JUDICIAL ACTIVISM AND SUO MOTO

By:
JAVWAD TARIQ NASIM
(Advocate High Court)
(L.L.B Honours,
University of London)
(L.L.M in International and Commercial Law,
University of Buckingham, UK)

Judicial Activism:

The concept of judicial activism was created and introduced by "Arthur Schlesinger Jr." (an American historian and social critic) to the public in a Fortune magazine article in January 1947.[1]

For an informal definition one can phrase out Judicial Activism as being the process or concept in a judicial system that justifies making decisions which are contrary to established precedents and laws, whether statutory or constitutional. Such decisions are applauded by the general public rather than juristic philosophers and writers.

Numerous legal and non-legal sources have attempted to define the word and have done so successfully in various different expressions. Some of the good sources need to be quoted here as follows:

"A philosophy of judicial decision-making whereby judges allow their personal views about public policy, among other factors, to guide their decisions, usu. with the suggestion that adherents of this philosophy tend to find constitutional violations and are willing to ignore precedent."[2]

The term "Judicial activism" is different from the term "An Activist judge" and should not be confused to mean the same because the former relates to the definitions and concepts defined above while the latter may be referring to a judge who has not literally overturned an established rule or principle but has just given an important judgement/decision on an important law point. Important decisions on points of law even though not in conflict with established laws will be an activist decision by an activist judge. Thereby meaning that the progress of the judiciary is also linked to the term "activism".

The concept of judicial activism especially to laymen is more of a "protector of individual rights" rather than a concept of "restraining constituional violations even if it involves ignoring precedents" even though both concepts are one of a kind when it comes to their effect in their application.

The Debate - Arguing For and Against Judicial Activism:

It is difficult to say whether the concept of judicial activism has made more critics of itself or supporters but in the view of its critics of `the application of the concept usurps power of the legislature, thereby diminishing the rule of law and democracy'. The main objection with the concept is that in the view of its critics, the Courts (Judiciary) are established to rule upon (uphold) the rules and legislation drafted by the legislature and not to check the validity of the legislation. The duly elected participants/members of the parliament have the sole authority to make laws and the courts are only a forum that would interpret them and decide whether someone is following it or deviating from it. The supporters of the concept of "separation of powers" also argue along the same line by arguing that the three organs of the state i.e. the Legislature, the Executives and the Judiciary should operate individually and independently rather than stepping onto the jurisdiction of the other organs of the state.

However on the other hand the people who have defended judicial activism argue that it is the duty of the court and the court should take upon itself to guarantee the rights of individuals against the powerful hands of the few powerful people in the society. Laws that are inconsistent with fundamental rights should be declared to be void with no effect no matter how much loss the legislature has borne in introducing that illegal law. It is the view of the supporters of the concept that it is also the job of the courts to uphold the rights of the minority no matter what political pressures the court faces in making that decision. The country has to be "socially equal" in everyway to achieve full democracy. It cannot make double standards as to its own policy making and the courts should be there to watch that such double standards have not arisen between the general public and the government.

Another critic of the concept is the present Chief Justice of America, John Roberts who has condemned the concept of `judicial activism' in the following words;

"Judges are like umpires. Umpires don't make the rules; they apply them. The role of an umpire and a judge is critical. They make sure everybody plays by the rules. But it is a limited role. Nobody ever went to a ballgame to see the umpire."

Furthermore the Chief Justice has stated that `the courts are not under a commission or mission to solve the society's problems'. The courts in his view are only the adjudicators upon fact and law and they should responsibly do only the duty of interpreting law.

An example of a U.S case that involved important judicial activism is quoted as follows:

Dred Scott vs. Sandford[3]

This case also known as the "Dred Scott Decision", was a lawsuit, pivotal in the history of the United States, decided by the United States Supreme Court in 1857 that ruled that people of African descent, whether or not they were slaves, could never be citizens of the United States, and that Congress had no authority to prohibit slavery in federal territories. The decision for the court was written by the then Chief Justice of Amercia, Roger Taney. The implications of the decision are not under discussion because the important point to note here is that the Court took upon itself to lay down the law as opposed to interpreting it which is the primary duty of the Judiciary.

Judicial Activism in Pakistan:

Judicial activism in Pakistan is becoming a norm rather than an exception. The judiciary in Pakistan has assumed the role of upholding the constitutional rights of the citizens of Pakistan themselves, ensuring that the fundamental rights of the public are not being infringed by the powerful political parties at their whim.

One of the various modes in which judicial activism is practiced or is entrusted upon the courts to practice is through the concept of "Public Interest Litigation" (hereinafter referred to as "PLI"). The main appellate Court which is the court of last resort is the Supreme Court of Pakistan. The Supreme Court has been involved in historical problems which have frequently changed the level of judicial activism in Pakistan but the soaring level at which it has been for the past few years has never been witnessed before.

Pakistani courts have been involved in judicial activism since a long time back and one of the examples of such activism can be witnessed from the 1988, Saifullah's case. Despite the strong pressure by the executives, it was made mandatory that elections would be held on party basis. Later, the Lahore High Court and the Supreme Court both declared that the government of "Junejo" was dissolved unconstitutionally. The matter came down to an interpretation of Article 17 of the Constitution and by taking a very dynamic interpretation of Article 17 of the Constitution, the Nawaz Sharif government was restored in 1993. Had the Supreme Court interpreted the article literally, the case should have been heard by a High Court at first instance.

Therefore it is evident that the Pakistani courts have been involved in judicial activism since a long time back whether it is activism in relation to political affairs or activism for the protection of individual rights and the upholding of the rule of law.

The recent example of the "clash" between the Chief Justice of Pakistan, Iftikhar Muhammad Chaudhry and the President of Pakistan, can be attributed to Judicial Activism in Pakistan. Prior to the tussle between the two, the Chief Justice of Pakistan ("CJP") had been taking various harsh actions against several governmental authorities/bodies under the shield of Suo Moto. When the decisions of the CJP became agonizing for the President and his reign, he removed the CJP in one day by exercising the so-called powers of the President in the mistaken capacity of the Chief of Army Staff.

Suo Moto:

The concept of suo moto (in the context of Pakistan) can be defined as an inherent right of the Supreme Court and High Court of Pakistan to take cognizance of any act/omission of any public functionary in order to check the legality and more often, the legitimacy of any action of that public functionary. Anything under the sun can come under the notice of the two Apex courts of Pakistan.

In Pakistan the courts have gradually developed this doctrine and are acting upon it on a day to day basis whenever they get a chance. In other words a special tool named Suo Moto has been created by the Pakistani courts to legitimize the taboo of "Judicial Activism". The two terms "Suo Moto" and "Judicial Activism" are different concepts and are not interchangeable with each other; in fact the former is a part of the latter. Suo Moto can contribute to judicial activism but there are various other methods by which judicial activism can take place.

Suo moto has reached the status of an "inherent right" in Pakistan, in other words it means that it is perfectly legitimate for the Judiciary (High Court and Supreme Court) to interfere in the domain of other organs of the state. This in turn means that the doctrine of "Separation of Powers" is directly in conflict with the doctrine of Suo Moto.

Conclusion

While concluding this discussion on Judicial Activism and Suo Moto, it is necessary to evaluate the public perception of judicial activism in Pakistan. For the general public in Pakistan, suo moto action has been a divine revelation, something that can be equated to a blessing. The poor and suppressed community being the majority of the community in Pakistan is in strong favour of the doctrine of suo moto. The current CJP has taken numerous decisions behind the facet of suo moto jurisdiction including decisions on the enforcement of human rights and on cases such as the `missing persons' cases.

One of the manifold reasons for the success of the concept of Suo Moto is that it is effortlessly accessible to the poor (which is the majority class in the country) so for the poor and needy only a simple hand written "letter" can initiate proceedings in the highest court of Pakistan. The people who cannot even imagine affording the towering fees of big named attorney's can simply request the CJP through a letter about any malpractice of a governmental authority and the CJP (especially the ex-CJP) would be more than willing to cure the defects by ordering the needful.

In this way suo moto action is a blessing for those who have been victimized by the might of governmental authorities. Moreover another positive effect of the suo moto action is that the governmental authorities in order to save themselves the embarrassment of being called inefficient or ultra vires through court try to restrain themselves into doing acts which are within its legal sphere.

The new concept may be a violation of the rule of separation of powers but the question then arises, do we actually need a concept such as "separation of powers"? Is the legislature and executive doing anything according to the rules of natural justice so that the citizens and the organs (which are made up of the citizens themselves) are totally honest with the country? Instead of making the situation worse, the judiciary is helping the country in developing integrity and responsibility towards citizens, guaranteeing the enforcement of their fundamental rights and constitutional rights as promised in the Constitution of the Islamic Republic of Pakistan, 1973.

A developed country like the U.S which only requires checks and balances for its smooth running can afford to apply and abide by such a doctrine but where a country like Pakistan is being dictated by the military for the past 10 years, it is better for someone to take upon him/her self the responsibility of providing justice and who else is better equipped or legally capable to provide justice other than a Judge of the Supreme Court of Pakistan?

The recent decision of the Supreme Court of Pakistan regarding the holding of two posts simultaneously by the President i.e. the posts of Chief of Army Staff and the President of Pakistan has taken the general public by surprise (the Supreme Court has held with a majority of 6-3 in favour of the President that he can legally hold the two concerned posts at the same time) because the intensity and frequency of judicially active decisions since the past few months had created a strong belief in the general public's mind that the current President would not be allowed to keep both posts simultaneously.

Is this decision a product of judicial activism as well or has the government used its sticks against the judiciary to calm its activism down?  No  matter  what  explanations  the  Supreme  Court  gives  in  its detailed order, the language of Article 63 of the Constitution of the Islamic Republic of Pakistan is clear and unambiguous. It clearly lays down that a member of Majlis-e-Shoora (the Parliament) cannot be a person who has been in the Civil Services of Pakistan or has acted and worked in a post which is controlled or owned by the government.

This decision can also be viewed as judicial activism by the judges by ignoring the express prohibition in Article 63 of the Constitution of the Islamic Republic of Pakistan but this time the judicial activism was in favour of one man at the expense of a nation built up of millions of people.

A final verdict upon whether judicial activism is favorable or not can be concluded in making a statement that such activism is favorable for a third world country like Pakistan where justice and equality is not at arms length for the poor. Judicial activism has helped societies all over the world in developing their laws, however such activism should be checked and balanced so that the judiciary does not become the legislature and the interpreter of law. The role of the judiciary is to interpret the law as laid down by the legislature and in doing so it should keep in mind the intention of the legislature as well as the benefits and detriments of the final decision upon the society. Last but not the least, the actions and activism of the judiciary should replicate the needs of the society and any action taken on behalf of the public should be for the benefit of the public as a whole as opposed to the recent decision of the Supreme Court regarding the holding of two posts simultaneously by the President, which is on the face of it tainted with only one person's personal interests.

 



[1].              Keenan Kmiec in a 2004 California Law Review article.

[2].              Blacks Law Dictionary.

[3].              60 U.S. 393.