Is Focusing on a Single Decisive Issue Enough? Supreme Court on Judicial Duty

Judicial decision-making is not merely an exercise in arriving at a correct outcome; it is equally about the process by which that outcome is reached. Courts are expected to engage with all material issues arising in a case, give reasons for their conclusions, and ensure that litigants feel heard on every substantial contention raised. A judgment that resolves a dispute by focusing on only one decisive issue, while leaving other significant issues untouched, may appear efficient, but does it truly meet the constitutional and institutional standards of adjudication?

This question came under sharp focus in a recent judgment of the Supreme Court of India in Hemlata Eknath Pise v. Shubham Bahu-uddeshiya Sanstha Waddhamna & Ors. (2026 INSC 147). The Court held that deciding a case on a solitary point, while ignoring other vital issues, is a fundamental flaw that vitiates judicial orders. The ruling reinforces the duty of courts, especially constitutional courts exercising writ jurisdiction, to deliver comprehensive, reasoned decisions. 

Factual Background of the Case

The dispute arose out of disciplinary proceedings initiated against the appellant, Hemlata Eknath Pise, who was dismissed from service by the management of an educational institution. Aggrieved, she approached the School Tribunal, Nagpur, which by its order dated 8 August 2019 set aside the dismissal order and granted reinstatement with consequential benefits.

The management challenged the Tribunal’s order before the Bombay High Court (Nagpur Bench) by way of a writ petition. The High Court, by its judgment dated 5 September 2024, allowed the writ petition and remanded the matter to the Tribunal. The sole basis for remand was that the Tribunal had allegedly failed to examine whether the Secretary of the management was duly authorised, through a resolution, to initiate disciplinary proceedings against the appellant.

Crucially, while ordering remand, the High Court did not examine other substantial issues, including:

• Alleged violation of principles of natural justice during the disciplinary inquiry.
• Denial of opportunity to complete cross-examination of management witnesses.
• Findings of the Tribunal that charges were not proved.

The appellant sought review of the High Court’s order, specifically highlighting these ignored aspects. The review petition, however, was dismissed on 25 September 2024. This led to the appeal before the Supreme Court.

Issue 

The principal question before the Supreme Court was not merely about service law or disciplinary proceedings, but about judicial method and duty:

• Whether a court can dispose of a case by focusing on a single decisive issue, while failing to adjudicate upon other substantial issues arising from the record?

Closely connected to this were ancillary issues concerning the propriety of remand orders, the role of writ courts in service matters, and the effect of incomplete adjudication on litigants’ rights.

Supreme Court’s Reasoning and Findings

A. Error in Deciding Only One Issue

The Supreme Court observed that the High Court had restricted itself to a solitary point, the alleged lack of authorisation of the Secretary, while completely ignoring other serious contentions raised by the appellant. The Court held that such an approach is legally unsustainable.

The Supreme Court emphasised that even if the issue of authorisation was relevant, it was not the only issue. The High Court was duty-bound to consider:

• Whether the inquiry suffered from breach of principles of natural justice.
• Whether denial of cross-examination vitiated the disciplinary proceedings.
• Whether the Tribunal’s findings on merits were justified.

By failing to engage with these aspects, the High Court “faltered” in its adjudicatory duty.

B. Duty to Decide All Issues with Reasons

In a significant articulation of judicial discipline, the Supreme Court laid down a clear principle:

When several issues arise for determination, disposal ought to be preceded by recording answers to each issue with reasons, rather than focusing on just one decisive point.

This approach, the Court noted, serves multiple purposes:

1. Clarity and Finality – Parties receive a comprehensive decision addressing all their contentions.
2. Fairness to Litigants – Every substantial argument is acknowledged and adjudicated.
3. Assistance to Appellate Courts – Reasoned findings on all issues enable meaningful appellate review.

The Court warned that ignoring material issues creates uncertainty and leads to avoidable remands and prolonged litigation.

Remand Orders and Judicial Responsibility

A. Remand Is Not a Shortcut

The Supreme Court implicitly cautioned against the casual use of remand orders. While remand is sometimes necessary, it cannot be employed as a substitute for judicial analysis. A writ court cannot avoid deciding contentious issues merely by sending the matter back to the lower forum, especially when those issues were already examined by that forum.

In the present case, the Tribunal had rendered findings on the disciplinary inquiry. The High Court, instead of scrutinising those findings, chose to remand the matter solely on a technical ground. This, according to the Supreme Court, amounted to an abdication of judicial responsibility.

B. Impact on the Litigant

The Court also took note of the fact that the appellant had already reached the age of superannuation. Therefore, the issue of reinstatement was no longer live. What survived were questions relating to:

• Justification of the disciplinary action
• Entitlement to back wages
• Retiral benefits

A piecemeal adjudication, focusing on one issue alone, had the potential to cause serious prejudice to the appellant by delaying resolution of these crucial claims.

Outcome and Directions

The Supreme Court set aside both the High Court’s order allowing the writ petition and the order dismissing the review petition. The matter was remanded back to the High Court, not the Tribunal, for fresh consideration.

Importantly, the Court directed that:

• All questions of fact and law are kept open.
• The High Court should decide the writ petition comprehensively.
• The matter be disposed of expeditiously, preferably within four months.

The Supreme Court also encouraged the parties to explore mediation, reflecting a pragmatic approach to dispute resolution.

Conclusion

The Supreme Court has reiterated that adjudication is not merely about identifying a decisive point but about resolving the entire controversy placed before the court. When multiple substantial issues arise, a court must engage with each of them and provide reasons, rather than adopting a narrow approach that leaves important questions unanswered. Failure to do so compromises the quality and legitimacy of judicial decision-making.

The Court highlighted that incomplete adjudication often causes greater harm than delay, as it leads to remands, uncertainty, and prolonged litigation. A holistic judgment, addressing all relevant issues, protects the rights of litigants, ensures procedural fairness, and assists appellate courts in meaningful review. The ruling thus reinforces that judicial responsibility lies in delivering thorough and reasoned justice, not merely expeditious outcomes.

Important Link

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