Final Relief Granted Need Not Be Natural Consequence Of Ratio Decidendi Of Judgment: Supreme Court

The Supreme Court observed that the final relief granted by it need not be the natural consequences of the ratio decidendi of its judgment.

In this case, the MRTP commission dismissed a complaint filed by some home buyers (appellants) under Sections 36-A, 36-B(a) and (d), 36-D and 36-E read with Sections 2(i) and 2(o) of the MRTP Act. The buyers were aggrieved with the demand of extra charges by the builder. According to them, demand of extra charges after the commencement of construction amounted to manipulation of prices which resulted in increase in the cost to the detriment of the buyers.

Though the bench comprising Justices L. Nageswara Rao, BR Gavai and BV Nagarathna upheld the order of the MRTP Commission, it directed the builder to handover possession of the flats to the appellants on payment of Rs.25,00,000/-  for each flat by the appellants.

"26. It is settled law that final relief granted by this Court need not be the natural consequences of the ratio decidendi of its judgment.  Though, we have upheld the order of MRTP Commission, in the interest of justice, the respondent shall handover possession of the flats to the appellants on payment of Rs.25,00,000/- (Rupees Twenty-Five Lakhs Only) for each flat by the appellants.", the court observed.

The bench, in this regard, referred to two judgments viz. Sanjay Singh & Anr. v. U.P. Public Service Commission & Anr. (2007) 3 SCC 720 and U.P. Public Service Commission v. Manoj Kumar Yadav & Anr.  (2018) 3 SCC 706.

In Sanjay Singh, the court noted that every judgment of superior courts has three segments, namely, (i) the facts and the point at issue; (ii) the reasons for the decision; and (iii) the final order containing the decision. It was further observed that the reasons for the decision or the ratio decidendi is not the final order containing the decision.

"The reasons for the decision or the ratio decidendi is not the final order containing the decision. In fact, in a judgment of this Court, though the ratio decidendi may point to a particular result, the decision (final order relating to relief) may be different and not a natural consequence of the ratio decidendi of the judgment. This may happen either on account of any subsequent event or the need to mould the relief to do complete justice in the matter. It is the ratio decidendi of a judgment and not the final order in the judgment, which forms a precedent. The term 'judgment' and 'decision' are used, rather loosely, to refer to the entire judgment or the final order or the ratio decidendi of a judgment.", the court had observed.

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