The Allahabad High Court has declined to quash the elections to the executive body of the Civil Bar Association, Bulandshahr, in which no woman lawyer was elected as an office bearer, holding that the requirement of 30% representation for women stood fulfilled by the nomination of four women advocates to the body within four days of the poll.

The public interest litigation, filed by an advocate practising in the District Court, Bulandshahr, relied on the order dated 13.03.2026 passed by the Supreme Court in Deeksha N Amruthesh v. State of Karnataka and others, directing all High Courts to ensure that at least 30% of the members of the Bar involved in the election of the governing or executive body of Bar Associations are women. Until then, those directions had operated only for Karnataka.

The bench of Chief Justice Arun Bhansali and Justice Kshitij Shailendra held,

“it cannot be said that presently, there is less than 30% representation of women lawyers in the body elected on 16.04.2026 and the requirement of 30% representation was promptly fulfilled within next 4 days. As a matter of fact, 30% of 16 (12+4) comes to 4.8 and, therefore, inclusion of four women Advocates in the elected body, by way of prompt nomination, fulfils the purpose.”

The elections were notified on 04.04.2026 and held on 16.04.2026. The voter list carried 79 women members, none of whom was returned as an office bearer. The petitioner sought quashing of the election proceedings and their result, and fresh elections with 30% reservation for women lawyers and the post of Treasurer earmarked for a woman.

The respondents submitted that the order of 13.03.2026 reached them only on 08.04.2026, through the District Legal Services Authority, Bulandshahr, by which date the election programme had already been notified, and on 20.04.2026 the elected body nominated four women advocates, one as Joint Treasurer and three as executive members.

The petitioner replied that the nomination was without jurisdiction as no post of Joint Treasurer existed and every executive member post had gone to a male advocate.

The Court refused to accept that the respondents were unaware of the order when the election process had been set in motion.

“The reason is that the respondents, being an association of lawyers, are supposed to be aware of the orders of the Hon'ble Supreme Court, particularly in light of nature of controversy involved in the present case where the very election of Bar Association was to be conducted as per the directions issued. Further, the order of Hon'ble Supreme Court being in public domain, its ignorance cannot be accepted.”

With only 12 posts to be filled by election, the Court held that the 30% representation ought to have been provided within and amongst those 12 posts. It held that the failure to do so did not accord with the order of 13.03.2026.

It noted that paragraph 6 of that order was modified by the Supreme Court on 16.04.2026, the date of the election itself, to provide that where women advocates are not present or do not contest, the shortfall is to be ensured through nomination.

No woman lawyer having come forward when nomination papers were being filled, the Court held that the clause was attracted and the nomination was not illegal per se. It was observed that the nomination was made by the elected office bearers alone, and not by the Administrative Judge or Portfolio Judge in consultation with the District and Sessions Judge, the elected office bearers and the senior most women members, as the modified order requires.

Declining to set a further fact-finding exercise in motion, the Court observed,

“To direct an inquiry in this matter, in our opinion, would invite wastage of scarce administrative resources of the justice delivery system without any corresponding advancement of the cause of justice.”

Disposing of the petition, the Court directed the Bar Association to amend its bye-laws within one month to provide for 30% representation of women lawyers in all future elections, and within the same period to send intimation of the nomination, along with the entire election proceedings, to the Administrative Judge of District Bulandshahr. Unless the Administrative Judge orders otherwise, the elections and the nomination would remain intact.

It held that no exercise by the Registrar General was called for at this stage, though it was left open in case of future breach.

Case Title: Bhavna Pandit v. State of U.P. and 16 others

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