Administrative Law

Administrative / Adjudicatory / Legislative functions - A perusal of the provisions laying down the functions of the Central Electricity Regulatory Commission (the “CERC”) indicates that the statutory authority is enjoined with the task of regulation as well as adjudication of several aspects of the generation, transmission and distribution of electricity. Section 79 of the Electricity Act, 2003 enumerates the functions of the CERC which includes the dual functions of regulation and adjudication. Section 178, on the other hand, empowers the CERC to enact regulations by notification thereby delegating to the body, the power of legislating statutory regulations under the Act, 2003. The aforesaid two provisions indicate that the CERC functions as both, decision-making and regulation-making authority under Sections 79 and 178 respectively. However, while the authority exercising both these functions is one and the same, it is a settled position of law that the functions by themselves are separate and distinct. The functions under Section 79 are administrative or adjudicatory whereas those under Section 178 are legislative. (Para 37, 38) Power Grid Corporation v. Madhya Pradesh Power Transmission Company, 2025 LiveLaw (SC) 583 : 2025 INSC 697

Administrative Action - Judicial Review of - Statutory Authorities - Interplay with IBC Moratorium - Held that the constitutional jurisdiction of the High Court under Article 226 is not curtailed by Section 14 of the IBC - The High Court is competent to entertain a writ petition and direct statutory authorities to process a redevelopment proposal in favour of a new developer, even during the pendency of CIRP - Such directions fall in the public law domain and do not encroach upon the NCLT's jurisdiction or offend the moratorium, especially where the corporate debtor has no subsisting contractual or proprietary interest in the project. [Relied on Gujarat Urja Vikas Nigam Ltd v. Amit Gupta and others 2021 7 SCC 209; Embassy Property Developments Pvt. Ltd. v. State of Karnataka and others 2020 13 SCC 308; Para 17, 20] A.A. Estates v. Kher Nagar Sukhsadan Co-Operative Housing Society Ltd., 2025 LiveLaw (SC) 1151 : 2025 INSC 1366

Administrative Action – Public Tenders – Arbitrariness – Held, even in the absence of contractual rights, the State's administrative discretion in rescinding or cancelling an LoI is subject to constitutional discipline, particularly the requirement that State action must not be arbitrary, unreasonable, or actuated by mala fides- The scope of judicial review in contractual matters is confined to testing administrative action against the touchstones of illegality, irrationality, mala fides, and procedural impropriety, focusing on the decision-making process, not the decision itself- Courts should not interfere unless the State's action is "palpably unreasonable or absolutely irrational and bereft of any principle"- Reasons for Cancellation: Administrative orders must be read in light of the concomitant record, and reasons need not be stated in haec verba in the communication, so long as they can be discerned from the file and are not post-hoc justifications- The legitimacy of administrative reasoning must be tested with reference to the material that existed at the time the decision was made. [Relied on Tata Cellular v. Union of India 1994 6 SCC 651] State of Himachal Pradesh v. OASYS Cybernatics, 2025 LiveLaw (SC) 1142 : 2025 INSC 1355

Administrative Bodies - The significance of creation and establishment of these statutory and administrative bodies is not difficult to conceive. If these institutions and bodies work effectively and efficiently, it is but natural that the purpose and object of the legislation will be achieved in a substantial measure. It is, therefore, necessary to ensure that in the functioning of these bodies, there is efficiency in administration, expertise through composition, integrity through human resources, transparency and accountability, and response-ability through regular review, audits and assessments. While exercising judicial review of administrative action in the context of Statutes, laws, rules or policies establishing statutory or administrative bodies to implement the provisions of the Act or its policy, the first duty of constitutional courts is to ensure that these bodies are in a position to effectively and efficiently perform their obligations. Lifecare Innovations v. Union of India, 2025 LiveLaw (SC) 256 : 2025 INSC 269

Administrative Function – Judicial Review - The Impugned Report recommending the expulsion of the Petitioner was made by the Ethics Committee in the discharge of its administrative functions. These functions have been assigned in the Rules framed by the State Legislature under Article 208 of the Constitution. The Rules so enacted govern the internal functioning, discipline of the House and the procedure by which the House regulates its affairs. However, such administrative actions, even though referable to the Rules formulated under Article 208 of the Constitution, do not constitute the legislative functions of the House. The legislative functions pertain to law- making, deliberation, and policy formulation, whereas the present action of the Ethics Committee is purely administrative in nature, aimed at enforcing discipline and ethical standards amongst the members of the House. The distinction between legislative and administrative functions is well recognized in constitutional jurisprudence. When a legislative body frames rules under Article 208 and subsequently enforces them through disciplinary measures, such enforcement is an exercise of administrative power rather than legislative power. It is well established that administrative actions, even when undertaken by legislative bodies or their committees, are subject to judicial review where they affect the rights and interests of individuals. In fact, the substantive disciplinary or rationality of the self-security measure inflicted upon the erring member is open to judicial review on the touch stone of being unconstitutional, grossly illegal, irrational or arbitrary. There can thus be no doubt that if such an administrative decision is found to be arbitrary, mala fide, or in violation of constitutional rights, it is open to judicial intervention in the same manner as any other executive action of the State. Determining whether an impugned action or breach is an exempted irregularity or justiciable illegality is a matter of judicial interpretation and would undoubtedly fall within the ambit of Constitutional Courts. (Referred: Ashish Shelar and Ors. v. Maharashtra Legislative Assembly and Anr.; (2022) 12 SCC 273, Para 17 -20) Dr. Sunil Kumar Singh v. Bihar Legislative Council, 2025 LiveLaw (SC) 244 : 2025 INSC 264

Administrative Instructions - Government cannot amend or supersede statutory rules by administrative instructions, but if the rules are silent on any particular point, it can fill up the gaps and supplement the rules and issue instructions not inconsistent with the rules already framed. It is a settled proposition of law that an authority cannot issue orders/office memorandum/ executive instructions in contravention of the statutory rules. However, instructions can be issued only to supplement the statutory rules but not to supplant it. Referred: Jaiveer Singh v. State of Uttarakhand, 2023 INSC 1024; Para 21)) R. Ranjith Singh v. State of Tamil Nadu, 2025 LiveLaw (SC) 528 : 2025 INSC 612

Administrative Measure - The power of the State Transport Authority (STA) to delegate the issuance of contract carriage, special, tourist, and temporary permits to its Secretary is fully supported by the statutory provisions of Section 68(5) of the MV Act, and Rule 56(1)(d) of the KMV Rules, 1989. The delegation is a rational and necessary administrative measure that facilitates prompt and efficient processing of permit applications without undermining the oversight function of the STA. (Para 27) S.R.S. Travels v. Karnataka State Road Transport Corporation Workers, 2025 LiveLaw (SC) 166 : 2025 INSC 152 : (2025) 3 SCC 491

Administrative order punishing a delinquent employee - Certain generic principles governing interference with orders of punishment that are passed following inquiry proceedings have evolved over a period of time. Law is well settled that an administrative order punishing a delinquent employee is not ordinarily subject to correction in judicial review because the disciplinary authority is the sole judge of facts. If there is some legal evidence on which the findings can be based, then adequacy or even reliability of that evidence is not a matter for canvassing before the high court in a writ petition filed under Article 226 of the Constitution. However, should on consideration of the materials on record, the court be satisfied that there has been a violation of the principles of natural justice, or that the inquiry proceedings have been conducted contrary to statutory regulations prescribing the mode of such inquiry, or that the ultimate decision of the disciplinary authority is vitiated by considerations extraneous to the evidence and merits of the case, or that the conclusion of the disciplinary authority is ex facie arbitrary or capricious, so much so that no reasonable person could have arrived at such conclusion, or there is any other ground very similar to the above, the high court may in the exercise of its discretion interfere to set things right. After all, public servants to whom Article 311 of the Constitution apply do enjoy certain procedural safeguards, enforcement of which by the high court can legitimately be urged by such servants depending upon the extent of breach that is manifestly demonstrated. (Para 33) Bhupinderpal Singh Gill v. State of Punjab, 2025 LiveLaw (SC) 85 : AIR 2025 SC 620 : 2025 INSC 83

Administrative Tribunals Act, 1985 - Section 15 - Karnataka State Administrative Tribunal (KSAT) - Maintainability of Writ Petition under Article 226 of the Constitution - Service Law - Recruitment Disputes - Alternate Remedy - Jurisdiction of High Court – Held, High Courts should not entertain Writ Petition in matters within domain of Tribunals - The High Court erred in entertaining the writ petition challenging the provisional select list, as an efficacious alternative remedy was available before the KSAT - The Tribunal is the Court of first instance for all service disputes, and litigants cannot directly approach the High Courts, even to question the vires of statutory legislations - The present case does not fall under the recognized exceptions to the rule of alternative remedy, e.g., enforcement of fundamental rights, violation of natural justice, lack of jurisdiction, or challenge to the vires of the parent legislation - Appeals dismissed. [Relied on L. Chandra Kumar v. Union of India and Ors., (1997) 3 SCC 261; T.K. Rangarajan v. Government of T.N. and Others, (2003) 6 SCC 581; Paras 27-29, 32, 49-51] Leelavathi N. v. State of Karnataka, 2025 LiveLaw (SC) 1013 : 2025 INSC 1242

Administrative Tribunals Act, 1985; Section 20 - Time-Barred Claims - A time-barred service dispute cannot be brought within the limitation period by filing a belated representation. When a government servant is aggrieved by a denial of a benefit, which is not based on a formal order, then a representation must be filed within a reasonable time. The cause of action to approach the Administrative Tribunal arises when an order is passed on such representation or no order is passed after the lapse of six months from the submission of the representation. There may be situations such as denial of promotion or increment, which are not based on formal orders. In such cases, filing of a representation may be necessary, even if the service rules do not provide specifically for such a remedy. (Paras 34 - 36) Chief Executive Officer v. S. Lalitha, 2025 LiveLaw (SC) 479 : 2025 INSC 565

An ineffective hearing at the initial stage therefore taints the entire decision-making process leading to a cascade of flawed orders at subsequent stages. Providing a hearing to the affected individual, minimizes the risk of administrative authorities making decisions in ignorance of facts or other relevant circumstances, as it allows all pertinent issues to be brought to light. This process not only aids the administration in arriving at a correct decision but also enables courts to more effectively review such actions. The primary purpose of natural justice is to assist the administration in reaching sound decisions at the outset, reducing the likelihood of decisions being overturned later. Its significance lies in fostering fair and well-informed decision making at the very first instance. (Para 66) Krishnadatt Awasthy v. State of M.P., 2025 LiveLaw (SC) 129 : 2025 INSC 126 : AIR 2025 SC (CIVIL) 1043 : (2025) 7 SCC 545

Compliance with Court Orders - Delay and Obstination - Harassment of Daily Wage Workers - The Supreme Court dismissed a Special Leave Petition filed by the Union Territory, observing that the case presented a "glaring and textbook example of obstination" by state officials who took 16 years to comply with a High Court order. The Court expressed shock at the delay and the repeated harassment of poor daily wage workers through cryptic orders that disregarded the spirit of the 2007 High Court order. While the Court considered imposing exemplary costs and recommending disciplinary action against the delinquent officers, it refrained from doing so as contempt proceedings were pending before the Single Judge. The Court directed the Single Judge to expedite the contempt proceedings on a weekly basis to uphold the majesty and sanctity of law. (Para 2 – 4) Union Territory of Jammu and Kashmir v. Abdul Rehman Khanday, 2025 LiveLaw (SC) 303

Consumer Tribunal - The Union of India is directed to file an affidavit on the feasibility of a permanent adjudicatory forum for consumer disputes, either in the form of a Consumer Tribunal or a Consumer Court, within a period of 3 months from today, on the touchstone of the constitutional mandate. Such a forum shall consist of permanent members, including both staff and the Presiding officers. The Union of India may also consider facilitating sitting Judges to head the fora. The strength may be increased adequately. Ganeshkumar Rajeshwarrao Selukar v. Mahendra Bhaskar Limaye, 2025 LiveLaw (SC) 603 : 2025 INSC 752 : (2025) 8 SCC 634

Disciplinary Authority - In ordinary course, when a court concludes that the punishment imposed by the disciplinary authority is disproportionate to the gravity of the misconduct, it does not generally substitute its own assessment of the appropriate penalty. Instead, the established judicial approach is to remit the matter to the disciplinary authority for reconsideration. This principle stems from the recognition that the authority imposing the punishment is best placed to evaluate the nature of the misconduct and determine an appropriate sanction within the framework of service rules and regulations. Judicial restraint in such matters ensures that courts do not usurp the role of administrative authorities by engaging in executive decision-making. (Para 79, 80) Dr. Sunil Kumar Singh v. Bihar Legislative Council, 2025 LiveLaw (SC) 244 : 2025 INSC 264

Expert Body - AICTE which is an expert body mandated by law, inter alia, to prescribe essential qualifications for a teaching post, and hence we cannot question the logic and wisdom of this expert body which prescribes the essential qualifications for these posts. (Para 24) Secretary All India Shri Shivaji Memorial Society v. State of Maharashtra, 2025 LiveLaw (SC) 373 : 2025 INSC 422 : (2025) 6 SCC 605

File Noting - Mere noting in the official files of the Government while dealing with any matter pertaining to any person is essentially an internal matter of the Government and carries with it no legal sanctity. Harinagar Sugar Mills Ltd. v. State of Maharashtra, 2025 LiveLaw (SC) 673 : 2025 INSC 801 : (2025) 10 SCC 286

If the State Government is compelled to afford an opportunity of hearing to every individual or entity likely to be affected by its administrative decision-making, it would effectively paralyze governance by imposing an undue procedural roadblock. This would place the State in a position where its rule-making authority would be severely constricted, defeating the very purpose of efficient policy implementation and undermining its ability to discharge its administrative duties. (Para 47) P. Rammohan Rao v. K. Srinivas, 2025 LiveLaw (SC) 208 : 2025 INSC 212 : AIR 2025 SC 1335 : (2025) 4 SCC 127

Illegality and Irrelevant Considerations – Executive instructions mandating unnecessary requirements for statutory benefits are illegal – The Supreme Court set aside a Government Memorandum requiring an additional recommendation from the Assistant Registrar for stamp duty exemptions for Cooperative Societies - Held, executive actions that impose unnecessary, excessive, or redundant requirements must be set aside as illegal if they are based on irrelevant considerations or offer no value addition to the transaction. Adarsh Sahkari Grih Nirman Swawlambi Society Ltd. v. State of Jharkhand, 2025 LiveLaw (SC) 1175 : 2025 INSC 1389

In similar parlance to service law, administrative law also places great importance on approaching decision-making with proportionality. (Para 32) Dr. Sunil Kumar Singh v. Bihar Legislative Council, 2025 LiveLaw (SC) 244 : 2025 INSC 264

Judicial review of administrative actions are permissible on the grounds of illegality, unreasonableness or irrationality and procedural irregularity. Indian courts have applied the Leary principle as a rule and the Calvin principle as an exception. This is more so due to the institutional structure as the writ court does not usually go into facts and judicial review of administrative action is limited to the decision-making process and not the decision itself. In our view, the provision for an appeal should not rest on the assumption that the appellate body is infallible. When one party is denied the opportunity to present their case, the initial decision fails to provide meaningful guidance to the appellate authority, in achieving a fair and just resolution. (Para 14, 60) Krishnadatt Awasthy v. State of M.P., 2025 LiveLaw (SC) 129 : 2025 INSC 126 : AIR 2025 SC (CIVIL) 1043 : (2025) 7 SCC 545

Jurisdiction cannot be created by consent or waiver. The law does not permit a statutory functionary to assume powers not conferred upon it, regardless of how the parties engage in subsequent litigation. (Para 13) Harshit Harish Jain v. State of Maharashtra, 2025 LiveLaw (SC) 110 : (2025) 3 SCC 365

Jurisdictional Fact - Error in respect of - A jurisdictional fact is one on existence or non- existence of which depends assumption or refusal to assume jurisdiction by a court, tribunal or an authority. In Black's Legal Dictionary it is explained as a fact which must exist before a court can properly assume jurisdiction of a particular case. Mistake of fact in relation to jurisdiction is an error of jurisdictional fact. No statutory authority or tribunal can assume jurisdiction in respect of subject-matter which the statute does not confer on it and if by deciding erroneously the fact on which jurisdiction depends the court or tribunal exercises the jurisdiction then the order is vitiated. Error of jurisdictional fact renders the order ultra vires and bad. A court or tribunal cannot confer jurisdiction on itself by deciding a jurisdictional fact wrongly. (Referred: Wade, Administrative Law, Raza Textiles Ltd. v. CIT, (1973) 1 SCC 633: (1973) 87 ITR 539; Para 30) K.S. Manjunath v. Moorasavirappa @ Muttanna Chennappa Batil, 2025 LiveLaw (SC) 1084 : 2025 INSC 1298

Land Allotment - Public Trust Doctrine - This issue ought to be examined through the prism of administrative law principles vis-à-vis the contractual powers of the State. While it is well-settled that land allotment authorities such as UPSIDC possess the inherent right to cancel allotments upon violation of stipulated conditions, this Court has consistently emphasized that judicial intervention in matters concerning land revocation should be circumscribed to ensure adherence to procedural safeguards. This paradigm underscores the administrative autonomy vested in such authorities while safeguarding allottees' rights through procedural fairness. We, therefore, consider it necessary to examine whether UPSIDC's procedure for industrial land allotment meets standards of administrative propriety, particularly in light of the Public Trust Doctrine (Doctrine) mandating that public resources be managed with due diligence, fairness, and in conformity with public interest. Considering the broader implications for the transparent allocation of public resources and the need to strengthen administrative accountability in industrial land distribution, we deem it appropriate to issue the following direction: The State Government of Uttar Pradesh and UPSIDC are directed to ensure that any such allotment in the future be made in a transparent, non-discriminatory and fair manner by ensuring that such allotment process fetches maximum revenue and also achieves the larger public interest like industrial development priorities, environmental sustainability, and regional economic objectives (Para 20, 29, 38) Kamla Nehru Memorial Trust v. U.P. State Industrial Development Corporation Ltd., 2025 LiveLaw (SC) 652 : 2025 INSC 791 : AIR 2025 SC (Civil) 2248

Legal Notice – Essential Ingredients of – Discussed - the expression 'legal notice' connotes an unambiguous communication along with legal consequences to a noticee who is alleged to be in default. Illustratively, the essential elements of a legal notice would include: a. It should contain a clear and concise set of facts which convey the information leading to the relevant circumstances. This element is also fulfilled when reference is made to any earlier communications issued between the concerned parties; b. It should convey the intimation of any impending legal obligation or breach committed by any party; c. It should convey the intention of the party issuing the communication to hold the other party liable to appropriate legal action or charge; and d. The communication in toto must be unambiguous and should not mislead or suppress material information. If issued under a Statute, it must comply with the relevant requirements prescribed therein as well. (Para 23) Kamla Nehru Memorial Trust v. U.P. State Industrial Development Corporation Ltd., 2025 LiveLaw (SC) 652 : 2025 INSC 791 : AIR 2025 SC (Civil) 2248

National Tribunals Commission – Mandatory Direction - Reiterating earlier constitutional directives, Supreme Court ordered the Union of India to establish a National Tribunals Commission within four months—a structural safeguard for ensuring independence, transparent recruitment, and uniform administration of tribunals. [Paras 151–153] Madras Bar Association v. Union of India, 2025 LiveLaw (SC) 1120 : 2025 INSC 1330

Natural Justice - The position of law is crystallized on the aspect of compliance with the principles of natural justice in both administrative spheres as well as judicial decisions. It is trite law that the principles of natural justice cannot be applied in any straitjacket formula and it is imperative to understand that there are certain exceptions to their applicability. (Para 29) Amrit Yadav v. State of Jharkhand, 2025 LiveLaw (SC) 180 : 2025 INSC 176

Need for accountability and its dimensions – Explained - Accountability in itself is an essential principle of administrative law. Judicial review of administrative action will be effective and meaningful by ensuring accountability of the officer or authority in charge. (Para 68) BSES Rajdhani Power Ltd. v. Union of India, 2025 LiveLaw (SC) 780 : 2025 INSC 937

Prohibition under Article 212(1) operates only with respect to the scrutiny of 'Proceedings in the Legislature' on the touchstone of 'Irregularity of Procedure'. It does not oust the power of judicial review of the decisions of the Legislature, whether Legislative or Administrative, on the grounds of illegality or unconstitutionality. (Para 15) Dr. Sunil Kumar Singh v. Bihar Legislative Council, 2025 LiveLaw (SC) 244 : 2025 INSC 264

Quasi-judicial Functions – Excise of Quasi-judicial Power - Res Judicata – Principle of - Quasi-judicial bodies are also bound by the principles of res-judicata to prevent re-litigation on the same issue. Once a Competent Authority (quasi-judicial in nature) settles an issue, that determination attains finality unless it is set aside in accordance with law. Any quasi-judicial Authority would not ordinarily have the power to unilaterally take a contrary view taken by a coordinate or predecessor authority at an early point in time. The Supreme Court set aside the High Court's order which had upheld the second order passed by the quasi-judicial body despite the first order passed by the quasi-judicial body was not followed and remained unchallenged. (Para 10 - 13) Faime Makers Pvt. Ltd. v. District Deputy Registrar, 2025 LiveLaw (SC) 379 : 2025 INSC 423 : (2025) 5 SCC 772

Recusal is an acceptable mechanism and serves to eliminate any reasonable likelihood of bias. (Para 28) Krishnadatt Awasthy v. State of M.P., 2025 LiveLaw (SC) 129 : 2025 INSC 126 : AIR 2025 SC (CIVIL) 1043 : (2025) 7 SCC 545

Subordinate / Delegated Legislation – Explanation attached to a notification - Notification / provision has to be read as a whole and should not be construed in terms that are contrary to the main provision. (Para 22) Madhya Pradesh Road Development Corporation v. Vincent Daniel, 2025 LiveLaw (SC) 364 : 2025 INSC 408 : (2025) 7 SCC 798

The prejudice theory must be understood as an exception to the general rule and cannot therefore be the norm. (Para 54) Krishnadatt Awasthy v. State of M.P., 2025 LiveLaw (SC) 129 : 2025 INSC 126 : AIR 2025 SC (CIVIL) 1043 : (2025) 7 SCC 545

The principle of audi alteram partem lies at the very heart of procedural fairness, ensuring that no one is condemned or adversely affected, without being given an opportunity to present their case. (Para 36) Krishnadatt Awasthy v. State of M.P., 2025 LiveLaw (SC) 129 : 2025 INSC 126 : AIR 2025 SC (CIVIL) 1043 : (2025) 7 SCC 545

The principles of natural justice are founded on three fundamental rules that ensure fairness in legal and administrative proceedings. Firstly, the Hearing Rule (Audi Alteram Partem) which mandates that no person should be judged without being given a fair opportunity to present his case. Secondly, the Bias Rule (Nemo Judex in Causa Sua) which asserts that no one should act as a judge in its own case, thereby safeguarding impartiality and preventing any form of bias. Lastly, the principle of Reasoned Decision, also known as Speaking Orders, requires every decision to be supported by valid and clearly stated reasons to promote transparency and accountability in the decision-making process. (Para 20) S. Janaki Iyer v. Union of India, 2025 LiveLaw (SC) 655 : 2025 INSC 742 : (2025) 8 SCC 696

The process for arriving at a decision is equally significant as the decision itself. If the procedure is not 'fair', the decision cannot be possibly endorsed. The principles of natural justice as derived from common law which guarantee 'fair play in action', has two facets which include rule against bias and the rule of fair hearing. Additionally, a reasoned order has also been regarded as a third facet of the principles of natural justice and holds utmost significance in ensuring fairness of the process. (Para 16) Krishnadatt Awasthy v. State of M.P., 2025 LiveLaw (SC) 129 : 2025 INSC 126 : AIR 2025 SC (CIVIL) 1043 : (2025) 7 SCC 545

The significance of creation and establishment of these statutory and administrative bodies is not difficult to conceive. If these institutions and bodies work effectively and efficiently, it is but natural that the purpose and object of the legislation will be achieved in a substantial measure. It is, therefore, necessary to ensure that in the functioning of these bodies, there is efficiency in administration, expertise through composition, integrity through human resources, transparency and accountability, and response-ability through regular review, audits and assessments. While exercising judicial review of administrative action in the context of Statutes, laws, rules or policies establishing statutory or administrative bodies to implement the provisions of the Act or its policy, the first duty of constitutional courts is to ensure that these bodies are in a position to effectively and efficiently perform their obligations. So long as policy remains in the realm of even rules framed for the guidance of executive and administrative authorities it may bind those authorities as declarations of what they are expected to do under it. (Para 69) BSES Rajdhani Power Ltd. v. Union of India, 2025 LiveLaw (SC) 780 : 2025 INSC 937

Tribunals Reforms Act, 2021 -Constitutional Validity of - Tribunals Jurisprudence - Discussed. Madras Bar Association v. Union of India, 2025 LiveLaw (SC) 1120 : 2025 INSC 1330