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Supreme Court of India
Civil Law

Supreme Court Declines to Recall Samadhan Samaroh Award, Says Such Awards Have No Precedential Value

A. Tamilarasi v. Government of Tamil Nadu, rep. by its Principal Secretary, Department of School Education & Ors. Decided 6 November 2026

Published: · NyayVidhan · 2 min read

In A. Tamilarasi v. Government of Tamil Nadu & Ors., the Supreme Court declined to recall its Award dated 23.08.2026, passed during the Samadhan Samaroh in SLP (C) No. 8051 of 2019, even though the authorized officers were not present or those present were not duly authorized to appear. The Award was made on the peculiar facts of the case, and awards passed by the Court in Samadhan Samaroh do not have any precedential value. No punitive action is to be taken against the officers concerned (para 2).

Supreme Court Declines to Recall Samadhan Samaroh Award, Says Such Awards Have No Precedential Value

Judgment Intelligence

Disposed Of
A. Tamilarasi v. Government of Tamil Nadu, rep. by its Principal Secretary, Department of School Education & Ors.
Miscellaneous Application Diary No. 62785 of 2026 (arising out of the order dated 23.08.2026 in SLP (C) No. 8051 of 2019)
Court
Supreme Court of India
Date of Decision
6 November 2026
Bench
Chief Justice Surya Kant, Justice Joymalya Bagchi and Justice V. Mohana
Final Outcome

Miscellaneous application disposed of, with pending applications, if any: delay condoned; the Court declined to recall the Award dated 23.08.2026 and directed that no punitive action be taken against the officers concerned in connection with it (paras 1-3).

Source Supreme Court of India, api.sci.gov.in — order dated 6 November 2026 · Court's copy

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Key holdings

  1. The delay in filing the miscellaneous application was condoned (para 1).
  2. The Award of 23.08.2026 was made on the peculiar facts and circumstances of the case, without treating it as a binding precedent in any other case (para 2).
  3. Awards passed by the Court in Samadhan Samaroh do not have any precedential value (para 2).
  4. The Court declined to recall the Award although the authorized officers were not present or those present were not duly authorized to appear (para 2).
  5. No punitive action is to be taken against the officers concerned in connection with the passing of the Award (para 2).

Judgment digest by NyayVidhan: a summary of the court's judgment, not its text. The judgment itself is the authoritative version.

Brief Facts

The miscellaneous application arises out of the Supreme Court's own order of 23.08.2026 in SLP (C) No. 8051 of 2019, which the order calls the Award passed during the Samadhan Samaroh (cause title; para 2). The cause title names A. Tamilarasi as petitioner and the Government of Tamil Nadu, through the Principal Secretary, Department of School Education, and others as respondents. Two applications were listed with it: one for condonation of delay in filing and one for recalling the Court's order. The order does not describe the dispute in the special leave petition or the terms of the Award.

Court's Findings

The Court condoned the delay (para 1). It explained that the Award dated 23.08.2026 passed during the Samadhan Samaroh ‘was made having regard to the peculiar facts and circumstances of this particular case, without treating it as a binding precedent in any other case’ (para 2). It added: ‘Even otherwise, the awards passed by this Court in Samadhan Samaroh do not have any precedential value’ (para 2). It then clarified that it was ‘not inclined to recall the Award’, even though ‘the authorized officers were not present or the officers who were present were not duly authorized to appear’ (para 2). It also directed that ‘no punitive action shall be taken against the officers concerned in connection with the passing of the Award’ (para 2). The order gives no further reasons and says nothing about the terms or merits of the Award.

Legal Principle

The order lays down no wider rule. It records that this Award was made on the peculiar facts of the case, without treating it as a binding precedent, and that awards passed by the Court in Samadhan Samaroh do not have any precedential value; the Court declined to recall the Award although duly authorized officers had not appeared (para 2).

NyayVidhan's view · Practice note

Why It Matters

This order should be read narrowly. It concerns one Award passed during the Samadhan Samaroh, which the Court said was made on the peculiar facts of the case without treating it as a binding precedent in any other case; it added that awards passed by the Court in Samadhan Samaroh do not have any precedential value (para 2). A party relying on such an award in another case cannot treat it as precedent. The order also shows that the absence of duly authorized officers did not lead the Court to recall the Award, and that it directed no punitive action against the officers concerned (para 2).

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.

Topics: Binding Precedent (Article 141) Condonation of Delay Government Litigation Management

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