The Supreme Court recently dealt with an
unusual situation where a trial court judge declined to exercise jurisdiction
on the ground that the timeline fixed by the apex court for disposing of a case
had already expired. The bench, comprising Justices Pankaj Mithal and Prasanna
B. Varale, strongly disapproved of this approach, emphasizing that the expiry
of a time limit set by the Court does not divest a trial judge of jurisdiction.
The matter arose in connection with a
miscellaneous application filed in a criminal appeal. Earlier, by an order
dated January 18, 2024, the Supreme Court had directed the Judicial Magistrate,
4th Court at Alipore, South 24 Parganas, to dispose of proceedings in Case No.
AC-2053/2017 within a period of six weeks. When the trial court judge was
unable to complete the hearing and deliver a decision within the prescribed
timeframe, he passed an order on March 19, 2024. In that order, the judge
recorded that since the matter had not been disposed of within the stipulated
period, he had ceased to have jurisdiction and could not proceed further.
The Supreme Court expressed its displeasure
over this reasoning, observing that the manner in which the trial judge dealt
with the situation was deeply problematic. According to the bench, if the judge
found himself unable to conclude the proceedings within the fixed period, the
correct course of action would have been to seek an extension of time from the
Supreme Court. What was not permissible, the Court clarified, was for the judge
to declare that jurisdiction was lost merely because the deadline had lapsed.
The bench noted that time limits imposed by
the Supreme Court are designed to expedite proceedings and ensure that cases do
not remain pending indefinitely. However, such directions do not curtail the
fundamental jurisdiction of a trial court to hear and decide matters placed
before it. A failure to adhere to the timeline cannot be equated with a
forfeiture of authority. The Supreme Court underscored that judges are expected
to continue with proceedings unless specifically restrained, and administrative
difficulties or delays do not absolve them of this responsibility.
Finding the conduct of the trial judge
highly unusual, the Supreme Court directed the District Judge concerned to seek
an explanation. The District Judge was asked to call upon the trial judge to
set out the reasons and circumstances that led him to record that he had ceased
to have jurisdiction in the matter. The Supreme Court further instructed that
the explanation should be forwarded to it within one month for consideration.
The Court’s intervention makes it clear
that judicial officers cannot abdicate responsibility on the basis of
procedural timelines fixed for efficiency. While delays may sometimes be
unavoidable, the appropriate step is to approach the higher court for an
extension, not to withdraw from adjudication altogether. The ruling thus
reinforces the principle that the jurisdiction of a trial court flows from law
and cannot be curtailed by the expiry of a deadline, unless expressly withdrawn
by a competent judicial order.