Transferred judicial officers must pronounce judgments in cases reserved prior to relinquishing charge.

The petitioner challenged an order dated January 3, 2026, passed by the Trial Court in a rent control matter (RC ARC No. 5136/16).

Final arguments in the case concluded on August 21, 2025, and the matter was reserved for judgment on September 17, 2025, by the then-presiding judge ("learned predecessor judge").

Subsequently, the predecessor judge was transferred via a High Court order dated October 17, 2025.

Despite several listings for pronouncement, the judge eventually passed the impugned order releasing the case from the stage of judgment, stating that certain clarifications were necessary and he was no longer in a position to hear the matter due to his transfer.

The petitioner contended that the judge was mandated to pronounce the judgment as per the terms of the High Court's transfer order.

1. Whether a judicial officer who has reserved a case for judgment prior to their transfer is mandated to pronounce the judgment notwithstanding the transfer order.

2. Whether the release of a case from the stage of judgment for "clarifications" after a significant delay is legally sustainable when it contradicts administrative transfer guidelines.

The Court exercised its supervisory jurisdiction under Article 227 of the Constitution of India.

High Court Transfer Order No. 41/DHC/Gaz/G-7/VI.E.2(a)/2025, specifically Note 2, which mandates that transferred judicial officers must notify and pronounce judgments in all reserved matters within 2–3 weeks of the transfer, regardless of their new posting.

Precedent set in Parvesh Mann @ Sagar Mann v. State (NCT of Delhi) and B.D. Sharma v. State of NCT of Delhi & Anr., which establish that once final arguments are heard, the predecessor judge is bound to pronounce judgment to avoid unnecessary delays and burdens on successor judges.

The Court observed that the matter had remained reserved for judgment for approximately four months before the impugned order was passed.

It noted that the predecessor judge's observation regarding the necessity of "further clarifications" was unjustified given the extensive period the matter was kept reserved.

The Court reasoned that releasing the case at such a late stage and directing a rehearing by a successor judge directly contravened the explicit mandate of the High Court’s transfer order dated October 17, 2025.

It emphasized that such actions defeat judicial efficiency, cause "avoidable delay in adjudication," and impose an "unnecessary burden" on the successor judge who would be forced to rehear arguments already concluded.

Consequently, the administrative requirement for the outgoing judge to complete reserved matters took precedence over the judge's discretionary claim that clarifications were needed.

It held that the predecessor judge was duty-bound to pronounce the judgment in accordance with the transfer order.

The Court directed that RC ARC 5136/16 be transferred from the South-East District (Saket Courts) to the court of the predecessor judge, currently posted as CJM, Shahdara (Karkardooma Courts), specifically for the purpose of the pronouncement of the judgment.

All pending applications were disposed of accordingly.