Pradip Chandra Parija And Ors vs Pramod Chandra Patanaik And Ors

The Supreme Court addressed whether a Bench of two Judges can disagree with a judgment of three Judges and refer the matter to a larger Bench. Citing Article 145(2) and (3) of the Constitution, the Court held that a two-Judge Bench must follow the precedent set by a three-Judge Bench unless it is overruled or deemed per incuriam. The Court clarified that the proper procedure is to refer the matter to a three-Judge Bench rather than directly to a five-Judge Bench, emphasizing the importance of judicial discipline and hierarchy in the judicial system.