Wednesday, November 4, 2015

THE TEN COUNTER-ARGUMENTS: A Critique of the Judgment of the Hon'ble High Court of Jammu & Kashmir in the Ashok Kumar Case

In a recent judgment, a two-Judge bench of the Hon'ble High Court of Jammu and Kashmir ruled that Article 370 of the Constitution of India had assumed permanence and that the provision is beyond amendment, repeal or abrogation. The Court went on to say that Article 35A gives 'protection' to existing laws in force in the State of Jammu and Kashmir. The dispute before the Hon’ble High Court of Jammu and Kashmir related to the right of the reserved category government servants to accelerated promotion provided under Section 6, J&K Reservation Act, 2004, read with Rule 9 & 34, J&K Reservation Rules, 2005.

I will desist from going into the merits of the specific controversy and the efficacy of the Court’s adjudication, because that is not the focus of this article. The focus herein is the objective analysis and critically evaluation of the Court’s rationale for concluding that Article 370 is “non-abrogable” and “non-amendable”.

The Cabinet Mission, 1946
1.       To begin with in Para 16 of the judgment, the Hon’ble Judges have stated:

“The State of Jammu and Kashmir ("the State" hereinafter) like other 600 and odd princely States, regained its sovereignty on 15th August 1947, on the lapse of British Paramountcy, enactment of Indian Independence Act 1947 and emergence of Dominions of India and Pakistan. This was made clear by Cabinet Mission Memorandum dated May 12, 1946 as regards "States Treaties and Paramountcy" and Statement of Viceroy of May 16, 1946, to the effect that "Paramountcy can neither be retained by the British Government nor transferred to the new Government."

There is substantial distortion of facts, mischievous or otherwise, in the untenable averments that: “the State of Jammu and Kashmir...like other 600 and odd princely States, regained its sovereignty on 15th August 1947, on the lapse of British Paramountcy...”

The Cabinet Mission’s “Memorandum on States’ Treaties and Paramountcy”, dated May 12, 1946─ presented to His Highness the Chancellor of the Chamber of Princes (Note: Hajji Nawab Hafiz Sir Hamidullah Khan, the last ruling Nawab of Bhopal was the Chancellor of the Chamber of Princes in 1946) on 12 May, 1946was drawn up while the Mission was in discussions with Indian National Congress (INC) and Muslim League (ML) leaders. It represented the substance of what was communicated to the representatives of the States at their first interviews with the Mission.

Various discussions were held subsequently with party leaders to discuss proposals for transfer of power. Congress and League leaders did not agree on the terms of the Mission’s formula. Hence, the Cabinet Mission to India announced its “suggested” plan unilaterally on May 16th 1946 (but, published on May 22nd 1946), which looked to create a united dominion of India as a loose confederation of provinces. The provisions regarding Indian (princely) States specified:

“After transfer of power to the British Indian Provinces, Great Britain would neither retain paramountcy over the Indian States itself nor transfer it to the new Government of British India. It was however hoped that the States would negotiate their way in the Union Government.”

Interestingly, the Hon’ble Judges while taking due cognizance of the first part of the provision, deemed it unnecessary to either (a) consider the part that talks about (princely) States negotiating “their way in the Union Government”; or, (b) mention the fact that retention of paramountcy and attainment of independence by the states was never envisaged.”  

Regardless, both the Indian National Congress and the Muslim League rejected this May 16th, 1946 proposal.

The Mission then proposed an alternative plan on 16th June 1946, wherein the idea of partition was mooted. The Congress Party rejected this plan too was rejected. The Muslim League, which had initially accorded its acceptance, in its later resolution of July 29, 1946 withdrew its acceptance.

However, Lord Listowel, the Secretary of State for India, in his address to the House of Lords on the Indian Independence Bill, 1947, explained the operational aspects of independence on 16th July 1947 as follows:

“From that moment the appointments and functions of the Crown Representative and his officers will terminate and the States will be the masters of their own fate. They will then be entirely free to choose whether to associate with one or other of the Dominion Governments or to stand alone and His Majesty's Government will not use the slightest pressure to influence their momentous and voluntary decision. But I think it can hardly be doubted that it would be in the best interests of their own people, and of India as a whole, that in the fullness of time all the States should find their appropriate place within one or other of the new Dominions. It would be a tragedy for India, if the States were not to enrich the Motherland to which they belong with the martial valour for which they are renowned, and which they have displayed so gallantly in two world wars, with the tradition of service that animates their rules, and with the advanced social institutions that some of them possess.”

Then, again the Viceroy and Governor General of India and representative of the British Crown of erstwhile India, Lord Mountbatten, during his speech to the Chamber of Princes on July 25, 1947 affirmed that the Indian Independence Act, 1947, (which was enacted by the British Parliament on 18th July, 1947) had released “the States from all their obligations to the Crown." He said that they were technically independent, or, put another way, rudderless, on their own. The old links were broken, but "if nothing can be put in its place, only chaos can result— a chaos that "will hit the States first". He advised them therefore to forge relations with the new nation closest to them. As he put it bluntly, "you cannot run away from the Dominion Government which is your neighbour any more than you can run away from the subjects for whose welfare you are responsible".

In short, he told the rulers of the erstwhile princely states that in the circumstances it was best they make peace and sign the Instrument of Accession.

Thus, it is clear that the “attainment of independent statehood” was only a theoretical possibility. In reality, statehood was neither contemplated for nor offered to the princely states, regardless of how one interprets the memoranda, reports, statements, etc., of the Cabinet Mission and other functionaries of the British Crown. And, since the INC and ML rejected the proposals, any tacit understanding to the contrary between the Cabinet Mission and the Chancellor of the Chamber of Princes was non-binding. They were, at best, sincere assurances and, at worst, empty promises of the Cabinet Mission. Historical evidence stands testament to the fact that not even one of the princely states eventually became an independent, sovereign State.

Limited Sovereign Powers at the Stroke of Midnight
2.       In Para 17 of the judgment, the Hon’ble Judges have put on record that:

“The Ruler of an Indian Princely State having regained absolute sovereignty on the lapse of Paramountcy and end of its Treaty obligations towards Imperial power, got power to decide future of his State including an option to accede to either of the two Dominions India or Pakistan in accordance with Cabinet Mission Memorandum 1946, Statements of June 3, July 25, 1947 and the Indian Independence Act, 1947.”

I have already talked about the fallacies of using the Cabinet Mission Memorandum to either logically validate or legitimately justify the attainment of absolute sovereignty by princely States on the lapse of British paramountcy. Statements of the Governor General and the representative of the British Crown in India, Lord Mountbatten, too have no legal standing or evidentiary value.

One would have to exclusively scrutinise the Indian Independence Act, 1947 and the provisions thereunder to interpret the powers that devolved on the princely states post independence. It is a fact that the Indian Independence Act provides for the creation of only two dominions, viz., India and Pakistan [S. 1 and S. 2(4)]. No explicit provisions exist that support the view that princely States were accorded absolute sovereignty, for, had that been the case, then:
1.       S.1 of the Indian Independence Act would have referred to “British India” and not “India”. The General Clauses Act, 1897 makes it amply clear that the latter term was used synonymously with British Raj, which included the territory directly administered by Britain (and hence referred to as “British India”) as well as the princely states ruled by individual rulers under the paramountcy of the British Crown.
2.       S.8 of the Indian Independence Act would have provided suitably for a Constituent Assembly without representation from some (if not all) of the princely states, which chose, by virtue to having absolute sovereignty, to attain statehood by refusing to execute the Instrument of Accession.
3.       S.9 of the Indian Independence Act would have excluded application of the Government of India Act, 1935, either through provisions within the Act or by order of the Governor-General to make such provision for excluding such application to the princely states, either specifically or otherwise, which chose not to execute the Instrument of Accession.

Then again, the Government of India Act, 1935 which despite never being fully implemented, was adopted and operated as part of the constitutional basis, for the dominions of India and Pakistan, after independence till the Constitution came into force also provided for representation of Jammu and Kashmir in the Federal Legislature. This clearly indicates that Jammu & Kashmir not being part of either of the two dominions was not envisaged at all.

If sovereignty and independence had indeed been a viable option, would not the British have made arrangements for allocating part of the Armed Forces to the State of Jammu & Kashmir and placing it under the command of the Maharaja, so as to enable him to defend his territory better?

Object of Accession
3.       In Para 20 of the judgment, the Learned Judges have recounted that:

“The immediate object of accession, unlike other Princely States...was to make possible and legitimize deployment of troops of Indian Army to the State...”

The object of the accession, notwithstanding its extent of proximity, is immaterial in the context of the result of the accession, i.e., the integration of the State of Jammu and Kashmir with the Dominion of India. Thus, when the Instrument of Accession was executed by the ruler of the princely State of Jammu and Kashmir, who, as per the observations of the Judges in the preceding parts of the Judgment, enjoyed absolute sovereignty over the State.

Given the prevailing, exigent circumstances, the Maharaja made a choice out of his own volition. There was neither coercion nor undue influence exercised by the Government of India to compel him into signing the Instrument of Accession. Consequently, the validity or legitimacy of the Instrument can hardly be called to question.

Instrument of Accession
4.       In Para 21 of the judgment, the Learned Judges go on to mention:

“Though the Instrument of Accession signed by the Ruler of the State was similar to such Instruments signed by Rulers of other Princely States..., yet the attending circumstances of the signing of Instrument of Accession and its acceptance, sufficiently indicate that contemporaneously with the signing of the Instrument of Accession, a Constitutional framework was conceived where under the State unlike other States that acceded to Dominion of India, was to enjoy a special constitutional status.”

Indeed, it is ironical that the Hon’ble High Court has concluded that a “...constitutional framework was conceived where under the State...was to enjoy a special constitutional status” without relying on any evidence in support of such inference. The Instrument of Accession was exactly the same as what about 500 other princely states executed (Pg. 56 of Justice A.S. Anand’s book titled “The Constitution of Jammu & Kashmir: Its Development& Comments”).

The correspondence exchanged between Lord Mountbatten and Maharaja Hari Singh shows no traces of any such overt or covert commitment to any “special constitutional status,” except for the “wish” of Lord Mountbatten’s government that “as soon as law and order have been restored in Kashmir and her soil cleared of the invader the question of the State’s accession should be settled by a reference to the people.”

To begin with, that was a “wish”, which under any and all tenets of jurisprudence is not tantamount to a contractual promise, or obligation, or commitment for according any “special constitutional status”. That “wish” was subject to the “restoration of law and order” in Kashmir and the “clearance of her soil of the invader.” The later, as we all know has not been achieved yet. Furthermore, that “wish” or “desire” was extinguished once Lord Mountbatten’s government was replaced by C. Rajagopalachari’s government.

The Learned Judges have also held that the condition mentioned in Para 4 of the Instrument of Accession confers special privileges on the State. The relevant Para 4 of the boilerplate Instrument reads: “4. I hereby declare that I accede to the Dominion of India on the assurance that if an agreement is made between the Governor-General and the Ruler of this State whereby any functions in relation to the administration in this State of any law of the Dominion Legislature shall be exercised by the Ruler of this State, then any such agreement shall be deemed to form part of this Instrument and shall be construed and have effect accordingly.”

The fact remains that no agreement was subsequently made between the Governor-General and the Ruler of the State of Jammu and Kashmir. Hence, the Para merits neither further mention nor extra attention in the context of any assessment of whether any special status was conferred on the State of Jammu and Kashmir.

The same argument of “special status” is applied to Para 7 of the Instrument of Accession, which reads as follows: “7. Nothing in this Instrument shall be deemed to commit me in any way to acceptance of any future Constitution of India or to fetter my discretion to enter into arrangement with the Government of India under any such future constitution.”

Clearly, under the terms of this Instrument of Accession, the Ruler exercised his discretion in designating four of his state subjects, viz., Sheikh Abdullah, Motiram Baigra, Mirza Mohmmad Afzal Beg and Maulana Mohammad Sayeed Masoodi, to represent the State of Jammu & Kashmir in the Constituent Assembly of India. And, when the four representatives affixed their signatures, the Maharaja accorded his unconditional acceptance to the Constitution of India.

Temporary Provisions for Jammu & Kashmir
5.       Further, the Hon’ble Court goes on to cite In Para 21 that:

“...the State was to stand on a different pedestal and to be given distinct and different status as regards constitutional powers, it was to enjoy after accession.”

The Judges have selectively quoted statements of Shri. N. Gopalaswami Ayyangar, who identified eight special circumstances while introducing the Draft Clause 306A (corresponding to Article 370 in the Constitution of India), to support their views on special status for J&K.

A comprehensive review of the transcripts of the Constituent Assembly proceedings show that Shri. Ayyangar referred to Draft Clause 306A as an “interim system / arrangement” four times. He also made a mention thrice of the “special conditions” that necessitated the inclusion of such “interim or temporary provisions”. Under no stretch of one’s imagination can an “interim”, i.e., “temporary” provision desirable because of “special conditions” be deemed to confer “special status” on the State of Jammu & Kashmir. Any attempt to justify the anointment of “special status” on Jammu and Kashmir by such reference to Constituent Assembly debates would be motivated, if not mischievous, manipulative or mala fide.

Needless to say, the Learned Judges have based their assertions on completely fallacious statements and lopsided arguments, ill-founded on fact; unfounded in law, and, ill-conceived in logic.

The Judges also aver that the Dominion of India had decided to treat the State differently and not at par with other States because “the [decision] to accept the Constitution (of India)...in its entirety to their States...was not taken by the Ruler of the State.” This convoluted rationale does not hold up against the fact that the four representatives of the State of Jammu and Kashmir in the Constituent Assembly of India unequivocally and unconditionally accepted and adopted the Constitution of India. Thus, through that act, the Ruler of Jammu & Kashmir, Maharaja Hari Singh bestowed his allegiance to the sovereignty of India and the supremacy of its Constitution.

State of Jammu and Kashmir: Equal or Unequal
6.       Then again, the Judges tenuously attempt to prove the special status of Jammu and Kashmir in Para 21 by reiterating that:

(iii) The Ruler a few months after signing of the Instrument of Accession, in the Declaration of 5th March, 1948 announced his resolve to constitute a National Assembly to frame Constitution for the State.
(iv) The State did not adopt Government of India Act, 1935 or the Constitution for the intervening period till Constituent Assembly was convened, Constitution framed and adopted, but decided to adopt and abide by Jammu and Kashmir Constitution Act, 1939.

This misconception of “special status” is repeated in paras 24, 25, 26 and elsewhere. The attempt is to imply that the State's accession is somehow unique.

As a matter fact, during the intervening, transitional period between gaining of independence and the coming into force of the Constitution, i.e., between August 15, 1947 and January 26, 1950, the Government of India Act, 1950 was the constitutional framework of India. Section 2(1) of the Act makes it clear that the princely States were kept out of the ambit of the Act.

Consequently, after accession, other princely states, such as Mysore, too chose to be governed under their existing administrative and governance framework. The Maharaja of Mysore too had signed the Instrument of Accession with the Dominion of India, whereby, on all subjects, except foreign affairs, defence and communication, the state had absolute power to administer. Indeed, Mysore too convened a Constituent Assembly of its own to frame a Constitution. The members of the Constituent Assembly were elected by the old limited franchise during the elections held in February, 1948. But, it was felt that a separate Constitution for Mysore State was redundant. So, in November 1949 it was announced that on 26th January 1950, when India’s new Constitution would come into effect, the old Representative Assembly and the Legislative Council in Mysore State would be abolished and Mysore’s Constituent Assembly would become the main legislative body.

Thus, there is absolutely nothing exceptional or extraordinary about the decisions and declarations of the Ruler to convene the Constituent Assembly for the State of Jammu and Kashmir.

Origin of Article 370
7.       In Para 23, the esteemed Judges look to imply that Article 370, with “its roots in paras 4 and 7 of the Instrument of Accession...provided for the convening of a Constituent Assembly to frame the Constitution of the State.”

This again is either a misrepresentation or misunderstanding of facts borne out of inadequate historical research. Like I have already mentioned, other states too (case in point, Mysore) had convened Constituent Assemblies based on the provisions of the Instrument of Accession. In other words, Article 370 or no Article 370, the Instrument of Accession had the relevant provisions empowering rulers to convene Constituent Assemblies for their respective States.

Article 370: The Link Between State of J&K and India
8.       The revered Judges then observe in Para 25 that:

“Article 370 is the only provision of the Constitution that applies to the State, on its own... [besides] Article 1 made applicable by sub clause (c) clause (1) Article 370. The Constituent Assembly (of Jammu and Kashmir) in terms of proviso to Clause (3) Article 370 is conferred power to recommend to the President that Article 370 be declared to cease to be operative or operate only with the exceptions and modifications mentioned in the recommendation, if any so made. It is only on such recommendations that the President in terms of Clause (3) Article 370 of the Constitution may, by public notification, declare that Article 370 shall cease to be operative or shall be operative only with such exceptions and modifications and from such date, specified in the notification. The Constituent Assembly did not make such a recommendation before its dissolution on January 25th, 1957. Resultantly, Article 370, notwithstanding its title showing it a "temporary provision" is a permanent provision of the Constitution. It cannot be abrogated, repealed or even amended as mechanism provided under Clause (3) of Article 370 is no more available.”

The juristic rationale above is weak and flawed, to say the least, for the following reasons:
1.       The political doyens, legal luminaries, social activists, cultural stalwarts and other representatives who entered the Constituent Assembly of Jammu and Kashmir were all very erudite, experienced and accomplished people. They all had the confidence of the people of J&K reposed in them.
2.       In such a scenario, it is a safe assumption that they knew that no Constitution is a rigid, static document; but a dynamic, constantly-evolving legislative framework, which binds people together.
3.       Had the Constituent Assembly of J&K (CAJK) felt that the provision of Article 370 was permanent and that it envisaged an ongoing role for the Assembly, then they surely would never have disbanded themselves.
4.       Furthermore, the CAJK clearly saw its role and terms of reference as being that of drafting the Constitution of J&K. They had neither the mandate nor the locus standi to advise or recommend the repeal of Article 370, which is / was a parliamentary prerogative.
5.       Finally, as we all know, the Supreme Court of India has not included Article 370 as being an integral part of the Basic Structure, which implies that the provisions can be amended and even abrogated, provided such amendment or abrogation is not ultra vires the Constitution
6.       Hence, how can the sovereign rights of the Indian Statehood, supremacy of its Constitution and legislative powers of Parliament in a representative democracy be diminished or curtailed because of a technicality?
7.       Indeed, it is not morally, legally or constitutionally valid to impose fetters on parliamentary power conferred by the Constitution of India only because of an act of omission of a subordinate body set up under that same Constitution, the grundnorm of the land.

Thus, the views of the scholarly judges of the Hon’ble High Court of Jammu & Kashmir, with regard to the perpetuation of Article 370, are such that in the constitutional schema, it is akin to the tail wagging the dog. The point is that the Union cannot be denied the exercise of its sovereign powers because of a procedural lapse by the Constituent Assembly of Jammu and Kashmir.

Impact of Article 35A
9.       Next, the Hon’ble Judges have maintained in Para 27 that:

“The Article 35A gives protection to existing laws in force in the State and to any law enacted after 1954 by the State legislature, defining the classes of persons treated as permanent residents of the State, conferring on permanent residents any special rights and privileges or imposing upon other persons any restrictions as respects employment in the State Government, acquisition of immovable property in the State, settlement in the State or right to scholarship and other aids granted by the State.”

It is surprising that the Judges hold such an opinion about Article 35A, which essentially is the result of the Executive usurping powers of the Legislative. Regardless, the fact of the matter is that Article 35A has derogated and diminished the rights, some fundamental, others constitutional, of the people of Jammu and Kashmir. A few of such curbs and curtailment pertain to rights of other backward castes; women’s inheritance rights; right to education; etc.

I will dwell deeper on this issue of impact of Article 35A on the rights of the people of Jammu and Kashmir in a separate article.

Unbridled Presidential Powers
10.   In Para 36, the Judges have concluded that:

”...the President under Article 370(1) is conferred with power to extend any provision of the Constitution to the State with such exceptions and modifications as the President may deem fit subject to consultation or concurrence with the State Government and that such power would include one to amend or alter the provision to be applied, delete or omit part of it, or make additions to the Provisions proposed to be applied to the State.”

Clearly, entrusting the President with such sweeping powers, in contravention of all accepted norms of creating checks and balances within government through the “separation of powers” among the branches of the state, is a mockery of the founding principles of a democratic republic. Be as it may, the risk of vesting the President with such extensive discretionary power is that the political discourse for the State could be easily hijacked, more so if it were a weak or ineffective President. Worse, it could lead to an autocratic or authoritarian regime in the State of Jammu and Kashmir.

Further, as has been held by the Apex Court in the Puranlal Lakhanpal case (AIR 1961 SC 1519), which the Judges have also cited: “...the object behind enacting Article 370 (1) was to recognise the special position of the State of Jammu and Kashmir and to provide for that special position by giving power to the President to apply the provisions of the Constitution to that State with such exceptions and modifications as the President might by order specify.”

So then, while admitting that Article 370 recognises the special position of the State of Jammu and Kashmir, as held in the Puranlal Lakhanpal judgment, it is pertinent to note that no judgment of that Supreme Court has concurred with the view that Article 370 is a permanent feature of the Constitution of India. 

Indeed, it is high time the people of Jammu and Kashmir initiated an honest dialogue and made an objective attempt to assess whether Article 370 has truly furthered the interests of the State. If the conclusion is that Article 370 has had a deleterious, detrimental effect on the State of Jammu and Kashmir and its people, then the State and Union should work towards either its amendment or its abrogation. Blindly clinging on to Article 370 because of political pressures or perverse propaganda serves neither the interests of the State of Jammu & Kashmir nor the Union of India.

The Hon’ble Judges Janak Raj Kotwal and Hasnain Massodi have surely used convoluted logic, perhaps out of ignorance, if not incompetence, to conclude that the said Article is “beyond amendment, repeal or abrogation.”  It appears that, in the process of making invalid, inaccurate, inappropriate and mostly untenable arguments, they have extensively adopted a policy, intentionally or otherwise, of suppressio veri, suggestio falsi.


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