Saturday 10 September 2016

THE PETITION BY NATIONAL LAWYER'S CAMPAIGN FOR FAIR SELECTION OF JUDGES IN SUPREME COURT OF INDIA

IN THE SUPREME COURT OF INDIA
CIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO. 704 OF 2016


IN THE MATTER OF

National Lawyers’ Campaign For
Judicial Transparency And Reforms 
and Others                                                               …PETITIONERS
Versus
              The Supreme Court of India and Another                …RESPONDENTS

SYNOPSIS AND LIST OF DATES

          The first petitioner is a registered society working for the betterment of judicial system and is approaching this court as a representative of it's member lawyers and their litigants, where they have to face the court across the length and breadth of the nation as a matter of profession. The first petitioner is registered organization of lawyers, having branches across the nation which is functioning for the transparency, accountability and reforms in judiciary.  The second petitioner is an ordinary lawyer, practicing in various courts, including the Supreme Court of India and is a member of Supreme Court Bar Association. The instant Writ Petition is filed for the enforcement of the fundamental rights as enshrined in Articles 14,15,16,17 & 19 and even 21 of the Constitution.
The 1st Petitioner was formed since it was felt by the ordinary lawyers that the collegium system of appointment of Judges to the higher judiciary, one which is nothing but rewriting of the Constitution, to keep political interference in judicial appointments completely at bay, so too to appoint the very best and most deserving Judges, has totally failed and it has, instead, meant monopolizing the august office of Judges of the higher judiciary by the kith and kin of sitting and former Judges of the Supreme Court and High Courts, their juniors, celebrated lawyers, Chief Ministers, Governors et al, and a few first generation lawyers who are all politically connected or are close to big industrial houses. 
The fact that there is no effective mechanism whatsoever to address complaints of misconduct and malpractice on the part of Judges of the higher judiciary; that the Judicial Standards and Accountability Bill, 2012 introduced in the Parliament remaining in cold storage; that the Hon'ble Judges were not forthcoming to welcome the said Bill, nay, they were opposed to the same, made the concern of the ordinary lawyers further aggravated.
That nothing could be expected from the political parties and the political leadership to bring in greater transparency and accountability in the higher judiciary is a fact which cannot be wished away.  These days, challenge to the constitutionality of an Act of Parliament, a statutory instrument, by way of a PIL is a big industry. Today, with utmost respect, this country is ruled by Judges.   All this is done in the name that the Act of Parliament violates the basic structure of the Constitution; all this is done by a procedure called PIL which has no foundation in jurisprudence or law.
The plea is that if legal luminaries could seek a declaration that the aforesaid Acts are unconstitutional, the ordinary lawyers, the lay people, also have a right to seek a declaration that the said Acts are constitutional and that if the validity of the said Acts could be questioned, then all those who support and oppose the same – millions and millions on each side – have a right to be heard. This Hon’ble Court disposed of the NJAC case directing the Government to frame a Memorandum of Procedure (MoP) for appointment of Judges to the higher judiciary and  felt that the MoP should provide for improvement of the collegium system of appointment of Judges in four areas, namely:
   (i) Transparency,
   (ii) Collegium Secretariat,
   (iii) Eligibility Criteria and
   (iv) Complaints.
The collegium system, which this Hon'ble Court itself found to be a total failure, a synonym for favourtism, nepotism, non-transparent, oligarchy and secrecy, was revived. Everything is done in a most cabal, non-transparent and secret manner.
Since the then Hon'ble Chief Justice of India (CJI) Shri H.L. Dattu refused to be involved in the selection of two eminent persons who were to be part of the Selection Committee on the premise that the constitutionality of the Acts are under challenge, for more than six months from the day the said Acts were notified till the judgment in the NJAC case came, no appointments were made.   This resulted in total breakdown of the justice delivery system. Could the nation afford further appointments to be made by the collegium in a most non-transparent way, which has meant the higher judiciary becoming the exclusive province of those lawyers who belong to the elite class, the kith and kin of sitting and former Judges of the Supreme Court and High Courts, their juniors, celebrated lawyers, Chief Ministers, Governors et al, and a few first generation lawyers who are all politically connected or are close to big industrial houses? The answer to the current scenario, nothing short of an emergency, is to not insist upon appointment in a secretive and cabal manner, which is the synonym for the current collegium system, but to embrace change/s. Since many appointments of Judges to the higher judiciary are made since the judgment in the NJAC case without bringing in any transparency in terms of the order dated 16.12.2015, the Petitioners apprehend that many more such appointments are all likely to be made without effecting any improvements to the collegium system of appointment suggested in the said order.  
In the eyes of the Petitioners, what is paramount is a system of appointment of Judges independent of both the executive and the judiciary.   Hence the instant Writ Petition (Civil).

The List of  Dates
26.01.1950      The Constitution of India came into force, with the appointments of the judges being the constitutional procedure established.
30.12.1981      Judges-1 Case (S.P. GUPTA Vs. UNION OF INDIA & ANR.  {1982 AIR  149 = 1982(2)SCR 365 = 1981 Suppl. SCC 87 = 1981(4) SCALE 1975})judgment pronounced, which upheld the constitutional provision of appointments.
06.10.1993      Judges-2 Case (Supreme Court Advocates-on-Record Association v. Union of India, (1993) 4 SCC 441 )judgment pronounced, which established the system of Collegium as an extra constitutional body.
28.10.1998      Judges-3 Case (Reference By President of India Under Article 143(1) Of The ... vs Unknown, AIR 1999 SC 1, RLW 1999 (1) SC 168, 1998 (5) SCALE 629, 1998 Supp 2 SCR 400) judgment pronounced, which reiterates the collegium.
04.04. 2011     Judges-4 Case (Suraz India Trust Vs. Union of India & Anr., (2012) 13 SCC 497-B) referred to the constitutional Bench, by an order of  the full bench of this Hon’ble Court, whereas the successive Chief Justices of India, have not till date constituted the said Constitutional Bench to adjudicate the constitutional  issues related to the appointment of judges.
31.12.2014      Constitution (99th Amendment) Act, 2014 and the National Judicial Appointment Commission Act, 2014 are passed by the Parliament of India.
13.04.2015      Constitution (99th Amendment) Act, 2014 and the National Judicial Appointment Commission Act, 2014 are notified by the government of India as operational.
07.04.2015      Judges-5 Case (Supreme Court Advocates-on-Record Association v. Union of India and Others (JT 2015 (10) SC 1), 2015(5)GLT(SC)12, 2015(11)SCALE1.) the order of the Three Bench judge referring the matter to the Constitution bench.
15.04.2015      The Constitution Bench was constituted and the sitting started.
28.04.2015      The Chief Justice of India refuses to take part in the selection committee meeting, which was supposed to select two eminent persons to the National Judicial Appointment Commission and the stand still in appointments to the higher judiciary emerges in to mounting vacancies.

16.10.2015       The Constitution Bench of this Hon’ble Court  by a majority judgment declared the Constitution (99th Amendment) Act, 2014 and the National Judicial Appointment Commission Act, 2014 as void and unconstitutional.
03.11.2015      Further sitting of the Constitutional Bench, after passing the final order and judgment, for the improvement of the collegium system.
05.11.2015      The Constitutional Bench of this Hon’ble Court, invite the public opinion on the issue of improving the collegium system. After quashing the said Acts has, by order dated 5th November, 2015, invited suggestions from the public at large to improve the collegium system amounts to legislation in substitution of the Parliament, nay, even its constituent power.

18 & 19.11.2015      Further sitting of the Constitutional Bench, hearing the public opinion.
19.11.2015       Further orders of this Hon’ble Court by its Constitutional Bench for the revival of the collegium, without causing any improvement, as  sought by the constitution Bench of this Hon’ble Court or suggested by the public at large, reserving the order and concluding the hearing.
16.12.2015      Final order of the Constitutional Bench of this Hon’ble Court, disposing of the petitions, keeping the improvement of the collegium unfinished, and leaving to the Union Government for the issue of Memorandum of Procedure for the appointments Judges, and the expected and most promising ‘Perestroika’ and ‘Glasnost’ being dumped to the drains, and further allowing the imperfect system of collegium to function, causing serious damage and prejudice to the interest of the Nation as well as the independence and reputation of judiciary.
The memorandum of procedure prepared by the Union Government, in accordance with the order dated 16.12.2015, of this Hon’ble Court is pending before the Chief Justice of India.
April,2016       The Collegium of appointments further recommends a bulk of appointments to various High Courts, mostly the elite class, the kith and kin of sitting and former Judges of the Supreme Court and High Courts, their juniors, celebrated lawyers, Chief Ministers, Governors et al, and a few first generation lawyers who are all politically connected or are close to big industrial houses, resulting into ‘judicial dynasty’, without inviting any application from any eligible candidates for such appointments, without causing any transparency, without laying down the bench mark and yardstick to evaluate merits and without having any mechanism for dealing with complaints.
13.05.2016      The Government of India appoints 4 judges to the Hon’ble Supreme Court of India, as recommended by the Collegium of appointments, without resorting to any reformations or revising the memorandum of procedure, as laid down by the constitutional Bench in Judges-5 case, and even when the petition challenging the said appointments were pending before the court of competent jurisdiction. 
12.08.2016      The Chief Justice of India issues a threatening warning to the Union Government, placing the entire onus of delay for the appointments of judges is at the hands of the Union Government. 
August,2016  The Government of India appoints Chief Justices to various High Courts, as recommended by the Collegium of appointments, without resorting to any reformations or revising the memorandum of procedure, as laid down by the constitutional Bench in Judges-5 case. 
29.08.2016      The instant Writ Petition (Civil) Filed.
IN THE SUPREME COURT OF INDIA
CIVIL ORIGINAL JURISDICTION
WRIT PETITION (C) NO.   704 OF 2016

IN THE MATTER OF
1.          National Lawyers’ Campaign for
       Judicial Transparency and Reforms,
Represented by it's Joint Secrety, A.C.Philip
Having it's registered address at:
       304, Hari Chambers, 3rd Floor,
       54/68 SBS Marg,
       Near Old Custom House, Fort,
       Mumbai- 400 023,
              &
Office address at:
       No.47, G.L. Sanghi Chambers Block,
       Supreme Court Campus, New
       Delhi-110 001.                             … PETITIONER No.1

2.    A.C. Philip,
Joint Secretary of Petitioner No.1,
Advocate,
Aringada House,
Anachal, Karumalloor P.O,
Ernakulam District,
Kerala State-683 501.           … PETITIONER No.2

3.    Himanshu Luthra,
Advocate,                       … PETITIONER No.3

Versus
1.  The Supreme Court of India,
       Tilak Marg,
       New Delhi 110 001,
       through its Registrar General.              … RESPONDENT No.1

2.  Union of India,
       represented by its Secretary in
       Department of Justice,
       New Delhi- 110001.                            … RESPONDENT No.2

      

PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA SEEKING DECLARATION AND OTHER RELIEFS.

TO
THE HON’BLE CHIEF JUSTICE AND
HIS COMPANION JUSTICES OF THE
HON’BLE SUPREME COURT OF INDIA

THE HUMBLE PETITION OF THE PETITIONER ABOVE NAMED

MOST RESPECTFULLY SHEWETH
1.  The 1st Petitioner is a Non-Governmental Organization registered under the Societies Registration Act, 1860.  Its primary objective is to secure greater transparency and accountability, particularly the higher judiciary and to usher in campaign for reforms which will make the judiciary far more democratic and being in the service of the common man.  The 2nd Petitioner is the Joint Secretary of the 1st Petitioner.  The 3rd Petitioner is advocate, who consider it be no sin to aspire for the august office of the judges of the High Court/Supreme Court; such an ambition is only legitimate and just, provided he were to be found eligible and deserving to be appointed, by a judicial appointments commission, which  is independent of the executive, so too equally of the judiciary, to emphasize, independent of both, by following an open and transparent procedure, where he competes with the hundreds and thousands of his brother and sister lawyers equally or more competent. For him it is in the interest of the republic that not only the judicial appointments are made in a just, open and transparent manner, but shall be seem to be so in the eye of the public at large, lest, the office of the judges should lack democratic legitimacy.

2.  The legal status of the Respondents is manifest from the very cause title and, therefore, requires no elaboration.  In view of the remedies sought for in the instant Writ Petition, if one were to follow the fundamental principle of law that in a suit or other legal proceeding of the like nature for enforcement of the rights which one claims to invest in him, all necessary, proper and even formal parties are to be arraigned as parties to it.  Therefore, the Hon'ble Chief Justice of India and the Hon'ble senior Judges of the Supreme Court who constitute to be the collegium, the Chief Justices and senior Judges of the various High Courts, who constitute to be the collegiums of the respective High Courts, are necessary parties to the instant Writ Petition.  However, whenever petitions are instituted in support of the National Judicial Appointment Commission seeking a declaration that the Constitution (Ninety-ninth Amendment) Act, 2014 and the National Judicial Appointment Commission Act, 2014 (the Acts, for short) are constitutional and that the judgments in Judges-2, Judges-3 and Judges-4 (NJAC case) are unconstitutional and void and wherein the said Hon'ble Judges are arraigned as parties, the Registry has taken objection, which has meant prosecution of those petitions almost an impossibility.  Therefore the Petitioners consider it only appropriate to seek permission of this Hon'ble Court to allow those Hon'ble Judges to be arraigned as additional Respondents to the instant petition, if need be, in due course.

3.  Though in paragraph 1 above a brief description of the 1st Petitioner is given, the Petitioners consider it appropriate to elaborate its aims and objectives a little more.  The 1st Petitioner is the first ever organization of its nature in India, nay, for that matter, may be even anywhere in the world.  The 1st Petitioner is an organization primarily of the first generation lawyers who hail from humble backgrounds, being the sons and daughters of the common man, the farmers, the toiling class, the teachers, taxi drivers, small scale traders, employees in the lower rungs of the Government and private sector, who constitute 95% of the legal fraternity.  The 1st Petitioner has a huge support base of lay people who consider that the judiciary in India is far less transparent than it ought to be.  Though the Judges enjoy enormous public confidence, of which great erosion has happened in the recent past, they are continued to be regarded as demigods and their words are treated as gospel.  Many of them have lived upto the great confidence, faith and trust placed in them by the common man.  Judges in India enjoy absolute immunity.  The Contempt of Court laws, which are quite often used against honest and outspoken persons have meant the lay people, nay, the legal fraternity, refraining from speaking fearlessly against many an acts and omissions on the part of the Hon'ble Judges of the higher judiciary.  The concept of scandalizing the Court by criticism thereof has its foundation that the independence of the judiciary is maintained; the misconduct, nay, even corruption on the part of the Judges of the higher judiciary are not allowed to be raised; the true state of affairs of the higher judiciary is kept away from the knowledge of the common man, nay, he is kept ignorant thereof on the premise that if he is allowed to know the same his confidence in the institution will be lost. The fact that respect is to be commanded and that the best way to deserve it, is by the quality of judgments delivered, the impartiality and the independence, nay, the high morality, is often lost sight of.

4.  The 1st Petitioner was formed since it was felt by the ordinary lawyers that the collegium system of appointment of Judges to the higher judiciary, one which is nothing but rewriting of the Constitution, to keep political interference in judicial appointments completely at bay, so too to appoint the very best and most deserving Judges, has totally failed and it has, instead, meant monopolizing the august office of Judges of the higher judiciary by the kith and kin of sitting and former Judges of the Supreme Court and High Courts, their juniors, celebrated lawyers, Chief Ministers, Governors et al, and a few first generation lawyers who are all politically connected or are close to big industrial houses.  The fact that corruption in the higher judiciary is no longer deniable but has assumed a proportion of high concern with the relatives and friends of Judges acting as conduits who have amassed huge wealth within the country and abroad, bringing back such money to India by ingenious methods and said to have even invested in private airports and not an FIR could ever be registered against a Judge without permission of the Hon'ble Chief Justice of India etc., meant many of the ordinary lawyers being greatly concerned.  The fact that there is no effective mechanism whatsoever to address complaints of misconduct and malpractice on the part of Judges of the higher judiciary; that the Judicial Standards and Accountability Bill, 2012 introduced in the Parliament remaining in cold storage; that the Hon'ble Judges were not forthcoming to welcome the said Bill, nay, they were opposed to the same, made the concern of the ordinary lawyers further aggravated.  The fact that the “In House” mechanism for addressing complaints against Judges of the higher judiciary, namely, the Charter/Resolution called the “Restatement of Values of Judicial Life” passed by the Supreme Court of India in its Full Court meeting held on May 7, 1997, which was ratified and adopted by Indian Judiciary in the Chief Justices’ Conference 1999, failed to take off also meant the ordinary lawyer, nay, the lay man, informed about the affairs of the higher judiciary. 

5.  That nothing could be expected from the political parties and the political leadership to bring in greater transparency and accountability in the higher judiciary is a fact which cannot be wished away.  The reason is simple.  When it comes to constitutional matters, the affairs of the higher judiciary, be it appointment of Judges, be it the mechanism for addressing complaints against Judges of the higher judiciary, the opinion of a few Senior Advocates in the Supreme Court is the opinion of the political parties whom they represent.  In the case of Congress party, it is the opinion of S/Shri Kapil Sibal, P. Chidambaram, Abhishek Manu Singhvi, Salman Khurshid et al and when it comes to BJP it is the opinion of S/Shri Arun Jaitley, Ravi Shankar Prasad, Mukul Rohatgi et al.  With utmost respect, the Petitioners beg to submit that the aforesaid legal luminaries, though in the case of S/Shri Arun Jaitley and Ravi Shankar Prasad some connection with the grassroots cannot be denied, by and large are drawing room politicians for whom legal profession means enormous money, without meaning any disrespect to them, so too the other creamy lawyers like S/Shri Soli Sorabjee, Fali S. Nariman, Harish Salve, K.K. Venugopal, Rajeev Dhawan et al. the petitioners have felt it only appropriate to name the distinguished lawyers, only to emphasise the fact that they have never ever thought of or spoken of the rights of the non-elite class of lawyers for being considered for appointment as judges, the total discrimination which the ordinary lawyers face today. The principles of natural justice require, while the petitioners have named the legal luminaries here, they be arraigned as respondents. However, the petitioners have been advised, it would be suffice if a leave is sought to arraign them as Respondents, if this courts is pleased to deem so or altogether seek deletion of the reference to them.  However it is felt that the discrimination and injustice the ordinary lawyers face, whom a legal luminary described as ‘disgruntled’ and yet another legal luminary as ‘voice outside’, justify a reference of them by name, with a permission to arraign them as Respondents, if need be in due course of time, if it is ever felt that an allegation is made against distinguished lawyers, who are not parties to the instant petition. 
6.  These days, challenge to the constitutionality of an Act of Parliament, a statutory instrument, by way of a PIL is a big industry. The Petitioners believe that the essence of a democracy is the right to criticize, the right to dissent and the right to speak unpleasant truth, even about persons who claim great respectability. The so-called legal luminaries assert from rooftops that the judiciary in India is most powerful.  They are true, but the question is, is it at all desirable?  The Petitioners beg to disagree. The Constitution never conceived such a position.  Today, with utmost respect, this country is ruled by Judges.  On all matters, which exclusively fall in the domain of executive and legislative policies, the fiat of the Supreme Court prevails.  The Parliament cannot even create a National Tax Tribunal; the National Tax Tribunal Act, 2005 was struck down as unconstitutional  by the Supreme Court in Madras Bar Association v. Union of India, (2014) 10 SCC 1.  Both the Houses of the Parliament and 21 State Legislatures could not by a unanimous amendment of the Constitution establish a National Judicial Appointment Commission.  All this is done in the name that the Act of Parliament violates the basic structure of the Constitution; all this is done by a procedure called PIL which has no foundation in jurisprudence or law.  Elsewhere in the world, Parliament enacts the law and the Parliament alone can declare what law of the land is.  The Constitution of India too conceives the same only.  Article 141 merely states that judgments of the Supreme Court are binding precedents; it does not say that the judgments of the Supreme Court are declaration of law binding on all citizens; it merely states that the judgments of the Supreme Court are binding on Courts and Tribunals in the country. But, judiciary has imposed taxes, like National Green Tribunal imposing an “environmental compensation charge” over and above the municipal toll tax or the so-called green cess imposed by this Hon’ble Court for the heavy diesel cars in Delhi,  without any legislative authority, without any money bill passed by any house of people’s representatives, in total disregard to the Constitution, especially Articles,265,109,110,117,198 & 199 of the Constitution of India. The imposing of tax is the sole domain of the people’s representatives, to which even the Council of state has no effective role to play, apart from decorative.  Elaborating these issues would mean this petition becoming voluminous, an exercise which will prove to be counter-productive.  Therefore, the Petitioners refrain from doing so.  All that the Petitioners beg to submit, even if one were to conceive that the Supreme Court has the power to strike down an Act of  Parliament in the realm of executive and legislative policy (which involves no violation of fundamental rights), is that it could be possible only after hearing the 129 crore people of this country.  If the Supreme Court can lay down the policies, it cannot be by hearing a few elite lawyers.  But, unfortunately, without notice to the public at large and without hearing them, entirely behind their back, decisions on matters of executive and legislative policies involving no violation of fundamental rights are taken and the last such instance is the NJAC case.  Ordinary lawyers are convinced that the elite class of lawyers in the Supreme Court are a self-serving class and, therefore, a time has come for a campaign where the ordinary lawyers take the leadership, standing shoulder to shoulder with the ordinary people.  The 1st Petitioner, therefore, came into existence and its objectives are quoted infra:-
(a)        Advertisement of vacancies of Judges of the higher judiciary, invitation of applications and references , open and transparent selection and appointment, instead of the current system of appointment by invitation where only the elite and super elite are invited, in a democratic legitimacy in the matter of selection and appointment of Judges;

(b)        Creation of a Judicial Ombudsman or such other mechanism as is contemplated in the Judicial Standards and Accountability Bill, 2012 or the Charter/Resolution called the “Restatement of Values of Judicial Life” passed by the Supreme Court of India in its Full Court meeting held on May 7, 1997, which was ratified and adopted by Indian Judiciary in the Chief Justices’ Conference 1999 or any other meaningful mechanism where grievances against Judges could be addressed;

(c)         Audio/video-recording of proceedings of all Courts and Tribunals and in particular the Supreme Court and High Courts, which will ensure transparency and accountability;

(d)        Reintroduction of the transfer policy, which was described by the Seven-Judge Constitution Bench in Judges-1 case as a panacea for allegations of favouritism and conflict of interest where a lawyer is elevated as a Judge of the very same High Court where he has been practicing;

(e)        Bring an end to the “Uncle Judge Syndrome” by transferring Judges whose immediate relatives are practicing in the very same Court;

(f)          Abolition of the practice of designation of Advocates as a Senior Advocates or, at least, introduction of a common dress code for all lawyers, including those who are designated as Senior Advocates;

(g)        Repeal of Contempt of Courts Act, 1971, for the said Act constitutes to be the one single obstacle which has rendered freedom of speech enshrined in Article 19 of the Constitution redundant.  In none of the civil law countries, the law of contempt exists.  In England, in the 19th Century itself, contempt by scandalizing  a Court was declared to be obsolete;

(h)        Introduce a transparent mechanism in the appointment of Standing Counsel/Panel Advocates/Legal Officers for Central and State Governments, Statutory Bodies, Public Sector Undertakings etc., so that the prevailing system of nepotism, political favour etc., are brought to an end;

(i)          Simplification of procedures to make the judiciary as an institution for the common man rather than it being meant to be for the Judges and elite lawyers.


7.  As aforesaid, the 1st Petitioner came into existence for the ordinary class of lawyers, who constitute 95% of the legal fraternity, who felt that there is no forum to speak for them and to ensure that they are treated equally and fairly.  The collegium system of appointment of Judges to the higher judiciary meant total exclusion of the ordinary class of lawyers, the sons and daughters of the common man, from being considered.  In a system where the Judges appointed themselves, they chose to appoint their kith and kin and the elite.  The Parliament brought the aforesaid Acts and thereby sought to make a reality the universal concept of an Independent Judicial Appointment Commission, where neither the executive nor the judiciary has a determinative say, but the selection is founded on merit and character by invitation of applications and references.  It was inconceivable that the legal luminaries would en-bloc oppose the same.  They might have felt that the said Acts, which will open up equal opportunities in the appointment to the higher judiciary to the sons and daughters of the common man, would mean their determinative say in such appointments would be lost forever and hence they used the Supreme Court Advocates on Record Association (SCAORA) as a pawn to achieve the said object and, in fact, succeeded in securing a declaration at the hands of this Hon'ble Court that the said Acts are unconstitutional.  If the so-called legal luminaries, the distinguished Fali Nariman and others, had a right to speak against the said Acts, thousands and thousands of ordinary lawyers and millions of lay people too had a right to assert that the said Acts are the will of the people and are constitutional, and no right will lie because it infringed nobody’s fundamental right, but, on the contrary, their enactment it is a matter of legislative policy which fell in the exclusive domain of the Parliament.  The plea is that if legal luminaries could seek a declaration that the aforesaid Acts are unconstitutional, the ordinary lawyers, the lay people, also have a right to seek a declaration that the said Acts are constitutional and that if the validity of the said Acts could be questioned, then all those who support and oppose the same – millions and millions on each side – have a right to be heard.  This Hon'ble Court realized, even while it asserted that it has a right to decide whether the said Acts are violative of the basic structure of the Constitution and was pleased to do so, that to improve the collegium system, which this Hon'ble Court by the judgment in the NJAC case revived, the public at large ought to be heard.  In a way that was a realization that the said Acts are not justiciable, though such a realization dawned upon it subsequent to the declaration that the said Acts are unconstitutional.

8.  By order dated 05.11.2015, passed in the above Writ Petition, this Hon'ble Court was pleased to invite suggestions from the public at large for improvement of the collegium system of appointment of Judges responded to it; suggestions running into thousands of pages were received.  This Hon'ble Court, though it did not say so in so many words, realized that hearing the public at large is an impossibility and that the course of action embarked upon by it, is nothing but legislation, and it found itself to be on crossroads as to whom to be heard and whose opinions are to be listened, and disposed of the NJAC case directing the Government to frame a Memorandum of Procedure (MoP) for appointment of Judges to the higher judiciary. 

9.  As could be seen from the order dated 16.12.2015, which is marked as Exhibit-P1(pages ___to ____) to the instant petition, passed by this Hon'ble Court, based on the opinion of the public at large, this Hon'ble Court felt that the MoP should provide for improvement of the collegium system of appointment of Judges in four areas, namely:
       (i) Transparency,
       (ii) Collegium Secretariat,
       (iii) Eligibility Criteria and
       (iv) Complaints.

In this respect, the Petitioners are reminded of the words of Horace, parturient montes, nascetur ridiculus mus – mountains will be in labour, and an absurd mouse will be born inasmuch as the entire matter was back to square one, once again.  The aforesaid Acts, which have received the unanimous support of both the Houses of the Parliament and as many as 21 State Legislatures, were quashed and set aside by the majority judgment of this Hon'ble Court in its judgment dated 16th October, 2015, and an independent Judicial Appointment Commission envisaged thereby was not allowed to take its birth. The collegium system, which this Hon'ble Court itself found to be a total failure, a synonym for favourtism, nepotism, non-transparent, oligarchy and secrecy, was revived.  Since the then Hon'ble Chief Justice of India (CJI) Shri H.L. Dattu refused to be involved in the selection of two eminent persons who were to be part of the Selection Committee on the premise that the constitutionality of the Acts are under challenge, for more than six months from the day the said Acts were notified till the judgment in the NJAC case came, no appointments were made.  The collegium system, where under the Judges enjoy absolute power to appoint their kith and kin and, therefore, arguably could have caused no delay in the appointment of Judges, it is believed, could not make timely appointments due to ‘pulls and strings’.  The collegium system could not even resolve something which probably could have offered no difficulty, namely, timely appointments, for, they need to consult none except themselves; they need not hear any complaints because the world outside does not know who are being appointed till the Warrant of Appointment is issued.  Everything is done in a most cabal, non-transparent and secret manner.

10.              As aforesaid, the total ban/suspension of appointment of Judges to the higher judiciary, added with the backlog in existence when the said Acts were brought into force, meant many High Courts in the country functioning with less than 50% to 70% of their Judge-strength; it also meant a few vacancies in the Apex Court.  This resulted in total breakdown of the justice delivery system, for, the suspension of appointments for more than six months meant the last straw in the camel’s back.  To the present Hon'ble CJI, whom the Petitioners consider to be the noblest of CJIs the country ever had and a person of unquestionable integrity, nobility and erudition, the scenario was heartbreaking.  Same is the position with any citizen who has a concern for the nation.  There cannot be two opinions that appointments of Judges to the higher judiciary cannot brook any delay.  The Petitioners too are in complete agreement with the Hon'ble CJI; so too that of any righteous man, be it from the judiciary, the Bar or the lay people.  But the question of equal importance, if not of greater importance is, could the nation afford further appointments to be made by the collegium in a most non-transparent way, which has meant the higher judiciary becoming the exclusive province of those lawyers who belong to the elite class, the kith and kin of sitting and former Judges of the Supreme Court and High Courts, their juniors, celebrated lawyers, Chief Ministers, Governors et al, and a few first generation lawyers who are all politically connected or are close to big industrial houses?

11.              The Petitioners submit that in the matter of appointment of Judges to the higher judiciary, there is no diversity at all.  The Petitioners are no great supporters of the system of appointment prior to the judgment in    Judges-2 case when the executive had the predominant role.  But at that time also it was the voice of the judiciary which used to prevail, the views of the brothers in robes.  The question, therefore, which arises today is whether, in the garb of shortage of Judges in such enormous proportion where admittedly some of the high Courts have only 50% of their Judge strength, which has led to a breakdown of the justice delivery system, the collegium could be allowed to make further appointments or, even if heaven were to fall, should not diversity and transparency in judicial appointments be obtained.  The Hon'ble CJI spoke in the open Court on 11th August, 2016 and again on 15th August, 2016 on the lawns of this Hon'ble Court that in view of the emergent situation that certain High Courts are working with almost 50% of the Judge strength, without bringing in any improvement to the collegium system in terms of the judgment in the NJAC case, appointments should be made.  The Petitioners consider that the contrary view is more valid; if the higher judiciary is allowed to be completely manned by Judges who are from a small pool of the kith and kin of Judges, you will be creating a judiciary which is a class apart from the common man and the elite class of Judges who are socially and economically very different from the ordinary class of lawyers and citizens, a class of Judges who will not be able to empathize with the cause of the poor, the common man.  Therefore, the Petitioners would submit that even if heavens were to fall, let it fall and no further appointments to the august office of the higher judiciary be made without a just and transparent system of selection and appointment is brought into existence. 

12.              The Petitioners would like to make it abundantly clear that the NLC, the 1st Petitioner, believes that if the executive Government is allowed to have a big say in the appointment of Judges to the higher judiciary, that will mean those who are highly connected with the executive, the political leadership and its supporters and sympathizers being rewarded by judicial appointments.  It has happened in the rest of the world; it has happened in this country too, though on a negligible level.  Nobody could dispute that appointment of Judges by the collegium system is a synonym for favouritism, nepotism and oligarchy.  An independent Judicial Appointment Commission, as reflected in the Acts, was the will of the people, sadly though the said Acts were set aside.  However, the Petitioners do not think that that is the end of the road.  The order dated 16.12.2015 (Exhibit-P1 hereto) passed by this Hon'ble Court has given a road map for improvement of the collegium system of appointment of Judges.  It is within that road map to advertise vacancies, invite applications, establish a Secretariat to scrutinize those applications, short-list the same, select the candidates on a tentative basis, notify such selection to the public at large, invite objections and complaints, if any, from the public, etc., all to be done in a transparent manner, making it expressly clear that the entire mechanism is amenable to the provisions of the Right to Information Act, 2005.  All this is possible only if the Hon'ble CJI, the Hon'ble members of the collegium, the legal luminaries who oppose an independent Judicial Appointment Commission, which will have neither the Government nor the Judges exclusive say, but the civil society, have some say to introspect.  The answer to the current scenario, nothing short of an emergency, is to not insist upon appointment in a secretive and cabal manner, which is the synonym for the current collegium system, but to embrace change/s.

13.              The instant petition is not a PIL.  The concept of pro bono litigation, which is meant to provide access to justice to someone in jail, a slum dweller and the like who out of poverty, illiteracy and other disabilities could not approach the constitutional Courts, is today abused to be as one where a person/entity, as SCOARA in the NJAC case, who has all the means to access to justice and maintain a petition on his/its own, asserting it to be a PIL.  The very word “PIL” is allergic to the Petitioners; so too the words “basic structure”; so too the supreme Court declaring the law of the land, for, Kesavananda Bharati v. the State of Kerala (1973) Supp. SCR 1, did not say that the basic structure is justiciable; Article 141 also does not say that a judgment of the Supreme Court is the law of the land, but that it is only a binding precedent.  The 1st Petitioner is an association of the non-elite class of lawyers, the first generation lawyers who have no Godfathers to secure them anointed as a Judge of the Supreme Court or a High Court.  The 2nd and 3rd Petitioners are lawyers who consider that the august offices of the Supreme Court and High Courts being public officers, they too have a right to be considered and selected for the said post, if found to be eligible and deserving.  They consider that they commit no crime in aspiring to become a Judge of the higher judiciary, while at the same time consider that the competent authority who find them to be wholly unsuitable, unmeritorious and reject their candidature, they will accept that fait accompli with all grace.  The Petitioners are asserting all these to make it clear that they are entitled to invoke the jurisdiction of this Hon'ble Court under Article 32 of the Constitution which is available only where the rights enshrined in Part III thereof are infringed.  Since many appointments of Judges to the higher judiciary are made since the judgment in the NJAC case without bringing in any transparency in terms of the order dated 16.12.2015 (Exhibit P-1), the Petitioners apprehend that many more such appointments are all likely to be made without effecting any improvements to the collegium system of appointment suggested in the said order.  The Petitioners’ apprehensions stand further aggravated in view of the recent public statements at the hands of the Hon'ble CJI that the collegium could not tolerate any more delay in the appointment of Judges and that the Government is duty bound to clear forthwith the names of Judges sent by the collegium by resort to a secret selection.  Hence, the instant Writ Petition for enforcement of the fundamental rights of the 2nd and 3rd Petitioners; so too the members of the 1st Petitioner, for equal treatment and equal opportunity for selection and appointment as Judges of the higher judiciary.
14.              Considering the larger issue, the Petitioner, has instituted, the instant Writ Petition under Article 32 of the Constitution of India before this Hon’ble Court, on the following amongst other :-

GROUNDS

(A)      Apart from the undeniable proposition that legislations in the realm of executive and legislative policies, which involve no violation of anybody’s fundamental rights, are not justiciable, judicial review is amenable only where fundamental or legal rights are alleged to have been infringed, which infringement entails in a person such remedies which are recognized in law, namely, common law, equitable or declaratory, the judgment in the NJAC case and the ongoing feud between the Government on the one hand and the Hon'ble CJI and the collegium of which His Lordship is the head on the question of framing of the MoP for appointment of Judges to the higher judiciary in terms of the order dated 16.12.2015 passed by this Hon'ble Court, the instant Writ Petition deals with issues which neither the executive nor the judiciary nor even the press has taken notice of.
(B)      In the eyes of the Petitioners, what is paramount is a system of appointment of Judges independent of both the executive and the judiciary.  If executive has a predominant say, there is possibility of judicial appointments being reduced to rewarding or patronage of their supporters, though, at least so far as India is concerned, not much proof is available.  The Petitioners consider that what is of paramount importance is a mechanism, independent of the judiciary.  They assert so based on the statistics collated by them.  It is a plain truth that Judges who have usurped the power of appointment have appointed their kith and kin, near and dear ones.  For the so-called legal luminaries, whom the Petitioners do not wish to name for considerations of reticence, the collegium system was one which offered them enough room for patronage and influence.  The Petitioners dare to say that they opposed the idea of an independent Judicial Appointment Commission, the NJAC, en-bloc because of the fear of loss of their power of patronage and influence.  Otherwise there was no conceivable reason for them to have opposed an independent Judicial Appointment Commission, independent of both the executive and the judiciary which would have resulted in selection of Judges from a diverse and wider pool of candidates in a non-discriminatory manner.  For the Petitioners, unless the apartheid, which is the result of designation of lawyers as Senior Advocates, is brought to an end and an open and transparent system of selection and appointment of Judges is brought into existence by bringing an end to the collegium system, there is no future for them and those similarly situated.  It is not a mere question of the concern of the ordinary lawyers alone; the largest democratic society in the world, which we are, demands that “Judges are not only selected in a fair and open way but are seen by the public to have been chosen in the fairest possible way taking nothing into account other than their ability”.
(C)      Diversity is the key factor; diversity and merit are not incompatible; and paramount of all is good character.  Since the judgment in Judges-2 case, to repeat, since the Judges started appointing themselves, the august office of Judges of the higher judiciary is monopolized by the kith and kin of sitting and former Judges of the Supreme Court and High Courts, their juniors, celebrated lawyers, Chief Ministers, Governors et al, and a few first generation lawyers who are all politically connected or are close to big industrial houses, who later on appointed their kith and kin as Judges of the higher judiciary or designated their near and dear ones as Senior Advocates.  There is not a single lawyer, who is the son or daughter or brother or nephew of a sitting or retired Judge, who has crossed the age of 45 years, who continue to remain as an ordinary lawyer; they are all appointed as a Judge of the higher judiciary or designated as Senior Advocate.  Many of the Judges have got their sons appointed at the youngest possible age, sometimes even at the age of 40 years, as a Judge of the High Court which meant a guarantee that one day they are appointed as a Judge of the Supreme Court or even becoming the CJI.  These are facts which are undeniable.   Sun, moon and truth can never be hidden, said Buddha.  In support of their plea, the Petitioners beg leave of this Hon'ble Court to produce at the time of hearing the “uncle-Judge syndrome”, the “senior counsel syndrome” chart, and the “progeny/senior counsel syndrome” chart.
15.               The petitioner has not filed any similar petition on the same cause of action before this Hon’ble Court or any other Courts. The instant Writ is not barred by the by the doctrine of estoppel res judicata.
16.              The Petitioner states that requisite Court-fee of Rs. 250/- as per Rules has been paid.
17.              The Petitioner states that there is no period of limitation for preferring this Petition and hence the same is within limitation.
18.              The Petitioner states that the Petitioner has no other efficacious alternative remedy than to prefer the instant Writ Petition under Article 32 of the Constitution of India.
19.              That the Petitioner crave leave to add, amend or alter any of the foregoing grounds with the permission of this Hon’ble Court.
20.              That the Petitioner have no other alternative efficacious remedy except by moving the present writ petition under Article 32 of the Constitution of India.
PRAYERS
It is, therefore, most respectfully prayed that this Hon’ble Court may graciously be pleased to:


  1. (a)        declare that the fundamental rights of the Petitioners, namely, the members of the 1st Petitioner and Petitioner Nos.2 and 3, all ordinary lawyers considering themselves to be considered for appointment as a Judge of the High Court or the Supreme Court along with hundreds and thousands of such lawyers, stand abrogated since the mechanism of appointment of Judges independent of the executive and, to emphasize, equally independent of the judiciary, was killed even before it was allowed to take birth by the judgment in the NJAC case and no mechanism in substitution thereof, which will provide for a just, fair, open and non-discriminatory selection and appointment of Judges from a diverse and wider pool of candidates than the traditional ones, namely, the kith and kin of Judges, their near and dear ones, has been brought into existence and that the proposed Memorandum of Procedure, which seeks to provide for a non-statutory, if not secretive, eligibility criteria and procedure, is violative of Part III of the Constitution;
  2. (b)      to declare that the concept of democratic legitimacy in the matter of appointment of Judges to the higher judiciary, so too to secure a selection from a diverse and wider pool of candidates, so too a fair and non-discriminatory selection and appointment will bring an end to the patronage and influence of the so-called legal luminaries and, above all, to be seen by the public at large that the Judges who decide their affairs and destiny are selected in the fairest possible way, independent of both the executive and the judiciary, and that no appointment could be made solely on the recommendation of the collegium but could only be on the recommendations of a non-governmental/ non-departmental public body which is, to repeat, independent of both the executive and the judiciary;
  3. (c)       to issue a writ of mandamus or any other appropriate writ, order or direction, directing the Union of India to bring into existence such legislative or administrative measures for the creation of a non-governmental/non-departmental public body, nay, a Judicial Appointment Commission which will be independent of both the executive and the judiciary to select  Judges for the higher judiciary by inviting applications from all eligible candidates, invite references from all stakeholders, the Bar Associations, the public at large, and above all to see that “Judges are not only selected in a fair and open way but are seen by the public to have been chosen in the fairest possible way taking nothing into account other than their merit and character”;
  4. (d)      to grant a writ of injunction or prohibition restraining and prohibiting the Respondents from selecting and appointing Judges to the higher judiciary except by way of a non-discriminatory process which will afford equal opportunity to be considered for all eligible lawyers, where there is no room for patronage and influence but which will ensure a fair selection from a diverse and wider pool of candidates, so too it will appear to the public at large that Judges who decide their affairs and destiny are not selected in an opaque manner but that they are not only selected in a fair and open way but are seen by the public to have been chosen in the fairest possible way taking nothing into account other than their merit and character;
  5. (e)       to declare that if legal luminaries could seek a declaration that the aforesaid Acts are unconstitutional, the ordinary lawyers, the lay people, also have a right to seek a declaration that the said Acts are constitutional and that if the validity of the said Acts could be questioned, then all those who support and oppose the same – millions and millions on each side – have a right to be heard. 
  6. (f)        to arraign the Hon’ble Chief Justice of India, the Hon’ble Judges of the Supreme Court of India who are the members of the collegium, so too the Hon’ble the Chief Justices of the various High Courts, so too the Hon’ble Judges, who are the members of the collegium of all the High Courts, so too the senior lawyers about whom certain references are made in paragraph5 of the instant writ petition, so too amend the writ petition if so felt necessary in due course of time.

AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN DUTY BOUND SHALL EVER PRAY:
DRAWN BY                                     FILED BY
(Mathews J.Nedumpara)         (_____________)
Advocate                              Advocate for the Petitioner
New Delhi




APPENDIX
CONSTITUTION OF INDIA
21. Protection of life and personal liberty.-
No person shall be deprived of his life or personal liberty except according to procedure established by law.
32. Remedies for enforcement of rights conferred by this Part.-
(1) The right to move the Supreme Court by appropriate proceedings for the enforcement of the rights conferred by this Part is guaranteed.
(2) The Supreme Court shall have power to issue directions or orders or writs, including writs in the nature of habeas corpus, mandamus, prohibition, quo warranto and certiorari, whichever may be appropriate, for the enforcement of any of the rights conferred by this Part.
(3) Without prejudice to the powers conferred on the Supreme Court by clause (1) and (2), Parliament may by law empower any other court to exercise within the local limits of its jurisdiction all or any of the powers exercisable by the Supreme Court under clause (2).
(4) The right guaranteed by this article shall not be suspended except as otherwise provided for by this Constitution.


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