Supreme Court Mandates a Uniform Cadre and Regularisation Framework for Court Managers Across India

Introduction

On 16 May 2025, in All India Judges Association & Ors. v. Union of India & Ors., (2025 INSC 713), a three-judge Bench of the Supreme Court of India (presided by C.J.I. B.R. Gavai) exercised its inherent/original jurisdiction in a long-running public interest litigation (PIL) that began in 1989. The judgment addresses the hitherto ad-hoc and fragmented status of Court Managers – professionally trained MBAs appointed to relieve judges of administrative burdens.

Prompted by applications from individual Court Managers, their Welfare Association, and a fresh writ petition, the Court crafted an enforceable blueprint for:

• Creating a uniform national service framework for Court Managers;
• Regularising existing contractual personnel with retrospective benefits (sans back-wages);
• Adopting the Gauhati High Court’s 2018 Rules as a model code for every State;
• Fixing explicit deadlines and imposing personal accountability on Registrars General and Chief Secretaries.

Summary of the Judgment

1. Model Rules: Assam’s 2018 Rules were declared the reference template. All High Courts must draft or amend rules on recruitment, pay, duties, promotion/ACP, and disciplinary matters within three months; States must approve them within a further three months.
2. Rank & Pay: Court Managers shall hold at least Class-II (Group-‘B’ Gazetted) status with commensurate pay-scale and allowances.
3. Regularisation: All existing Court Managers (contract/ad-hoc) must face a suitability test. Those found fit are to be absorbed with retrospective continuity; arrears of salary are, however, denied.
4. Promotional Avenues/ACP: High Courts must create promotional ladders or an assured career progression scheme taking cues from Chhattisgarh’s 2017 Rules.
5. Duties & Supervision: Court Managers in High Courts will work under Registrars General; district-level managers under the respective District Judges/Registrars. Their functions must not overlap with existing registry officers.
6. Enforcement: Registrar Generals and State Chief Secretaries are personally responsible for compliance; the Court retained seisin for monitoring.
7. Specific Reliefs: Disposed I.A. 135045/2023 with a request to the Punjab & Haryana High Court to decide connected LPA 1951/2019 consistently with the instant directions.

Analysis

A. Precedents Cited & Their Influence

• Thirteenth Finance Commission Report (2010-2015): First recommended appointment of MBAs as Court Managers, earmarking ₹300 crore. Provided functional blueprint.
• Finance Ministry Guidelines (20 Sept 2010 & 10 Jul 2013): Operationalised the grant; capped additional support to ₹20,000 p.m. per manager. These documents established central fiscal endorsement.
• All India Judges Association v. Union Of India (2018) 17 SCC 555: In earlier infrastructure order, the Court directed States to regularise existing Court Managers. 2025 decision treats this as partly disobeyed and now reinforces it with timelines.
• Report of the Second National Judicial Pay Commission (SNJPC) – 4 Feb 2022: Extensively analysed stagnation, pay disparity and vacancies; lauded Assam’s 2018 Rules; proposed supplemental directives. The Court adopts those proposals almost verbatim.
• Constitutional Provisions: Article 229 (control of HC over its staff) & Article 309 (State power to regulate services) – Court reconciles these by letting HCs draft rules (under 229) but requiring State approval (under 309), affirming federal balance.

B. Legal Reasoning

1. Need-Based Justification: The Court reiterates that efficient court administration is inseparable from the constitutional promise of speedy justice. Administrative support through trained managers is therefore not a luxury but a systemic necessity.
2. Egalitarian Premise: Just as pay-parity for judges nationwide has been judicially mandated, corresponding managerial support must also be uniform lest disparities erode equality and efficiency.
3. Doctrine of Continuity & Legitimate Expectation: Contractual Court Managers, some serving for a decade on subsistence honorarium, acquired equitable expectation of permanence. Denial would be arbitrary; hence regularisation with a suitability filter is constitutionally compelled (Art. 14).
4. Minimum Interference with Executive/HC Autonomy: Instead of imposing a rigid central rule, the Court adopts a “model-rules” approach permitting contextual tweaks, thereby respecting Art. 229 autonomy and State budgetary variations.
5. Accountability Mechanism: By placing personal responsibility on Registrar Generals and Chief Secretaries, the Bench operationalises meaningful compliance, invoking the constitutional principle of effective orders.

C. Impact Assessment

• National Uniformity: Eliminates fragmented service conditions—ranging from ₹40,000 fixed pay in Rajasthan to ₹7 lakh annual contracts in Gujarat—thereby stabilising HR management in courts.
• Judicial Efficiency: With professional managers handling planning, statistics, IT, HR, and infrastructure, judges can devote more hours to adjudication, reducing pendency.
• Institutionalisation of a Cadre: Court Manager is no longer an experimental grant-based post but a permanent part of judicial establishment, influencing future Finance Commission grants and State budgets.
• Ripple for Allied Services: The reasoning may extend to other ad-hoc judicial support roles (e-court technical staff, mediators, stenographers) demanding regularisation under parity logic.
• Administrative Law Precedent: Re-emphasises that prolonged contractual service in essential public posts triggers constitutional protection against arbitrary disengagement.

Complex Concepts Simplified

• Inherent/Original Jurisdiction (Art. 32): Power of the Supreme Court to entertain PILs directly without appeal, especially where fundamental rights or systemic reforms are in issue.
• Court Manager: A non-judicial professional (usually MBA, sometimes with law background) tasked with managing finance, HR, IT, statistics and infrastructure of courts.
• Class-II / Group-‘B’ Gazetted Officer: Government classification signifying a supervisory, mid-level officer entitled to formal ‘gazette’ notification, better pay scales, and allowances.
• Assured Career Progression (ACP): Scheme granting financial up-gradation at fixed intervals when regular promotions are not feasible, preventing stagnation.
• Suitability Test: A one-time evaluation (could be written, interview, or performance appraisal) used to filter existing contractual staff before absorption.

Conclusion

The 2025 ruling cements the place of Court Managers as an institutionalised, nationwide cadre essential to modern judicial administration. By compelling every High Court and State Government to adopt model rules, regularise existing personnel, create promotional avenues, and provide equitable pay, the Supreme Court bridges a decade-long implementation gap since the Thirteenth Finance Commission and its own 2018 directions.

Key takeaways:

1. Uniform Framework: Assam’s 2018 Rules become the de facto national template, fostering standardisation while preserving local flexibility.
2. Regularisation with Safeguards: Constitutional values of equality and non-arbitrariness guide the absorption process, balanced by a suitability filter to retain meritocracy.
3. Enhanced Judicial Productivity: By offloading managerial tasks, judges can focus on adjudication, aligning with the constitutional mandate of speedy justice (Art. 21).
4. Accountability & Deadlines: Personal liability for non-compliance is an innovative enforcement tool likely to inspire similar orders in other systemic reform cases.
5. Precedential Value: The judgment will serve as a touchstone for future litigation involving contractual public employees, particularly in critical sectors where continuity is vital.

In essence, the Supreme Court has transformed an under-utilised reform into a permanent fixture of the justice delivery architecture, marking a significant stride towards a 21st-century, performance-oriented judiciary.