Legal Review and Analysis of Ranjeet Baburao Nimbalkar vs State of Maharashtra & Anr 2025 INSC 1460
Case Synopsis
Ranjeet Baburao Nimbalkar vs State of Maharashtra & Anr., 2025 INSC 1460.
Synopsis: An Administrative Facilitation. The Supreme Court upheld the authority of a High Court Chief Justice to designate regular off-seat sittings under Section 51(3) of the States Reorganisation Act, 1956, ruling that such administrative arrangements aimed at litigant convenience do not constitute the creation of a permanent bench and fall squarely within the Chief Justice's administrative domain.
1. Heading of the judgment
Case Title: Ranjeet Baburao Nimbalkar vs State of Maharashtra & Anr
Citation: 2025 INSC 1460
Court: Supreme Court of India
Judges: Justice Aravind Kumar, Justice N.V. Anjaria
Date of Judgment: December 18, 2025
2. Related laws and sections
Constitution of India: Article 14 (Right to Equality), Article 21 (Right to Life and Personal Liberty), Article 32 (Power to issue writs).
States Reorganisation Act, 1956: Section 51 – Principal seat and other places of sitting of High Courts for new States. The judgment primarily interprets Sub-section (3).
General Clauses Act, 1897: Section 14 (Power to be exercised from time to time).
Precedents Relied Upon:
State of Maharashtra v. Narayan Shamrao Puranik, (1982) 3 SCC 519.
Federation of Bar Associations in Karnataka v. Union of India, (2000) 6 SCC 715.
State of Rajasthan v. Prakash Chand, (1998) 1 SCC 1.
Anita Kushwaha v. Pushap Sudan, (2016) 8 SCC 509.
3. Basic judgment details
Facts of the Case
The petitioner challenged Notification No. P.0108/2025 dated 01.08.2025, issued by the Bombay High Court on its administrative side, appointing Kolhapur as an additional place where its Judges and Division Courts may sit. This decision was taken under Section 51(3) of the States Reorganisation Act, 1956, with the approval of the Governor of Maharashtra. The notification aimed to serve litigants from the districts of Kolhapur, Sangli, Satara, Ratnagiri, and Sindhudurg, who faced hardship due to the distance from the principal seat in Mumbai. The petitioner argued that this effectively created a permanent bench through the "backdoor," bypassing the procedure for establishing permanent benches under Section 51(2), which requires a Presidential order after consultation.
Issues Framed by the Court
The true construction and scope of Section 51(3) of the States Reorganisation Act, 1956.
The extent of the Chief Justice's administrative authority and the necessity of consultation.
The legal effect of past administrative decisions rejecting similar proposals.
The limits of judicial review in matters of judicial administration.
The validity of the challenge under Articles 14 (arbitrariness) and 21 (access to justice) of the Constitution.
Ratio Decidendi (Court's Reasoning)
The Supreme Court dismissed the writ petition, upholding the validity of the notification. The core reasoning is as follows:
On Section 51(3): The Court held that Section 51(3) is an independent, continuing, and residuary power vested in the Chief Justice of a High Court, subject only to the Governor's approval. It is not a temporary or emergency provision. The "non-obstante" clause gives it an overriding effect. The power under Sub-section (3) is distinct from that under Sub-section (2); the former does not create a permanent bench with territorial bifurcation but allows the Chief Justice to organise sittings for the "more convenient transaction of judicial business" without altering the High Court's fundamental structure.
On Chief Justice's Authority & Consultation: The Chief Justice, as the head of the institution, is the primary authority for administrative decisions like organising sittings. While internal consultation is a sound practice, Section 51(3) does not mandate consultation with the Full Court or any specific body as a legal requirement. The only statutory condition is the Governor's approval.
On Past Decisions: Administrative decisions are contextual and not eternally binding. A change in circumstances, such as accumulated demand or improved infrastructure, legitimately warrants a fresh decision. Past rejections do not create an estoppel against a successor Chief Justice.
On Judicial Review: The Court reaffirmed that judicial review of such administrative decisions is limited to examining legality, jurisdiction, bona fides, and the absence of arbitrariness. Courts cannot substitute their own view for that of the competent authority on merits or policy.
On Constitutional Challenges (Articles 14 & 21):
Article 14: The choice of Kolhapur, based on its centrality to a cluster of distant districts, has a rational nexus with the objective of improving access to justice. Article 14 does not demand that all regional demands be met simultaneously.
Article 21: Decentralising High Court sittings to reduce geographical barriers directly furthers the right to access to justice under Article 21. Arguments about resource allocation between higher and district judiciary pertain to policy, not constitutional invalidity.
4. Core principle of the judgment
The Central Issue and the Supreme Court's Address:
The core issue was whether the Chief Justice of a High Court could use the power under Section 51(3) of the States Reorganisation Act, 1956, to establish a long-term or regular sitting at a location other than the principal seat, or whether such an arrangement could only be created as a "permanent bench" under the more formal process of Section 51(2).
The Core of the Judgment: Administrative Flexibility vs. Structural Reform
The Supreme Court drew a definitive line between administrative convenience and structural reconfiguration of a High Court.
Section 51(2) – For Structural Change: This provision is for creating a permanent bench, which involves a territorial bifurcation of the High Court's jurisdiction and confers exclusive jurisdiction on that bench. It is a significant structural step requiring a Presidential order after consultation, ensuring Central Government involvement.
Section 51(3) – For Administrative Facilitation: This provision is a tool for administrative flexibility. It allows the Chief Justice to decide where judges sit to conduct the court's business more conveniently. It does not bifurcate territory or create a new juridical entity. Judges sitting at such a location remain judges of the undivided High Court, subject to the Chief Justice's administrative control. The duration of the sitting is irrelevant to its legal character under this sub-section.
The Court emphatically ruled that using Section 51(3) to hold sittings at a place like Kolhapur regularly, even indefinitely, is legally permissible. It is not a colourable exercise of power to circumvent Section 51(2), as long as no formal territorial jurisdiction is carved out. The judgment reaffirms the primacy of the Chief Justice in the administrative functioning of the High Court and insulates such operational decisions from excessive judicial or executive interference, provided they are taken bona fide and with the Governor's approval.
5. Analysis and interpretation
A. Statutory Interpretation of a Permanent Statute:
The Court interpreted the States Reorganisation Act, 1956, as a permanent framework statute, not a transitory one. Consequently, the powers under Section 51 are living powers capable of being exercised as and when needed. This interpretation, cemented by the precedent in Puranik, allows the judiciary to adapt to evolving demographic and logistical challenges.
B. Constitutional Scheme of Judicial Administration:
The judgment reinforces the constitutional schema of separation of powers in judicial administration. It clarifies the distinct roles:
Union Government (via President): For foundational decisions (principal seat under S.51(1)) and structural changes (permanent benches under S.51(2)).
Chief Justice of High Court: For day-to-day and strategic administrative decisions to ensure efficient justice delivery (sittings under S.51(3)).
This distribution is deliberate and meant to protect the internal autonomy of the High Court.
C. Judicial Restraint in Institutional Management:
The Supreme Court practiced significant judicial restraint. It refused to impose additional procedural mandates (like Full Court consultation) not found in the statute. It distinguished between legal requirements and desirable practices, leaving the finer points of administrative prudence to the wisdom of the institution's head.
6. Final outcome
The Supreme Court dismissed the writ petition. It upheld Notification No. P.0108/2025, declaring that the Chief Justice of the Bombay High Court acted within his statutory powers under Section 51(3) of the States Reorganisation Act, 1956, in appointing Kolhapur as an additional place of sitting. The Court found the decision to be rational, bona fide, and in furtherance of access to justice. It was clarified that the Union Government's power to establish a permanent bench for the region under Section 51(2) remains unaffected.
7. MCQ Questions based on the judgment
Question 1: According to the Supreme Court's judgment in Ranjeet Baburao Nimbalkar vs State of Maharashtra (2025 INSC 1460), what is the primary legal distinction between establishing a sitting under Section 51(3) and a permanent bench under Section 51(2) of the States Reorganisation Act, 1956?
a) The requirement of the Governor's approval.
b) The necessity of a Presidential order.
c) The creation of a territorial bifurcation and exclusive jurisdiction.
d) The mandatory consultation with the Chief Justice.
Question 2: In the aforementioned judgment, the Supreme Court held that the absence of Full Court consultation before issuing the notification for a High Court sitting at Kolhapur?
a) Renders the notification void ab initio.
b) Is a mere procedural irregularity requiring fresh consideration.
c) Is a sound institutional practice but not a statutory mandate under Section 51(3).
d) Violates the principles of natural justice.