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Issues Involved:
1. Validity of judgments pronounced by an Additional Sessions Judge whose appointment was later declared invalid. 2. Application of the de facto doctrine to judgments rendered by judges with invalid appointments. 3. Impact of invalid judicial appointments on the rights of the appellants under Art. 21 of the Constitution. Summary: 1. Validity of Judgments Pronounced by an Invalidly Appointed Judge: The primary issue was the effect of the Supreme Court's declaration that the appointment of an Additional Sessions Judge was invalid on judgments pronounced by the judge prior to such declaration. The appellants argued that the judgments rendered by the judges were void as they were never duly appointed as District Judges. The High Court overruled this point, holding that the judgments were valid and could not be questioned in collateral proceedings. 2. Application of the De Facto Doctrine: The court examined the de facto doctrine, which is a doctrine of necessity and public policy. It was established that "the acts of the officers de facto performed by them within the scope of their assumed official authority, in the interest of the public or third persons and not for their own benefit, are generally as valid and binding, as if they were the acts of officers de jure." The doctrine is aimed at preventing public and private mischief and protecting public and private interests. The court cited various precedents, including Pulin Behari v. King Emperor and Norton v. Shelby County, to support the validity of acts performed by de facto officers. 3. Impact on Rights Under Art. 21 of the Constitution: The appellants argued that their Fundamental Right under Art. 21 of the Constitution was violated as their liberty was being taken away otherwise than in accordance with the procedure established by law. The court disagreed, stating that the de facto doctrine saves the acts of judges whose appointments were later invalidated. The court emphasized that the doctrine is not a stranger to the Constitution or legislative enactments, citing Art. 71(2) of the Constitution and Sec. 107(2) of the Representation of the People Act 1951. Conclusion: The court concluded that the judgments pronounced by the judges, who were not mere usurpers but held office under colour of lawful authority, were valid. The de facto doctrine applied, and the judgments could not be questioned in collateral proceedings. The appeals were dismissed, and the court found no reason to interfere with the concurrent findings of fact arrived at by the lower courts.
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