Meet Justice K.N. Singh and his Notable Judicial decisions

Justice Kamal Narain Singh (1926–2022) served as the 22nd Chief Justice of India, holding office from November 25 to December 12, 1991—the shortest tenure for any CJI. Despite his brief period as Chief Justice, Justice K.N. Singh had a significant impact during his five-year tenure on the Supreme Court, authoring 100 judgments and participating in 336 benches, with a focus on service and constitutional law.

Judicial Career and Philosophy
Justice K.N. Singh began his legal career in the Allahabad High Court, specializing in civil, constitutional, and taxation matters. He was known for his humanitarian approach, simplicity, and a pragmatic outlook that sought to address the root causes of legal issues rather than merely resolving individual cases. His judgments often reflected a forward-looking perspective, particularly in matters concerning environmental protection and social justice.

Landmark Judgments
1. M.C. Mehta v. Union of India (Ganga Pollution Case, 1987):
Justice Singh was part of the bench that delivered a pioneering judgment on river pollution as public interest litigation. Recognizing the failure of authorities to prevent industrial waste from polluting the Ganga, the court ordered tanneries to set up primary treatment plants and directed that new factories could only be licensed if they had adequate waste treatment facilities. Notably, Singh’s judgment emphasized that while closures could lead to unemployment and loss of revenue, the health, life, and ecology of people held greater importance. He also advocated for environmental education in schools, directing the government to introduce textbooks and teacher training to foster environmental awareness.

2. Shasi Nayar v. Union of India:
In this case, the constitutional validity of the death penalty and the method of execution by hanging were challenged. Justice Singh upheld capital punishment, stating it served a social purpose and that India was not yet ready for its abolition. He also found that execution by hanging was reasonable, scientific, and not violative of Article 21, as it was among the least painful methods available.

3. Charan Lal Sahu v. Union of India (Bhopal Gas Leak Case):
Justice Singh was part of the five-judge bench that upheld the constitutional validity of the Bhopal Gas Leak Disaster (Processing of Claims) Act, 1985. The Act empowered the Central Government to represent all victims, making it easier for them to seek compensation. The court held that the government’s role was facilitative, not adjudicatory, thus ensuring fairer proceedings for those unable to represent themselves.

Legacy
Justice K.N. Singh is remembered for his commitment to environmental protection, procedural fairness, and his pragmatic, humanitarian approach to justice. His judgments in landmark cases like the Ganga Pollution Case and Bhopal Gas Disaster have had a lasting impact on Indian jurisprudence, particularly in environmental and social justice domains.

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