Ratio decidendi - Indian Laws - General

Meaning of word Ratio decidendi In the leading case of Qualcast (Wolverhampton) Ltd. vs. Haynes, 1959 AC 743, it was laid down that the ratio decidendi may be defined as a statement of law applied to the legal problems raised by the facts as found, upon which the decision is based. The other two elements in the decision are not precedents. A judgment is not binding (except directly on the parties to the lis themselves), nor are the findings of fact. This means that even where the direct facts of an earlier case appear to be identical to those of the case before the court, the judge is not bound to draw the same inference as drawn in the earlier case. If a decision is on the basis of reasons stated in the decision or judgment, only the ratio decidendi is binding. The ratio or the basis of reasons and principles underlying a decision is distinct from the ultimate relief granted or manner of disposal adopted in a given case. (SECUNDRABAD CLUB ETC. VERSUS C.I.T. -V ETC.- 2023 (8) TMI 925 - SUPREME COURT) In Krishena Kumar v. Union of India and others- 1990 (7) TMI 366 - SUPREME COURT, the Constitution Bench, while appreciating the concept of ratio decidendi, adverted to the principles stated in Caledonian Railway Co. v. Walker s Trustees (1882) 7 App Cas 259 : 46 LT 826 (HL) and Quinn and observations made by Sir Frederick Pollock and thereafter laid down thus:- The ratio decidendi is the underlying principle, namely, the general reasons or the general grounds upon which the decision is based on the test or abstract from the specific peculiarities of the particular case which gives rise to the decision. The ratio decidendi has to be ascertained by an analysis of the facts of the case and the process of reasoning involving the major premise consisting of a pre-existing rule of law, either statutory or judge-made, and a minor premise consisting of the material facts of the case under immediate consideration. If it is not clear, it is not the duty of the court to spell it out with difficulty in order to be bound by it. In the words of Halsbury (4th edn., Vol. 26, para 573) The concrete decision alone is binding between the parties to it but it is the abstract ratio decidendi, as ascertained on a consideration of the judgment in relation to the subject matter of the decision, which alone has the force of law and which when it is clear it is not part of a tribunal s duty to spell out with difficulty a ratio decidendi in order to bound by it, and it is always dangerous to take one or two observations out of a long judgment and treat them as if they gave the ratio decidendi of the case . If more reasons than one are given by a tribunal for its judgment, all are taken as forming the ratio decidendi.