The court expressly disposed of all linked appeals and applications together, providing formal clarity on the status of each proceeding and confirming the absence of cost orders. This judgment upholds procedural regularity and reinforces clarity for practitioners regarding omnibus orders in similar matters. The ruling has binding precedential value for cases on procedural finality before the Calcutta High Court, especially in the context of grouped appeals and applications.
Summary
| Category | Data |
|---|---|
| Case Name | MAT/1162/2025 of JAYANTA SARDAR AND ORS Vs STATE OF WEST BENGAL AND ORS. |
| CNR | WBCHCA0345012025 |
| Date of Registration | 24-07-2025 |
| Decision Date | 10-09-2025 |
| Disposal Nature | DISPOSED |
| Judgment Author | HON’BLE JUSTICE SOUMEN SEN, HON’BLE JUSTICE APURBA SINHA RAY |
| Court | Calcutta High Court |
| Bench | Division Bench (Soumen Sen, J. and Apurba Sinha Ray, J.) |
| Precedent Value | Binding precedent for procedural disposition of linked appeals and applications in similar situations |
| Type of Law | Procedural (Appellate Procedure/Disposition of Appeals and Applications) |
| Ratio Decidendi |
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| Facts as Summarised by the Court |
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Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and benches of the Calcutta High Court |
| Persuasive For | Other High Courts considering omnibus or grouped procedural dispositions |
What’s New / What Lawyers Should Note
- Explicit direction that grouped or omnibus disposal of appeals and applications must be formally recorded in judgments, even if pronouncement occurs orally.
- Clarification that no order as to costs applies unless specifically stated otherwise.
- Confirms that appeals arising from related factual backgrounds or the same set of judgments may be disposed of uniformly, ensuring procedural consistency.
- Lawyers should reference this judgment when seeking clarity or rectification in collective procedural dispositions.
Summary of Legal Reasoning
- The court noted that although the judgment disposing of multiple connected appeals and applications was pronounced on 10.09.2025, its formal recording did not explicitly reflect that all matters were disposed of.
- To correct this procedural omission, the court added an express paragraph confirming that all appeals and connected applications stand disposed of with no order as to costs.
- For subsequent grouped appeals arising from similar circumstances and judgments, the court clarified that they would also be disposed of “in terms of the judgment dated 10.9.2025.”
- The reasoning focuses on procedural regularity and the need for clarity in the formal documentation of court orders, ensuring that parties and courts have certainty regarding the disposal status of all linked matters.
Factual Background
Multiple appeals and applications were filed before the Calcutta High Court, all arising out of the same or similar judgments. The court pronounced a common order on 10.09.2025, intending to dispose of all linked matters together. However, the formal written judgment omitted this explicit disposition. The court subsequently issued a clarificatory order to ensure that the record accurately reflects the collective disposal without costs.
Statutory Analysis
The judgment deals with procedural aspects of appellate practice but does not reference or interpret specific statutory provisions. The focus is on clarifying the record and ensuring uniformity in the disposal of grouped matters.
Dissenting / Concurring Opinion Summary
No separate dissenting or concurring opinions are reported in the judgment. The division bench was unanimous.
Procedural Innovations
- Issuance of a clarificatory paragraph to cure an inadvertent omission in the operative part of the judgment, explicitly recording the disposal of all grouped cases and applications in writing.
- Explicit direction that future similarly situated connected matters follow the procedural disposition laid out in the main omnibus order.
Alert Indicators
- ✔ Precedent Followed – The court reinforces established practice of ensuring that procedural orders disposing multiple linked matters are explicitly recorded and formally reflected in the written judgment.