Context

A recent incident involving the Supreme Court’s censure of an Allahabad High Court judge has reignited debate about the apex court’s authority over High Courts’ internal administration—specifically, the Chief Justice’s exclusive “Master of the Roster” (MoR) power. The case, involving Justice Prashant Kumar, raised broader issues of judicial discipline, institutional autonomy, and constitutional hierarchy.

The Incident & Its Fallout

A Bench led by Justices Pardiwala and Mahadevan directed that Justice Prashant Kumar be removed from the criminal roster and paired with a senior judge after an “erroneous” judgment. This triggered objections from the Allahabad High Court, which argued it constituted a breach of its administrative autonomy. Following communications from the Chief Justice of India, the Supreme Court clarified that its ruling did not intend to infringe on the Chief Justice’s MoR powers.

Constitutional Principles at Stake

• Master of the Roster Principle:
  • Entrails the exclusive right of a Chief Justice—High Court or Supreme Court—to constitute benches and allocate cases. Key precedents affirm this prerogative: State of Rajasthan v. Prakash Chand (1998), State of Rajasthan v. Devi Dayal (1959), and Mayavaram Financial Corporation (Madras HC, 1991).
• Supreme Court’s Binding Authority:
  • Article 141 mandates that decisions of the Supreme Court are binding throughout India.
  • Article 142 empowers the Court to issue orders necessary for “complete justice,” enabling it to take corrective measures.
• Judicial Independence vs. Oversight:
  • High Courts enjoy constitutional autonomy (Art. 214), and the Supreme Court lacks superintendence over them. Yet, the integrated judiciary framework permits intervention when integrity or rule of law is at stake. In Tirupati Balaji Developers (2004), the SC described itself as the “elder brother,” not an administrative overlord.

Issues Raised

• Scope of SC Intervention: Can the Supreme Court issue administrative directives affecting a High Court Chief Justice’s roster authority?
• Judicial Discipline vs. Undermining Autonomy: How can errors be corrected without compromising institutional independence?
• Use of Article 142: Does preventive intervention under this provision set a precedent for future interventions?
• Separation within the Judiciary: Where is the line between hierarchical oversight and judicial autonomy?

In-House Mechanism vs. Public Correction

While serious misconduct among judges is typically addressed through confidential in-house procedures or through impeachment by Parliament, the Supreme Court’s public directive in open court was corrective rather than punitive. The approach—pairing the errant judge with a senior adjudicator—was meant to enhance judicial quality while signaling accountability.

Way Forward

• Define clear guidelines elucidating when the Supreme Court may legitimately intervene in High Courts’ administrative matters.
• Strengthen internal supervisory mechanisms to address judicial errors without resorting to public admonishment.
• Enhance capacity-building, mentorship, and training to minimize repeated lapses in judicial decisions.

Conclusion

The MoR principle is a foundational safeguard of judicial independence, but it does not immune the judiciary from scrutiny or intervention when errors threaten the rule of law. The Supreme Court’s constitutional powers under Article 142 enable exceptional corrective action—but such powers must be exercised judiciously to preserve institutional autonomy and public trust.