Yes – reaffirming that a Division Bench decision on an identical controversy is binding on Single-Judge Benches of the Rajasthan High Court and must be applied as binding authority under Article 226.
Summary
| Category | Data |
|---|---|
| Case Name | CW/1620/2025 of SURESH CHAND SHARMA S/O LATE SHAMBHU DAYAL SHARMA Vs STATE OF RAJASTHAN |
| CNR | RJHC020088642025 |
| Date of Registration | 27-01-2025 |
| Decision Date | 25-08-2025 |
| Disposal Nature | DISPOSED OF |
| Judgment Author | MAHENDAR KUMAR GOYAL, J. |
| Court | High Court of Judicature for Rajasthan at Jaipur |
| Bench | Single-Judge Bench (Mahendar Kumar Goyal, J.) |
| Precedent Value | Binding Authority |
| Overrules / Affirms | Affirms |
| Type of Law | Constitutional Law (Writ Petition under Article 226) |
| Questions of Law | Whether a Single-Judge Bench must follow a recent Division Bench judgment on the same controversy. |
| Ratio Decidendi |
The Court held that once a Division Bench has decided a legal controversy, the issue ceases to be res integra and is binding on Single-Judge Benches under the doctrine of stare decisis. The Division Bench judgment dated 13.08.2025 in Dr. Sukh Ram & Anr. v. State of Rajasthan & Ors. (DB Civil Writ Petition No.9910/2025) resolved the controversy. Therefore, the present writ petition and all pending applications were disposed of in identical terms. |
| Judgments Relied Upon | Dr. Sukh Ram & Anr. v. State of Rajasthan & Ors., DB Civil Writ Petition No.9910/2025, decided 13.08.2025 |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Principle of stare decisis and binding nature of Division Bench decisions. |
| Citations | [2025:RJ-JP:33580] |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All Single-Judge Benches of the High Court of Rajasthan |
| Follows | Dr. Sukh Ram & Anr. v. State of Rajasthan & Ors., DB Civil Writ Petition No.9910/2025 (13.08.2025) |
What’s New / What Lawyers Should Note
- Reaffirms that Division Bench decisions on a given controversy are binding on Single-Judge Benches.
- Clarifies that once a Division Bench resolves an issue, it ceases to be res integra for subsequent petitions.
- Single-Judge Benches must dispose petitions in identical terms without re-examining the legal question.
Summary of Legal Reasoning
- The parties drew the court’s attention to the Division Bench judgment in Dr. Sukh Ram & Anr. v. State of Rajasthan & Ors. dated 13.08.2025.
- The Bench observed that the controversy was no longer res integra.
- Applying the doctrine of stare decisis, the Single-Judge Bench was bound by the Division Bench decision.
- The writ petition and all pending applications were accordingly disposed of in identical terms.
Arguments by the Parties
Petitioner
- The Division Bench in DB Civil Writ Petition No.9910/2025 has already decided the issue.
- The present writ petition should be disposed of in identical terms.
Respondent (State of Rajasthan)
- Did not contest disposal in view of the binding Division Bench decision.
Alert Indicators
- ✔ Precedent Followed – Division Bench authority applied by Single-Judge Bench.
Citations
- [2025:RJ-JP:33580]
- Dr. Sukh Ram & Anr. v. State of Rajasthan & Ors., DB Civil Writ Petition No.9910/2025, decided 13.08.2025