Bengal Immunity Co. v. State of Bihar
Rule established
The Supreme Court of India can overrule its own previous decisions; stare decisis is not an inflexible rule in India
Facts
- Bengal Immunity Co. challenged the imposition of sales tax by Bihar on goods dispatched from Calcutta to Bihar
- The case involved interpretation of Article 286 of the Constitution regarding inter-state trade
- An earlier seven-judge bench decision in State of Bombay v. United Motors (1953) had interpreted the provision differently
- A larger bench was constituted to reconsider the correctness of the earlier ruling
Issues
- Whether the Supreme Court of India is bound by its own previous decisions under the doctrine of stare decisis
- Can a larger bench overrule an earlier decision if convinced it was wrongly decided
Held
- The Supreme Court held that unlike the House of Lords (which at that time considered itself bound by its own decisions), the Supreme Court of India is not absolutely bound by its own previous pronouncements. While the doctrine of stare decisis promotes certainty, uniformity, and predictability in the law, it must yield when a previous decision is found to be plainly erroneous or based on a misapprehension of law. The court overruled the earlier decision, affirming that judicial correctness must prevail over mere consistency.
Ratio Decidendi
The Supreme Court of India is not inflexibly bound by the doctrine of stare decisis and may overrule its own previous decisions when satisfied that the earlier view was erroneous, as the need for correctness in law outweighs the desirability of certainty achieved through rigid adherence to past pronouncements.
How to use it in an exam
- This is the leading case on the flexibility of stare decisis in India. Use it to contrast the Indian position with the pre-1966 House of Lords position (Practice Statement). It demonstrates that precedent is persuasive authority even within the same court when justice demands departure. Essential for any answer on binding force of precedent.
- Key line: "Stare decisis is not an inexorable command in India; the Supreme Court can overrule its own decisions when the earlier view is plainly erroneous."
Source
Source: Supreme Court Reports
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.