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In Trimurthi Fragrances (P) Ltd. v. Government of NCT of Delhi, decided on 19 September 2022, which…

Trimurthi Fragrances held that a majority decision of a Bench of larger strength prevails over a decision of a smaller Bench regardless of the size of the majority. The…

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In Trimurthi Fragrances (P) Ltd. v. Government of NCT of Delhi, decided on 19 September 2022, which rule did the Supreme Court apply to conflicting precedents of Benches of different strengths?

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Answer and explanation

Correct answer A

Trimurthi Fragrances held that a majority decision of a Bench of larger strength prevails over a decision of a smaller Bench regardless of the size of the majority.

The judgment illustrates the rule by contrasting a unanimous five-judge decision with a seven-judge decision reached by a four-to-three majority.

Option feedback

Option A

Bench strength controls. A majority decision of the larger Bench binds smaller Benches even when the vote is close.

Option B

The Court specifically rejected using unanimity in a smaller Bench to displace a larger Bench’s ruling.

Option C

Counting majority votes across separate Benches does not determine precedential priority.

Option D

A later date alone does not allow a smaller Bench to displace the larger Bench’s rule.

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