Stare Decisis, Judicial Discipline, and Precedential Effect of Coordinate Benches

Under the established principles of precedent and judicial discipline affirmed by the Constitution Bench in National Insurance Co. Ltd. v. Pranay Sethi, a coordinate Bench of equal strength is bound by the ratio decidendi of an earlier coordinate Bench decision. If a subsequent Bench of equal strength disagrees with the legal principle or statutory interpretation laid down by an earlier coordinate Bench, it cannot simply strike a divergent note, distinguish the earlier binding view on tenuous grounds, or render a contrary decision; it is duty-bound to refer the matter to a larger Bench. Passing observations, conclusions reached sub silentio without arguments addressed or statutory provisions analyzed, or orders passed on equitable concessions do not constitute binding precedent under Article 141. The binding ratio of Ramesh Gobindram regarding the limited scope of Tribunal jurisdiction and Civil Court ouster survived subsequent divergent coordinate decisions like Anis Fatma Begum, as those divergent decisions failed to follow proper judicial referral procedure to a larger Bench. (Habib Alladin & Ors. v. Mohammed Ahmed | 2026 INSC 90)