The Supreme Court criticised a High Court judge for adjudicating a case involving a former client, observing that a judge ought not to pass orders either in favour of or against a former client. The ruling reinforces the doctrine of judicial disqualification rooted in the maxim nemo judex in causa sua. The Court emphasised that the appearance of impartiality is as critical as actual impartiality, and prior professional relationships between a judge and a party constitute a disqualifying conflict of interest.

This ruling operationalises two foundational principles of natural justice: nemo judex in causa sua (no one shall be a judge in their own cause) and the reasonable apprehension of bias test. Indian courts have long recognised that bias can be actual, imputed, or apparent. The Supreme Court here applied the apparent bias standard — it is not necessary to prove that the judge was actually influenced; it suffices that a reasonable, fair-minded observer would apprehend a real possibility of bias given the prior attorney-client relationship.

The attorney-client relationship creates fiduciary obligations, privileged communications, and professional loyalties that do not simply dissolve upon elevation to the bench. When a former client's matter comes before such a judge, the structural risk of partiality — whether conscious or unconscious — is high enough to require recusal.

For CLAT PG, this connects to: (1) Judicial ethics and the Code of Conduct for judges, (2) Grounds for disqualification and recusal under CPC Order I and common law principles, (3) The distinction between actual bias and apparent bias, and (4) PIL maintainability where judicial misconduct is alleged. The examiner will test whether aspirants can identify the correct legal standard — apparent bias — not merely the factual scenario, and distinguish it from cases of personal interest, pecuniary bias, or subject-matter bias.