Bansidhar Shankarlal v. Mohd. Ibrahim & Another (1971) 2 S.C.R. 476
On September 25, 1970, India's Supreme Court issued a judgment in Bansidhar Shankarlal versus Mohd. Ibrahim & Anr. that remains part of the Court's civil jurisprudence. The case, reported in 1971 at 2 S.C.R. 476, was decided by a single-judge bench.
The judgment is catalogued as a Supreme Court decision, placing it within the highest court's precedential authority. Practitioners and law firms tracking Supreme Court rulings would have noted this September 1970 decision as it circulated through legal channels.
Case Citation and Reporting
The formal citation—[1971] 2 S.C.R. 476—follows the Supreme Court Reports indexing system. The decision appeared in print in 1971, though the bench heard and decided it in 1970. This lag between judgment date and publication date is typical of the era's reporting cycle.
Single-judge benches were common in 1970 for certain categories of Supreme Court work. The one-judge composition shapes how the decision was received by the bar.
Implications for Civil Practice
The case involves a dispute between named parties. Without access to the full text or headnotes, the precise legal questions and holdings remain constrained by what the source material confirms: that a judgment was rendered, reported, and has been cited in subsequent legal research.
For legal professionals in 1970 and after, published Supreme Court decisions served as binding authority on courts below. Law firms would have reviewed this judgment for relevance to client disputes of similar character.
Historical Context in Indian Courts
By 1970, India's Supreme Court had been functioning for over two decades since independence. The Court's docket included civil matters, constitutional questions, and disputes between private parties. Bansidhar Shankarlal represents routine appellate work during this period.
Single-judge decisions from this era remain good law unless subsequently overruled by larger benches or by legislative amendment. The case's continued citation in legal databases confirms its status in the jurisprudential record.
Documentation and Legal Research
The availability of headnotes—summaries highlighting key holdings—varies across Supreme Court Reports editions. This judgment's headnotes status is not specified in available records, which may affect how quickly lawyers could access its core ratio.
Statute citations are similarly not specified for this decision. Whether the judgment interprets specific statutory sections or common law principles cannot be determined from the metadata alone. Legal researchers relying on statute-based searches might or might not encounter this case depending on the indexing system used.
Bar Impact and Professional Reception
When Supreme Court judgments are published, law firms integrate them into practice advisories and client counseling. Senior advocates would have briefed younger associates on precedents relevant to their practice areas. The September 1970 timing placed this decision in circulation as the legal profession adapted to post-independence court structures.
For legal profession researchers tracking how firms stay current with appellate law, published Supreme Court decisions like Bansidhar Shankarlal mark the information flows that shape litigation strategy.
Limits of Available Information
The judgment's full text is not provided in accessible form here. The ratio decidendi—the binding principle of law established by the Court—cannot be extracted without that text. This creates a research gap for practitioners seeking to understand precisely what rule the bench laid down.
Cases from this era are increasingly digitized, but gaps in indexing and full-text availability remain common. Legal researchers may need to consult physical law libraries or subscription databases to retrieve the complete judgment and its ratio.
Precedent Status
As a Supreme Court judgment from 1970, Bansidhar Shankarlal would bind all subordinate courts in India. High courts would be required to follow it absent distinguishing factors. The single-judge composition does not diminish its binding force—Supreme Court judgments are binding law regardless of bench size.
Whether the case has been cited, distinguished, or implicitly overruled in subsequent litigation is a question for case law tracking systems. The judgment's current status in living law depends on how courts have engaged with it since 1970.