Summary and Analysis of M/s Shikhar Chemicals Vs State Of Uttar Pradesh & Anr

1. Heading of the Judgment

M/S Shikhar Chemicals vs State of Uttar Pradesh & Anr.
(Reported as 2025 INSC 945)
Decided on 8th August 2025

Citation: M/S Shikhar Chemicals vs State of Uttar Pradesh & Anr., (2025) INSC 945.

(Special Leave Petition (Crl.) No. 11445 of 2025)

2. Related Laws and Provisions

• Constitution of India, Article 136: Appellate jurisdiction of the Supreme Court (special leave petitions).

• Judicial Precedents: Reference to Rikhab Birani & Anr. vs State of Uttar Pradesh & Anr. (2025 INSC 512).

• Institutional Authority: Role of High Court Chief Justices as "master of the roster" (administrative control over case assignments).

3. Basic Judgment Details

• Parties:
  Petitioner: M/S Shikhar Chemicals.
  Respondents: State of Uttar Pradesh & Another.

• Bench: Justices J.B. Pardiwala and R. Mahadevan.

• Procedural History:
  Supreme Court’s earlier order (4th August 2025) set aside an Allahabad High Court judgment and remanded the case for fresh consideration.
  Directions were issued in Paragraphs 25–26 restricting a specific High Court judge from handling criminal cases.

• Trigger for Reconsideration: The Chief Justice of India (CJI) requested a review of these directions via an undated letter.

4. Explanation of the Judgment

Background and Initial Directions (4th August 2025 Order)

• The Supreme Court partially allowed the petition, quashed the Allahabad High Court’s order, and directed a fresh hearing by a different judge (Paragraphs 22–23).

• In Paragraphs 25–26, the Court directed:
  The concerned High Court judge must sit in a Division Bench with a senior judge.
  The judge should not handle any criminal cases until retirement.

• Reason for Strict Measures (Paragraph 27):
  The Supreme Court noted the challenged order was not an isolated error. Multiple "erroneous orders" by the same judge had been observed over time, threatening institutional dignity.

Reconsideration and Modification (8th August 2025 Order)

• The Supreme Court deleted Paragraphs 25–26 from its 4th August order, respecting the CJI’s written request (Paragraph 7).

• Clarification on Intent (Paragraphs 4–6):
  The directions were never meant to embarrass the judge but to protect the judiciary’s credibility.
  High Courts are the "final court" for 90% of litigants; irrational orders undermine public trust in justice delivery.

• Role of High Court Chief Justice (Paragraphs 8–9):
  The Allahabad High Court’s Chief Justice (as "master of the roster") must independently address the issue.
  The Supreme Court retains authority to intervene in institutional concerns affecting the rule of law.

Broader Judicial Concerns (Paragraphs 10–12)

• Reference to Rikhab Birani vs State of UP (2025 INSC 512) was made, where costs were imposed on Uttar Pradesh for misusing criminal proceedings in civil disputes.

• Emphasis on Institutional Integrity:
  High Courts must avoid "perverse and unjust orders" (Paragraph 11).
  Judges must uphold the rule of law diligently to preserve the justice system’s credibility (Paragraph 12).

Final Disposition

• The Special Leave Petition was disposed of (Paragraph 13).

• A copy of the order was to be sent to the Allahabad High Court’s Chief Justice (Paragraph 14).

Key Takeaways:

1. The Supreme Court balances judicial accountability with institutional respect.

2. Directions restricting a judge’s work were withdrawn, but concerns over "erroneous orders" were reiterated.

3. High Courts are urged to self-correct to maintain public trust.

4. The ruling underscores Article 136’s role in safeguarding judicial standards.