Legal Dispute in Indian Federation of United Nations Association: Supreme Court’s Ruling

The case of Suresh Srivastava & Ors. vs. Sundeep Bhutoria delves into a legal dispute involving the Indian Federation of United Nations Association (IFUNA). The Supreme Court was called upon to determine the validity of the High Court’s decision to register a Public Interest Litigation (PIL) concerning the association and to evaluate whether the respondent in the case should have been allowed to assist the court as an amicus curiae.

This case highlights the complexities of civil disputes intertwined with public interest concerns. The Supreme Court’s judgment carefully examined the role of PILs and the propriety of allowing a disputant to assume the role of a court assistant.

Background of the Case

The dispute originated from litigation between Suresh Srivastava and Sundeep Bhutoria, which was already pending in Civil Suit No. 554 of 2019 before the Additional District Judge-3, South District, Saket Courts, New Delhi. The High Court of Delhi, while disposing of the Letters Patent Appeal (LPA) No. 126 of 2022, directed the registration of a PIL to look into concerns related to IFUNA.

However, the appellants objected to the PIL, arguing that the High Court had overstepped its jurisdiction by initiating public interest proceedings based on a private dispute. Furthermore, the High Court’s order permitted the respondent, who was a direct disputant in the case, to assist the court in the PIL, effectively giving him the role of an amicus curiae.

Arguments of the Petitioner

The petitioners, led by senior counsel Pallav Shishodia, contended that:

The dispute between the parties was already being adjudicated in a separate civil suit, and there was no justification for the High Court to convert it into a PIL.
The High Court should not have granted the respondent an amicus role since he was not a neutral third party but rather a litigant with vested interests.
The High Court’s decision to register a PIL was beyond the scope of its jurisdiction, as it effectively treated a private legal conflict as a matter of public interest.

Arguments of the Respondent

The respondent, represented by senior counsel Gopal Sankaranarayanan, defended the High Court’s decision by stating:

The matter was of public importance since IFUNA, being an association linked to the United Nations framework, warranted scrutiny.
The High Court’s prima facie observations indicated potential governance issues within IFUNA, justifying the PIL registration.
The respondent had merely assisted the court in bringing certain facts to light and had not been granted special privileges beyond what was necessary to facilitate judicial scrutiny.

Supreme Court’s Analysis

The Supreme Court, presided over by Justices Dinesh Maheshwari and Aniruddha Bose, carefully examined the legal merits of the appeal. The Court acknowledged that while the High Court had the discretion to register a PIL in appropriate cases, it had erred in allowing a litigant with personal stakes to assume the role of an amicus curiae.

Key observations by the Supreme Court included:

Role of PILs: The Court reiterated that PILs should be non-adversarial and meant to address broader public concerns rather than private disputes masquerading as public interest issues.
Impartiality of Court Assistants: The Court found that allowing the respondent to assist the High Court in the PIL compromised the neutrality expected of an amicus curiae.
Separation of Proceedings: The Court affirmed that the dispute between the parties should continue in the civil court without interference from PIL proceedings.

Supreme Court’s Verdict

In its judgment dated March 21, 2022, the Supreme Court ruled as follows:

The PIL registered by the High Court could proceed but should be treated as a non-adversarial proceeding without the involvement of the respondent as an amicus curiae.
Paragraph 17 of the High Court’s order, which permitted the respondent to assist the Court, was annulled.
The petitioners were free to present their objections before the High Court regarding the PIL proceedings.

In summing up its decision, the Supreme Court stated:

“Even when we are not inclined to interfere with the matter at this stage, while leaving it open for the appellants to make all the relevant submissions before the High Court, we are of the view that when the High Court has registered the matter as a PIL, it ought to be dealt with as a non-adversarial litigation.”

Conclusion

The Supreme Court’s ruling in this case serves as an important precedent in delineating the boundaries of PILs and ensuring their impartial nature. By striking down the High Court’s decision to allow a disputant to assist as an amicus curiae, the Court reinforced the principle that PILs should be free from conflicts of interest and should genuinely serve the public good.

Petitioner Name: Suresh Srivastava & Ors..
Respondent Name: Sundeep Bhutoria.
Judgment By: Justice Dinesh Maheshwari, Justice Aniruddha Bose.
Place Of Incident: New Delhi.
Judgment Date: 21-03-2022.

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