It is, here, necessary to underline that the subject judgement of the
Supreme Court has not one but three salient facets.

The first, and the central, one is too obvious. The SC has rejected
outright the Special Leave Petition filed before it, which asked for a
reinvestigation - by rejecting the findings by the SIT earlier constituted
by it for that purpose, into the role of key members in the Gujarat
administration under the watch of which the 2002 carnage had taken place.
Unless one goes into specific merits of the case, that is quite par for the
course. (The first article, provided below, does that quite in good detail.)

The second one, which has attracted a lot of (unfavourable) attention, is
that the judgement has pronounced that a co-petitioner and also two others
- who were not even before the Court, " need to be in the dock and
proceeded with in accordance with law." It is, on the face of it, quite
unprecedented and it means that henceforth even seeking legal remedies for
some (perceived) grave injustice done by the state may attract prosecution
and punishment. (The second report below is primarily focussed on that.)
It bears mentioning that capitalising on that, without wasting any time,
next day afternoon - a Saturday, members of the Gujarat Anti-Terrorism
Squad (ATS) barged into the said co-petitioner's Mumbai residence to bring
her to Gujarat, without any warrant.
It is worth mentioning that Justice Khanwilkar, who had headed the
three-judge bench, has now given somewhat a repeat performance as the head
of a two-judge bench in another case (ref.: <
https://www.livelaw.in/top-stories/supreme-court-dismisses-plea-for-independent-probe-into-alleged-extra-judicial-killings-of-chhattisgarh-tribals-by-forces-with-rs-5-lakh-costs-203736
>).

*There is, however, a third dimension too*. This has, though, largely gone
under the radar.
Not too long after the judgement delivered, the Union Home Minister - in an
interview (ref.: <
https://www.republicworld.com/india-news/politics/amit-shah-breaks-silence-on-2002-gujarat-riots-exposes-troika-over-lies-against-pm-modi-articleshow.html>)
<https://www.republicworld.com/india-news/politics/amit-shah-breaks-silence-on-2002-gujarat-riots-exposes-troika-over-lies-against-pm-modi-articleshow.html>
to
the ANI that would be splashed all over by noon the following day, without
batting an eyelid has - using the judgement as the necessary and sufficient
prop, floated a bold narrative to trash all the charges  against Modi - for
inaction or even complicity, the then Gujarat Chief  Minister and hold
Teesta Setalvad primarily responsible for all the "lies" spread (ref.: <
https://twitter.com/ANI/status/1540555262612107264
<https://twitter.com/ANI/status/1540555262612107264?ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembed%7Ctwterm%5E1540555262612107264%7Ctwgr%5E%7Ctwcon%5Es1_&ref_url=https%3A%2F%2Fwww.republicworld.com%2Findia-news%2Fpolitics%2Famit-shah-breaks-silence-on-2002-gujarat-riots-exposes-troika-over-lies-against-pm-modi-articleshow.html>>).
So, *at one stroke of the judgement, the loads of opprobrium heaped upon
Modi by various entities - including the Supreme Court itself (that, inter
alia, had equated him with the Emperor Nero), the then Prime Minister from
his own party (who had publicly advised him to discharge his duties
befitting his office), the NHRC, a number of other national and
international bodies for human rights (that included a fact-finding report
by a team headed by a former Supreme Court judge and with a former High
Court judge as a member), foreign governments (the US had even
cancelled* *Modi's
visa), were just brushed aside - in fact, swept away*. This had, rather
recently, been sort of prefigured by the dropping of the Gujarat riots from
the NCERT history syllabus (ref.: <
https://indianexpress.com/article/education/ncert-drops-content-on-gujarat-riots-from-class-12-textbook-7974329/
>).
With the help of the over-obliging Indian media, this may soon become the
dominant narrative. That deserves to be duly noted.

*I/II*.
<<On August 16, 2017, Justice A.M. Khanwilkar was part of a bench of the
Supreme Court that, *33 years after the heart-wrenching events* [emphasis
added], reopened 241 cases arising out of the 1984 anti-Sikh pogrom and
appointed a Supervisory Commission to examine the closure reports filed in
these cases by the Special Investigation Team (SIT).

Despite the fact that multiple SITs, Commissions of Enquiry and individual
trials in the matter including, incidentally, a commission of enquiry
headed by Justice Nanawati and another earlier commission headed by the
then sitting Chief Justice of India, Justice Ranganath Mishra, had already
gone into the matter, the Supreme Court felt, and rightly so, that cases
where the SIT had filed closure reports needed to be looked into again.

Cut to June 24, 2022 and another bench headed by Justice Khanwilkar
expressed its indignation at the attempt by a widow, whose husband, a
former member of Parliament, had a burning tyre put around his neck, had
his hands and legs dismembered, and was burned alive on a pyre by a rioting
mob in the 2002 Gujarat riots, to “*keep the pot boiling*”.
...
Finally, the court has returned findings on the actions, motivations and
intentions of individuals involved without hearing them. For instance, the
court finds that the testimony of Sanjiv Bhatt, R.B. Sreekumar and Haren
Pandya (who was since murdered under mysterious circumstances) collectively
described as “*disgruntled officials of the State of Gujarat*” was
only to “*create
sensation by making revelations which were false to their own knowledge*”.
The court also refuses to entertain the petition at the instance of
activist Teesta Setalvad on the basis of the attack mounted by the
Solicitor General appearing for the State of Gujarat on her character and
antecedents, all without even having to place these supposed ‘facts’ on
affidavit.

Subsequent events have shown that the damning of the role played by
Setalvad, Sreekumar and Bhatt by the court in its judgement has had an
immediate impact on the liberty of the individuals concerned as the court’s
finding that they “*need to be in the dock and proceeded with in accordance
with law*” has been acted upon with alacrity by the Gujarat Police, which
moved to arrest Setalvad (from Mumbai) and Sreekumar (from Ahmedabad) the
very next day, which happened to be a Saturday since the judgement happened
to have been pronounced on a Friday.

It is a fairly elementary rule of natural justice that no finding can be
returned by a court about an individual without first giving them an
opportunity of being heard. Setalvad, although before the court as a
petitioner, was not called upon to defend her own conduct, and Sreekumar
and Bhatt were not before the court at all. It is contrary to all known
principles of natural justice for the court to have indicted them for their
respective roles in the saga. In fact, it was specifically stated by Sibal
that he did not wish to rely on the evidence of Bhatt as Bhatt’s evidence
was disputed and he was arguing his case only on the basis of undisputed
evidence that was before the SIT. Further, since Bhatt’s evidence related
to the meeting on February 27, 2002, which itself was not being pressed,
there was no occasion for the court to concern itself with his character
and antecedents.

The remit of the SIT, the magistrate in the protest petition, the high
court in revision and now the Supreme Court was merely to look at the
evidence available and decide whether a trial was necessitated to weigh the
evidence and decide the truth of the allegations. At this stage, all that
the court was required to do was to look at the body of evidence collected
by intelligence agencies demonstrating the failure of the administration at
every step, note the confessions that were part of the Tehelka tapes that
had already been forensically verified and which made out a clear case that
these failures of administration were deliberate and were, in fact,
carefully organised and orchestrated, note the fact that the amicus curie
appointed by the Supreme Court had disagreed with key findings of the SIT
and felt that a trial was necessary, note that the SIT had recorded the
denials by the accused and there were contradictory statements of witnesses
such as Bhatt and Sreekumar all of which required cross examination and
send the matter for trial.

Instead, the SIT as well as each of the courts have conducted a mini trial
where they have weighed evidence, discarded video recorded confessions on
the basis of lack of corroboration, discarded corroborating evidence on the
basis that it establishes the act but not the intention to commit a wrong,
accepted inadmissible exculpatory statements made to police by the
potential accused persons without any opportunity of cross examination,
discredited witnesses on the basis of their supposed antecedents, explained
away inconsistencies and returned findings of innocence, all of which can
be done only during a trial.

*In the end, all that remains to be done is for us, as historians of the
Supreme Court, to read the judgement and explain to future generations of
lawyers what the judgement leaves to be desired, until our audacity to
criticise judgements of this court too is indicted and this privilege taken
away* [emphasis added].

(Excerpted from: <
https://thewire.in/law/supreme-court-judgment-in-zakia-jafri-case-missed-both-the-woods-and-the-trees
>.)

*II*.
<<It is not just the dismissal of the appeal that has surprised people – an
appeal may, after all, be allowed or dismissed by an appellate court; it is
the gratuitous comments that the bench has pronounced on the appellants and
the counsel and the supporters of the appellants. In the most astonishing
comment, the Supreme Court has lauded the officials of the Special
Investigation Team who have defended the State and has excoriated the
appellants who have challenged the findings of the SIT. The Supreme Court
says in Paragraph 88:

“*While parting, we express our appreciation for the indefatigable work
done by the team of SIT officials in the challenging circumstances they had
to face and yet, we find that they have come out with flying colours
unscathed. At the end of the day, it appears to us that a coalesced effort
of the disgruntled officials of the State of Gujarat along with others was
to create sensation by making revelations which were false to their own
knowledge. The falsity of their claims had been fully exposed by the SIT
after a thorough investigation. Intriguingly, the present proceedings have
been pursued for last 16 years (from submission of complaint dated 8.6.2006
running into 67 pages and then by filing protest petition dated 15.4.2013
running into 514 pages) including with the audacity to question the
integrity of every functionary involved in the process of exposing the
devious stratagem adopted (to borrow the submission of learned counsel for
the SIT), to keep the pot boiling, obviously, for ulterior design. As a
matter of fact, all those involved in such abuse of process, need to be in
the dock and proceeded with in accordance with law*.”

“*Need to be in the dock* *…*”!! Has the Supreme Court now decided that
appellants before it and their counsel should be proceeded against merely
for being assiduous and persistent in their appeal? What about the NHRC
reports and the report of amicus curiae, Raju Ramachandran, which had
stated that investigation was required to probe the role of then chief
minister Narendra Modi? These were weighty grounds to question the view
taken by the SIT and therefore, they would confer sufficient heft to a
petition that sought to challenge the SIT’s findings. Moreover, the Supreme
Court’s own earlier observations clearly mention the laxity of the state
government officials. On April 12, 2004, a bench of Justices Doraiswamy
Raju and Arijit Pasayat while ordering a retrial in the Vadodara Best
Bakery case, said:

“*Those who are responsible for protecting life and properties and ensuring
that investigation is fair and proper seem to have shown no real anxiety.
Large number of people had lost their lives. Whether the accused persons
were really assailants or not could have been established by a fair and
impartial investigation. The modern day ‘Neros’ were looking elsewhere when
Best Bakery and innocent children and helpless women were burning, and were
probably deliberating how the perpetrators of the crime can be saved or
protected. Law and justice become flies in the hands of these wanton* *boys*
”.

It went on to say:

“*One gets a feeling that the justice delivery system was being taken for a
ride and literally allowed to be abused, misused and mutilated by
subterfuge. The investigation appears to be perfunctory and anything but
impartial without any definite object of finding out the truth and bringing
to book those who were responsible for the crime. The public prosecutor
appears to have acted more as a defence counsel than one whose duty was to
present the truth before the Court. The Court in turn appeared to be a
silent spectator, mute to the manipulations and preferred to be indifferent
to sacrilege being committed* *to justice. The role of the State Government
also leaves much to be desired*.”

The implications of the Zakia Jafri judgement are extremely serious. It has
overturned a core precept that, we believe, ought to guide an apex court
established under a liberal democratic Constitution: to safeguard the basic
right to life and liberty against questionable actions of the state. The
Court has come out with a doctrine which enjoins the state to arrest and
prosecute persons who dare to question the findings of investigating
agencies, if the Court decides that these findings are beyond reproach.>>

(Excerpted from: <
https://thewire.in/law/over-90-ex-bureaucrats-urge-supreme-court-to-withdraw-observations-in-zakia-jafri-judgment
>.)

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