Clean hands in special leave petitions: material misstatement can justify revocation of Article 136 relief.

Special leave under Article 136 is an extraordinary discretionary remedy available only to a petitioner who makes full and truthful disclosure of all material facts. Where leave is obtained on the basis of a false or misleading statement about a decisive document or fact, the foundation of the indulgence is vitiated. A litigant must approach the Court with clean hands, and material misrepresentation or suppression justifies refusal or revocation of the leave already granted. On that basis, the special leave was validly revoked and the petition liable to be rejected.

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Issues: Whether special leave granted under Article 136 of the Constitution of India was liable to be revoked on account of a false and misleading statement made in the petition concerning a material document.

Analysis: The grant of special leave under Article 136 is an extraordinary and discretionary jurisdiction, to be invoked only when the petitioner approaches the Court with full and truthful disclosure. Where the petition contains a materially false assertion on the very point that could justify interference, the Court is entitled to treat the foundation of the leave as vitiated. A litigant seeking such relief must come with clean hands, and misrepresentation or suppression of a decisive fact justifies refusal or revocation of the indulgence already granted.

Conclusion: The special leave was validly revoked, and the special leave petition was liable to be rejected.

Final Conclusion: Relief under Article 136 cannot be sustained when obtained on the basis of a material misstatement, and the Court will decline to continue its extraordinary discretionary intervention in such circumstances.

Ratio Decidendi: A party seeking special leave must make full and truthful disclosure of all material facts, and a material misrepresentation touching the decisive foundation of the petition justifies revocation of the leave granted.

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