Samarjeet Chatterjee vs. Secretary

Court:Supreme Court of India
Judge:Hon'ble Bela M. Trivedi
Case Status:Disposed
Order Date:16 Apr 2025
CNR:SCIN010136452025

AI Summary

The Supreme Court has dismissed a Special Leave Petition filed against a High Court order in a Public Interest Litigation, labeling the SLP as 'vexatious' and imposing a cost of Rs. 25,000 on the petitioner. This ruling underscores the judiciary's firm stance against frivolous litigation, ensuring judicial resources are not misused.

Ratio Decidendi:
A Special Leave Petition, if found to be vexatious in nature by the Supreme Court, is liable to be dismissed with costs.

Case Identifiers

Primary Case No:Diary No(s). 13645/2025
Case Type:Special Leave Petition (Civil)
Case Sub-Type:SLP - Public Interest Litigation (Vexatious)
Secondary Case Numbers:10674/2025
Order Date:2025-04-16
Filing Year:2025
Court:Supreme Court Of India
Bench:Division Bench
Judges:Hon'ble Bela M. Trivedi, Hon'ble Prasanna B. Varale

Petitioner's Counsel

Mr. JN Singh
Advocate - Appeared
Mr. Shashank Shekhar
Advocate on Record - Appeared

Advocates on Record

Shashank Shekhar

eCourtsIndia AITM

Brief Facts Summary

Samarjeet Chatterjee filed a Special Leave Petition (Civil) in the Supreme Court challenging a final judgment and order dated August 9, 2024, passed by the High Court of Judicature at Bombay at Nagpur in CACAO No. 1039/2023, which arose from Public Interest Litigation No. 06 of 2023. The petitioner also filed interlocutory applications for condonation of delay and exemption from filing a certified copy of the impugned judgment. The Supreme Court condoned the delay but ultimately dismissed the Special Leave Petition, finding it to be vexatious in nature, and imposed a cost of Rs. 25,000/- on the petitioner.

Timeline of Events

2023

Public Interest Litigation No. 06 of 2023 was filed.

2024-08-09

High Court of Judicature at Bombay at Nagpur passed an order in CACAO No. 1039/2023 in PIL No. 06 of 2023.

2025-03-13

Special Leave Petition (Civil) Diary No. 13645/2025 was filed in the Supreme Court.

2025-04-03

Interlocutory Applications for Condonation of Delay and Exemption from filing C/C of the impugned judgment were filed.

2025-04-16

The Supreme Court heard the matter, condoned the delay, and dismissed the Special Leave Petition with costs.

Key Factual Findings

The order impugned is the one passed by the High Court in CACAO No. 1039/2023 in Public Interest Litigation No. 06 of 2023 on 09.08.2024.

Source: Current Court Finding/Recited from Lower Court Judgment

The present special leave petition is vexatious in nature.

Source: Current Court Finding

Primary Legal Issues

1.Dismissal of Special Leave Petition on grounds of being vexatious
2.Imposition of costs for filing frivolous litigation

Secondary Legal Issues

1.Condonation of delay in filing a Special Leave Petition

Petitioner's Arguments

The order indicates that the learned counsel for the petitioner was heard, presumably presenting arguments for the admission of the Special Leave Petition and against it being deemed vexatious. Specific points of argument are not detailed in the order.

Respondent's Arguments

The order states 'UPON hearing the counsel the Court made the following O R D E R', implying that respondents' counsel may have been present, but no specific arguments made by them are summarized in the order.

Court's Reasoning

The Supreme Court condoned the delay in filing the Special Leave Petition. However, upon hearing the counsel for the petitioner, the Court found the Special Leave Petition to be 'vexatious in nature'. Due to this finding, the Court concluded that the petition deserved to be dismissed and proceeded to do so with costs.

Judicial Philosophy Indicators:
  • Emphasis on curbing vexatious litigation
  • Judicial efficiency and resource conservation
Order Nature:Procedural, Final
Disposition Status:Disposed
Disposition Outcome:Dismissed

Impugned Orders

High Court of Judicature at Bombay at Nagpur
Case: CACAO No. 1039/2023 in Public Interest Litigation No. 06 of 2023
Date: 2024-08-09

Specific Directions

  1. 1.Delay condoned.
  2. 2.The special leave petition is dismissed as vexatious in nature.
  3. 3.A cost of Rs.25,000/- is to be deposited by the petitioner before Supreme Court Advocates on Record Association (SCAORA) within two weeks from today.
  4. 4.Pending application(s), if any, shall stand closed.

Precedential Assessment

Persuasive (Procedural)

This order reinforces the Supreme Court's established practice of dismissing Special Leave Petitions found to be vexatious and imposing costs to deter frivolous litigation. While not a landmark ruling establishing a new legal principle, it serves as a strong reminder of judicial policy against abuse of process.

Tips for Legal Practice

1.Counsel must thoroughly assess the merits of a Special Leave Petition before filing, especially when challenging orders related to Public Interest Litigations, to avoid it being deemed 'vexatious' and dismissed with costs.
2.Be aware that the Supreme Court is actively imposing costs on litigants who file frivolous or vexatious petitions, signaling a stricter approach to managing judicial docket.
3.Even if delay in filing is condoned, the underlying merits and nature of the petition are paramount for its survival at the admission stage in the Supreme Court.

Legal Tags

Supreme Court dismissal vexatious Special Leave PetitionCosts imposed frivolous litigation IndiaChallenging High Court Public Interest Litigation orderCondonation of delay in Supreme Court procedureJudicial discretion on admitting Special Leave Petitions

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:

Case Registered

Listed On:

16 Apr 2025

Original Order Copy

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Order Text

ITEM NO.51 COURT NO.9 SECTION IX

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

SPECIAL LEAVE PETITION (CIVIL) Diary No(s). 13645/2025

[Arising out of impugned final judgment and order dated 09-08-2024 in CACAO No. 1039/2023 in Public Interest Litigation No. 06 of 2023 passed by the High Court of Judicature at Bombay at Nagpur]

SAMARJEET CHATTERJEE Petitioner(s)

VERSUS

SECRETARY & ORS. Respondent(s)

IA No. 84744/2025 - CONDONATION OF DELAY IN FILING IA No. 84742/2025 - EXEMPTION FROM FILING C/C OF THE IMPUGNED JUDGMENT

Date : 16-04-2025 This matter was called on for hearing today.

CORAM :

HON'BLE MS. JUSTICE BELA M. TRIVEDI HON'BLE MR. JUSTICE PRASANNA B. VARALE

For Petitioner(s) :

Mr. JN Singh, Adv. Mr. Shashank Shekhar, AOR

For Respondent(s) :

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

1. Delay condoned.

of 2023 on 09.08.2024

2. Heard learned counsel appearing for the petitioner.

3. The order impugned and which is challenged before this Court, is the order passed by the High Court in CACAO No. 1039/2023 in Public Interest Litigation No. 06

4. The present special leave petition being vexatious in nature, the same deserves to be dismissed and is accordingly, dismissed with a cost of Rs.25,000/- to be deposited by the petitioner before Supreme Court Advocates on Record Association (SCAORA) within two weeks from today.

5. Pending application(s), if any, shall stand closed.

(NISHA KHULBEY) (MAMTA RAWAT) SENIOR PERSONAL ASSISTANT ASSISTANT REGISTRAR