Judicial Recusal In India- Grounds, Procedure, Appellate Remedies - Legal Service India

I. Introduction:

The impartiality of the adjudicator is the bedrock of the rule of law. Where a judge cannot bring to bear an open mind — whether because of a financial stake, a prior professional association, a pre-formed view of the merits, or personal animus — the integrity of every order and judgment passed by that judge in the proceedings stands in jeopardy. It is to guard against this mischief that the doctrine of judicial recusal exists.

Table of Contents

What Is Recusal?

Recusal is the process by which a judge disqualifies himself or herself from hearing a case, either voluntarily or upon an application by a party. In India, recusal is not governed by a codified statute applicable to the superior courts; it rests instead upon two ancient maxims of natural justice:

Nemo judex in causa sua (no man shall be a judge in his own cause)
The imperative, drawn from Lord Hewart’s celebrated dictum in R. v. Sussex JJ., ex parte McCarthy [1924] 1 KB 256, that justice must not only be done but must manifestly and undoubtedly be seen to be done

The Supreme Court of India has quoted this dictum with approval in a series of decisions including State of West Bengal v. Shivananda Pathak, (1998) 5 SCC 513.

Scope Of This Article

This article examines the law of recusal comprehensively:

The grounds on which it may be sought
The procedure before subordinate courts, High Courts and the Supreme Court
The remedies available when recusal is refused
The principal Supreme Court judgments that have shaped the doctrine — including decisions that upheld the refusal of recusal as a matter of judicial duty

II. Constitutional And Common-Law Foundation:

While there is no constitutional provision that expressly mandates recusal by a superior court judge, the constitutional guarantee of a fair trial under Article 21 of the Constitution of India is wide enough to encompass the right to have one’s case decided by an impartial tribunal. Article 14 reinforces this by demanding equal treatment before the law, which cannot coexist with an adjudicator who is partial to one side.

Statutory Framework For Transfer

The Restatement Act, 1908 (CPC) provides statutory relief through Section 24 (transfer of civil cases) and the Code of Criminal Procedure, 1973 provides relief through Section 407 (transfer of criminal cases).

Statute	Section	Purpose
Code of Civil Procedure, 1908	Section 24	Transfer of civil cases
Code of Criminal Procedure, 1973	Section 407	Transfer of criminal cases

These provisions are deployed as the principal legal vehicle when a litigant seeks recusal of a subordinate court or High Court judge, and the prayer is addressed to a superior court.

Recusal In The Supreme Court

Where the judge whose impartiality is in question sits on the Supreme Court, the applicant has no recourse to transfer, and must instead seek relief through the Supreme Court’s own internal mechanisms.

III. Grounds for Seeking Recusal

A. Reasonable Apprehension of Bias — The Foundational Test

The cardinal test in Indian law is whether a fair-minded, fully informed member of the public would, upon a consideration of all the relevant facts, reasonably apprehend that the judge might not bring an impartial mind to the resolution of the controversy. This test was authoritatively stated by Justice M.N. Venkatachaliah (as he then was) in Ranjit Thakur v. Union of India, (1987) 4 SCC 611, in these terms:

“As to the tests of the likelihood of bias, what is relevant is the reasonableness of the apprehension in that regard in the mind of the party. The proper approach for the Judge is not to look at his own mind and ask himself, however honestly, ‘Am I biased?’ but to look at the mind of the party before him.”

In Ranjit Thakur, the Court set aside a Summary Court Martial and ordered reinstatement, finding that the participation of the very Commanding Officer who had earlier punished the appellant in the tribunal that tried him created a real likelihood of bias — a likelihood that would be apprehended by any reasonable observer. The decision remains the locus classicus on the objective test of apprehended bias and has been consistently followed in the sixty years since.

The test was further refined in State of Punjab v. Davinder Pal Singh Bhullar, (2011) 14 SCC 770, where the Court stated that the real likelihood test is whether a reasonable person, in possession of all relevant information, would have thought that bias was likely and whether the adjudicator was likely to be disposed to decide the matter only in a particular way.

Objective test based on a reasonable observer
Focus on perception of bias, not actual bias
Applies to all judicial and quasi-judicial proceedings

B. Pecuniary Interest — Automatic Disqualification

A pecuniary or financial stake by the judge in the outcome of the litigation operates as an absolute ground for disqualification. No further inquiry into the likelihood of bias is required; the connection between the financial interest and the proceedings suffices. This principle was laid down in Manak Lal v. Dr. Prem Chand Singhvi, AIR 1957 SC 425 : (1957) SCR 575, decided by a Bench comprising Justices Gajendragadkar, Das and Venkatarama Aiyyar.

Though the disqualification in Manak Lal related to prior representation rather than direct financial interest, the Court stated the broad principle that even the smallest pecuniary interest is sufficient to disqualify, and no enquiry into actual bias is needed.

This absolute rule was reaffirmed in Supreme Court Advocates-on-Record Association v. Union of India, (2016) 5 SCC 808 (the NJAC case), where the Constitution Bench held that where a judge has a pecuniary interest, no further inquiry is needed as to whether there was a real danger or reasonable suspicion of bias. In such cases, automatic disqualification follows.

Principle	Legal Position
Pecuniary Interest	Leads to automatic disqualification
Need to Prove Bias	Not required
Threshold	Even minimal financial interest is sufficient

C. Judicial Obstinacy as Bias — The Prejudgment Doctrine

A judge who has formed a concluded and definitive view on the merits of a case in earlier proceedings, and who demonstrates a determination to maintain that view against the judgment of a superior court, exhibits what the Supreme Court has termed “judicial obstinacy” — a form of bias that equally warrants recusal. This principle was established in State of West Bengal v. Shivananda Pathak, (1998) 5 SCC 513.

“Bias is a condition of mind which renders the judge unable to exercise impartiality in a particular case… [W]here there is evidence of prejudgment, or a ‘closed mind’, that can render an opinion biased. If a judgment is overruled by a higher court, the judge whose judgment is overruled must submit to that judgment. He cannot reiterate his overruled view in the same proceedings; if he does, it would be exhibitive of his bias in his own favour to satisfy his egoistic judicial obstinacy.”

Closed mind or prejudgment amounts to bias
Reiteration of overruled views indicates judicial obstinacy
General legal opinions do not automatically disqualify a judge

It is important to distinguish, as the Court itself did, between prejudging specific facts relating to a party (which is impermissible) and holding views on general questions of law, policy, or discretion (which does not mandatorily disqualify a judge). A judge may have written on a legal subject or expressed a view on a constitutional question without being thereby disqualified from adjudicating a case that raises that question: see Indore Development Authority v. Manoharlal, (2019) 8 SCC 1.

D. Prior Professional Association

A judge who has previously appeared as counsel for one of the parties to the dispute, or whose close family member has appeared in that capacity, carries an obvious conflict of interest. The principle in Manak Lal itself arose from the prior representation of the complainant by the tribunal Chairman.

The Supreme Court, in R.C. Chandel v. High Court of M.P., (2012) 8 SCC 58, reiterated that:

“When a litigant enters the courtroom, he must feel secured that the Judge before whom his matter has come would deliver justice impartially and uninfluenced by any consideration.”

E. Adverse Prior Observations — The Transfer Principle

Where a trial court judge has made strong or conclusive observations about a party’s case in the course of interlocutory orders, those observations may create such a degree of apprehended prejudice as to justify a transfer of the proceedings even if no formal application for recusal is made.

The Supreme Court applied this principle in Kanaklata v. State of NCT of Delhi, (2015) 15 SCC 529, where it overturned the High Court’s dismissal of a transfer petition under Section 406, Code of Criminal Procedure, 1973.

The trial court had made strong observations on the petitioner’s discharge application, observations that went to the merits of her case in a manner that, if left to stand, would create a reasonable apprehension that she might not receive a fair hearing.

The Supreme Court held that even non-binding prior remarks could justify a transfer if they carried a real risk of prejudicing a fair hearing, and ordered the matter transferred to another court. The decision is now routinely cited in applications for transfer grounded on apprehended bias arising from pre-trial observations: see recent applications arising from election matter proceedings.

IV. Procedure for Seeking Recusal

A. Before Subordinate Courts and Tribunals

A party who apprehends that a district judge, civil judge, magistrate, or tribunal member is biased may, without any statutory formality, orally raise the concern at the commencement of a hearing and request that the matter be referred to the supervising authority for reassignment. In practice, however, an affidavit-supported written application addressed to the presiding officer is preferable, recording the factual basis of the apprehension and calling upon the judge to recuse.

If the judicial officer declines, the aggrieved party’s remedy is a transfer application before the High Court:

Section 24, Code of Civil Procedure, 1908 for civil proceedings
Section 407, Code of Criminal Procedure, 1973 for criminal proceedings

Both provisions empower the High Court to transfer a case from one court to another within the State if it considers it expedient for the ends of justice. Bias or partiality of the presiding officer is a recognised ground for exercise of this power.

B. Before a High Court Judge

When the judge in question is a sitting judge of the High Court, the formal mechanism is a transfer petition to the Supreme Court under:

Section 25 of the Code of Civil Procedure, 1908 (civil matters)
Section 406 of the Code of Criminal Procedure, 1973 (criminal matters)

The Supreme Court is empowered to transfer any case from one High Court to another or to itself if satisfied that the transfer is expedient for the ends of justice.

Alternatively, a litigant may raise a plea for recusal directly before the judge or before the Chief Justice of the High Court, requesting that the Chief Justice exercise the administrative power to reassign the case to another bench. No statute governs this procedure; it rests on convention and the inherent power of the Chief Justice as Master of the Roster.

In practice, the application most commonly takes the form of a miscellaneous civil application or criminal miscellaneous application filed in the pending proceedings, supported by an affidavit setting out the specific facts that constitute the ground for recusal. The affidavit must disclose a genuine basis grounded in the Ranjit Thakur test; a vague or generalised apprehension will not suffice.

C. Before the Supreme Court

The Supreme Court operates no statutory mechanism for inter-bench transfers on grounds of bias; the constitutional character of the Court means that every Bench of the Supreme Court speaks for the Court as a whole. Accordingly, a party who apprehends bias must proceed as follows:

Step-by-Step Recusal Process

Step	Procedure
Step 1	Oral mention at the commencement of hearing: Counsel should immediately and respectfully raise the ground before the Bench is constituted for hearing the matter, setting out the factual basis concisely.
Step 2	Formal written application: If the oral mention does not result in recusal, a formal application (interlocutory application or writ miscellaneous application, as the case may be) should be filed addressed to the Bench or the Registrar (Supreme Court Rules, 2013, Order XV), supported by an affidavit. The application must: Identify the case number Name the judge(s) whose recusal is sought Set out the specific facts constituting the ground Affirm that the application is made in good faith and not for delay or forum shopping
Step 3	Decision by the concerned judge: The judge to whom the application is addressed decides the matter. If the judge recuses, the Chief Justice reassigns the matter by an administrative order in the exercise of the power as Master of the Roster.
Step 4	No statutory appeal: If the judge declines to recuse, there is no direct appeal from that decision. The applicant’s remedies are limited to the indirect mechanisms discussed in Part VI below.

Important Warning on Recusal Applications

A critical warning: the Supreme Court has, in Subrata Roy Sahara v. Union of India, (2014) 8 SCC 470, deprecated with the sharpest language the practice of bench-hunting, bench-hopping, or bench-avoiding. The Court, per Justice J.S. Khehar (as he then was), held that “In a case, where unfounded and motivated allegations of bias are sought to be made with a view of forum hunting / Bench preference or brow-beating the Court, then, succumbing to such pressure would tantamount to not fulfilling the oath of office.”

Counsel and parties are therefore put on strict notice that frivolous or tactical recusal applications invite adverse consequences including imposition of costs.

V. Landmark Supreme Court Judgments — Annotated

1. Manak Lal v. Dr. Prem Chand Singhvi, AIR 1957 SC 425 : (1957) SCR 575

Bench: Gajendragadkar, Das and Venkatarama Aiyyar, JJ.

A complaint of professional misconduct against an advocate was referred to a Bar Council Tribunal. The Chairman of the Tribunal had, on a prior occasion, appeared as counsel for the complainant in the underlying case. The appellant did not raise a timely objection and was held to have waived his right. The Court nonetheless enunciated the fundamental principles:

Every judicial tribunal must be free from bias, whether actual or reasonably apprehended.
Even the smallest pecuniary interest disqualifies a judge without need for further enquiry.
Prior representation of a party by the presiding officer creates a reasonable apprehension of bias, even absent actual bias.
The principle that justice must be seen to be done is not merely important but of fundamental importance.
Waiver of a known ground of disqualification, if deliberate and with knowledge of the legal consequences, disentitles the objector to raise it subsequently.

Significance: This is the earliest Supreme Court authority on the rule against bias and remains the starting point for any analysis of the subject. It also introduced the doctrine of waiver in the recusal context.

2. Ranjit Thakur v. Union of India, (1987) 4 SCC 611 : AIR 1987 SC 2386 : (1988) 1 SCR 512

Bench: Venkatachaliah and A.N. Sen, JJ.

A Signalman in the Army was tried by a Summary Court Martial presided over by the very Commanding Officer who had earlier punished him and against whom the Signalman had filed a complaint to higher authorities. The High Court dismissed the writ petition in limine. The Supreme Court allowed the appeal, set aside the court martial proceedings, and ordered reinstatement. Justice Venkatachaliah laid down the definitive objective test for bias:

“The proper approach for the Judge is not to look at his own mind and ask himself, however honestly, ‘Am I biased?’ but to look at the mind of the party before him. The test of likelihood of bias is the reasonableness of the apprehension in that regard in the mind of the party.”

Gross disproportionality of sentence may itself constitute evidence of bias.
Procedural safeguards in the Army Act were to be construed liberally.
Relied on Lord Denning and Ackner LJ jurisprudence.

Significance: The authoritative statement of the objective reasonable-apprehension test. Universally cited in every recusal application in India today.

3. State of West Bengal v. Shivananda Pathak, (1998) 5 SCC 513 : AIR 1998 SC 2050

Bench: S. Saghir Ahmad and G.B. Pattanaik, JJ.

In repeated rounds of litigation before the Calcutta High Court over seniority and promotion benefits, the same Division Bench judge reiterated his overruled view. The Supreme Court held this to constitute judicial obstinacy, classified as a form of bias.

(a) Bias is a condition of mind which renders the judge unable to exercise impartiality.
(b) Prejudging specific facts relating to a party is disqualifying.
(c) Judicial obstinacy amounts to bias.
(d) Mere expression of opinion does not establish bias; a “closed mind” is required.

Significance: Extended the recusal doctrine to include judicial obstinacy and closed-mindedness.

4. Supreme Court Advocates-on-Record Association v. Union of India, (2016) 5 SCC 808 (The NJAC Case)

Bench: Constitution Bench of Five Judges

The constitutional validity of the National Judicial Appointments Commission Act, 2014 was challenged. An application was made for Justice Khehar to recuse due to institutional interest. The Court applied the Doctrine of Necessity:

(a) Conflict was institutional, not personal.
(b) No alternative constitutional forum existed.
(c) Doctrine of Necessity applies when all judges are equally affected.
(d) Recusal must be reasoned for transparency (Kurian Joseph, J.).

Significance: Established Doctrine of Necessity and transparency in judicial recusals.

5. Subrata Roy Sahara v. Union of India, (2014) 8 SCC 470 : AIR 2014 SC 3241

Bench: K.S.P. Radhakrishnan and J.S. Khehar, JJ.

Subrata Roy sought recusal of judges who had passed the original contempt order. The application was rejected.

“The path of recusal is very often a convenient and a soft option…”

Unfounded allegations of bias must be rejected.
Bench-hunting and forum shopping strongly discouraged.
Duty to decide is part of judicial oath.

Significance: Leading authority against misuse of recusal applications.

6. Kanaklata v. State of NCT of Delhi, (2015) 15 SCC 529

Bench: T.S. Thakur and Adarsh Kumar Goel, JJ.

A transfer petition was filed due to strong observations by the trial judge. The Supreme Court allowed transfer.

“Strong observations… create a reasonable apprehension… that the petitioner cannot have a fair trial.”

Significance: Established that prior adverse observations may justify transfer.

7. R.C. Chandel v. High Court of M.P., (2012) 8 SCC 58

The Court emphasized that every litigant must feel assured of impartial justice.

Significance: Defines the aspirational standard of judicial impartiality.

8. Ashok Kumar Yadav v. State of Haryana, AIR 1987 SC 454

The Court refined the pecuniary bias rule and adopted the real likelihood test.

Real likelihood of bias is the correct test.
Doctrine of Necessity permits adjudication despite conflict.

Significance: Provides framework for modern recusal jurisprudence.

Quick Summary Table

Case	Key Principle	Significance
Manak Lal	Rule Against Bias + Waiver	Foundational case
Ranjit Thakur	Reasonable Apprehension Test	Widely cited standard
Shivananda Pathak	Judicial Obstinacy = Bias	Expanded doctrine
NJAC Case	Doctrine of Necessity	Institutional conflict clarity
Subrata Roy	Misuse of Recusal	Prevents forum shopping
Kanaklata	Adverse Observations	Ground for transfer
R.C. Chandel	Impartiality Standard	Aspirational benchmark
Ashok Kumar Yadav	Real Likelihood Test	Modern framework

VI. Remedies When Recusal Is Refused

A. Denial by a High Court Judge

A denial of a recusal application by a High Court judge may be challenged before the Supreme Court by way of a Special Leave Petition under Article 136 of the Constitution, arguing that the denial of recusal constitutes a violation of natural justice or fair trial rights under Article 21. The success of such a petition turns on the strength of the factual record of bias and the application of the Ranjit Thakur test.

Alternatively, a transfer petition under Section 25 CPC / Section 406 CrPC may be preferred before the Supreme Court, praying that the entire case be transferred from the High Court to the Supreme Court itself or to another High Court, on grounds of bias or the interests of justice. This is a more targeted and procedurally focused avenue that does not require the Court to express a view on the conduct of a sitting judge.

B. Denial by a Supreme Court Judge

There is no external forum to which an appeal from the refusal of a Supreme Court judge to recuse can be directed. The Supreme Court is the apex court of the republic. The remedies are internal and limited:

Review Petition (Order XLVII, CPC / Article 137): A review petition filed within 30 days of the order, arguing that the refusal of recusal constituted an error apparent on the face of the record. The scope of review is narrow; it is not a rehearing of the merits.
Curative Petition: Following the principles in Rupa Ashok Hurra v. Ashok Hurra, (2002) 4 SCC 388, a curative petition may be filed before the three seniormost judges of the Supreme Court (excluding the Bench whose decision is assailed) after the dismissal of a review petition, where there has been a violation of the principles of natural justice or where a judge who was party to the proceedings failed to disclose his connection with the subject matter. The curative petition is a last resort.
Challenge in Final Appeal / SLP: The party may reserve the ground of recusal denial as a challenge to the fairness of the proceedings in a subsequent Special Leave Petition or in an appeal from the final judgment, arguing that the denial vitiated the proceedings.
Transfer under Article 139A: Where broader fairness issues arise across multiple matters, Article 139A empowers the Supreme Court to withdraw a matter from any court and dispose of it itself, or to transfer it to another court.

In 2025, a petition before the Supreme Court seeking the issuance of mandatory guidelines for recusal was dismissed, the Court reaffirming that recusal is a matter of each judge’s individual conscience and that Article 142 does not empower the Court to compel recusal by one of its own members.

VII. The Doctrine Of Necessity

The Doctrine of Necessity is a recognised exception to the rule against bias. It provides that a judge or tribunal member who is otherwise disqualified on grounds of bias or personal interest may nonetheless hear and decide a matter if:

No alternative, unbiased adjudicator of equivalent jurisdiction is available, and
A refusal to proceed would result in a denial of justice or a legal deadlock.

The Indian Supreme Court applied the doctrine in Gullapalli Nageswara Rao v. APSRTC, AIR 1959 SC 308, and in Ashok Kumar Yadav. Its most prominent modern application is in the NJAC case, where the universal institutional conflict of all five judges was held to engage the doctrine, making recusal impermissible.

The doctrine was also considered but distinguished in the context of the series of recusals from the Chief Election Commissioner appointment petitions in 2025, where CJI Surya Kant recused and directed that judges in line to become Chief Justice should not sit on the Bench — a direction that itself attracted academic criticism as being inconsistent with the NJAC logic, since the conflict affected every judge of the Court in equal measure.

VIII. A Comparative Note

India’s conscience-based discretionary model contrasts sharply with the position in the United States, where Section 455 of Title 28 of the United States Code lays down a codified, objective standard: a judge shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned.

Under this standard, disqualification is a legal obligation rather than a matter of individual conscience, and it extends to a defined list of circumstances including financial interests above a de minimis threshold, a close family relationship to a party or counsel, and prior judicial involvement in the same matter.

The United Kingdom applies a similarly objective standard. In the celebrated case of R. v. Bow Street Metropolitan Stipendiary Magistrate and others, ex parte Pinochet Ugarte (No. 2) [2000] 1 AC 119, the House of Lords recalled a judgment on the ground that one of the Law Lords had a connection, through the charity Amnesty International, to a party in the proceedings — an indirect association that would not have attracted automatic disqualification under Indian law as it existed at the time.

Canada has enacted a comprehensive judicial code of conduct through the Canadian Judicial Council specifying circumstances mandating recusal. The absence of any equivalent code in India is widely regarded as a gap in the institutional architecture of the superior judiciary, and has periodically attracted calls for reform.

Comparative Summary Table

Jurisdiction	Approach	Nature of Recusal
India	Conscience-based	Discretionary
United States	Codified (Section 455)	Mandatory (Objective Standard)
United Kingdom	Objective Test	Strict Application
Canada	Judicial Code of Conduct	Structured Guidelines

Conclusions

The following propositions emerge from a comprehensive review of Indian recusal jurisprudence:

The objective test governs: The question is not whether the judge is actually biased but whether a fair-minded, fully informed member of the public would reasonably apprehend bias. Self-certification of impartiality does not suffice: Ranjit Thakur, (1987) 4 SCC 611.
Pecuniary interest is an absolute ground: It produces automatic disqualification without further inquiry into actual bias: Manak Lal, AIR 1957 SC 425; NJAC case, (2016) 5 SCC 808.
Judicial obstinacy is bias: A judge who in the same proceedings reiterates a view overruled by a superior court exhibits a closed mind that is the equivalent of bias: Shivananda Pathak, (1998) 5 SCC 513.
Prior adverse observations may justify transfer: Even without formal recusal, a transfer under Section 406 CrPC / Section 24 CPC may be ordered where prior observations create a reasonable apprehension of prejudice: Kanaklata, (2015) 15 SCC 529.
Recusal remains discretionary: A judge’s decision to recuse rests on personal conscience. Parties have no enforceable right to compel recusal absent judicial acknowledgment of the ground: Subrata Roy Sahara, (2014) 8 SCC 470.
Duty to decide exists: The oath of office under Article 219 of the Constitution imposes an affirmative duty to decide cases. Succumbing to baseless or tactical applications for recusal is a breach of that oath: Subrata Roy Sahara.
The Doctrine of Necessity overrides universal conflict: Where the disqualifying conflict affects every possible adjudicator of equivalent jurisdiction, the court must still hear and decide: NJAC case, applying Ashok Kumar Yadav, AIR 1987 SC 454.
Voluntary recusal requires transparency: A judge who voluntarily recuses ought to state reasons as part of the constitutional duty of transparency and accountability: Justice Kurian Joseph in the NJAC case.
No codified recusal code exists for superior courts: The 2025 dismissal of a petition for mandatory guidelines confirms that the current discretionary framework remains in force.
Remedies on denial are limited: Denial by a High Court judge may be challenged by SLP or transfer petition before the Supreme Court. Denial by a Supreme Court judge is non-appealable externally; review, curative petition, and challenge in final proceedings are the only recourses.

Table of Cases Cited

Manak Lal v. Dr. Prem Chand Singhvi, AIR 1957 SC 425 : (1957) SCR 575 — Bench: Gajendragadkar, Das and Venkatarama Aiyyar, JJ.
Ranjit Thakur v. Union of India, (1987) 4 SCC 611 : AIR 1987 SC 2386 : (1988) 1 SCR 512 : (1988) CriLJ 158 — Bench: Venkatachaliah and A.N. Sen, JJ.
Ashok Kumar Yadav v. State of Haryana, AIR 1987 SC 454 — real likelihood test; Doctrine of Necessity.
State of West Bengal v. Shivananda Pathak, (1998) 5 SCC 513 : AIR 1998 SC 2050 — Bench: S. Saghir Ahmad and G.B. Pattanaik, JJ.
Rupa Ashok Hurra v. Ashok Hurra, (2002) 4 SCC 388 — Constitution Bench; curative petition framework.
R.K. Anand v. Delhi High Court, (2009) 8 SCC 106 — obligation to resist bench-hunting.
Subrata Roy Sahara v. Union of India, (2014) 8 SCC 470 : AIR 2014 SC 3241 — Bench: K.S.P. Radhakrishnan and J.S. Khehar, JJ.
Kanaklata v. State of NCT of Delhi, (2015) 15 SCC 529 — Bench: T.S. Thakur and Adarsh Kumar Goel, JJ.
Supreme Court Advocates-on-Record Association v. Union of India (NJAC Case), (2016) 5 SCC 808 — Constitution Bench of Five Judges.
R.C. Chandel v. High Court of M.P., (2012) 8 SCC 58 — impartiality as the litigant’s reasonable expectation.
State of Punjab v. Davinder Pal Singh Bhullar, (2011) 14 SCC 770 — real likelihood test — reasonable person standard.
Indore Development Authority v. Manoharlal, (2019) 8 SCC 1 — prior decision in smaller combination does not disqualify judge from sitting in larger Bench.
Gullapalli Nageswara Rao v. APSRTC, AIR 1959 SC 308 — early application of Doctrine of Necessity.

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