Dr. Babloo Singh & Ors. v. State of U.P. & Ors.
Background
A long-running dispute concerned how reservation rules under UP Act No. 4 of 1994 apply to recruitment of lecturers in aided degree colleges: specifically whether vacancies across different colleges could be "clubbed" for applying the reservation roster. A Division Bench of the Allahabad High Court had decided this in "Dr. Vishwajeet Singh's case," which the Supreme Court affirmed on appeal in 2017. When a fresh writ petition raised doubts about that very decision, a five-Judge Full Bench of the High Court was asked to resolve the question afresh, but it declined, holding itself bound by the Supreme Court's 2017 affirmance. The present petitioners challenged that refusal to refer the matter to a larger bench.
Decision Breakdown
The Supreme Court held that since it had already specifically agreed with and affirmed the Division Bench's reasoning in Dr. Vishwajeet Singh's case while dismissing the earlier civil appeals, that decision had legally "merged" into the Supreme Court's own order under the doctrine explained in Kunhayammed v. State of Kerala. Consequently, the High Court's five-Judge bench was correct that it could not revisit or refer the same question to a still-larger bench, since doing so would mean sitting over a point the Supreme Court itself had already approved. Finding no fresh ground to revisit the issue, the Court dismissed the special leave petitions challenging the High Court's refusal to refer.
Lesson Learnt
Once the Supreme Court dismisses an appeal while expressly agreeing with and affirming the High Court's reasoning (not merely declining to interfere), that reasoning becomes binding Supreme Court law through the doctrine of merger: lower courts cannot reopen or refer the same question to a larger bench afterward.