Managing Committee, Contai Rahamania High Madrasah v. State of West Bengal -Fundamental Right - Judicial Decision

Case Name and Neutral Citation

• Case Name: The Managing Committee, Contai Rahamania High Madrasah & Anr. v. State of West Bengal & Ors.
• Neutral Citation: 2025 SCC OnLine SC 1823

Coram

• Hon’ble Mr. Justice Dipankar Datta
• Hon’ble Mr. Justice Augustine George Masih

Judgment Date

• Date of Judgment: 15 September 2025

Caselaws and Citations Referred

• Vasanta Sampat Dupare v. Union of India & Ors.
• • Citation: 2025 SCC OnLine SC 1823
• Manoj v. State of Madhya Pradesh
• • Citation: (2023) 2 SCC 353
• Sk. Mohd. Rafique v. Managing Committee, Contai High Madrasah
• • Citation: (2020) 6 SCC 689
• Naresh Shridhar Mirajkar v. State of Maharashtra & Anr.
• • Citation: AIR 1967 SC 1
• Other Constitution Bench Judgments Mentioned:
• • (1974) 1 SCC 717
  • (2002) 8 SCC 481
  • (2020) 13 SCC 411 in CA No. 2858 of 2007

Statutes/Laws Referred

• Constitution of India
• • Article 32 (Writ jurisdiction of Supreme Court)
  • Article 30 (Rights of minorities to establish and administer educational institutions)
• West Bengal Madrasah Service Commission Act, 2008

1. What was the main relief sought by the petitioners in this case?

Answer:The petitioners asked the Supreme Court to reconsider its 2020 judgment in Civil Appeal No. 5808 of 2017, which upheld the constitutional validity of the West Bengal Madrasah Service Commission Act, 2008. They claimed this judgment violated Article 30 of the Constitution and overruled earlier Constitution Bench decisions.

2. Under which constitutional provision was the writ petition filed?

Answer:The writ petition was filed under Article 32 of the Constitution of India, which empowers the Supreme Court to issue writs for the enforcement of fundamental rights.

3. What is Article 30 of the Constitution of India, and why was it relevant here?

Answer:Article 30 grants minorities the right to establish and administer educational institutions of their choice. The petitioners argued that the 2020 judgment infringed upon these rights by upholding the Madrasah Service Commission Act.

4. What previous Supreme Court judgments did the petitioners cite as being overruled?

Answer:The petitioners referenced:

• (1974) 1 SCC 717
• (2002) 8 SCC 481
• (2020) 13 SCC 411 in CA No. 2858 of 2007

They claimed the 2020 judgment conflicted with these Constitution Bench decisions.

5. Why did the Supreme Court dismiss the writ petition?

Answer:The Court found the petition misconceived, noting that the precedent set in Vasanta Sampat Dupare v. Union of India (2025) did not apply, as that case involved capital punishment and ongoing validity of a death sentence. Here, the issue was already settled in Sk. Mohd. Rafique v. Managing Committee, Contai High Madrasah (2020), which upheld the Act’s validity after thorough consideration.

6. What did the Supreme Court say about the impact of judicial decisions on fundamental rights?

Answer:The Court cited Naresh Shridhar Mirajkar v. State of Maharashtra (AIR 1967 SC 1), where a nine-Judge Constitution Bench held that a judicial decision does not offend any fundamental right. Thus, the petitioners’ claim was untenable.

7. What was the outcome of the case?

Answer:The writ petition was dismissed as an abuse of process, with costs of Rs. 1,00,000 imposed, to be paid to a society/organization caring for children with cancer, as identified by the Secretary General of the Court.

8. What legal principle regarding review and reconsideration of Supreme Court judgments was reinforced?

Answer:The Supreme Court reinforced that its judgments cannot be challenged via writ petitions under Article 32, especially when the issue has already been conclusively decided by a Constitution Bench, and that judicial decisions do not violate fundamental rights.

9. Which statute was at the center of the dispute?

Answer:The West Bengal Madrasah Service Commission Act, 2008, which regulates the appointment of teachers in madrasahs, was challenged for allegedly infringing minority rights under Article 30.

10. What directions did the Court give regarding the costs imposed?

Answer:The Court directed that the costs be deposited in the Registry within a month, after which the Secretary General would identify a suitable organization for the funds.