“Temples of Justice Cannot Become Fertile Ground for Corruption”: Supreme Court Sends Strong Signal on Judicial Probity

Background of the Case

The Supreme Court of India delivered a stern message on judicial integrity while dismissing a challenge to an order passed by the Allahabad High Court concerning the forcible eviction of a woman and her three minor children from their residence in Siddharthnagar district, Uttar Pradesh.

The eviction was carried out on the basis of an ex parte civil court injunction, allegedly obtained through the influence of a district court employee, raising serious concerns of collusion between judicial officers and court staff.

The apex court categorically observed that courts cannot become breeding grounds for corruption, as such acts strike at the core of public confidence in the justice delivery system.

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Supreme Court’s Observations on Judicial Corruption

A Bench led by Chief Justice of India Surya Kant refused to interfere with the Allahabad High Court’s directions, stating unequivocally:

“Temples of justice cannot be allowed to become fertile ground of corrupt activities.”

The Court described the trial court’s ex parte order as “perverse”, stating that it crossed “all parameters of judicial propriety.” The Bench emphasised that harsh corrective measures are sometimes necessary to protect institutional integrity and restore public faith in the judiciary.

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Facts Leading to the Illegal Eviction

The dispute arose when Sandeep Gupta, a district court employee, obtained an ex parte injunction order from a civil judge (junior division) in February last year. Acting on this order:

• The woman and her three minor children (aged 8, 4, and 3 years)

• Were forcibly evicted on July 18, with assistance from police and revenue officials

• Despite the property being jointly recorded in the names of multiple co-sharers

The Allahabad High Court found that the proceedings moved with “tearing hurry”, creating serious doubts about the bona fides of both judicial and administrative actions.

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Role of the Trial Court and Administrative Authorities

The High Court held that:

• The civil court acted in a colourable exercise of power

• District authorities executed the eviction without jurisdiction

• The judicial officer showed misplaced sympathy, leading to misuse of authority

The Supreme Court concurred, noting that when conspiracies originate within court premises, they pose a grave threat to the rule of law.

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Constitutional Provisions Involved

Article 14 – Right to Equality

The arbitrary eviction violated the guarantee against arbitrariness and unequal treatment, especially where judicial power was exercised discriminatorily.

Article 21 – Right to Life and Dignity

Forcible eviction without due process infringes the right to life with dignity, particularly affecting minor children.

Article 300A – Right to Property

Though no longer a fundamental right, deprivation of property must be in accordance with law, which was absent in this case.

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Statutory Provisions Relevant to the Case

Code of Civil Procedure, 1908

• Order XXXIX (Temporary Injunctions): Ex parte injunctions must be granted sparingly and with strict adherence to principles of natural justice.

• Section 95 CPC: Provides compensation where arrest, attachment, or injunction is obtained on insufficient grounds.

Indian Penal Code, 1860

Potential applicability of:

• Section 166 – Public servant disobeying law with intent to cause injury

• Section 219 – Public servant corruptly making a report or decision contrary to law

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Judicial Precedents on Judicial Accountability

State of Punjab v. Davinder Pal Singh Bhullar (2011)

The Supreme Court held that judicial discretion must not degenerate into arbitrariness, and misuse of power undermines justice.

K.K. Velusamy v. N. Palanisamy (2011)

The Court emphasised that procedural orders affecting rights must conform to fairness and transparency.

Delhi Judicial Service Association v. State of Gujarat (1991)

While safeguarding judicial independence, the Court clarified that judges are not immune from accountability for misconduct.

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Allahabad High Court’s Directions

The High Court ordered:

• Restoration of possession within 48 hours

• Compensation of ₹1 lakh to the victim for illegal dispossession and mental trauma

• Recovery of the amount as arrears of land revenue in case of default

• Disciplinary action against the trial court judge

• Initiation of proceedings against the court employee under service rules

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Supreme Court’s Endorsement of High Court’s Approach

Rejecting the appeal, the Supreme Court held:

• The High Court’s directions were necessary to reinforce public confidence

• No interference was warranted

• Judicial and court staff misconduct must attract zero tolerance

The Court made it clear that institutional integrity outweighs individual hardship in cases involving systemic abuse.

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Broader Implications for the Justice System

This ruling sends a strong message that:

• Judicial independence does not shield corruption

• Court staff misuse of influence will be dealt with severely

• Ex parte judicial orders affecting vulnerable citizens invite strict scrutiny

The judgment reinforces the principle that justice must not only be done but must be seen to be done.

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Conclusion

The Supreme Court’s ruling underscores that courts derive legitimacy from public trust, and any act that erodes this trust warrants decisive action. By endorsing an iron-hand approach, the Court reaffirmed that probity is the backbone of the judiciary.

The case stands as a reminder that corruption within courts is not merely misconduct—it is an assault on constitutional governance itself.