Courts Must Ideally Answer Every Issue Raised, Instead Of Focusing On A Single Decisive Point : Supreme Court

The Supreme Court has observed that it is incumbent upon the Courts to decide on all issues that arise in a matter and must not confine its enquiry to a single decisive issue.

A bench comprising Justices Dipankar Datta and Satish Chandra Sharma set aside the Bombay High Court's Nagpur bench order, which had “faltered” by focusing on only one issue and ignoring several others that went to the root of the disciplinary proceedings against the Appellant.

The appellant was dismissed from service by the respondent-management following disciplinary proceedings initiated in 2017. Challenging her dismissal, she approached the School Tribunal, Nagpur, which in August 2019 set aside the termination and ordered her reinstatement with consequential benefits.

The management carried the matter to the Bombay High Court. By an order dated September 5, 2024, a Single Judge allowed the writ petition and remanded the case to the Tribunal for fresh consideration, primarily on the ground that the Tribunal had not examined whether the Secretary of the management was duly authorised to initiate disciplinary proceedings. A subsequent review petition filed by the employee against the High Court's order was also dismissed, leading to an appeal before the Supreme Court.

Before the Supreme Court, the Appellant contended that the High Court was selective in deciding the issue. She claimed that the High Court had only considered an issue, particularly the school management resolution authorizing the Secretary thereof to initiate proceedings against the appellant, without giving due consideration to another vital issue regarding the non-adherence to the principles of natural justice, where the Appellant was not allowed to cross-examine the Respondents witnesses, which she claimed to be a denial of a meaningful opportunity of hearing.

Finding force in the Appellant's contention, the bench observed that when multiple issues arise for consideration, courts are duty-bound to decide each of them with reasons

“Law is pretty well-settled that when several issues arise for being answered by a Court in the facts of a given case, ideally, disposal thereof ought to be preceded by recording the Court's answers to each of such issues with reasons rather than the decision of the Court focusing on just one decisive point. This approach, apart from ensuring that all issues are considered providing clarity and assuring some sort of a finality, would respect the rights of the litigants to a comprehensive decision; also, if an appeal were carried from such decision, the appellate court would be benefitted by a reasoned decision of the original court.”, the court observed.

The Court further observed that the High Court's failure to deal with allegations of breach of natural justice constituted a fundamental flaw that vitiated its order.

“The High Court, thus, appears to have faltered in deciding only one single point while not dealing with the others, which is a fundamental flaw vitiating its order dated 5th September, 2024. Accordingly, we set aside the orders impugned in these appeals and order a remand of the writ petition to the High Court for a fresh consideration thereof in the light of the claims and defences of the parties”, the court held.

Accordingly, the appeal was allowed. However, taking note of the fact that the appellant has since attained the age of superannuation, the Court directed that the High Court, while rehearing the matter, should consider whether the Tribunal was justified in interfering with the disciplinary action and, if so, whether the appellant would be entitled to back wages and retirement benefits.

The Chief Justice of the Bombay High Court was requested to assign the matter to an appropriate roster Bench for disposal, preferably within four months. The parties were also left free to explore the possibility of a mediated settlement.

Cause Title: Hemlata Eknath Pise VERSUS Shubham Bahu Uddeshiya Sanstha Waddhamna & Ors.

Citation : 2026 LiveLaw (SC) 177

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Appearance:

For Petitioner(s) : Mr. Amol B. Karande, AOR

For Respondent(s) : Mr. Satyajit A. Desai, Adv. Mr. Sanchit Agrahari, Adv. Mr. Sachin Singh, Adv. Mr. Pratik Kumar Singh, Adv. Mr. Parth Johri, Adv. Mr. Shashank Upadhyay, Adv. Mr. Madhur Duggal, Adv. Ms. Anagha S. Desai, AOR Mr. Sravan Kumar Karanam, AOR Mr. Samarvir Singh, Adv. Mr. Siddharth Dharmadhikari, Adv. Mr. Aaditya Aniruddha Pande, AOR Mr. Shrirang B. Varma, Adv.