Gangasen V. G vs. The Secretary Health Department

Court:Supreme Court of India
Judge:Hon'ble Hon'Ble The Chief Justice
Case Status:Disposed
Order Date:28 Feb 2020
CNR:SCIN010040752020

AI Summary

The Supreme Court of India has dismissed a Special Leave Petition filed by Gangasen V.G., declining to exercise its extraordinary jurisdiction under Article 136 of the Constitution against a Kerala High Court order. This decision effectively upholds the lower court's ruling, marking the end of the legal challenge at the apex court.

Ratio Decidendi:
The Supreme Court will not entertain a Special Leave Petition under Article 136 of the Constitution of India if, in its discretion, it finds no sufficient grounds or exceptional circumstances to exercise its extraordinary jurisdiction.

Case Identifiers

Primary Case No:4468/2020
Case Type:Special Leave Petition (Civil)
Case Sub-Type:SLP - Service Matter
Secondary Case Numbers:4075/2020, SCIN010040752020
Order Date:2020-02-28
Filing Year:2020
Court:Supreme Court of India
Bench:Division Bench
Judges:Hon'ble Dr. Justice D.Y. Chandrachud, Hon'ble Mr. Justice Sanjiv Khanna

Petitioner's Counsel

Mohammed Sadique T.A.
Advocate - Appeared

Advocates on Record

Mohammed Sadique T.A.

eCourtsIndia AITM

Brief Facts Summary

The petitioner, Gangasen V.G., filed a Special Leave Petition (Civil) in the Supreme Court of India, challenging a final judgment and order dated October 29, 2019, passed by the High Court of Kerala at Ernakulam in OPKAT No. 1233/2013. The respondents included the Secretary, Health Department, and others. The petition also included an application for permission to file additional documents, which was disposed of with the main petition.

Timeline of Events

2013

OPKAT No. 1233/2013, the originating case for the impugned order, was filed in the High Court of Kerala.

2019-10-29

High Court of Kerala at Ernakulam passed the impugned final judgment and order in OPKAT No. 1233/2013.

2020-01-31

Special Leave Petition (Civil) filed in the Supreme Court.

2020-02-15

Special Leave Petition (Civil) registered in the Supreme Court.

2020-02-20

Application for permission to file additional documents filed by the petitioner.

2020-02-28

Supreme Court heard the Special Leave Petition and dismissed it.

Key Factual Findings

The Special Leave Petition does not present a suitable case for the exercise of jurisdiction under Article 136 of the Constitution of India.

Source: Current Court Finding

Primary Legal Issues

1.Whether the Supreme Court should exercise its discretionary power under Article 136 of the Constitution of India to entertain the Special Leave Petition challenging the High Court's order.

Questions of Law

The implicit question of law is the scope and exercise of the Supreme Court's extraordinary jurisdiction under Article 136 of the Constitution.

Statutes Applied

Constitution of India
Article 136
The Court considered whether the present case merited the exercise of its discretionary special leave jurisdiction.

Petitioner's Arguments

The petitioner sought special leave to appeal against the impugned judgment of the High Court of Kerala, implying arguments that the High Court's decision was erroneous, legally unsustainable, or involved a question of public importance requiring Supreme Court intervention.

Respondent's Arguments

No arguments were recorded or presented by the respondent side, as the Special Leave Petition was dismissed at the admission stage by the Supreme Court itself.

Court's Reasoning

The Court explicitly stated, 'We are not inclined to entertain the Special Leave Petition under Article 136 of the Constitution of India.' This indicates that the Court, after considering the petition, found no compelling reason, exceptional circumstances, or substantial question of law warranting the exercise of its extraordinary discretionary jurisdiction to hear the appeal.

Judicial Philosophy Indicators:
  • Emphasis on Judicial Discretion
  • Adherence to Jurisdictional Limits
Order Nature:Procedural
Disposition Status:Disposed
Disposition Outcome:Dismissed

Impugned Orders

High Court of Kerala at Ernakulam
Case: OPKAT No. 1233/2013
Date: 2019-10-29

Specific Directions

  1. 1.We are not inclined to entertain the Special Leave Petition under Article 136 of the Constitution of India.
  2. 2.The Special Leave Petition is accordingly dismissed.
  3. 3.Pending application(s), if any, stand disposed of.

Precedential Assessment

Non-Binding (Procedural)

The order is a summary dismissal at the admission stage, indicating the Court found no sufficient ground to entertain the petition, rather than laying down any substantive law or providing detailed reasoning on the merits of the case. Thus, it does not create a binding precedent.

Tips for Legal Practice

1.Advocates must diligently assess whether a case involves a substantial question of law or grave injustice before filing an SLP, as Article 136 is a discretionary remedy, not an automatic right of appeal.
2.A summary dismissal of an SLP at the admission stage indicates that the Supreme Court found no compelling reason to interfere with the lower court's decision, without necessarily pronouncing on the merits.
3.Legal professionals should counsel clients that the Supreme Court's refusal to entertain an SLP finalizes the High Court's order for that specific matter.

Legal Tags

Supreme Court discretionary jurisdiction Article 136 reviewSpecial Leave Petition dismissal without merits analysisChallenging High Court administrative tribunal judgmentFinality of High Court orders post Supreme Court rejectionJudicial discretion in entertaining civil appeals IndiaService matter litigation Supreme Court perspectiveScope of Supreme Court intervention in High Court rulingsProcedural dismissal of SLP by Apex CourtAdmissibility of Special Leave Petitions in IndiaImplications of Supreme Court refusing leave to appeal

Disclaimer: eCourtsIndia (ECI) is not a lawyer and this analysis is generated by ECI AI, it might make mistakes. This is not a legal advice. Please consult with a qualified legal professional for matters requiring legal expertise.

Order Issued After Hearing

Purpose:

FRESH

Before:

Hon'ble Hon'Ble The Chief Justice, Hon'ble Hon'Ble The Chief Justice

Stage:

FRESH (FOR ADMISSION) - CIVIL CASES

Remarks:

Dismissed

Listed On:

28 Feb 2020

In:

Judge

Category:

UNKNOWN

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Order Text

S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS

Petition(s) for Special Leave to Appeal (C) No.4468/2020

(Arising out of impugned final judgment and order dated 29-10-2019 in OPKAT No. 1233/2013 passed by the High Court of Kerala at Ernakulam)

GANGASEN V.G. Petitioner(s)

VERSUS

THE SECRETARY, HEALTH DEPARTMENT & ORS. Respondent(s)

(With appln.(s) for permission to file additional documents)

Date : 28-02-2020 This petition was called on for hearing today.

CORAM :

HON'BLE DR. JUSTICE D.Y. CHANDRACHUD HON'BLE MR. JUSTICE SANJIV KHANNA

For Petitioner(s)

Mr. Mohammed Sadique T.A., AOR

For Respondent(s)

UPON hearing the counsel the Court made the following O R D E R

We are not inclined to entertain the Special Leave Petition under Article 136 of the Constitution of India.

The Special Leave Petition is accordingly dismissed.

Pending application(s), if any, stand disposed of.

(Chetan Kumar) (Saroj Kumari Gaur) A.R.-cum-P.S. Court Master