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The UPSC Daily Chronicle

"Exhaustive 11-Topic Broadsheet Dossier • Integrated Prelims & Mains Analytics • Topper Model Answer"
Friday, 16 October 2026 Vol. IV, No. 289 Daily Edition • ₹ 0.00 / Free Academic Service New Delhi & National Network
LEAD FRONT-PAGE STORY: INHERENT POWERS & JUDICIAL REMEDIES GS Paper 2: Polity & Judiciary

1. ARTICLE 142 & 'COMPLETE JUSTICE': REVISITING THE SCOPE, DOCTRINAL RESTRAINTS & STATUTORY HARMONY

Supreme Court Reaffirms Inherent Equity: Extraordinary Powers Cannot Override Substantive Statutory Law or Basic Structure.

NEW DELHI — In a comprehensive review of extraordinary constitutional remedies, the Supreme Court has reiterated the essential doctrinal boundaries governing its inherent powers under Article 142(1) to do "complete justice". Delivering rulings across commercial arbitration, public appointments, and matrimonial dissolutions, the apex court affirmed that while Article 142 equips the higher judiciary with necessary elasticity to cure procedural lacunae and deliver substantive equity, it does not constitute an unbridled license to supplant substantive statutory enactments passed by Parliament.

Constitutional & Statutory Background Dossier:
  • Constitutional Text & Mechanism:
    • Article 142(1): Empowers the Supreme Court to pass such decree or make such order as is necessary for doing complete justice in any cause or matter pending before it, enforceable throughout the territory of India in such manner as prescribed by Parliament.
    • Article 144 Obligation: Mandates that all authorities, civil and judicial, in the territory of India shall act in aid of the Supreme Court.
    • Article 129: Declares the Supreme Court to be a court of record, with all the powers of such a court including the power to punish for contempt of itself.
  • Judicial Evolution & Self-Imposed Restraints:
    • Prem Chand Garg v. Excise Commissioner (1962): A 5-judge Constitution Bench ruled that an order under Article 142 cannot be inconsistent with the fundamental rights guaranteed under Part III, nor can it bypass specific statutory prohibitions.
    • Union Carbide Corporation v. Union of India (1991): The apex court observed that the power under Article 142 is at a higher pedestal than ordinary statutory limitations, but it cannot override basic principles of public policy or fundamental constitutional tenets.
    • Supreme Court Bar Association v. Union of India (1998): Firmly established that Article 142 is a supplementary power that cannot supplant substantive law; the court held it could not suspend an advocate's license while punishing for contempt, as that regulatory power exclusively resides with the Bar Council under the Advocates Act, 1961.
    • Shilpa Sailesh v. Varun Sreenivasan (2023): Constitution Bench held that the Supreme Court can grant a decree of divorce on the ground of irretrievable breakdown of marriage under Article 142, dispensing with the mandatory 6-month cooling-off period under Section 13B of the Hindu Marriage Act, 1955.
GS-1: ART & FOLK TRADITIONS Oral Epic Balladry

2. PANDAVANI OF CHHATTISGARH: TEEJAN BAI'S LEGACY & KAPALIK VS VEDAMATI GENRES

RAIPUR — Preserved through tribal bardic lore in Chhattisgarh and central India, Pandavani—the vibrant folk ballad narrating tales from the Mahabharata with Bhima as the central protagonist—has received expanded institutional support from the Sangeet Natak Akademi. Celebrated globally through legendary performers like Teejan Bai, the oral art form embodies the expressive vitality of indigenous tribal storytelling.

Stylistic Genres & Musical Apparatus:
• Two Traditional Styles: Vedamati (narrator sits on the floor and recites verses in a classical, text-heavy scholarly manner, popularized by Jhaduram Devangan) vs. Kapalik (the lead performer stands, acts, improvises, and dances with high theatrical dynamism, championed by Teejan Bai).
• Signature Instrument: The Tambura (single-stringed drone adorned with peacock feathers and bells), brandished fluidly by the narrator as Bhima's mace (*Gada*), Arjuna's bow (*Gandiva*), or Dushasana's chariot, supported by the Kartal (cymbals) and Harmonium.
GS-1: GEOGRAPHY & TRIBALS PVTGs & Tiger Reserve Coexistence

3. CHENCHU PVTG OF NALLAMALA HILLS: HABITAT RIGHTS IN NAGARJUNASAGAR TIGER RESERVE

SRISAILAM — In a landmark advancement under the Forest Rights Act (FRA), 2006, district administrations in Andhra Pradesh and Telangana are recognizing Habitat Rights under Section 3(1)(e) for the Chenchu tribe within the core and buffer zones of India's largest tiger sanctuary—the Nagarjunasagar-Srisailam Tiger Reserve (NSTR).

Anthropological & Ecological Profile:
• Habitat & Dwellings: Inhabit circular wattle-and-daub huts called Gudisas scattered across the rugged, dry deciduous tracts of the Nallamala Hills (Eastern Ghats), bisected by the Krishna River gorge.
• Foraging Economy: Classified as a Particularly Vulnerable Tribal Group (PVTG); highly skilled in collection of wild honey, gum karaya, medicinal tubers, and Mahua flowers (Madhuca longifolia); act as voluntary tiger trackers and forest fire wardens.
• Spiritual Kinship: Revere Lord Mallikarjuna at Srisailam Temple as *'Chenchu Mallaiah'*, tracing mythical matrimonial links with the deity.
GS-2: POLITY & GOVERNANCE Separation of Powers

4. TRIBUNAL REFORMS ACT & ARTICLE 323A/B: JUDICIAL INDEPENDENCE IN SELECTION

NEW DELHI — Scrutinizing persistent vacancies across appellate tribunals (NCLAT, NGT, ITAT, TDSAT), the Supreme Court has underscored that tribunal appointments under the Tribunals Reforms Act, 2021 must strictly preserve the doctrine of separation of powers and judicial independence, as mandated under Articles 323A and 323B.

Constitutional Doctrines & Precedents:
• Part XIV-A Genesis: Inserted by the 42nd Amendment (1976) to expedite specialized dispute adjudication.
• L. Chandra Kumar v. Union of India (1997): Established that tribunals are supplementary—not substitutes—to High Courts; their decisions are subject to judicial review under Articles 226/227 before High Court Division Benches, preserving the Basic Structure.
• Madras Bar Association Rulings (2020–2021): The apex court struck down restrictive executive provisions imposing a 4-year tenure and a minimum age bar of 50 years, directing that Search-cum-Selection Committees must be headed by the CJI or a senior SC judge with a casting vote.
GS-2: INTERNATIONAL RELATIONS Indo-Pacific Architecture

5. EAST ASIA SUMMIT (EAS) & ADMM-PLUS: MARITIME SECURITY & UNCLOS COMPLIANCE

VIENTIANE — At the 19th East Asia Summit (EAS) and the concurrent ASEAN Defence Ministers' Meeting Plus (ADMM-Plus), India championed a free, open, and rules-based Indo-Pacific, reiterating that maritime conduct in the South China Sea must strictly adhere to the 1982 UN Convention on the Law of the Sea (UNCLOS).

Institutional & Geopolitical Dimensions:
• 18-Nation Plenary: EAS comprises 10 ASEAN states plus 8 dialogue partners (India, US, China, Russia, Japan, South Korea, Australia, New Zealand), serving as the premier strategic dialogue forum in the Asia-Pacific.
• Convergence with AOIP: Mutual alignment between India's Indo-Pacific Oceans Initiative (IPOI) and the ASEAN Outlook on the Indo-Pacific (AOIP), prioritizing maritime domain awareness, plastic pollution mitigation, and disaster relief.
• Code of Conduct (CoC) Mandate: India stressed that the ongoing ASEAN-China Code of Conduct negotiations must not prejudice the legitimate navigational and commercial rights of third-party nations.
GS-2: SOCIAL JUSTICE & HEALTH Maternal & Child Welfare

6. PRADHAN MANTRI MATRU VANDANA YOJANA (PMMVY 2.0): INCENTIVIZING THE GIRL CHILD

NEW DELHI — Under the umbrella Mission Shakti (Samarthya sub-scheme), the Ministry of Women and Child Development has achieved universal digital DBT rollouts under PMMVY 2.0, transferring cash incentives directly to pregnant women and lactating mothers while strategically incentivizing positive sex ratios at birth.

Statutory Mandate & Cash Architecture:
• Section 4 of NFSA, 2013: Grants a statutory maternity entitlement of not less than ₹6,000 to compensate for wage loss and promote institutional childbirth.
• Two-Tier Benefit Structure: First Child: ₹5,000 transferred in two instalments (on early registration/ANC and on institutional birth/vaccination); Second Child: ₹6,000 granted in a single instalment exclusively if the newborn is a girl, directly countering female feticide.
• Poshan Tracker Synchronization: Monitors real-time child growth stunting, wasting, and anemia reduction across rural Anganwadis.
GS-3: ECONOMY & TAXATION Tax Dispute Resolution

7. GST APPELLATE TRIBUNAL (GSTAT): OPERATIONALISING 31 STATE BENCHES ACROSS INDIA

NEW DELHI — Resolving a prolonged seven-year institutional hiatus since the rollout of the Goods and Services Tax in 2017, the Ministry of Finance has notified the operationalization of the GST Appellate Tribunal (GSTAT) Principal Bench in New Delhi alongside 31 State Benches nationwide, decongesting High Courts from writ petitions under Article 226.

Statutory Framework & Composition:
• CGST Act, 2017 (Section 109): GSTAT serves as the second appellate authority hearing appeals against orders of Appellate and Revisional Authorities.
• Balanced Judicial Bench: Each bench comprises a Judicial Member, a Technical Member (Centre), and a Technical Member (State), ensuring collaborative federal dispute adjudication.
• Litigation Relief: Thousands of pending classification, input tax credit (ITC) denial, and valuation disputes will be adjudicated through a standardized, specialized statutory tax tribunal.
GS-3: SCIENCE & DEFENSE TECH Indigenous Air Defense

8. DRDO VSHORADS AIR DEFENSE SYSTEM: INDIGENOUS 4TH GEN MANPADS TRIALS

CHANDIPUR — The Defence Research and Development Organisation (DRDO) has successfully concluded developmental flight trials of the 4th-generation Very Short Range Air Defence System (VSHORADS) from a ground-based portable launcher at the Integrated Test Range off the coast of Odisha, establishing self-reliance in man-portable air defense.

Technical Architecture:
• MANPADS Role: Neutralizes low-altitude aerial threats (combat UAVs, attack helicopters, loitering munitions) at close ranges.
• Miniaturized Propulsion & RCS: Powered by a dual-thrust solid motor incorporating a miniaturized Reaction Control System (RCS) and an uncooled state-of-the-art Imaging Infrared (IIR) seeker, ensuring high agility during interception.
• High-Altitude LAC Readiness: Designed for rapid tactical deployment by infantry battalions across rugged mountainous terrains along the Line of Actual Control (LAC).
GS-3: ENVIRONMENT & WILDLIFE Freshwater Ecology

9. GANGETIC RIVER DOLPHIN (SUSU): PROJECT DOLPHIN & BIO-ACOUSTIC POPULATION AUDIT

BHAGALPUR — Under the MoEFCC's flagship Project Dolphin, wildlife biologists and the Wildlife Institute of India (WII) have rolled out a comprehensive bio-acoustic survey across the Ganga-Brahmaputra-Meghna basins to assess the population health of India's National Aquatic Animal, the Gangetic River Dolphin (Platanista gangetica).

Ecological & Protection Status:
• Sensory Biology: Essentially blind; navigates and hunts fish by emitting ultrasonic clicking sounds (echolocation / Susu); thrives strictly in freshwater deep river pools.
• Statutory Safeguards: Declared National Aquatic Animal in 2009; listed as Endangered on the IUCN Red List; Schedule I of the Wildlife (Protection) Act, 1972; Appendix I of CITES.
• Sanctuary Protection: Protected primarily in the Vikramshila Gangetic Dolphin Sanctuary (Bihar); key threats include barrage flow interruptions, mechanized vessel noise, and nylon monofilament gillnet entanglement.
GS-3: AGRICULTURE & FOOD SECURITY Pulses Self-Sufficiency

10. REVAMPED PM-AASHA SCHEME: 100% BUFFER PROCUREMENT FOR PULSES & SOIL HEALTH

NEW DELHI — The Union Cabinet has approved the restructuring of the Pradhan Mantri Annadata Aay Sanraksan Abhiyan (PM-AASHA) with an expanded outlay of ₹35,000 crore, guaranteeing 100% procurement at Minimum Support Price (MSP) for registered pulse farmers growing Tur (Arhar), Urad, and Masur.

Agronomic & Fiscal Benefits:
• Soil Biology: Pulses are leguminous crops whose root nodules host symbiotic Rhizobium bacteria, fixing atmospheric nitrogen into the soil and saving 25–30 kg of synthetic nitrogen fertilizer per hectare for subsequent crops.
• Import Substitution: Insulates India from volatile global pulses markets (import dependencies on Myanmar, Mozambique, and Australia), strengthening domestic buffer stocks managed by NAFED and NCCF.
11. RAPID PRELIMS FACT SHEET: HIGH-YIELD SPEED BULLETINS High-Yield Examination Nuggets
1. Kawal Tiger Reserve (Telangana):
Located in the northern plains of Telangana (Mancherial/Adilabad); southern extension of the Central Indian tiger landscape; catchment basin of the Godavari and Kadam rivers; prominent dry teak and bamboo forests.
2. FATF Mutual Evaluation of India:
Placed in the coveted 'Regular Follow-up' category by the Financial Action Task Force (FATF), marking the highest compliance tier for anti-money laundering (AML) and countering terror financing (CFT) standards among major economies.
3. PMAY-U 2.0 (Housing for All):
Expanded urban housing mission targeting 1 crore additional houses for economically weaker sections (EWS), LIG, and middle-income families; includes Interest Subsidy Scheme (ISS) of up to 4% for housing loans up to ₹25 lakh.
4. Stockholm Convention on POPs:
Global treaty under UNEP protecting human health and the environment from Persistent Organic Pollutants (POPs); targets chemical bio-accumulation and long-range environmental transport; India ratified the treaty in 2006.
CHRONICLE EDITORIAL DESK • CRITICAL POLICY APPRAISAL

THE BOUNDLESS HORIZON OF ARTICLE 142: RECONCILING INHERENT EQUITY WITH THE RULE OF LAW

The presence of Article 142 within the architecture of Part V of the Constitution represents a deliberate institutional provision to prevent substantive justice from becoming a casualty of rigid legal formalisms. By empowering the Supreme Court to pass decrees necessary for doing "complete justice", the framers ensured that no judicial dilemma would remain unresolved merely because statutory law had not anticipated its complex facts.

Yet, as constitutional jurists have warned since Prem Chand Garg, a power that is boundless in text must be disciplined by self-imposed institutional restraint. If Article 142 is routinely invoked to bypass explicit statutory mandates or legislate from the bench, it risks undermining the doctrine of separation of powers. The true greatness of the Supreme Court's inherent power lies not in building parallel statutory castles, but in acting as a vigilant, surgical equity valve that supplements the law without eroding the constitutional sovereignty of Parliament.

UPSC MAINS DAILY PROBABLE QUESTION & MODEL ANSWER GS Paper 2: Polity & Judicial Powers (15 Marks / 250 Words)
Probable Question:
"Article 142 of the Indian Constitution arms the Supreme Court with extraordinary powers to do 'complete justice', yet it cannot be deployed to build a castle in the air bypassing statutory mandates. Critically examine the scope, judicial doctrines, and self-imposed limitations governing the invocation of Article 142." (15 Marks, 250 Words)

1. Introduction: Constitutional Purpose & Inherent Jurisdiction:
Under Article 142(1), the Supreme Court is empowered to make such orders as necessary for doing "complete justice" in any cause or matter pending before it. Conceived by the drafting committee to prevent justice from becoming trapped within the technicalities of statutory procedural law, Article 142 acts as an ultimate constitutional reservoir of equity, ensuring that formal legal gaps do not obstruct equitable remedies.

2. Expansive Scope & Beneficial Invocations:
• Filling Legislative Vacuums: The court has stepped into statutory voids to protect fundamental rights, formulating binding guidelines such as the Vishaka Guidelines (1997) on workplace sexual harassment and environmental protection orders.
• Protecting Vulnerable Litigants: In Union Carbide Corporation (1991), the court bypassed ordinary tort litigation to order immediate financial compensation for Bhopal gas tragedy victims.
• Matrimonial Humaneness: In Shilpa Sailesh (2023), a 5-judge bench invoked Article 142 to dissolve marriages suffering from irretrievable breakdown, waiving the mandatory six-month statutory waiting period under the Hindu Marriage Act.

3. Judicial Doctrines & Self-Imposed Limitations:
The Supreme Court has consistently held that Article 142 is not an unbridled, legislative power:
• The Substantive Law Barrier (Prem Chand Garg, 1962): The court held that an order under Article 142 cannot be inconsistent with Fundamental Rights or substantive statutory provisions enacted by Parliament.
• Supplementary, Not Supplanting (Supreme Court Bar Association, 1998): A Constitution Bench settled that Article 142 is a corrective, curative power that must be exercised in harmony with statutory frameworks. The court cannot create a new substantive right or bypass specialized bodies (such as the Bar Council).
• Public Policy Restraints: The court cannot grant remedies that undermine fundamental public policy, constitutional conventions, or the core doctrine of Separation of Powers.

4. Systemic Concerns & Criticisms:
• Unpredictability & Subjectivity: Invocations often depend on the subjective satisfaction of individual benches, giving rise to charges of 'judicial lottery' and regulatory uncertainty (e.g., blanket liquor bans along highways or coal block cancellations).
• Erosion of Separation of Powers: Excessive recourse to Article 142 in policy, executive governance, and administrative matters risks encroaching on the legislative domain of elected representatives.

5. Conclusion:
Article 142 represents the beating conscience of the Constitution. Its enduring utility depends upon judicial discipline: deploying it as a rare, surgical instrument of last resort to deliver equity where procedural law falls short, while faithfully respecting the statutory supremacy of Parliament.

The UPSC Daily Chronicle • Published Daily for Civil Services Aspirants • Curated for Aditya Daw (aditya.n.daw@gmail.com)