V.C. Rangadurai v D. Gopalan
Rule established
An advocate must not suppress material facts from the court; the duty to the court overrides the duty to the client where they conflict.
Facts
- An advocate suppressed a material fact (a prior adverse order) from the court while arguing a fresh application on behalf of his client. The opposite party brought the suppression to the court's notice.
Issue
- Whether an advocate who suppresses material facts from the court to gain an advantage for the client is guilty of professional misconduct, and whether duty to the court overrides duty to the client.
Held
- The Supreme Court held that the advocate's primary duty is to the court, not the client. An advocate must not mislead the court by suppression of material facts or citations. Where duty to the court and duty to the client conflict, the duty to the court prevails. Suppression of material facts constitutes professional misconduct.
Ratio Decidendi
The Supreme Court held that the advocate's primary duty is to the court, not the client. An advocate must not mislead the court by suppression of material facts or citations. Where duty to the court and duty to the client conflict, the duty to the court prevails. Suppression of material facts constitutes professional misconduct.
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Source
Source: AIR 1979 Supreme Court 281
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.