No case for review of the verdict, rules Supreme Court while dismissing review petition challenging Aadhar Judgement

No case for review of the verdict, rules Supreme Court while dismissing review petition challenging Aadhar Judgement

Case Title: Beghar Foundation v. Justice K.S. Puttaswamy

By a 4:1 majority, the Supreme Court dismissed a slew of review petitions contesting the Constitution Bench's decision in the Aadhaar case [Puttaswamy  v. Union of India].

While Justices AM Khanwilkar, Ashok Bhushan, S. Abdul Nazeer, and BR Gavai agreed that there was no case for review of the verdict, Justice DY Chandrachud disagreed. The review petitions were heard 'by circulation,' rather than in open court.

According to the majority, a change in the law or subsequent decision/judgment of a coordinate or bigger Bench cannot be considered a reason for review in and of itself. 

Justice Chandrachud, on the other hand, believes that the review petitions should be kept pending until the bigger bench rules on the problems raised in Rojer Mathew. In his dissent he observed:

"If these review petitions are dismissed and the bigger bench reference in Rojer Mathew disagrees with the majority decision in Puttaswamy (Aadhaar-5J.), it will have serious ramifications not only for judicial discipline but also for the goals of justice. As a result, the current batch of review petitions should be kept pending until the bigger bench resolves the issues raised in Rojer Mathew. In all humility, I find that the fundamental norms of uniformity and the rule of law demand that a decision on the Review Petitions be postponed till the case is sent to the Larger Bench," in his dissenting opinion, as stated by Justice DY Chandrachud.

Justice AK Sikri wrote the majority judgement in the Aadhaar Case, which read down some of the provisions of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits, and Services) Act 2016, striking down a few but significant ones (primarily Sections 33(2), 47, and 57), while upholding the rest. In his dissent, Justice Chandrachud stated that the entire Aadhaar initiative is unlawful.

Later, in its judgement [Rojer Mathew v. South Indian Bank Ltd] examining the validity of provisions of the Finance Act 2017 affecting tribunals, another Constitution Bench led by Justice Ranjan Gogoi (then CJI) questioned the majority judgment's interpretation that the Aadhaar Bill is a Money Bill within the meaning of Article 110(1) of the Constitution. It was highlighted that the majority opinion in the Aadhaar judgement did not analyse the effect of the word "only" in Article 110(1) and did not examine the ramifications of a finding when part of the provisions of a statute approved as a "Money Bill" do not adhere to Article 110(1)(a) (g). As a result, the bench referred the case to a larger bench.