delhi High Court on 20-02-2006.⁸ Justice Khanna was elevated as a Judge of the Supreme Court of India on 18-01-2019 and became Chief Justice of India on 11-11-2024.⁹

• Did You Know? Justice Sanjiv Khanna was directly elevated from his parent High Court – the Delhi High Court, which is a rare occurrence.¹⁰

Administrative Achievements¹¹

Throughout his legal career Justice Khanna held many significant positions. He is presently the Patron-in-Chief of the National Legal Services Authority (NALSA) and the Chairperson of the National Judicial Academy, Bhopal (NJA). He earlier held key roles including Chairman of the Supreme Court Legal Services Committee (SCLSC) from June to December 2023 and Executive Chairman of NALSA from December 2023 to November 2024.

During his tenure in the Delhi High Court, Justice Khanna took on several important responsibilities. He served as the Chairman and Judge-in-Charge of institutions such as the Delhi Judicial Academy, Delhi International Arbitration Centre, and various District Court Mediation Centres, playing a crucial role in strengthening judicial education and alternative dispute resolution mechanisms.

Notable Judgements at Supreme Court

• Did You Know? As a Judge of Supreme Court India, Justice Sanjiv Khanna has authored 123 judgments and was part of 1000+ decisions.¹²

Over his tenure, Chief Justice Khanna has been at the helm of several landmark judgments that continue to shape Indian jurisprudence. In 2019, his ruling that the office of the Chief Justice of India is subject to the Right to Information Act underscored his belief that transparency within the judiciary and opened a critical dialogue on public accountability in a traditionally opaque system.¹³ His 2021 dissenting opinion on the procedural lapses in the Central Vista project, a major redevelopment initiative in Lutyens’ Delhi, highlighted his readiness to challenge governmental excesses, ensuring that power remains subject to diligent oversight and due process.¹⁴ In 2023, Chief Justice Khanna’s opinion in a five-judge bench was pivotal in upholding the government’s abrogation of Article 370.¹⁵

Also in 2023, he co-authored a judgment that granted the Supreme Court the power to dissolve marriages on the grounds of “irretrievable breakdown”, thereby taking progressive step towards simplifying divorce procedures.¹⁶ His judicial acumen was again on display when he played a central role in the judgment declaring the electoral bond scheme unconstitutional and asserted that the right to privacy of donors could not outweigh the electorate’s collective right to information.¹⁷ Notably, the bench led by Chief Justice Khanna granted Arvind Kejriwal a three-week bail to campaign for the Lok Sabha elections, a decision that was later followed by an extension of interim bail in a significant Enforcement Directorate case involving the Aam Aadmi Party leader.¹⁸ Many more such judgments as discussed below –

• Did You Know? It was a rare coincidence for Justice Sanjiv Khanna to begin his first day as a judge in Supreme Court sitting in the same courtroom from which his uncle, Late Justice H. R. Khanna, last retired.¹⁹

Constitution Bench and Larger Bench Decisions

In Aligarh Muslim University v. Naresh Agarwal, 2024 SCC OnLine SC 3213, an appeal against Allahabad High Court’s Order in Naresh Agarwal v. Union of India, 2005 SCC OnLine All 1705, whereby, Aligarh Muslim University’s (‘AMU’) action of 50 percent seat reservation in postgraduate medical courses for Muslim candidates by claiming it to be a minority institution, was struck down and held that AMU cannot have an exclusive reservation because it is not a minority institution, the Seven-Judge Constitution Bench comprising of Dr. DY Chandrachud, CJ., Sanjiv Khanna, Surya Kant, JB Pardiwala, Dipankar Datta, Manoj Misra and Satish Chandra Sharma, JJ. in 4: 3 overruled the Five-Judge Bench verdict in S. Azeez Basha v. Union of India, 1967 SCC OnLine SC 321, which held that an institution incorporated by a statute cannot claim to be a minority institution, hence AMU as created by an Act of Parliament, is not a minority institution so as to be covered under Article 30 of the Constitution of India.

The Chief Justice Chandrachud had authored the majority opinion in the case, joined by Justices Sanjiv Khanna, JB Pardiwala, and Manoj Misra. In contrast, Justices Surya Kant, Dipankar Datta, and Satish Chandra Sharma each wrote separate dissenting opinions, outlining their differing perspectives on the matter.

In Gayatri Balasamy v. ISG Novasoft Technolgies Ltd., 2025 SCC OnLine SC 986, a 4:1 majority ruling, a five-judge Bench comprising Sanjiv Khanna*, CJI., B.R. Gavai, Sanjay Kumar, Augustine George Masih, and K.V. Viswanathan**, JJ. held that the Appellate Courts may exercise limited powers to modify arbitral awards under Sections 34 and 37 of the Arbitration and Conciliation Act, under certain specific circumstances:

• Severability — When the invalid portion of the award can be separated from the valid part.

• Apparent Errors — To correct clerical, computational, or typographical errors evident on the face of the record.

• Post-Award Interest — To modify post-award interest where appropriate.

• Article 142 Powers — The Supreme Court may exercise its special powers under Article 142 of the Constitution to modify awards, but such powers must be used sparingly and with great caution, in accordance with constitutional limits.

In Assn. for Democratic Reforms (Electoral Bond Scheme) v. Union of India, (2024) 5 SCC 214, the 5-Judge Constitution Bench of Dr. DY Chandrachud*, CJI., Sanjiv Khanna**, BR Gavai, JB Pardiwala, Manoj Misra, JJ. gave a unanimous verdict with two opinions, one authored by Dr. Justice DY Chandrachud for Justice Gavai, Justice Pardiwala and Justice Misra, and other by Justice Sanjiv Khanna, with slight variance in the reasoning, and held that anonymous electoral bonds are violative of the right to information under Article 19(1)(a) of the Constitution. Thus, the electoral bonds scheme was struck down for being unconstitutional. The proviso to Section 29-C(1) of the Representation of the People Act, 1951, Section 182(3) of the Companies Act, 2013, and Section 13-A(b) of the Income-tax Act, 1961, as amended by the Finance Act, 2017, were also held to be unconstitutional and struck down.

“The Right to know is paramount for free and fair elections and democracy.”

In Article 370 of the Constitution, In re, 2023 SCC OnLine SC 1647, the five-Judge Constitution Bench comprising of Dr. DY Chandrachud*, CJI., Sanjay Kishan Kaul,** Sanjiv Khanna,*** B.R. Gavai, and Surya Kant, JJ., delivered its verdict pertaining to the petitions filed against abrogation of Article 370 by the Central Government. The Bench unanimously upheld the Union’s action of abrogating Article 370. It further directed the restoration of statehood. Justice Khanna concurred with the two judgments delivered by the CJI and Justice Kaul.

“Article 370 was enacted as a transitional provision and did not have permanent character. The abrogation of Article 370 does not negate the federal structure, as the citizens living in Jammu and Kashmir do and will enjoy same status and rights as given to citizens residing in other parts of the country.”

In Interplay between Arbitration Agreements under the Arbitration & Conciliation Act, 1996 and the Indian Stamp Act, 1899, In re, (2024) 6 SCC 1, a 7-Judge Bench comprising of Dr. DY Chandrachud*, CJI, Sanjay Kishan Kaul, Sanjiv Khanna*, BR Gavai, Surya Kant, JB Pardiwala, and Manoj Misra, JJ. held that the unstamped agreement is inadmissible under the Indian Stamp Act, 1899 but cannot be rendered void ab initio. Thus, arbitration clauses in unstamped or inadequately stamped agreements are enforceable. Justice Khanna wrote a concurring judgment.

“An instrument whether unstamped or insufficiently stamped will not fall foul on the ground of consideration or object of the agreement being immoral, neither will it fall foul as opposed to public policy.”

In Shilpa Sailesh v. Varun Sreenivasan, (2023) 14 SCC 231, the Constitution Bench comprising of Sanjay Kishan Kaul, Sanjiv Khanna*, A.S. Oka, Vikram Nath, and J.K. Maheshwari, JJ., held that the Supreme Court has the discretion to dissolve the marriage by passing a decree of divorce by mutual consent, without being bound by the procedural requirement to move the second motion subject to the requirements and conditions laid down under Amardeep Singh v. Harveen Kaur, (2017) 8 SCC 746 and Amit Kumar v. Suman Beniwal, (2023) 17 SCC 648.

In Supreme Court of India v. Subhash Chandra Agarwal, (2020) 5 SCC 481, a five-judge Constitution Bench of Ranjan Gogoi, (CJ) and NV Ramana,*** Dr. DY Chandrachud,*** Deepak Gupta and Sanjiv Khanna,* JJ., upholding the 2010 landmark judgment of the Delhi High Court bringing the Chief Justice of India’s office under Right to Information, held that the office of the Chief Justice of India comes under the definition of ‘public authority’ in the Right to Information Act.

The Court held that the information sought relating to the appointment of Supreme Court and High Court judges is ‘third party’ information and thus the process under Section 11 Right to Information Act, 2005 must be complied with. The Court also held that the information with respect to the judges of the Supreme Court who have declared their assets does not constitute the ‘personal information’ of the judges and thus, does not engage the right to privacy.

“Judicial independence and accountability go hand in hand as accountability ensures and is a facet of judicial independence.”

In Roger Mathew v. South India Bank Ltd., (2020) 6 SCC 1, a 5-judge Constitution Bench of Ranjan Gogoi*, CJ and NV Ramana, Dr. DY Chandrachud***, Deepak Gupta*** and Sanjiv Khanna, JJ., assessing the constitutional validity of Section 184 of the Finance Act, 2017 and held that Section 184 is valid and does not suffer from excessive delegation of legislative functions as there are adequate principles to guide framing of delegated legislation, which would include the binding dictums of this Court.

The Court struck down the Tribunal, Appellate Tribunal and other Authorities (Qualifications, Experience and other Conditions of Service of Members) Rules, 2017, made under Section 184 of the Finance Act, 2017, for being contrary to the parent enactment and the principles envisaged in the Constitution i.e. being destructive of judicial independence.

The Court also dealt with the difference with money bill and finance bill and held that the Money bill can be introduced only in Lok Sabha and the role of the Rajya Sabha is merely consultative.

• Did You Know? Justice Sanjiv Khanna recused himself from hearing AAP leader Satyendar Jain’s case due to personal connections. The dispute involved corruption allegations by Dr. S.C. Vats, escalating to the High Court after the 2020 Delhi Assembly elections.²⁰

Other important Supreme Court Decisions

• Did You Know? Justice Sanjiv Khanna recused himself from hearing Sajjan Kumar’s appeal in 1984 anti-Sikh riots case and he is the one who had dismissed Sajjan Kumar’s bail in the Delhi High Court in 2015.²¹

While considering a petition under Article 32 read with Article 129 of the Constitution seeking initiation of suo motu criminal contempt proceedings against BJP MP Nishikant Dubey, for making deliberate and scandalizing remarks against the Supreme Court of India and the Chief Justice of India in Vishal Tiwari v. Union of India;²² the Division Bench of Sanjiv Khanna, CJ., and Sanjay Kumar J., declined to entertain the petition. However, the Court opined that the comments by the BJP MP were highly irresponsible and reflect a penchant to attract attention by casting aspersions on the Supreme Court of India and its Judges. This apart, the statements show ignorance about the role of the constitutional courts and the duties and obligations bestowed on them under the Constitution.

While considering the writ petitions challenging the insertion of ‘socialist’ and ‘secular’ in the Preamble to the Constitution by the Constitution (Forty-second Amendment) Act in 1976 in Balram Singh v. Union of India, 2024 SCC OnLine SC 3433; the Division Bench of Sanjiv Khanna, CJ., and Sanjay Kumar, J., dismissed the petitions stating that there was no legitimate cause or justification for challenging this Constitutional Amendment after nearly 44 years. The Court further said that the words “socialist” and “secular” terms have achieved widespread acceptance with their meanings understood by “We, the people of India” without any semblance of doubt. Furthermore, the additions to the Preamble have not restricted or impeded legislations or policies pursued by elected governments, provided such actions did not infringe upon fundamental and constitutional rights or the basic structure of the Constitution.

In State of W.B. v. Baishakhi Bhattacharyya, 2025 SCC OnLine SC 719, an appeal filed against the judgment passed by the Calcutta High Court, wherein, the Court set aside the 2016 selection process conducted by the West Bengal Central School Service Commission (‘WBSSC’) for the recruitment of non-teaching staff in Groups C and D, and Assistant Teachers for Classes IX and X, as well as Classes XI and XII, the division bench of Sanjiv Khanna*, CJI, and Sanjay Kumar, J. upheld the impugned judgment that canceled the entire selection process en bloc but made certain modifications to the directions issued by the High Court.

In State of A.P. v. Rao, V.B.J. Chelikani, 2024 SCC OnLine SC 3432, a civil appeal challenging the allotment of land parcels, vide several State Government Memoranda, within the Greater Hyderabad Municipal Corporation limits, the division bench of Sanjiv Khanna*, CJI. and Dipankar Datta, J. said that the State cannot exercise discretion to benefit a select few elites disproportionately, especially ones who are already enjoying pre-existing benefits and advantages. Further, the Court allowed the appeal to the extent they classify MPs, MLAs, officers of the AIS/State Government, Judges of the Constitutional Courts, and journalists as a separate class for allotment of land at the basic rate. , and declared the impugned Government Memoranda (GoMs) bad in law, being violative of Article 14 of the Constitution of India.

“Government servants, elected legislators, Judges in the Supreme Court and High Court, and prominent journalists do not belong to the “weaker” or per se deserving sections of our society, warranting special State reservations to land allotment.”

In Solar Energy Corpn. of India Ltd. (SECI) v. Wind Four Renergy (P) Ltd., 2024 SCC OnLine SC 219, an appeal filed by Solar Energy Corporation of India Limited (‘SECI’) against the judgment and order passed by the Appellate Tribunal for Electricity, wherein the Tribunal allowed the appeal preferred by Wind Four Renergy Private Limited (‘WFRPL’) and directed that the period of 132 days, for which delay was to be condoned, would commence from the date of the impugned judgment, that is, 11-01-2022, the division bench of Sanjiv Khanna* and Dipankar Datta, JJ. while setting aside the impugned judgment and restoring the order passed by the CERC, reinforced the importance of adhering to project timelines in the renewable energy sector, and held that the objective and purpose of timelines is to ensure early supply of green energy and reduction of carbon footprint. Further, it directed that SECI is entitled to recover the bank guarantee amount of Rs.10 crores along with simple interest at 12% per annum, to be paid within 6 months.

In Radhika Agarwal v. Union of India, 2025 SCC OnLine SC 449, a matter concerning the power to arrest under the Customs Act, 1962 and the Central Goods and Services Tax Act, 2017 (‘CGST Act’), the three Judge Bench of Sanjiv Khanna*, CJI, MM. Sundresh and Bela M. Trivedi**, JJ. rejected the challenge to the constitutional validity as also the right of the authorised officers under the Customs Act and the GST Acts to arrest with elucidation and clarification on the pre-conditions and when and how the power of arrest is to be exercised.

“The framework of the Customs Act clearly reflects the legislative intent to establish a distinct and unique procedure for the exercise of arrest powers by a customs officer.”

In CCE (GST) v. Citibank N.A., (2025) 1 SCC 750, a 3-judges bench of Sanjiv Khanna,* Sanjay Kumar and R. Mahadevan, JJ., held that payment of service tax by acquiring bank (which acquires credit card slips from Merchant Establishment at whose premises it places its device “point of sale” or “PoS” machine) on the entire merchant discount rate (MDR), including that on share of issuing bank (which issues credit card) i.e. without the imposition of such obligation on issuing bank, not permissible.

While considering the instant matter in T.N. Cements Corpn. Ltd. v. Unicon Enterprises Facilitation Council, (2025) 4 SCC 1, wherein the Court had to consider whether a writ petition under Article 226 of the Constitution would be maintainable against an order passed by the Micro and Small Enterprises Facilitation Council (MSEFC) in exercise of power under Section 18 of the Micro, Small and Medium Enterprises Development Act, 2006 (MSMED Act) and if yes, then under what circumstances; the 3-Judge Bench of Sanjiv Khanna, CJ*., Sanjay Kumar and Manmohan, JJ., deemed it fit to refer the matter to a larger bench of 5 Judges. The Court identified the following issues to be determined by a larger Bench:

1. Whether the ratio in India Glycols Ltd. v. Micro and Small Enterprises Facilitation Council, 2023 SCC OnLine SC 1852, that a writ petition could never be entertained against any order/award of the MSEFC, completely bars or prohibits maintainability of the writ petition before the High Court?

2. If the bar/prohibition is not absolute, when and under what circumstances will the principle/restriction of adequate alternative remedy not apply?

3. Whether the members of MSEFC who undertake conciliation proceedings, upon failure, can themselves act as arbitrators of the arbitral tribunal in terms of Section 18 of the MSMED Act read with Section 80 of the A&C Act?

The Court clarified that the 1st and 2nd question will subsume the question of when and in what situation a writ petition can be entertained against an order/award passed by MSEFC acting as an arbitral tribunal or conciliator.

In Arvind Kejriwal v. Enforcement Directorate, (2025) 2 SCC 248, a criminal appeal by Chief Minister of Delhi and AAP’s leader Arvind Kejriwal challenging his arrest by the Directorate of Enforcement (‘ED’) under the Prevention of Money Laundering Act, 2002 (PMLA) in the alleged Delhi liquor excise policy case, Sanjiv Khanna* and Dipankar Datta, JJ. granted interim relief by granting him interim bail, while referring his petition challenging the arrest by the ED to a larger bench.

“Any undue indulgence and latitude to the ED will be deleterious to the constitutional values of rule of law and life and liberty of persons. An officer cannot be allowed to selectively pick and choose material implicating the person to be arrested. They have to equally apply their mind to other material which absolves and exculpates the arrestee.”

The Bench referred following questions to the Larger Bench –

1. Whether the “need and necessity to arrest” is a separate ground to challenge the order of arrest passed in terms of Section 19(1) of the PMLA?

2. Whether the “need and necessity to arrest” refers to the satisfaction of formal parameters to arrest and take a person into custody, or it relates to other personal grounds and reasons regarding necessity to arrest a person in the facts and circumstances of the said case?

3. If questions (1) and (2) are answered in the affirmative, what are the parameters and facts that are to be taken into consideration by the Court while examining the question of “need and necessity to arrest”?

In a judgment filed by staff unions and officers’ associations of various banks, against the judgments passed by the Madras High Court and the Madhya Pradesh High Court, wherein the Courts dismissed their writ petitions, challenging the vires of Section 17(2)(viii) of the Income Tax Act, 1961 or Rule 3(7)(i) of the Income Tax Rules, 1962, the division bench of Sanjiv Khanna* and Dipankar Datta , JJ., in All India Bank Officers’ Confederation v. Central Bank of India, (2024) 9 SCC 664, has held that Section 17(2)(viii) does not lead to an excessive delegation of the ‘essential legislative function’, and the Rule 3(7) is intra vires Article 14 of the Constitution of India.

In Sharif Ahmed v, State of U.P., 2024 SCC OnLine SC 726, petitions were filed by the petitioners challenging legal proceedings initiated alleging various criminal charges, including breach of trust, fraud, and assault, leading to legal proceedings against them. The case relates to chargesheets being filed without stating sufficient details of the facts constituting the offense or putting the relevant evidence on record merely carrying a reproduction of the details mentioned by the complainant in the First Information Report, and then proceed to state whether an offence is made out, or not made out, without any elucidation on the evidence and material relied upon. A division bench of Sanjiv Khanna* and SVN Bhatti, JJ., dismissed the charges against the petitioners and granted anticipatory bail further quashing the summoning order and non-bailable warrants against Manager Singh.

In Birla Corpn, Ltd. V, Bhanwar Singh, 2024 SCC OnLine SC 41, a case filed due to concerns about the potential impact of mining activities, particularly blasting operations, on the Chittorgarh Fort, a historical monument of significant cultural importance. The petition was likely filed by parties concerned about the preservation of the fort and its surroundings, possibly including local residents, heritage conservation groups, or government authorities responsible for monument protection. A division bench of Sanjiv Khanna and S V Bhatti, JJ., held that while mining activities were permissible, blasting operations within a five-kilometre radius of the fort were prohibited to prevent potential damage to its structures. Manual or mechanical mining operations within this radius were allowed, subject to valid leases and compliance with regulations. Additionally, the court ordered the establishment of a multidisciplinary expert committee to study the environmental impact of blasting operations beyond the prohibited radius. The committee was tasked with assessing the impact on the fort’s structures, identifying causes of damage, and conducting an environmental impact assessment. The petitioner, Birla Corporation Limited, was directed to bear the expenses of the study.

In Rama Devi v. State of Bihar, (2024) 10 SCC 462, set of criminal appeals one by the State of Bihar, through the Central Bureau of Investigation (‘CBI’), and the other by Rama Devi, the wife of one of the deceased— Brij Bihari Prasad, a member of the Bihar Legislative Assembly against a decision of the Patna High Court reversing the Trial Court’s decision convicting the nine accused persons, the three-Judge Bench of Sanjiv Khanna,* Sanjay Kumar and R. Mahadevan, JJ. partially allowed the appeals and restored the Trial Court’s decision to convict the two of the accused persons (A-4 and A-8), including Vijay Kumar Shukla (former MLA Munna Shukla). The Court set aside the High Court’s decision in reference to these two accused persons, however, giving the benefit of doubt, the Court refused to interfere with the impugned decision in reference to the other accused persons.

In EVM-VVPAT verification case, Assn. For Democratic Reforms v. Election Commission of India, (2025) 2 SCC 732, the Division Bench comprising of Sanjiv Khanna* and Dipankar Dutta**, JJ., in separate but concurring judgments, rejected the petitions seeking directions for 100% cross-verification of all Voter Verifiable Paper Audit Trail (VVPAT) slips with votes cast through Electronic Voting Machines (EVMs) during elections. The following directions were given:

1. On completion of the symbol loading process in the VVPATs undertaken on or after 01-05-2024, the symbol loading units shall be sealed and secured in a container and shall be kept in the strong room along with the EVMs at least for a period of 45 days post the declaration of results.

2. A team of engineers should check the burnt memory in the microcontroller EVM, after the declaration of the results, on a request made by the candidates who scored the second and the third position behind the highest polled candidate. The Court clarified that the verification expenses shall be borne by the candidate making such request. However, the expenses will be refunded if the EVMs are found to be tampered with.

In Bharti Cellular Ltd. v. CIT, (2024) 8 SCC 608, bunch of appeals pertaining to liability to deduct tax at source under Section 194-H of Income Tax Act, 1961 (‘1961 Act’) against telecom companies regarding amount payable under franchise/distributorship agreements, the Division Bench of Sanjiv Khanna* and SVN Bhatti, JJ. held that Section 194-H of 1961 Act was not applicable to them since they did not control the income of such franchise/distributors.

In DBS Bank Ltd. v. Ruchi Soya Industries Ltd., (2024) 3 SCC 752, the Division Bench of Sanjiv Khanna* and SVN Bhatti, JJ. referred the question that — whether Section 30(2)(b)(ii) of the Insolvency and Bankruptcy Code, 2016, as amended in 2019, entitles the dissenting financial creditor to be paid the minimum value of its security interest, to the larger Bench, considering the difference of opinion.

In Manish Sisodia v. CBI, 2023 SCC OnLine SC 1393, a criminal appeal filed by Aam Aadmi Party (‘AAP’) leader Manish Sisodia, seeking bail in a case registered by the Central Bureau of Investigation (‘CBI’) under Prevention of Corruption Act, 1988 and Penal Code, 1860, and Directorate of Enforcement (‘ED’) under the Prevention of Money Laundering Act, 2002, the Division Bench of Sanjiv Khanna* and SVN Bhatti, JJ. refused to grant bail to Manish Sisodia profit margin of wholesale distributors of liquor comparing 5% commission under old and 12% under the new regime.

“Rule of law means that laws apply equally to all citizens and institutions, including the State. Rule of law requires an equal right to access to justice for the marginalised. The rule also mandates objective and fair treatment to all. Thirdly, rule of law is a check on arbitrary use of powers. It secures legitimate exercise of power for public good.”

While hearing a batch of civil appeals for the interpretation of the provisions of the Electricity Act, 2003 (‘the Act’) and Rule 3 of the Electricity Rules, 2005 (‘the Rules’) for being classified as a Captive Generating Plant (‘CGP’) and a captive user in Dakshin Gujarat Vij Co. Ltd. v. Gayatri Shakti Paper & Board Ltd., 2023 SCC OnLine SC 1276, the division Bench of Sanjiv Khanna* and M.M. Sundresh, JJ. held that in case of change of ownership, shareholding, or consumption, the principle of weighted average should be applied to ensure compliance of the proportional electricity consumption requirement stipulated under the second proviso to Rule 3(1)(a).

“SPVs which own, operate and maintain CGPs are an ‘association of persons’ in terms of the second proviso to Rule 3(1)(a) of the Rules, however, the companies, body corporates and other persons, who are shareholders and captive users of a CGP set up by a SPV, are required to comply with Rule 3(1)(a) of the Rules read with the second proviso of the Rules.”

In IDBI v. CCE & Customs, (2023) 10 SCC 107, the Division Bench of Sanjiv Khanna* and Sudhanshu Dhulia, JJ., held that the des towards customs duty i.e. government dues falling under Section 530 of the Companies Act, 1956 does not have primacy, over dues of secured creditor i.e. dues falling under Section 529-A of the Companies Act, 1956 and Section 142-A of the Customs Act, 1962, does not alter this position.

In State of Rajasthan v. Asharam, 2023 SCC OnLine SC 423, an appeal filed by the State against the Judgment of the Rajasthan High Court allowing the application filed by the Asharam Bapu under Section 391 of the CrPC, and directing summoning and recording of evidence of Ajay Pal Lamba, Deputy Commissioner of Jodhpur Police who has written a book “Gunning For The Godman: The True Story Behind Asharam Bapu’s Conviction”, the Division Bench of Sanjiv Khanna* and MM Sundresh, JJ. refrained from examining whether there is sufficient evidence and material to uphold the conviction of Asharam, as the questions of merits are to be considered by the High Court while adjudicating the criminal appeal against conviction and held that the test to allow additional evidence is not satisfied. Thus, set aside the impugned judgment.

In Career Institute Educational Society v. Om Shree Thakurji Educational Society, 2023 SCC OnLine SC 586, the Division Bench of Sanjiv Khanna and M.M. Sundresh, JJ., reiterated that it is not everything said by a Judge when giving judgment that constitutes a precedent. The only thing in a Judge’s decision binding as a legal precedent is the principle upon which the case is decided and, for this reason, it is important to analyse a decision and isolate from it the obiter dicta. Read more

In Anna Mathews v. Supreme Court of India, (2023) 5 SCC 661, the Division Bench of Sanjiv Khanna and B.R. Gavai, JJ., said that when eligibility is put in question, the question would fall within the scope of judicial review. However, the question of whether a person is fit to be appointed as a judge essentially involves the aspect of suitability and stands excluded from the purview of judicial review.

In Smriti Debbarma v. Prabha Ranjan Debbarma, 2023 SCC OnLine SC 9, the Division Bench of Sanjiv Khanna* and J.K Maheshwari, JJ., held that the Gauhati High Court had rightly examined the aspect of demarcation and identification of Schedule A property. Further, the Court said the plaintiff has not been able to establish her title and ownership over the Schedule A property. A decree of possession cannot be passed in favour of the plaintiff on the grounds that respondents have not been able to fully establish their right, title and interest in Schedule A property.

In Dilip Hariramani v. Bank of Baroda, 2022 SCC OnLine SC 579, the Division Bench of Ajay Rastogi and Sanjiv Khanna*, JJ., explained the law on vicarious liability under the Negotiable Instruments Act, 1881 (‘NI Act’) and held that while Section 141 of the NI Act extends vicarious criminal liability to officers associated with the company or firm when one of the twin requirements of Section 141 has been satisfied, which person(s) then, by deeming fiction, is made vicariously liable and punished, such vicarious liability arises only when the company or firm commits the offence as the primary offender.

In BBR (India) (P) Ltd. v. S.P. Singla Constructions (P) Ltd., (2023) 1 SCC 693, the Division Bench of Ajay Rastogi and Sanjiv Khanna*, JJ., held that subsequent hearings or proceedings at a different location other than the place fixed by the arbitrator as the ‘seat of arbitration’ should not be regarded and treated as a change or relocation of jurisdictional ‘seat’.

In ONGC v. Afcons Gunanusa JV, (2024) 4 SCC 481, the three-judge Bench of Dr. DY Chandrachud*, Surya Kant and Sanjiv Khanna*, JJ., held that arbitrators do not have the power to unilaterally issue binding and enforceable orders determining their own fees. However, Khanna, J., wrote a separate opinion where he agreed with the majority opinion of certain parts but disagreed on the point that in the absence of any agreement between the parties, or the parties and the arbitral tribunal, or a court order fixing the fee, the arbitral tribunal is not entitled to fix the fee. He said that arbitrator’s fee, being a component of cost, can be fixed by the arbitral tribunal when it is not already predetermined by way of an agreement between the parties, or by a court order.

In Commr. of Gift Tax v. BPL Ltd., 2022 SCC OnLine SC 1405, the Division Bench of Sanjiv Khanna* and J.K. Maheshwari, JJ., while answering the appeals relating to the valuation of shares of BPL Sanyo Technologies Ltd. and BPL Sanyo Utilities and Appliances Ltd. gifted by the assessee to Celestial Finance Ltd. in 1993, held that equity shares which are quoted and transferable in the stock exchange are to be valued based on the current transactions and quotations in the open market.

In PTC (India) Financial Services Ltd. v. Venkateswarlu Kari, (2022) 9 SCC 704, the Division Bench of M.R Shah and Sanjiv Khanna*, JJ., held that mere exercise of the right by the pawnee to record himself as the ‘beneficial owner’, which is a necessary precondition before the pawnee can exercise his right to sell, is not ‘actual sale’ and would not affect the rights of the pawnor of redemption under Section 177 of the Contract Act. The Court observed that,

“Every transfer or sale is not ‘actual sale’ for the purpose of Section 177 of the Contract Act. To equate ‘sale’ with ‘actual sale’ would negate the legislative intent.”

In Irappa Siddappa Murgannavar v. State of Karnataka, (2022) 2 SCC 801, a case where a death row convict subjected a 5-year-old girl to rape, killed her by strangulation, and then disposed of her body, tied in a gunny bag, into a stream, the 3-judge bench of L. Nageswara Rao, Sanjiv Khanna* and BR Gavai, JJ has, finding hope for reformation and rehabilitation of the appellant, commuted his death sentence to that of life imprisonment.

While the Court noted that the appellant has committed an abhorrent crime, it said that, considering the mitigating circumstances like his young age, weak socioeconomic background, absence of any criminal antecedents, etc.; there was hope for reformation, rehabilitation, and thus the option of imprisonment for life was certainly not foreclosed.

In Amish Devgan v. Union of India, (2021) 1 SCC 1, a Division bench comprising of AM Khanwilkar and Sanjiv Khanna,* JJ., refused to quash the FIRs registered against News18 Journalist Amish Devgan for using the term “Lootera Chisti” in one of his shows but has granted interim protection to him against arrest subject to his joining and cooperating in investigation till completion of the investigation.

The Court noted the observation in Noise Pollution (V), In Re, (2005) 5 SCC 733,

“Article 19(1)(a) cannot be pressed into service for defeating the fundamental right guaranteed by Article 21 as if one claims to right to speech, the others have the right to listen or decline to listen.”

The Court opined that the true test of a valid FIR is only whether the information furnished provides reason to suspect the commission of an offence which the police officer concerned is empowered under Section 156(1) of the Criminal Code to investigate.

“…the FIR registered first in point of time, should be treated as the main FIR and others as statements under Section 162 of the Criminal Code. However, in exceptional cases and for good reasons, it will be open to the High Court or this Court, as the case may be, to treat the subsequently registered FIR as the principal FIR. However, this should not cause any prejudice, inconvenience or harassment to either the victims, witnesses or the person who is accused.”

Read More | FIR is not a detailed chronicle of all intricate and minute details of an offence: Supreme Court

The Court also made an attempt to define “hate speech” and explain what will invite penal action and stated that “Dissent and criticism of the elected government’s policy, when puissant, deceptive or even false would be ethically wrong, but would not invite penal action.”

Read More | Freedom & rights cannot armour those who promote & incite violence| 15 notable excerpts on ‘hate speech’ from Supreme Court’s verdict in Amish Devgan case

In Rajiv Suri v. DDA, (2022) 11 SCC 1, a 3-judge bench comprising of A. M. Khanwilkar*, Dinesh Maheshwari and Sanjiv Khanna**, JJ, by a 2:1 verdict, held that there is no infirmity in the grant of “no objection” by the Central Vista Committee (CVC) and “approval” by the Delhi Urban Art Commission (DUAC) and “prior approval” by the Heritage Conservation Committee (HCC) to the Central Vista Project and given a go ahead to the Central Vista Project.

Justice Sanjiv Khanna dissented with the opinion expressed by A.M. Khanwilkar, J. on the aspects of public participation on interpretation of the statutory provisions, failure to take prior approval of the Heritage Conservation Committee and the order passed by the Expert Appraisal Committee.

According to Justice Khanna the core issue in the present case is whether or not the authorities have performed their duty to consult the public, followed the prescribed procedure and the authority competent acted to modify or amend in terms of the Development Act and the Development Rules.

Justice Khanna opined that “…mere uploading of the gazette notification giving the present and the proposed land use with plot numbers was not sufficient compliance, but rather an exercise violating the express as well as implied stipulations, that is, necessity and requirement to make adequate and intelligible disclosure.”

In Laxmi Singh v. Rekha Singh, (2020) 6 SCC 812, a 3-judge bench of N V Ramana, Sanjiv Khanna* and Krishna Murari, JJ held that the applicable statutory rules providing for voting on no-confidence motion by secret ballot have binding effect. Hence, re-voting or fresh voting, directed on the no-confidence vote in question, in the facts and circumstances of the case, as the same had not been done by secret ballot. Such re-voting, held, must be by way of secret ballot in accordance with the 1966 Rules.

“The principle of secrecy of ballots is an important postulate of constitutional democracy whose aim is the achievement of this goal.”

The Court relied on the judgement in the case of Kuldip Nayar v. Union of India, (2006) 7 SCC 1 and S. Raghbir Singh Gill v. S. Gurcharan Singh Tohra, 1980 Supp SCC 53, observed that “The primary principle and test to be applied by the courts is purity of election, that is, free and fair election. Secrecy of voting is an adjunct to the principle of purity of election.”

“Secrecy is not an absolute principle enshrined in law, but a requirement to subserve the larger public interest of purity of election. Secrecy cannot stand aloof, in isolation or in confrontation to the foundation of free and fair elections.”

Dismissing the review petition filed by Appellant to review it’s 2:1 verdict awarding death sentence in Manoharan v. State, (2020) 5 SCC 782, a 3-judge bench of RF Nariman, Surya Kant* and Sanjiv Khanna,* JJ., held that the dissent by one Judge is not a bar for upholding death penalty.

The Court held that in the present case the appellant misused societal trust and the crime was not a crime a passion but a well crafted crime. The Crime committed by the Appellant were grave and shock the conscience of this Court and society that we cannot commute the sentence and without any doubt it will fall under rarest of the rare category.

“It was not in the spur of the moment or a crime of passion; but craftily planned, meticulously executed and with multiple opportunities to cease and desist.”

Agreeing with the Justice Surya Kant on the dismissal of review petition and upholding of the conviction of the accused, Justice Khanna held that there is no good ground and reasons to review his observations and findings in the minority judgment.

Considering the serious nature of the crime involving rape and murder of 2 children in Manoharan v. State, (2019) 7 SCC 716, a 3-judge bench comprising of RF Nariman,* Surya Kant and Sanjiv Khanna,** JJ., with 2:1 verdict upheld the death sentence confirmed by the High Court.

“There can be no doubt that today’s judgment is in keeping with the legislature’s realisation that such crimes are on the rise and must be dealt with severely.”

Justice Khanna, while dissenting only on the issue of upholding death sentence confirmed by the High Court, held that the present case does not fall under the category of ‘rarest of rare’ case but would fall within the special category of cases, where the appellant should be directed to suffer sentence for life.

• Did You Know? The Collegium headed by the then Chief Justice of India, Ranjan Gogoi recommended the elevation of Justice Maheshwari and Justice Khanna after reviewing its earlier deliberations held on 12-12-2018, in which Delhi High Court Chief Justice Rajendra Menon and Rajasthan High Court Chief Justice Pradeep Nandrajog were said to have been considered for elevation.²³

Notable Judgements at High Court

In Kailash Gahlot v. Election Commission of India, 2018 SCC OnLine Del 8125, the Division bench of Sanjiv Khanna* and Chander Shekhar, JJ while deciding the validity of disqualification of 20 AAP MLAs for holding offices of profit as ‘parliamentary secretaries’ in the Delhi government by President Ram Nath Kovind, set aside the disqualification on the ground of failing to comply with the principles of natural justice by the Election Commission as the MLAs were not given an oral hearing or an opportunity of being heard.

In ATV Projects (India) Ltd. v. Union of India, 2017 SCC OnLine Del 12136, the Division Bench of Sanjiv Khanna and Prathiba M. Singh*, JJ., while upholding the validity of Section 4(b) of the Sick Industrial Companies (Special Provisions) Repeal Act, 2003, observed that

“…once a law is repealed and a new legislation has been put in its place, it is not open for anyone to contend that it should be continued to be governed by the old enactment, except where actions under the existing laws had concluded. The applicability of the repealed legislation is only to the extent as provided in the Savings clause and nothing more.”

In Wing Commander Arvind Kumar v. Directorate General, BSF, 2017 SCC OnLine Del 10880, a Division Bench comprising of Sanjiv Khanna* and Navin Chawla, JJ, ruled in favour of an Air Force officer on deputation to the BSF Air Wing, enforcing the rule laid down in Group Captain Joe Emmanuel Stephen v. Directorate General of BSF, 2013 SCC OnLine Del 2472, that there cannot be two different pay scales, one applicable to deputationists and the other to the officer of the parent cadre/department when both are performing identical and same duties.

While deciding a petition challenging the validity of an order dated 09-07-2010 passed by the Ministry of Finance dismissing its revision application, dealt with a very important question i.e. whether the High Court of Delhi can issue a writ against a person or authority not located within its territories, simply because the quasi judicial tribunal which passed the impugned order is located within the territorial jurisdiction of the Delhi High Court in Sterling Agro Industries Ltd. v. Union of India, 2011 SCC OnLine Del 3162, a 5-judge bench of Dipak Misra*, CJ and Vikramajit Sen, A.K. Sikri, Sanjiv Khanna and Manmohan, JJ., held that an order of the appellate authority constitutes a part of cause of action to make the writ petition maintainable in the High Court within whose jurisdiction the appellate authority is situated but, the same may not be the singular factor to compel the High Court to decide the matter on merits. The High Court may refuse to exercise its discretionary jurisdiction by invoking the doctrine of forum conveniens.

“The principle of forum conveniens in its ambit and sweep encapsulates the concept that a cause of action arising within the jurisdiction of the Court would not itself constitute to be the determining factor compelling the Court to entertain the matter. While exercising jurisdiction under Articles 226 and 227 of the Constitution of India, the Court cannot be totally oblivious of the concept of forum conveniens.”

While disposing of a petition that demanded implementation of the tariff order passed by the Delhi Electricity Regulatory Commission (DERC) in Nand Kishore Garg v. Govt. (NCT of Delhi), 2011 SCC OnLine Del 2366, a division bench of Dipak Misra*, CJ., and Sanjiv Khanna, J., directed the Commission to proceed afresh by following the due procedure and do the needful. The Court observed that,

“The commission under the 2003 Act is required to deal with the aspect of tariff determination with intellectual integrity, transparent functionalism and normative objectivity and not act in a manner by which its functioning invite doubt with regard to its credibility.”

The Court reprimanded the Delhi government for “unjustifiably intruding and encroaching on the functions of the commission by interdicting”.

While deciding the writ petition challenging the disclosure on grounds of infringement of the right to privacy in Rajinder Jaina v. Central Information Commission, 2009 SCC OnLine Del 3511, a single-judge bench of Sanjiv Khanna*, J., held that the information was already existed in the public domain therefore no claims as to privacy could be made. The Court applied the ratio laid down in Raj Gopal v. State of A.P., (1994) 6 SCC 632, whereby the Court held that once a matter becomes an issue of public record, no privacy can be claimed for it.

While dealing with yet another case related to refusal of the Central Information Commission to divulge information under the Right to Information Act, 2005 and involving an interpretation of S. 8(1)(i) in Union of India v. Central Information Commission, 2009 SCC OnLine Del 3876, a single-judge bench of Sanjiv Khanna*, J., held that the purpose of the proviso is only to clarify that while deciding the question of larger public interest i.e., the question of balance between ‘public interest in form of right to privacy’ and ‘public interest in access to information’ is to be balanced.

“The proviso is a guiding factor and not a substantive provision which overrides Section 8(1)(j) of the RTI Act. It does not undo or rewrite Section 8(1)(j) of the RTI Act and does not itself create any new right.”

Views and Initiatives

• Did You Know? On 07-04-2025, in a significant stride toward cross-border judicial cooperation, Justice Sanjiv Khanna as Chief Justice of India signed of a Memorandum of Understanding (MoU) with the Supreme Court of Nepal. The MoU aims to institutionalize a partnership that spans beyond diplomatic protocol — offering a framework for judicial exchanges, joint research, training initiatives, and knowledge-sharing programs.²⁴

Mediation

Justice Sanjiv Khanna, while speaking at the inaugural National Mediation Conference 2025,²⁵ made a powerful case for institutionalising mediation as a primary tool for dispute resolution in India and called Mediation a “wiser form of Justice”. He highlighted mediation as an “effective and wise alternative” to conventional litigation, pointing to its potential to resolve disputes in a manner that is both humane and enduring.

“Our goal must be to show every litigant, every citizen, every businessman, every person, that mediation is not a lesser form of justice but a wiser form of it… Court litigation and adjudication are, in a way, grim and shallow. At times, the root cause remains unaddressed and the ailment and bane remain. The relationships are strained, if not broken. There is a winner, there is a loser,”

Role of the Judiciary in India²⁶

Speaking at a commemorative event “Celebrating 75 Years of the Constitution of India,” hosted by the Supreme Court Advocates-on-Record Association (SCAORA), Justice Sanjiv Khanna on 26-03-2025, underlined the judiciary’s foundational role in India’s democratic framework and the unique relationship it enjoys with the people of India. He elaborated on how the Courts have become the first refuge for citizens to challenge not only administrative decisions but even the constitutional validity of legislation. He further added that in a democracy where the rule of law reigns supreme, the judiciary’s openness to hearing matters from all strata of society is a testament to its accessibility.

“What makes the judiciary unique is our direct connect with the people… The most easy access which the people have is the access to the judiciary in any of the three institutions… It was the judiciary where anybody could raise any grievance and ask for explanation, even against the state and citizens could approach the courts challenging the constitutional vires of the legislation.”

Lawyers’ vital role in Judiciary²⁷

On Constitution Day, November 26, Justice Sanjiv Khanna, while addressing at an event organised by the Supreme Court Bar Association, delivered a message that underscored the foundational role of lawyers in the Indian legal system, noted that “the better the bar, the better the judges,” in capturing the essence of the interdependence between the bench and the bar. He emphasised that although judges in robes are the visible face of the judiciary, the institution is equally represented by lawyers who argue, interpret, and shape the law from the other side of the courtroom. He said that “you are as much members of the judiciary as judges.”

Justice Khanna made it clear that a functional adjudicatory system in India cannot be imagined without the active engagement of the bar. He called for greater collaboration between judges and lawyers to strengthen justice delivery, expressing his belief in mutual respect and cooperation as guiding principles.

Reforms to support the Legal Community²⁸

Acknowledging the practical challenges faced by lawyers, Justice Khanna announced several steps aimed at improving their day-to-day functioning. Among the key initiatives was the reintroduction of physical cause lists—schedules of cases to be heard—outside courtrooms, responding to longstanding demands from members of the bar.

He also spoke of upgrades to Court infrastructure, including improved Wi-Fi connectivity and the installation of additional routers, which will make it easier for lawyers to work within court premises. Importantly, he noted that lawyers would no longer be required to generate OTP pins daily, a small but significant step towards streamlining their workflow.

Addressing concerns related to adjournment requests, Justice Khanna took a firm yet reasoned position and said that “I’ve looked at the data; it won’t be possible for us to go back to the earlier system. That may be counterproductive.” He explained that the Supreme Court had seen a steep decline in adjournment applications—from about 100 per day to around 150 per month. Over recent months, about 1,400 such applications were received, reflecting a significant drop. The change, he suggested, is fostering a more efficient judicial process.

Legal assistance for juveniles in prisons

In a landmark initiative²⁹ to commemorate the 75th year of India as a Republic, Justice Sanjiv Khanna, Judge of the Supreme Court of India and Executive Chairman of National Legal Services Authority (NALSA), launched a Pan-India campaign titled “Restoring the Youth”, nation-wide drive, which ran from January 25 to February 27, 2024, sought to identify prisoners who were juveniles at the time of their alleged offenses and to ensure they receive the legal recognition and protection due to them under the Juvenile Justice framework. Justice Khanna said that

“Criminals are made by circumstances. No one is born a criminal. The path towards criminality is often a result and consequence of experiences and circumstances mostly shaped by neglect, external influences or lack of guidance.”

Legal Aid³⁰

In a landmark initiative, a two-day conference focused on advancing people-centric justice and strengthening the role of legal aid in building resilient justice systems, organising by National Legal Services Authority (NALSA) with support from the Government of India and in partnership with the International Legal Foundation (ILF), UNDP, and UNICEF, Justice Sanjiv Khanna emphasised that legal aid must be seen beyond its conventional understanding as assistance for the indigent. He said that “Legal aid has a functional role in strengthening the justice system … It empowers individuals to participate and engage with public institutions and become active and equal stakeholders.”

Justice Khanna underlined that the Constitution of India places a solemn obligation on the State to provide free legal aid to ensure access to justice for all and stated that the Legal Services Authorities Act, 1987, serves as the foundation upon which India’s legal aid structure and outreach are built.

Legacy

Justice Sanjiv Khanna has established himself as a towering figure in the Indian judiciary- a man whose reputation for meticulousness, independence, and principled conduct has left an indelible mark on the nation’s legal landscape. Colleagues often describe him as a no-nonsense jurist who does not shy away from expressing contrarian opinions, a trait that underscores his unwavering commitment to judicial transparency and fairness.

His judgments reflect a deep-seated conviction that the judiciary must act not only as the arbiter of law but also as a guardian of democratic values and individual rights. In doing so, he carries forward the legacy of integrity and courage that was championed by his esteemed predecessor, Justice H.R. Khanna, nearly half a century ago.

As he lays down the gavel, the Indian judiciary salutes him not just as a Chief Justice, but as an expectational human being. His legacy will resonate in courtrooms, classrooms, and constitutional discourse for years to come.

* Judge who has penned the judgment.

** Judge who has penned the dissenting opinion

*** Judge who has penned a concurring opinion.