Summary and Analysis of Siddharth vs State of Madhya Pradesh & Others 2025 INSC 1082

1. Heading of the Judgment

Siddharth vs. State of Madhya Pradesh & Others
Citation: 2025 INSC 1082
Court: Supreme Court of India
Decided on: September 09, 2025
Coram: Justice Vikram Nath and Justice Sandeep Mehta

2. Related Laws and Legal Principles

While the judgment does not explicitly cite specific sections of a statute, it deals with and reinforces several fundamental legal principles:

• Professional Ethics for Advocates: The case centers on the duties of an advocate under the standards of professional conduct expected by the courts, particularly the duty of candor and the obligation not to mislead the court.

• Inherent Powers of the Court: The Supreme Court exercised its inherent power to expunge remarks made by a High Court against an advocate. This power is used to prevent injustice and protect an individual's reputation from unwarranted aspersions that are not necessary for the decision of a case.

• Principles of Natural Justice: The judgment implicitly touches upon the principle that adverse remarks affecting one's reputation should not be made without giving the person a proper opportunity to be heard.

• Doctrine of Bona Fide Mistake: The Court considered whether the advocate's conduct was a deliberate attempt to mislead or a genuine, unintentional error.

3. Basic Judgment Details

• Parties:
  Appellant: Siddharth (An Advocate)
  Respondents: State of Madhya Pradesh & Others

• Origin: The appeal arose from a final order dated April 06, 2022, passed by the High Court of Madhya Pradesh at Jabalpur in Writ Petition No. 6228 of 2022, and a subsequent order dated January 05, 2024, dismissing the appellant's application to modify that final order.

• Nature of Case: Civil Appeal originating from a Special Leave Petition (Civil) seeking expunction of adverse remarks made against an advocate in a High Court order.

• Final Outcome: The Supreme Court allowed the appeal, expunged the adverse remarks against the appellant-advocate, and set aside the High Court's order dismissing his application for modification.

4. Explanation of the Judgment

Background and Issue Before the Supreme Court

The appellant, Siddharth Gupta, is an advocate who had filed and argued Writ Petition No. 6228 of 2022 before the High Court of Madhya Pradesh on behalf of his clients. While dismissing the writ petition, the Division Bench of the High Court made strong adverse observations against the appellant's professional conduct in paragraph 7 of its order.

The High Court remarked that the appellant's conduct "borders on professional impropriety." The specific allegation was that while relying on a Supreme Court judgment (Index Medical College Hospital & Research Centre), the appellant failed to inform the High Court that a related judgment by a Coordinate Bench of the same High Court (Arushi Mahant & Ors. vs. State of M.P.), which had upheld the constitutional validity of a rule, had not been challenged further and thus remained good law. The High Court felt that the appellant gave the impression that the entire batch of cases, including Arushi Mahant, had been overturned by the Supreme Court, which was not the case. The court recorded its "displeasure" against the appellant.

Aggrieved by these remarks that cast a serious aspersion on his professional integrity, the appellant filed an application before the High Court seeking their expunction. When this application was dismissed, he approached the Supreme Court.

Submissions and the Supreme Court's Reasoning

Before the Supreme Court, senior counsel for the appellant offered an unconditional apology for any mistake committed during the arguments. Crucially, it was argued that the appellant was not involved as a counsel in the connected Arushi Mahant case. Therefore, any omission to disclose the specific status of that particular judgment was a bona fide (good faith) mistake and not an intentional act to mislead the court.

The Supreme Court, after considering the submissions and the facts, agreed with the appellant's position. The Court noted the following key points in its reasoning:

1. Avoidable Remarks: The Court felt that in the specific facts and circumstances of the case, the severe adverse observations against the advocate "could have been avoided."

2. Bona Fide Omission: The Court accepted the appellant's core defense that since he was not the lawyer in the Arushi Mahant case, it was possible that the fact that this specific judgment had not been challenged further may have "bona fide escaped his notice." This established a lack of malicious intent.

3. Protection of Reputation: The Supreme Court routinely expunges remarks that are not essential for deciding the case and can cause permanent damage to an individual's professional reputation, especially when the conduct in question appears to be an unintentional error rather than a deliberate malfeasance.

Supreme Court's Directions and Conclusion

Based on this reasoning, the Supreme Court issued the following directives:

• The adverse observations made in Paragraph 7 of the High Court's order dated April 06, 2022, were expunged to the extent they related to the appellant, Siddharth Gupta.

• Consequently, the High Court's order dated January 05, 2024, which had dismissed the appellant's application for modification/expunction of these remarks, was quashed and set aside.

In-Depth Analysis

This judgment underscores a balanced approach taken by the Supreme Court in matters involving criticism of advocates by judges. The Court acknowledges that judges have the right and duty to comment on conduct that obstructs the administration of justice. However, this power must be exercised with caution and restraint.

The core principle reaffirmed here is that adverse remarks must be proportional and necessary. Before making such remarks, the court should consider:

• Whether the remark is necessary for the decision of the case.

• Whether the person against whom the remark is made was given a fair opportunity to explain.

• Whether the act in question was a deliberate, malicious act or a bona fide error.

By expunging the remarks, the Supreme Court did not dilute the high standard of conduct expected from advocates. Instead, it highlighted that the system should allow for human error without immediately attributing ill intent, thereby protecting an advocate's reputation from being unfairly tarnished for what amounts to a negligent but not malicious omission. This ensures that the relationship between the Bench and the Bar remains based on mutual respect and a shared commitment to justice.