Citation Codes

Equivalent Citations

citation codes

Case Number

LPA No. 49 of 2009 (O&M), L.P.A No. 61 of 2009, L.P.A No. 66 of 2009, LPA No. 49 of 2009 (O&M); L.P.A No. 61 of 2009; and L.P.A No. 66 of 2009

Attorney(S)

Mr. Hemen Aggarwal, and Mr. S.K Sharma, Addl. Central Government Standing counsel.

Judges

Uma Nath Singh
A.N Jindal, JJ.

Acts

Force Act.Regulation 423 of the Medical Service of Armed Forces Regulation, 1983

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Smart Summary

Structured Summary of the Opinion — Letters Patent Appeals (May 19, 2009)

Factual and Procedural Background

This matter arises from Letters Patent Appeals challenging the judgment dated 21.05.2008 of the learned Single Judge, which had allowed four writ petitions: Writ Petition Nos. 6531 of 2005, 8384 of 2005, 10299 of 2005 and 12095 of 2006. The common legal question identified in the Single Judge's order was whether an army personnel who, while on leave, suffers injuries resulting in disability exceeding 25% is entitled to a disability pension.

The learned Single Judge had held that petitioners whose disability was assessed as exceeding 20% were entitled to disability pension from the date of invalidation from service, and directed payment of interest at 4% per annum where arrears were not paid within the stipulated period, under para 173 of the Pension Regulations for the Army, 1961.

The Division Bench (A.N. Jindal, J.) heard the Letters Patent Appeals and, after considering regulations, appendix provisions and multiple authorities, accepted the Letters Patent Appeals and dismissed the writ petitions. The judgment is dated May 19, 2009.

Legal Issues Presented

Whether an army personnel while on leave who suffers injuries resulting in disability exceeding 25% is entitled to disability pension.
Whether a disability assessed at 20% or more (as referred to in para 173 of the Pension Regulations for the Army, 1961) entitles an invalidated service member to disability pension from the date of invalidation.
Whether injuries or disabilities sustained while on leave are "attributable to" or "aggravated by" military service within the meaning of the Pension Regulations and allied rules (including Appendix-II and Regulation 423 of the Medical Service Regulations).

Arguments of the Parties

Union of India (Respondent) — Arguments as recorded

Advocates Mr. Heman Aggarwal and Mr. S.K. Sharma argued that injuries suffered by army personnel while on leave cannot, merely by reason of being on leave (or otherwise on active duty), be regarded as attributable to or aggravated by military service.
The Union relied upon Division Bench authorities of this Court (specified in the opinion as CWP Nos. 20348 of 2005 and 6959 of 2004) in support of the submission that injuries on leave are not automatically attributable to service.

Petitioners — Account of their arguments

The opinion does not contain a detailed account of the petitioners' legal arguments.

Table of Precedents Cited

Precedent	Rule or Principle Cited For	Application by the Court
CWP No. 12434 of 1999 (Division Bench) — decided 22.09.2006	Held (in facts of that case) that a soldier on annual leave who met with an accident beyond his control could be treated as on duty; emphasised nexus between normal living subject to military law while on leave and injuries suffered.	The Single Judge relied on this Division Bench authority to allow disability pension claims; the Division Bench in the present opinion noted that Single Judge had relied on it but examined whether the present cases were covered by the principles and ultimately concluded they were not.
Jarnail Singh v. Union of India and others, 1997 (3) SCT 484 (also cited as Jarnail Singh 1998 (1) SLR 418)	Used as precedent for the proposition that person on casual/annual leave can be treated as on duty for certain purposes and to illustrate when a causal nexus may or may not exist.	Referenced by courts relied upon by the Single Judge; the present Division Bench considered its ratio among other authorities and found that the facts before it did not fall within the principle as applied in the cited decisions.
Naik Kishan Singh v. Union of India and others, CWP No. 5531 of 2007 (decided 27.03.2007)	Referenced as authority where claim for disability pension was allowed (in circumstances where accident occurred while on leave).	Relied upon by the Single Judge; noted by the Division Bench in its survey of authorities but the court concluded the present cases were not covered by such authority.
Gurjit Singh v. Union of India and others, CWP No. 648 of 2007 (decided 20.02.2008)	Another Division Bench judgment relied on by the Single Judge which supported allowance of disability pension in leave-related injury circumstances.	Recorded as a judgment the Single Judge relied upon; the Division Bench examined the precedents collectively and reached its own conclusion that the present petitions did not fall within the principles applied in those judgments.
Union of India v. Baljeet Singh, 1997 (1) SLR 98	Explains criteria in guidelines under Regulations (including Regulation 173) for when disease/injury is attributable to military service; emphasises an affirmative factual determination is necessary that injury/disease was due to military service or aggravated by it.	Noted as a foundational apex authority relied upon by Division Bench judgments in favour of petitioners. The present Division Bench took notice of Baljeet Singh, discussed its principles and distinguished its application to the cases before it.
Dilbagh Singh Ors. (Ex. Nk) v. Union of India and Ors., 2008 (4) SCT 432 (Full Bench, Delhi High Court)	Full Bench issued guidelines (seven summarized points) emphasizing need for causal connection with service, that casual/annual leave status is not determinative and that injuries from activities unconnected with military service do not attract disability pension.	The Division Bench expressly considered these Full Bench guidelines and used them as a comparator in construing the phrase "disability attributable to or aggravated by military service" in the present appeals.
Ex. Sepoy Hayat Mohammed v. Union of India & Ors., 2008 (1) SCT 425	The Apex Court noted that treating personnel on leave as subject to Army Act or recall was intended for particular exigencies and it is impermissible to extrapolate such a rule to a general liability to pay disability pension.	Cited to caution against applying the "on leave = on duty" reasoning in a blanket manner to create liability for disability pension; the Division Bench relied on this observation in discounting an expansive approach.
Union of India & Ors. v. Surinder Singh Rathore, (2008) 5 SCC 747	Explains attributability of disease to service: disease will be regarded as attributable when it arose during service and service conditions contributed to onset; if service conditions influenced subsequent course it is aggravated by service.	The Division Bench treated this apex authority as clarifying principles on attributability and incorporated its guidance into the formulation of the corollary principles applied to the facts before it.
Joginder Singh (ratio referenced)	Referenced by the Full Bench (Dilbagh) to illustrate that certain personal activities (for example attending a marriage) do not constitute military duties and therefore may not create causal connection with service.	The present Court noted that the ratio was considered in prior authorities and that attendance at private activities may not create a causal link with military duties; the court found that the petitioners' cases did not fall within the principles that would make such activities attributable to service.

Court's Reasoning and Analysis

The Division Bench proceeded by a structured analysis: it first recorded the Single Judge's conclusion and then examined the statutory and regulatory framework governing disability pension entitlements, particularly:

Para 173 of the Pension Regulations for the Army, 1961, which provides that a disability pension may be granted where an individual is invalidated out of service on account of a disability "which is attributable to or aggravated by military service" and is assessed at 20% or over.
Appendix-II to the Regulations (defining when a personnel is to be treated as "on duty" and providing examples where an accident occurring when not strictly "on duty" may nonetheless be attributable to service), including the clause that treats risk "definitively enhanced in kind or degree by the nature, conditions, obligations or incidents of his service" as capable of making an accident attributable to service.
Regulation 423 of the Medical Service Regulations, 1983, which sets out the approach to "attributability to service," emphasising causal connection, consideration of direct and circumstantial evidence, benefit of reasonable doubt to the individual, the role of medical boards, and that wounds/injuries will be regarded as attributable if sustained during actual performance of duty.

The Court surveyed prior decisions at length. It noted that some Division Bench decisions had allowed disability pension claims where injuries occurred while the soldier was on leave (relying on the notion that persons on leave are still subject to Army discipline and recall). The Court also recorded the Full Bench (Dilbagh) guidelines, which emphasized that a causal connection with military service is essential and that mere presence on leave is not determinative.

The Court accepted the principle drawn from apex and other authorities that attributability or aggravation by military service requires a factual and causal nexus between the duties/conditions of service and the injury/disease. It relied particularly on the explanation in Surinder Singh Rathore and the cautions expressed in Ex. Sepoy Hayat Mohammed about not extrapolating the "on leave" status into an automatic liability to pay disability pension.

On the basis of these authorities and the regulatory provisions, the Court formulated corollary principles construing the phrase "disability attributable to or aggravated by the military service." Those principles include (as expressed in the opinion):

Disability arising during service on account of conditions and incidents of service is attributable to service.
Disability sustained while en route to/from residence and place of duty during leave may be covered if it has the requisite connection.
If no disease existed at entry and it was not detectable on entry but is found at boarding out, it is ordinarily deemed to have arisen in service; there must be a sufficiently close connection between injury and duties.
Disability resulting from self-infliction, negligence, misconduct, or activities remotely connected with service will not be attributable to service.
Disabilities arising from being targeted (e.g., as a traitor or rival group member) on account of one's status in the forces may be attributable to service.
Disability suffered while "on duty" as defined in Appendix-II is covered.

Applying those principles to the cases before it, the Court concluded that none of the petitioners' cases were covered by the formulated principles or by the Full Bench guidelines and apex authority relied upon. The Court therefore found that the Single Judge's allowance (which had relied upon certain Division Bench decisions treating leave-status incidents more liberally) was not sustainable on the facts before it.

Holding and Implications

HOLDING: The Letters Patent Appeals are ACCEPTED and the civil writ petitions filed by the petitioners are DISMISSED.

Implications:

Direct effect on the parties: The petitioners who had been allowed disability pension by the Single Judge are denied that relief by the Division Bench; their writ petitions are dismissed.
On legal principle: The Division Bench reiterated that entitlement to disability pension under Para 173 requires an affirmative factual finding of attributability or aggravation by military service based on the regulatory tests (Appendix-II, Regulation 423 and related authorities). The judgment emphasises that mere occurrence of injury while on leave does not automatically translate into an entitlement; a causal nexus with service must be established.
The opinion does not purport to lay down a completely novel rule beyond construing existing regulations and authorities; it applies established principles (including those explained by the Supreme Court in Surinder Singh Rathore and the guidance in Dilbagh). The Court concluded the present cases did not meet those principles and therefore dismissed the petitions.

Judge: A.N. Jindal, J. — Decision dated: May 19, 2009.

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Union Of India And Others v. Sumanjit Singh

A.N Jindal, J

These L.P As are against the judgment dated 21.5.2008 passed by the learned Single Judge, whereby he allowed all the four writ petition Nos. 6531 of 2005, 8384 of 2005, 10299 of 2005 and 12095 of 2006, involving the common question of law which reads as under :-

“Whether an army personnel while on leave suffers injuries resulting disability exceeding 25% is entitled to disability pension?”

The learned Single Judge while allowing the aforesaid petitions observed that the petitioners having disability exceeding 20% were entitled to disability pension from the date of invalidation from service. The petitioners were also allowed interest @ 4% per annum if the arrears of pension are not paid within stipulated period under the provisions of para 173 of the Pension Regulation of the Army, 1961 which envisages that only those candidates are entitled for disability pension whose disability is assessed as 20% or more. The aforesaid para is re-produced as under :-

“Para 173. Unless otherwise specifically provided a disability pension consisting of service element and disability element may be granted to an individual who is invalidated out of service on account a disability which is attributable to or aggravated by military service in non-battle casualty and is assessed at 20 per cent or over.”

Mr. Heman Aggarwal, & Mr. S.K Sharma, Advocates appearing on behalf of Union of India while urging that any injury suffered by the army personnel while on leave, and otherwise on active duty in the army, if suffers any disability, then the same cannot be said to be attributable or aggravated to the military service, has placed reliance on the judgment delivered by the Division Bench of this Court in CWP No. 20348 of 2005 and 6959 of 2004. Whereas the learned Single Judge has placed reliance upon the Division Bench judgment delivered by this Court in C.W.P No. 12434 of 1999 decided on 22.9.2006, wherein the facts were that “a Sepoy in the Indian Army was on leave to his home town and while moving on scooter, he met with an accident with a truck and suffered injuries, resulting amputation of his leg. He was invalidated from service being low medical category. His claim for disability was rejected by the authorities. This Court, while further relying upon the Division Bench judgments of this Court in Jarnail Singh v. Union of India and others 1997 (3) SCT 484, and Naik Kishan Singh v. Union of India and others, CWP No. 5531 of 2007 decided on 27.3.2007 the claim for disability pension was allowed with the following observations:-

“No doubt, when the petitioner met with an accident, he was on annual leave, but the accident was beyond control of the petitioner who was not performing any act, he ought not to have done. In view of the settled law by the Apex Court, a person on casual/annual leave is deemed to be on duty and there must be apparent nexus between normal living of person subject to military law while on leave and injuries suffered by him. A person on annual leave is subject to Army Act and can be recalled at any time as leave is at discretion of authorities.”

Another judgment referred to by Single Judge is Gurjit Singh v. Union of India and others, CWP No. 648 of 2007, decided on

20.2.2008. The reasons for relying upon the aforesaid Division Bench judgments of this court has been given by the learned Single Judge, as under :-

“All the above referred cases are squarely covered by the judgments of Division Bench referred to hereinabove. As a matter of fact, the Hon'ble Division Bench relied upon the judgment of the Apex Court in the case of Union of India v. Baljeet Singh 1997 (1) SLR 98.”

As a matter of fact, the words “injury attributable to” or “aggravated by the military services” refers to any non battle casualty. As per para 173 of the Pension Regulations of the Army, 1961 these words are to be determined on the basis of the parameters as set down in Appendix-II. The words “disability” attributable to or aggravated by the military service has been explained in Appendix-II of the Pension Regulation Rules. The relevant extract of the Appendix-II is reproduced for facility of reference :-

“12. A personel subject to the disciplinary code of the Armed Forces is on “duty” :-

(a) When performing an official task or a task, failure to do which would constitute an offence triable under the disciplinary code applicable to them.

(b) When moving from one place of duty to another place of duty irrespective of the mode of movement.

(c) During the period of participation in recreation and other unit activities organized or permitted by Service authorities and during the period of travelling in a body or singly by a prescribed or organized route.

(d) When proceeding from his duty station to his leave station or returning to duty from his leave station, provided entitled to travel at public expense i.e on railway warrant, on concessional voucher, on cash TA (irrespective of whether railway warrant/cash TA is admitted for the whole journey or for a portion only), in government transport or when road mileage is paid/payable for the journey.

(e) When journeying by a reasonable route from one's official residence to and back from the appointed place of duty irrespective of the mode of conveyance, whether private or provided by the Government.

(f) An accident which occurs when a man is not strictly “on duty” as defined may also be attributable to service, provided that it involved risk which was definitively enhanced in kind or degree by a nature, conditions, obligations or incidents of his service and that the same was not a risk common to human existence in modern conditions in India. Thus for instance, where a person is killed or injured by another party by reason of belonging to the Armed Forces, he shall be deemed “on duty” at the relevant time. This benefit will be given more liberally to the claimant in cases occurring on active services as defined in the Army/Navy/Air Force Act.”

Regulation 423 of the Medical Service of Armed Forces Regulation, 1983 seeks to define the term “attributability to service” and incidents which will fall within the parameters of this phrase :

“423. Attributability to Service :

(a) For the purpose of determining whether the cause of a disability or death is or is not attributable to service, it is immaterial whether the cause giving rise to the disability or death occurred in an area declared to be a Field Service/Active Service area or under normal peace conditions. It is, however, essential to establish whether the disability or death bore a casual connection with the service conditions. All evidence both direct and circumstantial will be taken into account and benefit of reasonable doubt, if any, will be given to the individual. The evidence to be accepted as reasonable doubt, for the purpose of these instructions should be of a degree of cogency, which though not reaching certainty, nevertheless carry the high degree of probability. In this connection, it will be remembered that proof beyond reasonable doubt does not mean proof beyond a shadow of doubt. If the evidence is so strong against an individual as to leave only a remote possibility in his favour, which can be dismissed with the sentence “of course it is possible but not in the least probable” the case is proved beyond reasonable doubt. If on the other hand, the evidence be so evenly balanced as to render impracticable a determinate conclusion one way or the other, then the case would be one in which the benefit of doubt could be given more liberally to the individual, in cases occurring in Field Service/Active Service areas.

(b) The cause of disability or death resulting from wound or injury will be regarded as attributable to service if the wound/injury was sustained during the actual performance of “duty” in armed forces. In case of injuries which were self inflicted or due to an individual's own serious negligence or misconduct, the Board will also comment how far the disability resulted from self-infliction, negligence or misconduct.

© The cause of disability or death resulting from a disease will be regarded as attributable to service when it is established that the disease arose during service and the conditions and circumstances of duty in the armed forces determined and contributed to the onset of the disease. Cases, in which it is established that service conditions did not determine or contribute to the onset of the disease but influenced the subsequent course of the disease will be regarded as aggravated by the service. A disease which has led to an individual's discharge or death will ordinarily be deemed to have arisen inservice if no note of it was made at the time of the individual's acceptance for service in the armed forces. However, if medical opinion holds, for reasons to be stated that the disease could not have been detected on medical examination prior to acceptance for service, the disease will not be deemed to have arisen during service.

(d) The question, whether a disability or death is attributable to or aggravated by service or not, will be decided as regards its medical aspects by a medical board or by the medical officer who signs the death certificate. The medical board/medical officer will specify reasons for their/his opinion. The opinion of the medical board/medical officer, in so far as it relates the actual cause of the disability or death and the circumstances in which it originated will be regarded as final. The question whether the cause and the attendant circumstances can be attributed to service will, however, be decided by the pension sanctioning authority.

(e) To assist the medical officer who signs the death certificate or the medical board in the case of an invalid, the C.O unit will furnish a report on :

(i) AFMS F-81 in all cases other than those due to injuries.

(ii) IAFY-2006 in all cases of injuries other than battle injuries.

(f) In cases where award of disability pension or reassessment of disability is concerned, a medical board is always necessary and the certificate of a single medical officer will not be accepted except in case of stations where it is not possible or feasible to assemble a regular medical board for such purposes. The certificate of a single medical officer in the latter case will be furnished on a medical board form and countersigned by the ADMS (Army)/DMS (Navy)/DMS (Air).”

The Division Bench judgments of this court as referred to above, has mainly allowed the disability pension while relying upon the Apex Court judgment delivered in case Union of India v. Baljeet Singh, 1997 (1) SLR 98, wherein it was observed as under :-

“6. … It is seen that various criteria have been prescribed in the guidelines under the Regulations as to when the disease or injury is attributable to the military service. It is seen that under Regulation 173 disability pension would be computed only when disability has occurred due to wound, injury or disease which is attributable to military service or existed before or arose during military service and has been and remains aggravated during the military service. If these conditions are satisfied, necessarily the incumbent is entitled to the disability pension. This is made amply clear from Clauses (a) to (d) of para 7 which contemplates that in respect of a disease the rules enumerated thereunder required to be observed. Clause © provides that if a disease is accepted as having arisen in service, it must also be established that the conditions of military service determined or contributed to the onset of the disease and that the conditions were due to the circumstances of duty in military service. Unless these conditions satisfied, it cannot be said that the sustenance of injury per se is on account of military service. In view of the report of the Medical Board of doctors, it is not due to military service. The conclusion may not have been satisfactorily reached that the injury though sustained while in service, it was not on account of military service. In each case, when a disability pension is sought for making a claim, it must be affirmatively established, as a fact, as to whether the injury sustained was due to military service or was aggravated which contributed to invalidation for the military service.”

While taking notice of and distinguishing Baljeet Singh's case (supra), the Full Bench of the Delhi High Court in case Dilbagh Singh Ors. (Ex. Nk) v. Union of India and Ors. 2008 (4) SCT 432 took a contrary view and summed up the matter while issuing the following guidelines :-

“1. Firstly, it is required to be established that the injury or fatality suffered by the concerned military personnel bears a casual connection with military service.

2. Secondly, if this obligation exists so far as discharged from the Armed Forces on the opinion of the Medical Board the obligation and responsibility a fortiori exists so far as injuries and fatalities suffered during casual leave are concerned.

3. Thirdly, as a natural corollary it is irrelevant whether the concerned personnel was on casual or annual leave at the time or at the place when and where the incident transpired. This is so because it is the causal connection which alone is relevant.

4) Fourthly, since travel to and fro the place of posting may not appear to everyone as an incident of military service, a specific provision has been incorporated in the Pension Regulations to bring such travel within the entitlement for Disability Pension if an injury is sustained in this duration.

5) Fifthly, the Hon'ble Supreme Court has simply given effect to his Rule and has not laid down in any decision that each and every injury sustained while availing of casual leave would entitle the victim to claim Disability Pension.

6) Sixthly, provisions treating casual leave as on duty would be relevant for deciding questions pertaining to pay or to the right of the authorities to curtail or cancel the leave. Such like provisions have been adverted to by the Supreme Court only to buttress their conclusion that travel to and fro the place of posting is an incident of military services.

7) Lastly, injury or death resulting from an activity not connected with military service would not justify and sustain a claim for Disability Pension. This is so regardless of whether the injury or death has occurred at the place of posting or during working hours. This is because attributability to military service is a factor which is required to be established.”

The ratio of the judgment delivered in case Jarnail Singh v. Union of India 1998 (1) SLR 418 was also discussed by the Full Bench of the Hon'ble Delhi High Court in case Dilbag and Ors. (Ex. Nk) v. Union of India and Ors. 2008 (4) SCT 432 and observed as under :-

“We see no casual connection, whatsoever, between the accident and the discharge of duties; attending a marriage cannot possibly be seen as analogous to military duties. The ratio of Joginder Singh is not applicable.”

The main reason which influenced the Division Bench of this Court to grant Disability Pension was that persons on annual leave are subject to Army Act and can be recalled at any time as leave is at the discretion of the authorities concerned. But the Apex Court in case Ex. Sepoy Hayat Mohammed… v. Union Of India & Ors.…, 2008 (1) SCT 425 observed that “the petitioner was eligible for the grant of Disability Pension owing to the fact that while on casual leave in his home he suffered several injuries owing to a steel girder and roof slabs falling on him. One of the reasons which appear to have persuaded the same Division Bench was that persons on annual leave are subject to the Army Act and can be recalled at any time as leave is at the discretion of the Authorities concerned. A rule of this nature is necessary to cover the eruption of insurgencies or the breakout of a war. They neither envisaged nor attempted to deal with liability to pay Disability Pension. It is impermissible to extrapolate a rule catering for a particular situation to altogether different circumstances.”

The Apex Court in case Union of India and others v. Surinder Singh Rathore, (2008) 5 SCC 747 while explaining the disability attributable to the service observed as under :-

“9 © The cause of a disability or death resulting from a disease will be regarded as attributable to service when it is established that the disease arose during service and the conditions and circumstances of duty in the armed forces determined and contributed to the onset of the disease. Cases, in which it is established that service conditions did not determine or contribute to the onset of the disease but influenced the subsequent course of the disease, will be regarded as aggravated by the service. A disease which has led to an individual's discharge or death will ordinarily be deemed to have arisen in service if no note of it was made at the time of the individual's acceptance for service in the armed forces. However, if medical opinion holds, for reasons to be stated that the disease could not have been detected on medical examination prior to acceptance for service, the disease will not be deemed to have arisen during service.”

Thus, as a corollary of the aforesaid judgments, we construe the words “disability attributable to or aggravated by the military service” as under :-

1. Disability which has been attracted by the army personnel on account of the disease which occurred during his service on account of the conditions and incidents of the service.

2. If the petitioner was on his way to and from his residence to place of duty, during his period of leave, the disease or disability so attracted by the army personnel would be covered by the disability attributable to or aggravated by the Military Service

3. If the personnel had no disease at the time of entry into service and the same was not detected on medical examination prior to his entry into service, however, it was detected at the time of boarding him out then the same would be deemed to have occurred during service. The disease must have direct and approximately close connection between the injury suffered and the discharge of his duties.

4. The disability or the injury suffered by the personnel, by way of self infliction, negligence or misconduct, during his period of leave, or he suffers such injury at the hands of some one, or has been for a different motive, remotely connected with the army services would not amount to an injury attributable to aggravated by the military service.

5. If the army personnel is caused any type of injury or suffers any disability on account of the fact that he has been considered as traitor, rebellion or a member of a rival group of the armed forces, then such disability could be covered and could be termed as disability attributable to and aggravated by the military services.

6. Disability suffered by any army personnel on duty as defined in Appendix II of the Army Regulations Rules, 1961.

Thus, on examination of the cases before us, none of the cases is covered by the aforesaid principles and also by the guidelines issued by the Apex Court in Surinder Singh Rathore's case (supra) so also by the Full Bench of Delhi High Court in case Dilbagh Singh Ors. (Ex. Nk) v. Union of India and Ors. 2008 (4) SCT 432.

Consequently, the Letters Patent Appeals are accepted and civil writ petitions filed by the petitioners stand dismissed.

(Uma Nath Singh)

(A.N Jindal) JUDGE

Judge

May 19, 2009 deepak

Union Of India And Others v. Sumanjit Singh

Structured Summary of the Opinion — Letters Patent Appeals (May 19, 2009)

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

Union of India (Respondent) — Arguments as recorded

Petitioners — Account of their arguments

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

Union Of India And Others v. Sumanjit Singh

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