Reconciling Conflicting Supreme Court Judgments: High Courts Must Harmonize Rather Than Choose

Judicial precedents play a crucial role in shaping legal principles and ensuring consistency in the application of the law. However, there are instances where two Supreme Court judgments appear to contradict each other, creating a complex situation for High Courts. How should High Courts proceed in such cases? Can they selectively follow one precedent while disregarding the other, or must they attempt to reconcile the conflicting judgments?

The Supreme Court addressed this dilemma in the recent case of M/s A.P. Electrical Equipment Corporation vs. Tahsildar & Ors¹, emphasizing that High Courts should not arbitrarily follow one precedent while disregarding another. Instead, they are required to analyze both judgments, understand their reasoning, and attempt to harmonize them. If reconciliation proves impossible, the matter should be referred to a larger bench of the Supreme Court for authoritative clarification.

The case involved M/s A.P. Electrical Equipment Corporation (now ECE Industries Limited), which had purchased land in Fatehnagar Village, Rangareddy District, for industrial purposes. Initially, the government had exempted the land under the Urban Land (Ceiling and Regulation) Act, 1976, but later withdrew the exemption and declared a portion of approximately 46,538.43 sq. meters as surplus. The authorities claimed to have taken possession through a panchnama in 2008, but the company contested this, arguing that the possession was only symbolic and not physical.

A Single Judge of the High Court ruled in favor of the company, but a Division Bench later overturned the decision. The matter was ultimately brought before the Supreme Court, where the core issue was whether the High Court could selectively follow one conflicting Supreme Court decision on a particular legal issue while ignoring another. Faced with this inconsistency, the High Court had opted to follow one of the decisions without attempting to reconcile the conflicting interpretations.

The Supreme Court ruled that High Courts must strive to reconcile conflicting judgments rather than arbitrarily following one. The Court emphasized that such an approach preserves legal coherence and maintains judicial discipline. The judgment relied on the well-established principle reiterated in Quinn v. Leathern²  and Punjab Cooperative Bank Ltd. v. Commissioner of Income Tax, Lahore³, which states:

“Every judgment must be read as applicable to the particular facts proved or assumed to be proved. The generality of expressions found in judgments are not intended to be expositions of the whole law but are governed or qualified by the particular facts of the case in which such expressions are found.”

The court further reinforced the necessity of adhering to the established judicial hierarchy, as upheld in State of Uttar Pradesh v. Raj Narain⁴ and State of U.P. v. Ram Chandra Trivedi⁵ where it was reiterated that courts must harmonize conflicting decisions where possible and should avoid selective application.

However, several Supreme Court judgments have reinforced the importance of judical discipline when addressing conflicting decisions. The principle that a larger bench’s decision prevails over that of a smaller bench has been firmly established in Union of India v. K.S. Subramanian⁶, In this case, the Court ruled that if a smaller bench of the Supreme Court delivers a ruling conflicting with a larger bench, the decision of the larger bench must take precedence.

Additionally, in Central Board of Dawoodi Bohra Community vs. State of Maharashtra⁷, it was held that a bench of lesser strength is bound by the decision of a larger bench and cannot disregard it. This principle ensures consistency in judicial pronouncements and prevents fragmentation in legal interpretations.

The obligation to maintain consistency was further underscored in Sundarjas Kanyalal Bhatija v. Collector, Thane⁸, where the Supreme Court held that judicial discipline requires High Courts to follow Supreme Court rulings with coherence and uniformity. 

Similarly, in Minerva Mills Ltd. v. Union of India⁹, the court emphasized the need for harmony between different constitutional provisions, which can be analogously applied to the reconciliation of conflicting judgments.

The Supreme Court’s ruling serves as a guiding principle for High Court by asserting that High Courts must not disregard a Supreme Court decision simply because it conflicts with another ruling. However, the High Courts must endeavor to harmonize conflicting judgments rather than choosing one and overlooking the other.

The Supreme Court underscored the obligation of High Courts to reconcile conflicting decisions. The court stated that it is essential for the judiciary to maintain consistency and clarity in the law, which can only be achieved through a careful examination of the conflicting judgments. The High Courts are expected to examine the reasoning in both judgments and find a way to reconcile them instead of ignoring one in favor of the other.

Ignoring such rulings can lead to arbitrary interpretations of the law, resulting in unequal treatment and potential injustices. It can also create a patchwork of legal standards that vary from one jurisdiction to another. If reconciliation is not possible, referring the matter to a larger bench ensures clarity and authoritative resolution.

This judgment highlights the importance of judicial discipline and mandates that if a smaller bench of the Supreme Court has given a conflicting ruling with a larger bench, the decision of the larger bench will prevail.

In conclusion, this recent Supreme Court ruling strengthens the doctrine of precedent and ensures that the judiciary operates with clarity, consistency, and discipline. By ensuring that conflicting judgments are reconciled rather than arbitrarily chosen, the ruling strengthens the doctrine of precedent and maintains the integrity of judicial decision-making.

It ultimately protects the rights of citizen by ensuring that the law is applied uniformly. The judgment reinforces the idea that everyone is subject to the same legal standards, which is a cornerstone of democracy. By maintaining consistency in judicial interpretations, the ruling upholds the rule of law and ensures that legal interpretations remain systematic and uniform across different courts in India.

References

1. 2025 SCC OnLine SC 447
2. (1901) AC 495
3. AIR 1940 AC 1055
4. (1975) 4 SCC 428
5. (1976) 4 SCC 52
6. (1976) 3 SCC 677
7. (2005) 2 SCC 673
8. (1989) 3 SCC 396
9. (1980) 3 SCC 625