Supreme Court sanction validity judgment holds High Court must not intervene when SC is seized; challenge to sanction can be made only before Supreme Court.
Case Name: In Re: T.N. Godavarman Thirumulpad — I.A. Nos. 20650 & 75033 of 2023; I.A. No. 199355 of 2024; Transferred Case (Criminal) No. 2 of 2025
Citation: 2025 INSC 1344
Date of Judgment/Order: 11 November 2025
Bench: B.R. Gavai, CJI; K. Vinod Chandran, J.; N.V. Anjaria, J.
Held: The Supreme Court held that when a sanction order is passed during the pendency of suo motu proceedings before the Court, and in furtherance of its earlier directions, no other court—including a High Court—may entertain a challenge to that sanction. Any such challenge amounts to interference in proceedings before the Supreme Court. The Court found that both the officer, Mr. Rahul, and the Uttarakhand High Court acted improperly: the officer should have approached the Supreme Court instead of filing a writ petition, and the High Court should not have granted interim relief despite explicit references in the sanction order to Supreme Court directions. While accepting the officer’s unconditional apology in view of his service record and reliance on incorrect legal advice, the Court held that the validity of the sanction can be challenged only before the Supreme Court.
Summary: These proceedings arise from ongoing Supreme Court monitoring of illegal constructions and extensive tree felling in the Corbett Tiger Reserve. The CBI investigation, status reports, and departmental inquiries were supervised by the Supreme Court. Although sanctions were granted against all other officers, the State of Uttarakhand initially refused sanction against Mr. Rahul. After oral observations by the Supreme Court on 8 September 2025 questioning this special treatment, the State reversed its earlier decision and granted sanction on 16 September 2025, which was accepted by the Court on 17 September 2025. Despite personally following Supreme Court proceedings by video conferencing, Mr. Rahul filed a writ petition before the Uttarakhand High Court challenging the sanction. The High Court admitted the matter and stayed the operation of the sanction order. When this conduct was brought to the Supreme Court’s attention, it expressed deep concern, noting that the officer’s actions—and the High Court’s interim stay—ran contrary to judicial propriety, as the sanction was integrally linked to Supreme Court–monitored proceedings. The Court emphasised that the High Court failed to notice that the sanction order itself referred to Supreme Court directions. During the hearing, after initially attempting to justify his conduct, the officer tendered an unconditional apology, attributing his misstep to incorrect legal advice.
Decision: The Supreme Court accepted the officer’s unconditional apology, discharged the notice of contempt, and permitted withdrawal of Writ Petition (Criminal) No. 1220 of 2025, which had already been transferred to the Supreme Court as T.C. (Crl.) No. 2 of 2025. The transferred case was disposed of. The Court clarified that while the officer remains free to seek discharge or quashing on any permissible legal grounds, he may challenge the validity of the sanction order only before the Supreme Court and before no other forum. All pending applications were disposed of.