"Finality Of Judicial Verdicts Fundamental To Rule Of Law": Supreme Court Rejects Plea To Modify Bail Condition Of Murder Accused
The Apex Court reiterated that sanctity and conclusiveness of judicial orders ensure the resolution of disputes and maintain public confidence in the justice delivery system, holding that any re-opening of settled issues merely because a later view appears preferable would undermine Article 141.
Justice Dipankar Datta, Justice Augustine George Masih, Supreme Court
The Supreme Court has held that finality of judicial decisions is an essential element of the rule of law and refused to modify a condition restricting the movement of an accused who was granted bail in a pending murder trial in West Bengal.
The Court observed that relaxing the condition would dilute the very basis on which bail had been allowed.
The Apex Court was hearing an application filed by the appellant seeking modification of the earlier bail order of the Supreme Court in a criminal appeal arising out of charges of conspiracy and murder, along with an application for cancellation of bail filed by the brother of the deceased.
A Bench comprising Justice Dipankar Datta and Justice Augustine George Masih, while rejecting the application, stated that “it is fundamental to the rule of law to maintain the sanctity and finality of judicial verdicts. Judicial orders which determine issues arising between the parties to the lis bind them and its conclusive nature ensures resolution of disputes so that justice is served. The strength of judicial power lies less in the hope of perfection and more in the confidence that decisions, once made, are settled”.
While making these observations, the Bench further clarified that “if any modification of such condition is made now and thereby the stringency relaxed, that would not only amount to overstepping the order of this Court granting bail but would send a wrong message of this Court being unconcerned with the principle of finality of judicial decisions.”
Senior Advocate Vikas Singh represented the appellant, while Senior Advocates P.S. Patwalia and Shadan Farasat represented the respondents.
Background
The appellant had been facing trial along with several co-accused for offences including murder, criminal conspiracy and offences under the Arms Act, arising from an incident of October 2019. He remained in custody for more than five years while the trial progressed.
During the course of proceedings before the High Court and Supreme Court, multiple bail applications were rejected. Subsequently, on 3 January 2025, a coordinate Bench of the Supreme Court granted bail subject to stringent conditions, including a direction that the appellant remain confined to the city of Kolkata and mark attendance daily.
Not satisfied with this restriction, the appellant approached the Supreme Court seeking the removal of the condition requiring him to remain in Kolkata. Meanwhile, the deceased’s brother filed an application seeking cancellation of bail, alleging misuse of liberty.
Both applications were heard together in the present proceedings.
Court’s Observation
The Supreme Court, at the outset, took note that a previous application for modification was rejected by the bench presided over by Justice A.S. Oka and that the present application was filed a couple of months after he demitted office and found it to "be an attempt to take a chance because of the changed scenario."
The Bench stressed that "the prospect of opening up a further round of challenge before a succeeding bench, hoping that a change in composition will yield a different outcome, would undermine this Court’s authority and the value of its pronouncements".
In that backdrop, the Apex Court examined the doctrinal importance of finality attached to judicial orders and cautioned against attempts to reopen matters already adjudicated. The Bench observed that “it is fundamental to the rule of law to maintain the sanctity and finality of judicial verdicts” and that judicial conclusive determinations bind parties, prevent endless litigation and uphold public confidence.
Referring to Article 141, the Court explained that a pronouncement of law by the Supreme Court must settle the controversy and be followed by all courts. It cautioned that reopening cases in hope of a different outcome based on changing Bench composition “would undermine this Court’s authority and the value of its pronouncements.”
The Bench noted its concern over a “growing trend” of settled verdicts being sought to be revisited and emphasised that such attempts weaken consistency in legal interpretation. Quoting Associate Justice of the U.S. Supreme Court, Robert Jackson, the Court reiterated that “we are not final because we are infallible, but we are infallible only because we are final.”
“Judicial discipline, propriety and comity, which are also inseparable parts of a just and proper decision-making process, demand that a subsequent bench of different combination defers to the view expressed by the earlier bench, unless there is something so grossly erroneous on the face of the record or palpably wrong that it necessitates a re-look in exercise of inherent jurisdiction either by a review petition or through a curative petition”, the Bench stated.
On the specific prayer for modification of the bail condition, the Court held that allowing relaxed movement would defeat the basis on which the concession of bail was granted. The earlier Bench had balanced the competing considerations of long incarceration and the seriousness of the allegation while imposing strict territorial limits. In the absence of any significant change in circumstances, the condition could not be diluted.
The Court further observed that the appellant continues to receive official security cover in his home district. Given this context and the stage of the criminal trial, the Bench considered it appropriate that he remain in Kolkata until completion of the proceedings.
Regarding the prayer for cancellation of bail, the Court noted the concerns raised but held that there was no conclusive material to establish breach of conditions or misuse of liberty. Therefore, cancellation of bail would not serve any useful purpose at the current stage of the trial.
The Court reiterated that judicial discipline and propriety require deference to earlier decisions unless there exists gross error, which must be addressed only through review or curative jurisdiction.
Conclusion
The Supreme Court dismissed both the application seeking cancellation of bail and the request to modify the bail condition requiring the appellant to remain confined to Kolkata.
The Court directed the Sessions Court to proceed with the remaining trial expeditiously in accordance with the law.
Cause Title: Sk. Md. Anisur Rahaman v. The State of West Bengal & Anr. (Neutral Citation: 2025 INSC 1360)
Appearances
Petitioner: Senior Advocate Vikas Singh
Respondents: Senior Advocates P.S. Patwalia and Shadan Farasat
