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Supreme Court of India 2018-02-21 allowed

Advanta India Ltd vs B.N. Shivanna

Bench: 2 — A.K. Sikri

In Brief

An advocate was found guilty by the Bar Council's Disciplinary Committee of serious professional misconduct—defrauding a company of Rs. 72 lakhs by falsely claiming to file criminal petitions and fabricating a High Court order. The Bar Council's appellate order reduced his punishment from lifetime debarment to 18 months. He then filed a review petition, which the Bar Council allowed in 2015, revisiting the same issue of procedural fairness (denial of cross-examination rights) that it had already considered and rejected. The Supreme Court held that the Bar Council exceeded its review jurisdiction, as it cannot become an appellate authority over its own previous finding. The Court invoked the maxim that a party cannot take advantage of its own wrong. The 2015 review order was set aside and the 2011 order was revived, allowing the appellant's original appeal challenging the quantum of punishment to proceed.

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Legal Professional Conduct Bar Council Discipline Review Jurisdiction Fraud and Misconduct by Advocates Administrative Law Natural Justice

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