Sudama Singh & Ors. v. Deepak Mohan Spolia & Ors.
Background
Residents of the New Sanjay Camp slum cluster in Delhi, whose jhuggies (hutments) had been demolished for an underpass, had won a 2010 Delhi High Court judgment in their PIL declaring the demolition illegal and directing relocation with alternative sites for "eligible" petitioners. When the authorities did not fully implement this, the petitioners filed a contempt petition, but the High Court held that only the four named writ petitioners, not the other affected persons listed in annexures to the petition, were entitled to the relocation benefit, and dismissed the contempt plea. The aggrieved appellants (through advocate Prashant Bhushan) appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that the High Court erred by reading only paragraph 62 of the 2010 judgment in isolation and ignoring the rest of the judgment, which made clear that the benefit extended to all affected persons named in the annexures to the writ petition, not merely the four formal petitioners. The Court reasoned that in a public interest litigation it is well-settled that not every affected person needs to be a named petitioner, and since the original petitioners had themselves furnished the names of affected persons as annexures, those persons were also entitled to relief (subject to verification of eligibility under the relocation policy). The appeals were allowed to this extent, and the respondents were directed to implement the judgment accordingly within three months.
Lesson Learnt
In public-interest litigation, relief granted to "the petitioners" can extend to all similarly situated persons named in the petition's annexures, not just the formally named petitioners: courts must read a judgment's operative directions together with its full reasoning, not in isolated fragments.