SC Expunges Strictures on Rajasthan Judicial Officer

Judicial Officer Should Not Be Castigated Unheard for Typographical Errors: Supreme Court Expunges High Court Strictures

Published: 3 November 2026 · NyayVidhan · 3 min read

The Supreme Court expunged strictures that the Rajasthan High Court recorded, while refusing suspension of sentence in a POCSO case, against the trial judge, a District Judge cadre officer whose name the Court masked, and set aside its directions for her training and an ACR entry. The remarks were made on the judicial side without giving her a chance to explain, over inadvertent typographical errors that did not affect the outcome (paras 16, 21, 24, 26).

Key holdings

Strictures recorded on the judicial side without a chance to show cause offend natural justice and audi alteram partem (paras 16, 24).

Castigating a judicial officer for inadvertent typographical errors that did not affect the outcome was avoidable (para 21).

Concerns about a judgment's quality go in a remark slip for the administrative Judge or Chief Justice (paras 22, 25).

The High Court's remarks and its directions on training and ACR placement were expunged and set aside (para 26).

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

Brief Facts

A child in conflict with law, found fit to be tried as an adult, and an adult co-accused were tried separately for sexual offences against a child arising from the same FIR, as Section 23 of the Juvenile Justice Act, 2015 bars joint proceedings (paras 7-9). The appellant, the trial judge, convicted both in separate judgments on the same day; some evidence details from one trial were inadvertently carried into the other (paras 10-11). On 1 May 2025 the High Court, rejecting the convict's application for suspension of sentence, said she had used ‘cut, copy and paste’, recorded adverse remarks and directed training in judgment writing and a copy of its order for her ACR for 2024 (para 13).

Court's Findings

Opening with Alexander Pope's ‘to err is human, to forgive, divine’ and the Jain virtue of Uttama Kshama, the Court said supervision under Article 227 should guide and nurture the district judiciary (paras 4-6). It found the strictures uncalled for and avoidable: they were recorded on the judicial side without letting the officer show cause or place her explanation on record, violating natural justice (para 16). She explained that the two trials shared almost the same witnesses and evidence and that, with the court's sole stenographer on leave, part of the judgment was dictated to a clerk (paras 17-19). The High Court should have acted with greater magnanimity as guardian of the district judiciary, and castigating an officer for inadvertent typographical errors that did not affect the outcome was avoidable (paras 20-21). Referring to Kaushal Singh, which relied on In Re: ‘K’ and Sonu Agnihotri, the Court reiterated that High Courts should ordinarily refrain from such strictures on the judicial side (para 22). Such remarks may destroy a career and chill the district judiciary (para 23). Any error needed her explanation first (para 24); under Shuvendu Saha, the course is a remark slip for the administrative side (para 25).

Legal Principle

A High Court should not record strictures against a judicial officer in a judicial order without first giving the officer an opportunity to explain. Concerns about the quality of a judgment belong in a remark slip placed before the administrative Judge or the Chief Justice, for action on the administrative side (paras 22, 24-25).

NyayVidhan's view · Practice note

Why It Matters

For trial judges, this ruling confirms that remarks on their work in a judicial order, made without first hearing them, can be expunged on appeal together with consequential directions such as training or an ACR entry (paras 24, 26). For High Courts, it points to the administrative route: a remark slip placed before the administrative Judge or the Chief Justice, where the officer can explain (paras 22, 25). An officer facing such remarks should put her or his explanation on record, as this officer did on overlapping evidence and a stenographer on leave (paras 17-19). For an earlier ruling expunging strictures against a Rajasthan judicial officer, see Kaushal Singh v. The State of Rajasthan (2025 INSC 871).

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

Precedents Relied Upon

Kaushal Singh v. State of Rajasthan 2025 SCC OnLine SC 1473
Relied Upon Discussed at ¶ 22
High Courts should ordinarily refrain from passing strictures against judicial officers while deciding matters on the judicial side; concerns about an officer's conduct go to the Chief Justice on the administrative side, where the officer can explain. Strictures recorded there without an opportunity to explain were expunged; the Court relied on it to expunge the remarks here.
In Re: ‘K’, A Judicial Officer (2001) 3 SCC 54
Referred To Discussed at ¶ 22
Noted as one of the decisions whose principles Kaushal Singh relied on: the distinction between criticising an erroneous judicial order and adverse comments on the personal conduct or calibre of the judicial officer.
Sonu Agnihotri v. Chandra Shekhar & Ors. 2024 SCC OnLine SC 3382
Referred To Discussed at ¶ 22
Noted as one of the decisions whose principles Kaushal Singh relied on: criticism of an erroneous order is distinct from adverse comments on the personal conduct or calibre of the judicial officer.

View all precedents (4)

Shuvendu Saha v. State of West Bengal and Anr. 2026 INSC 367
Relied Upon Discussed at ¶ 25
Where the situation warrants it, observations on the merits or quality of a judgment or the proceedings of the presiding officer should be recorded in a remark slip placed before the administrative Judge or the Chief Justice for action on the administrative side; condemning the officer's conduct on the judicial side without natural justice is unsustainable.