Ayub Khan vs State of Rajasthan (2024) - Case Analysis

Introduction of Ayub Khan vs State of Rajasthan (2024)

The case of Ayub Khan vs State of Rajasthan (2024) centres around judicial discretion and the supervisory powers of higher courts over trial courts. The issue arose after the failure of a District and Sessions Judge to comply with directions issued by the High Court of Rajasthan. The case examines whether such non-compliance amounts to judicial indiscipline and whether an explanation could be sought from the judge in a judicial order.

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Why in the Spotlight? - Ayub Khan vs State of Rajasthan (2024)

The 2-Judge Bench of the Supreme Court comprising Justice Abhay S Oka and Justice Augustine George Masih disagreed with the directions issued by the High Court of Rajasthan. The Court ruled in favour of Ayub Khan and stated that requests for explanations should be made on the administrative side and not through judicial orders.

Historical Context and Facts of Ayub Khan vs State of Rajasthan (2024)

The case at hand revolves around the legal issues regarding judicial discretion and supervisory powers. The following are the brief facts of the case -

Position of the Appellant and Bail Application

The Appellant Ayub Khan is a District and Sessions Judge in the Rajasthan Judicial Service joined in 1993. The Appellant rejected a bail application filed by an accused charged under Section 307 r/w Section 34 of the Indian Penal Code (IPC) and Sections 3, 3/25, and 5/25 of the Arms Act, 1959.

High Court Appeal

Aggrieved by the decision of the lower court the accused filed a bail application in the Rajasthan High Court. The High Court granted bail to the accused. Following this, the High Court issued adverse observations against the Appellant for not complying with certain directions issued in the case of Jugal Kishore vs. State of Rajasthan.

Non-compliance with Court Directions

The Appellant Ayub Khan failed to comply with the directions of the High Court issued in the case of Jugal Kishore. It required the Trial Courts to record complete details of the antecedents of the accused in a prescribed tabular form while deciding bail applications.

Explanation by the Appellant

The Appellant Ayub Khan after being called to explain the non-compliance acknowledged the oversight and explained it was due to excessive workload. He assured the High Court that future bail orders would follow the prescribed format.

Impugned Order

On 5th May, 2023 the High Court issued an impugned order observing that the failure of the Appellant Ayub Khan to comply with judicial and administrative orders was a serious matter. The Court expressed concern regarding judicial indiscipline and directed the matter be brought to the notice of the Hon’ble Chief Justice for necessary action.

Appeal in the Supreme Court

Aggrieved by the orders issued by the Rajasthan High Court, the Appellant Ayub Khan approached the Supreme Court. The Appellant Khan filed an appeal in the Supreme Court.

Issue addressed in Ayub Khan vs State of Rajasthan (2024)

The main question which was addressed in this case was whether the failure of the Appellant to comply with specific directions issued by the Rajasthan High Court regarding the format for recording the antecedents of accused persons while deciding bail applications amounts to judicial indiscipline and contempt of court?

Judgment and Impact of Ayub Khan vs State of Rajasthan (2024)

The 2-Judge Bench of the Supreme Court comprising Justice Abhay S Oka and Justice Augustine George Masih disagreed with the directions issued by the High Court of Rajasthan. The directions mandated Trial Courts to include a tabular chart detailing the antecedents of the accused when deciding on bail applications. 

The Supreme Court made it clear that High Courts cannot compel the Trial Courts to follow a certain format for writing bail orders. It also made it clear that the directions issued in the Jugal Kishore vs State of Rajasthan case were not meant to be mandatory. The Court noted that strict adherence to such directions could delay bail hearings.

The Supreme Court condemned the decision of Rajasthan High Court to seek an explanation from the Appellant Ayub Khan, a District and Sessions Judge, for not following the prescribed format in his bail order. The Court ruled that any such explanation should have been sought on the administrative side and not through a judicial order. It highlighted that requesting an explanation in a judicial order was inappropriate and a waste of valuable judicial time.

Conclusion

In Ayub Khan vs State of Rajasthan (2024) the Supreme Court ruled in favor of Ayub Khan, disagreeing with the directions issued by the Rajasthan High Court. The Court criticised the decision of the Rajasthan High Court to seek an explanation from Ayub Khan through a judicial order. The Court stated that such matters should be handled administratively. The Court also expunged the adverse remarks made against him.