Abstract
This article examines the Supreme Court of India’s recent intervention in litigation arising from the 2026 student protests associated with the Cockroach Janta Party (CJP), with particular attention to the Court’s orders of 28 July, 18 August and 1 September 2026 in Shailendra Mani Tripathi v. Union of India and connected proceedings. The litigation raises an unusually dense cluster of constitutional questions: the relationship between Articles 19(1)(a) and 19(1)(b); the State’s duty to maintain public order; limits on police crowd-control powers; the use of pellet guns, tear gas, lathis and other force; protection of minors; publication and retention of protesters’ personal data; and the exceptional remedial authority under Article 142.
The paper situates the 2026 proceedings within the Supreme Court’s longer jurisprudence on protest, including Himmat Lal K. Shah, Ramlila Maidan Incident, Mazdoor Kisan Shakti Sangathan, Anita Thakur and Amit Sahni (Shaheen Bagh). It also engages with recent legal scholarship on Shaheen Bagh, public order and legal mobilisation. The central argument is that the 2026 orders should not be read as creating an unqualified right to protest or as immunising violence. Rather, they deepen an emerging constitutional model in which peaceful dissent receives affirmative protection, State restrictions must remain connected to genuine public-order concerns, police force must be necessary and proportionate, protester data requires constitutional safeguards, and remedial relief may be calibrated to protect the future of young participants without extinguishing accountability for grave criminal conduct.
The 18 August order is particularly significant because it constituted a High-Powered Enquiry Committee (HPEC) and identified issues extending beyond individual criminal liability: proportionality of force, use of metallic projectiles, visible identification of police personnel, surveillance, treatment of women protesters, compensation, blanket prohibitory orders, and possible misuse of Section 152 of the Bharatiya Nyaya Sanhita, 2023. The 1 September order then used Article 142 to quash protest-related FIRs and extend closure to other FIRs concerning the same July incidents, while retaining a carve-out concerning 2,873 persons identified by Delhi Police and directing a pan-India compensation policy for families affected by NEET-UG-related student suicides.
The article concludes that the litigation may become a leading contemporary authority on the constitutional governance of protest in the digital-surveillance era, but that its lasting doctrinal value will depend on the HPEC’s findings and the Court’s eventual resolution of the pending constitutional questions.
Keywords: right to protest; Article 19; Article 21; Article 142; public order; police force; privacy; student protest; CJP; NEET-UG 2026; constitutional remedies.
Important note: The expression “judgements” in the title is used broadly because the principal Supreme Court interventions in the CJP litigation are orders/records of proceedings rather than a single final constitutional judgment. The 1 September order is reported as 2026 SCC OnLine SC 1754. The paper distinguishes holdings, interim directions, observations, and pending issues.
1. Introduction and Research Questions
Protest occupies an unusual position in constitutional democracy. It is neither merely speech nor merely physical assembly. A protest communicates, creates collective visibility, claims political space and seeks to influence public institutions. Indian constitutional law protects these functions through a combination of Articles 19(1)(a), 19(1)(b), 19(1)(c) and, where coercive State action is involved, Article 21. Yet these freedoms coexist with the State’s responsibility to preserve public order and the rights of non-participants.
The 2026 CJP/NEET-UG protests brought these tensions into sharp relief. The Supreme Court record describes allegations of lathi charges, pellet guns, rubber bullets, electronic batons and tear gas, while the State side alleged that some persons with criminal antecedents entered the demonstrations and that police personnel were seriously injured. The Court therefore confronted not a simple binary of “peaceful protesters versus State”, but a mixed factual environment requiring protection of lawful dissent alongside investigation of violence on all sides.
The litigation also moves beyond the traditional protest-versus-traffic paradigm. The 18 August order expressly addressed surveillance and publication of protester data, police identification, crowd-control technology, protection of women and children, and the possible use of preventive and penal provisions as a chilling mechanism. This makes the case relevant to a modern constitutional question: how should a democratic State regulate mass dissent when physical crowd control, digital identification and criminal process operate simultaneously?
Research Questions
- 1. What constitutional principles govern the Supreme Court’s response to the CJP/NEET-UG protests?
- 2. How do the 2026 orders develop the Court’s earlier right-to-protest jurisprudence?
- 3. What limits does proportionality place on police crowd-control measures?
- 4. How should Article 142 be understood when used to terminate protest-related FIRs?
- 5. What is the constitutional significance of the HPEC and its proposed inquiry into force, surveillance and accountability?
- 6. What doctrinal questions remain open as of 9 September 2026?
2. Methodology and Source Base
This is a doctrinal and analytical legal-research paper. It uses primary judicial materials, constitutional provisions, reported legal databases and peer-reviewed/academic legal scholarship. The analysis separates (a) binding or operative directions in court orders, (b) judicial observations made during interim proceedings, and (c) secondary commentary. Because the CJP litigation remains pending, the article does not present interim observations as final constitutional holdings.
Primary materials include the Supreme Court’s orders in Shailendra Mani Tripathi v. Union of India dated 28 July and 18 August 2026 and the 1 September 2026 order reported as 2026 SCC OnLine SC 1754. Earlier authorities are used to construct the doctrinal lineage: Himmat Lal K. Shah v. Commissioner of Police; Ramlila Maidan Incident, In Re; Mazdoor Kisan Shakti Sangathan v. Union of India; Anita Thakur v. State of J&K; and Amit Sahni v. Commissioner of Police (Shaheen Bagh).
Secondary literature includes Sanjana Hooda’s 2025 Erasmus Law Review article on Shaheen Bagh as legal mobilisation; Prateek Kumar’s 2025 Delhi Journal for Law and Justice article on right to protest versus public order; U.D. Gupta’s 2021 Jindal Global Law Review article on the politics of space at Shaheen Bagh; and scholarship examining commuter rights, public protest and the balance between civil liberties.
| Source category | Materials used | Analytical purpose |
| Constitutional text | Arts. 14, 19, 21, 22, 32, 142 | Rights, restrictions, remedies |
| Recent SC orders | 28 Jul; 18 Aug; 1 Sep 2026 | Core CJP/NEET-UG litigation |
| Earlier SC cases | Himmat Lal; Ramlila Maidan; MKSS; Anita Thakur; Amit Sahni | Doctrinal lineage |
| Academic scholarship | Hooda (2025); Kumar (2025); Gupta (2021); commuter-rights research | Critical and socio-legal interpretation |
| Legal commentary | SCC Times, Indian Express, Indian Kanoon, LiveLaw and related reporting | Procedural developments and cross-checking |
Limitation: The paper is a research synthesis prepared as of 9 September 2026. It does not purport to substitute for the certified Supreme Court record, the eventual HPEC report, or the final constitutional adjudication. Numerical claims about participants, injuries or prior criminal records are reported allegations or official claims unless independently established in a final adjudication.
3. Constitutional Framework: Protest as a Composite Fundamental Freedom
The Constitution does not contain a standalone textual phrase “right to protest”. The Supreme Court has nevertheless treated peaceful protest as flowing from a combination of freedoms. Article 19(1)(a) protects speech and expression; Article 19(1)(b) protects peaceful assembly without arms; Article 19(1)(c) protects association; and Article 19(1)(d) may become relevant where a peaceful procession or movement is involved. These freedoms are subject to the specified reasonable restrictions.
In Himmat Lal K. Shah, the Court recognised that the right to hold public meetings and processions is connected to assembly and movement, while also recognising regulatory power over public spaces. Ramlila Maidan strengthened the proposition that the State cannot use public-order powers as a licence for arbitrary or excessive interference. Mazdoor Kisan Shakti Sangathan emphasised that peaceful demonstrations are a fundamental democratic means of airing grievances and that the State must balance protest with the rights of others.
Amit Sahni (Shaheen Bagh) refined the spatial dimension. The Court affirmed the right to protest but rejected an indefinite occupation of public ways. The important doctrinal distinction is therefore between the existence of a right and the choice of place, duration and manner in which the right is exercised. The State may regulate those modalities, but restrictions must remain constitutionally defensible.
| Right / interest | Constitutional source | Typical restriction | CJP litigation relevance |
| Speech & dissent | Art. 19(1)(a) | Art. 19(2) | Political criticism, slogans, online mobilisation |
| Peaceful assembly | Art. 19(1)(b) | Public order; sovereignty/integrity etc. | Jantar Mantar assemblies and marches |
| Association | Art. 19(1)(c) | Art. 19(4) | Collective organisation and movement |
| Movement | Art. 19(1)(d) | Art. 19(5) | Marches and access routes |
| Life & liberty | Art. 21 | Procedure established by law + fairness | Arrest, force, injury, dignity |
| Equality / non-arbitrariness | Art. 14 | Reasonableness, non-arbitrariness | Selective enforcement, profiling |
| Constitutional remedies | Arts. 32/226 | Jurisdictional limits | Direct Supreme Court intervention |
| Complete justice | Art. 142 | Case-specific constitutional limits | Quashing FIRs and consequential relief |
4. The 28 July 2026 Order: Immediate Constitutional Safeguards
In Shailendra Mani Tripathi v. Union of India, the Supreme Court was confronted with petitions under Article 32 alleging excessive use of force during student protests at Jantar Mantar and elsewhere. The 28 July order recorded allegations of pellet-gun injuries, rubber bullets, electronic batons, lathis said to contain nails, tear gas and assaults involving plain-clothes personnel. The State disputed the allegations and asserted that violent elements had injured more than 280 police officers.
The Court found a prima facie compelling case for an independent and impartial investigation and preserved the evidentiary record. The order directed preservation of CCTV, drone footage, body-worn camera recordings, videography, wireless records and PCR material. It also restricted disclosure of protesters’ personal information and digital data and directed that no public data/details of protesters be published for the time being.
Most importantly for immediate liberty, the Court permitted investigation of FIRs but prohibited coercive measures against protesting students, subject to the exception for persons with criminal antecedents. It also directed release of minors under eighteen who had been arrested or detained in connection with the protests, again subject to the stated exception. These directions show a calibrated approach: investigation was not stopped, but coercive consequences were temporarily restrained.
| Direction | Constitutional rationale | Significance |
| Preserve CCTV/drone/body-cam/PCR evidence | Fair investigation; Art. 21 | Prevents evidentiary destruction and supports accountability |
| Do not publish protester personal data | Privacy; dignity; chilling-effect concerns | Recognises digital harms beyond physical arrest |
| No coercive action against student protesters, subject to exception | Liberty + presumption of innocence | Protective interim relief without blanket immunity |
| Release detained minors without criminal antecedents | Child protection + liberty | Heightened constitutional sensitivity to minors |
| Independent investigation contemplated | Institutional accountability | Moves beyond police self-review |
The order is significant because it reframes protest policing as an evidence-and-accountability problem, not only an order-maintenance problem. The State retains authority to investigate genuine offences, but the method of crowd control and the handling of protester information become judicially reviewable constitutional questions.
5. The 18 August 2026 Order: The High-Powered Enquiry Committee
The 18 August order deepened the case. The Court constituted a five-member High-Powered Enquiry Committee chaired by former Supreme Court judge Justice R. Subhash Reddy, with Justice Ravi Shankar Jha (former Chief Justice of the Punjab and Haryana High Court), Justice Shalinder Kaur (former Delhi High Court judge), former CBI Director Rishi Kumar Shukla and retired Meghalaya DGP Dr L.R. Bishnoi. The committee was empowered to seek forensic, technical and domain expertise.
The terms of reference are unusually broad. On the protester side, the Court identified excessive force, proportionality of police response, the desirability of banning metallic kinetic projectiles, visible police identification, surveillance, violence or harassment against women protesters, medical support and compensation, regulation of blanket prohibitory orders under Section 163 BNSS, and safeguards against misuse of Section 152 BNS to chill dissent. On the State side, the Court required investigation of alleged violence by protesters, damage to public and private property, and injuries suffered by police personnel.
This symmetrical framing is constitutionally important. The right to protest cannot become a shield for assault or destruction, while the State’s duty to maintain public order cannot become a licence for indiscriminate force. The Court’s design therefore resembles a “dual accountability” model: both the coercive State and violent individuals remain subject to law.
| HPEC issue cluster | Why it matters doctrinally |
| Force and projectiles | Necessity, proportionality, bodily integrity under Art. 21 |
| Police identification | Accountability, traceability and due process |
| Surveillance/data | Privacy, informational autonomy and chilling effect |
| Women/children | Dignity, vulnerability and heightened safeguards |
| Section 163 BNSS | Prevention must respond to genuine/imminent public-order risks |
| Section 152 BNS | Political dissent must not be criminalised through overbroad application |
| Protester violence/property damage | Rule of law and equal protection |
| Police injuries | State personnel are also rights-bearers deserving protection |
6. The 1 September 2026 Order: Article 142 and Quashing of FIRs
On 1 September 2026, the Supreme Court took the most consequential remedial step in the litigation. In Shailendra Mani Tripathi v. Union of India, reported as 2026 SCC OnLine SC 1754, a three-judge bench headed by CJI Surya Kant invoked Article 142 to quash FIRs connected with the 20–25 July 2026 protests. The Court directed that any other FIR concerning the same incidents that had not been formally brought before it should not be pursued or investigated and should be treated as closed. It also directed that no State or Union Territory should register a fresh FIR in relation to those incidents.
The Court’s reasoning, as reported in legal summaries of the order, focused on the future prospects of young protesters who had participated bona fide in the demonstrations. The Court nevertheless retained a carve-out permitting action against the 2,873 persons identified by Delhi Police in the relevant proceedings, reflecting the distinction between participation in a protest and allegations of serious criminality.
The use of Article 142 deserves particular attention. Article 142 empowers the Supreme Court to make orders necessary to do complete justice in a cause or matter before it. The provision has long generated debate because it permits the Court to fashion remedies that do not fit neatly within ordinary procedural pathways. The CJP order illustrates both the strength and the constitutional sensitivity of that power: a single national remedial direction can prevent fragmented State-by-State prosecution, but extraordinary jurisdiction must remain connected to the case before the Court and exercised with principled restraint.
| Article 142 question | Assessment |
| Why use Article 142? | To provide uniform, immediate and final relief concerning the same protest incidents |
| What was avoided? | Fragmented closure of FIRs through multiple police/prosecutorial processes |
| What was preserved? | Accountability for persons within the stated criminal-antecedent carve-out |
| Why future prospects matter? | An FIR can create practical consequences for education, employment, travel and public life even without conviction |
| Main constitutional concern | Ensuring exceptional relief remains principled and does not become ad hoc governance |
| Systemic consequence | A model for national remedial coordination in mass-rights litigation |
7. Comparative Doctrinal Analysis with Earlier Supreme Court Cases
The CJP litigation should be read as the latest layer in a long constitutional conversation. The earlier cases do not provide a single formula, but together establish several propositions: peaceful assembly is protected; restrictions may be imposed to protect public order and the rights of others; public spaces cannot be occupied indefinitely; police power is reviewable; and excessive force is incompatible with constitutional governance.
| Case | Core proposition | Development in 2026 litigation |
| Himmat Lal K. Shah v. Commissioner of Police (1973) | Public meetings/processions fall within constitutional assembly rights; regulation is possible. | Supports regulated but genuine access to protest space. |
| Ramlila Maidan Incident, In Re (2012) | State action during protest must respect constitutional limits; force cannot be arbitrary. | Strengthens scrutiny of crowd-control tactics. |
| Mazdoor Kisan Shakti Sangathan v. Union of India (2018) | Peaceful protest is fundamental; State must balance competing rights. | Provides doctrinal basis for balancing protest, public order and third-party rights. |
| Anita Thakur v. State of J&K (2016) | Peaceful protest is protected; excessive police force can violate constitutional norms. | Directly relevant to proportionality of force. |
| Amit Sahni v. Commissioner of Police (2020) | Right to protest exists, but public ways cannot be occupied indefinitely. | Supports time/place/manner regulation without erasing the right. |
| Aslam Ismail Khan / later protest cases | Peaceful civic action should not be criminalised where offence ingredients are absent. | Supports careful FIR scrutiny. |
| Shailendra Mani Tripathi (2026) | Interim protection, HPEC, privacy safeguards and Art. 142 relief. | Integrates protest, police accountability, data protection and extraordinary remedies. |
The doctrinal movement is therefore from recognition of protest, to regulation of space, to review of force, and finally to systemic oversight of police conduct and protester data. The 2026 orders do not abandon the public-order principle; they insist that public order be pursued through proportionate and accountable means.
A further development is institutional. Earlier cases frequently addressed a particular protest site or regulatory order. The 2026 litigation creates a continuing supervisory structure through an HPEC, periodic reporting and preservation of digital evidence. This potentially shifts the Court’s role from resolving a discrete dispute to supervising a national constitutional fact-finding exercise.
8. Critical Issues: Article 142, Surveillance, Police Power and Chilling Effects
8.1 Article 142 and judicial overreach. The strongest criticism of the 1 September order is not that relief was inherently illegitimate, but that extraordinary remedial power can blur institutional boundaries. If the executive itself seeks closure, Article 142 may appear facilitative rather than confrontational; nevertheless, the Court must explain why constitutional “complete justice” requires a remedy beyond ordinary criminal procedure. The better reading is that the Court used Article 142 to create uniformity and prevent continuing collateral consequences while leaving serious criminality outside the general amnesty.
8.2 Protester databases and informational privacy. The 28 July and 18 August orders are notable for treating digital information as part of the constitutional problem. Identification of protesters can serve legitimate investigative functions, but public disclosure or indefinite retention can produce a chilling effect. The Court’s temporary confidentiality direction should be understood within the broader Article 21 jurisprudence on privacy and dignity. Future adjudication may have to determine retention periods, access controls, independent oversight and rules for facial-recognition or database matching.
8.3 Crowd-control force and proportionality. The HPEC’s reference to metallic kinetic projectiles is doctrinally important because it converts a factual allegation into a normative question about permissible policing technology. The correct constitutional inquiry is not simply whether an instrument is “non-lethal” in name, but whether its deployment is necessary, suitable, minimally impairing and proportionate to the threat. Warning, graduated response, identification of officers and medical assistance become relevant to that analysis.
8.4 Chilling effects of preventive and penal provisions. Blanket prohibitory orders and broad penal provisions can chill speech even when no prosecution ultimately succeeds. The Court’s decision to examine Section 163 BNSS and Section 152 BNS is therefore significant. The constitutional concern is not that these provisions are invalid per se; it is whether they are used routinely, without a proximate and evidence-based public-order justification, to suppress dissent.
8.5 The State’s counter-rights. A rights-based account must also recognise that police officers, commuters, residents, businesses and public-property custodians possess legal interests. Stone-pelting, assault, arson or deliberate destruction are not transformed into protected expression merely because they occur during a political protest. The Court’s HPEC terms of reference appropriately require investigation of alleged protester violence and police injuries.
9. Findings, Policy Recommendations and Future Constitutional Questions
Key Findings
- The Supreme Court’s 2026 CJP litigation strengthens, rather than abolishes, the constitutional status of peaceful protest.
- The Court is moving toward a proportionality-based framework for crowd control: public order is legitimate, but force must be necessary, measured and accountable.
- Privacy and informational control have become integral to protest rights because surveillance and public disclosure can chill future participation.
- The HPEC is institutionally significant because it can generate a factual record on police practices, protester conduct and systemic safeguards.
- Article 142 was used as a national remedial mechanism to end the collateral consequences of FIRs arising from a defined set of protest incidents, while preserving a criminal-antecedent carve-out.
- The ultimate constitutional doctrine remains unsettled because the Court expressly reserved broader questions for fuller hearing.
Policy Recommendations
- Adopt a national protest-policing protocol based on necessity, proportionality, warning, graduated response, visible officer identification and mandatory medical assistance.
- Create independent post-operation review for serious crowd-control incidents involving firearms, kinetic projectiles or severe injury.
- Require judicial or independent authorisation and strict retention rules for facial-recognition and protester databases, with non-disclosure safeguards.
- Ensure that prohibitory orders under Section 163 BNSS are reasoned, geographically and temporally limited, evidence-based and periodically reviewed.
- Develop prosecutorial guidelines distinguishing peaceful participation from specific criminal acts, avoiding collective criminalisation of assemblies.
- Provide special safeguards for children and vulnerable protesters, including prompt access to parents/guardians, counsel and medical care.
- Publish anonymised annual statistics on protest-related arrests, FIRs, force deployment, injuries and disciplinary outcomes.
- Preserve an avenue for accountability for genuine violence even where broader protest-related FIRs are withdrawn or quashed.
Questions for the next stage
As of 9 September 2026, the HPEC’s final findings are not available. The next stage should clarify: (i) the legal standard for banning or restricting kinetic projectiles; (ii) the constitutional limits of protest surveillance; (iii) how “criminal antecedents” should be operationalised without guilt by association; (iv) whether Article 142 can permanently close FIRs beyond the formal applications placed before the Court; and (v) what general protest-policing rules, if any, the Court should formulate.
10. Conclusion and References
The recent Supreme Court interventions arising from the CJP/NEET-UG protests represent a consequential moment in Indian constitutional law. The Court has neither declared an unlimited right to protest nor accepted unrestricted police discretion. Instead, the emerging framework is one of calibrated constitutionalism: protect peaceful dissent, regulate public spaces through reasoned restrictions, investigate violence on all sides, restrain disproportionate force, protect protester data, and provide effective remedies when State action threatens liberty and dignity.
The 28 July order supplied immediate safeguards; the 18 August order institutionalised fact-finding through the HPEC; and the 1 September order used Article 142 to terminate the specified FIR consequences while preserving a route for action against persons falling within the Court’s carve-out. Together they suggest that protest law in India is evolving from a narrow “right versus order” debate into a broader governance framework encompassing digital privacy, police technology, institutional accountability and the long-term consequences of criminal process.
The strongest contribution of the litigation may ultimately lie not in the quashing of FIRs but in the constitutional questions left open: when does crowd control become excessive force; when does surveillance become intimidation; when does preventive regulation become a prior restraint on dissent; and how should extraordinary judicial remedies preserve both democratic participation and the rule of law? The answers will depend substantially on the HPEC’s findings and the Court’s subsequent orders. Until then, the 2026 CJP litigation should be understood as an important, evolving chapter rather than a final statement of Indian protest jurisprudence.
Selected References
[1] Constitution of India, arts. 14, 19, 21, 22, 32 and 142.
[2] Himmat Lal K. Shah v. Commissioner of Police, (1973) 1 SCC 227.
[3] Ramlila Maidan Incident, In Re, (2012) 5 SCC 1.
[4] Anita Thakur v. State of J&K, (2016) 15 SCC 525.
[5] Mazdoor Kisan Shakti Sangathan v. Union of India, (2018) 17 SCC 324.
[6] Amit Sahni (Shaheen Bagh, In Re) v. Commissioner of Police, (2020) 10 SCC 439; Supreme Court judgment dated 7 Oct. 2020.
[7] Shailendra Mani Tripathi v. Union of India & Ors., W.P.(Crl.) Nos. 279–280/2026 & connected matters, order dated 28 July 2026.
[8] Shailendra Mani Tripathi v. Union of India & Ors., connected matters, order dated 18 Aug. 2026.
[9] Shailendra Mani Tripathi v. Union of India & Ors., 2026 SCC OnLine SC 1754, order dated 1 Sept. 2026.
[10] Hooda, Sanjana, “Of Protests, Publics and Law: Shaheen Bagh as an Instance of Legal Mobilization,” Erasmus Law Review, 18(2) (2025), pp. 27–43, DOI: 10.5553/ELR.2025.17.
[11] Kumar, Prateek, “Right to Protest Vs. Public Order: A Constitutional Dilemma in India,” Delhi Journal for Law and Justice, Vol. I, Issue I (2025), pp. 62–77.
[12] Gupta, U.D., “Chilli powder and resistance: Mirch Masala, Shaheen Bagh, and the politics of space,” Jindal Global Law Review, 12(1) (2021), pp. 157–169, DOI: 10.1007/s41020-021-00143-8.
[13] “Commuters’ Rights and Public Protest,” International Journal of Advanced Legal Research, Vol. 2, Issue 4 (2022).
[14] Prasad, Padmavathi & Sugumaran, Dharshini, “The Shaheen Bagh judgment and what it means for the right to protest in India,” Law and Other Things (2021).
[15] Supreme Court Observer, “SC quashes Jantar Mantar protest FIRs across India, permits fresh FIR against 2873,” 1 Sept. 2026.
[16] SCC Times, “NEET-UG 2026 Protest: Supreme Court quashes FIRs under Article 142,” 2 Sept. 2026.
[17] Bajpai, G.S. & Balyan, Chirag, “Crowd, Database And Citizen: Protest And Preventive State,” LiveLaw, 22 Aug. 2026.
[18] Indian Express, “Credit to both sides: Supreme Court scraps all FIRs against NEET protesters,” 2 Sept. 2026.
[19] Supreme Court of India, official website and judgments/orders database, consulted for constitutional and case-law verification.
Research cut-off: 9 September 2026. For publication, the author should re-check the certified 1 September 2026 order, subsequent orders after the cut-off, and the final HPEC report when available.
Principal online research sources
https://indiankanoon.org/doc/20269941/
https://indiankanoon.org/doc/75895676/
https://pure.jgu.edu.in/id/eprint/11709/
https://dup.du.ac.in/index.php/JLAJ/article/view/652
https://api.sci.gov.in/supremecourt/2020/2418/2418_2020_36_1501_24294_Judgement_07-Oct-2020.pdf
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