Binding precedent on municipal statute interpretation prevails; coequal Benches cannot overrule it without compelling reasons.

The earlier Supreme Court interpretation of Section 138(b) of the Madhya Pradesh Municipal Corporation Act, 1956 remained binding on the High Court under Article 141. Later coequal Benches could not overrule or disregard that authority merely because subsequent cases on similar municipal provisions distinguished it on the basis of differing statutory language, including the absence of a non obstante clause. The Court found no compelling grounds to revisit the earlier construction, as the threshold for reconsideration of precedent was not met. The binding force of the prior interpretation was affirmed and reconsideration was rejected.

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Issues: Whether the earlier decision construing Section 138(b) of the Madhya Pradesh Municipal Corporation Act, 1956 continued to bind the High Court and whether there were grounds for reconsideration of that decision.

Analysis: The decisive question was whether later coequal Benches could treat the earlier three-Judge decision on Section 138(b) as no longer binding because of subsequent decisions interpreting similar provisions in other municipal laws. The Court held that the earlier decision remained the only direct authority on the provision in question, that the later cases had merely distinguished it on the basis of the absence of a non obstante clause in the other statutes, and that a coequal Bench could not overrule or disregard it. The High Court's contrary view was held to be inconsistent with the law of precedents and Article 141 of the Constitution of India. The Court also found no compelling ground to revisit the earlier construction, since the test for reconsideration of precedent was not satisfied.

Conclusion: The binding force of the earlier interpretation of Section 138(b) was affirmed and the plea for reconsideration was rejected.

Final Conclusion: The challenge failed, and the Full Bench view upholding the earlier precedent was sustained.

Ratio Decidendi: A coequal Bench cannot overrule an earlier binding decision on the same statutory provision; at most, it may distinguish the case or refer the matter to a larger Bench, and reconsideration of precedent requires compelling and substantial reasons.

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