UNIT-2: SOME BASIC PRINCIPLES OF PROCEDURAL LAW

Principles: 
 

1. PRINCIPLE OF LOCUS STANDI

Locus standi is the Latin term that translates into a place of standing. In simple terms, it means the authority to file a suit at the court. In legal parlance, locus standi means the right bringing an action, to be heard in court, or to address the court on a matter pending before it to

It is the ability of the party to show the court that there exists sufficient connection or cause of action to the party, from the law suit. The question of locus standi generally comes up when one party files a suit for another's cause of action, such as in a Public Interest litigation.

According to Black's Law Dictionary, “Locus standi is a place of standing in the court as the right of appearance in the court of justice or legislative body on a given question”.

It is the sufficiency and directness of a litigant's interest in proceedings which warrants his/her title to prosecute the claim asserted.

There exist the following 3 possibilities in application of the locus standi rule:

• There is a direct impact on the party due to which the party is seeking legal intervention for relief, or
• There is a reasonable indirect effect on the party.
• Law confers upon the party an automatic standing as in public interest litigation

The principle of locus standi applies in civil cases and mostly in writs. In criminal cases, every person residing within a territorial jurisdiction has the standing to file reports or complaints. In civil cases, the party suing must be an aggrieved party. Similarly, it is a common understanding that a writ may be filed only by a person who has substantive interest.

An applicant whom the court regards as having no locus standi to initiate the action is an incompetent plaintiff. It also limits that person's access. to the court.

Necessity of locus standi

• It protects the interest of defendant.
• It prohibits unnecessary expenditure, time and tension
• It prohibits judicial control over legislative/Executive
• It provides remedy to real victims.
• It helps to prevent overflow of the case.
• It stops from raising intellectual curiosity.
• It reduces unnecessary challenges to an act.

Legal Provisions

• Constitutional Provisions:
  Art 133 (1) : Any citizen of Nepal may file a petition in the supreme court to have law or any part of law declared void on the ground of inconsistency with the Constitution because it imposes an unreasonable restriction on the enjoyment of any fundamental rights.
  Similarly, one can file a petition before the District court and High court pursuant to Article 159 and Art 144 respectively.

   

• Muluki Civil Code, 2074:
  Sec 26: A person who is arrested or detained or anyone on his / her behalf may file a petition in the Supreme Court, High Court or District court for the writ of Habeas Corpus. 
   

• Muluki Civil Procedure Code, 2074
  Sec 10: A person who intends to file a plaint in the Court shall set down in the plaint that s/he is entitled to make any claim or has lawful interest or concern in such a claim, and show his/her locus standi.
  Sec 86: A person shall make a plaint claiming for only the matter in which s/he has right.
  Sec 91: Any person may, with the leave of the court, file a plaint on a dispute involving the rights interest or concern of the Government of Nepal, Provincial Government or Local level or public interest or concern. 
  Sec 267: Guardian or curator may submit a plaint on behalf of minor, infirm, person with visual or speech impairment, of unsound mind and disappear ed person.

   

• Muluki Criminal Procedure Code, 2074 
  Sec 43: The following authority or person may file the following case required to he filed under this Act in the concerned court: 

1.  The concerned Government attorney in relation to a case related to any offence under Schedule-1 or Schedule -2, in the form of a charge-sheet.
2. The Government of Nepal, Constitutional body, court or any public authority, in relation to a case related to any offence under Schedule - 3 in the form of a complaint at report.
3. The concerned person or one who bas locus standi to file case, in relation to a case related to any offence under Schedule-4 in the form of a plaint.

• Sec 53: Except as otherwise provided in this Act, the following person may file a complaint in relation to offence enlisted in Schedule-4 in the court:

1. A person who has suffered injury from the offense.
2. In the case of any matter requiring complaint by a public servant who is deputed elsewhere or abroad in the course of his/her immediate successors, employment, any of his/her immediate successors.
3. In relation to any act or thing required to be done or preserved by any person by virtue of any post, office or any other capacity, the person holding such post, office or capacity
4. In relation to any matter in which a person with speech or visual impairment, child or person over 75 years of age or person who is physically or mentally incompetent is entitled to make complaint, his/her successor living in the joint family and, failing such successor, any other successor or guardian. 
5. In relation to any offence involving anybody corporate, the director, member, administrator or chief executive officer who is authorized to act as the chief of such body.

• Muluki CivilProcedure Code 2074 
  Sec 53: 1f a minor or a person of unsound mind who is to make plaint dies before the minor becomes major or the person becomes of sound mind, his/her heir may make a plaint within the statute of limitation from the date on which s/he dies. 

  If a minor becomes major or a person of unsound mind becomes of sound mind and thereafter dies, his/her heir may make a plaint within remaining period of the statute of limitation when such a remaining period is 35 days or more from the date on which s/he so dies and within 35 days from the date on which s/he so dies when such a remaining period is less than 35 days from such a date.

  Sec 54: Notwithstanding anything contained in sec 52 or 53, in the case of minor or person of unsound mind, his/her guardian or curator, if any, under law may make a plaint within the statute of limitation. 

   

Types of Locus Standi 

1. Public Locus Standi: It refers to the right to file a case on behalf of the public interest. It can be invoked by anyone who has sufficient interest in the matter at hand. 
2. Private locus standi: It refers to the right to file a case by only a person whose legal right has been violated.

Case Law

Radheshyam Adhikari vs HMG, NKP 2048, Vol-12,  DN- 4430 

Supreme Court held that disputes of public rights or concerns is not a dispute limited to the personal rights or concerns of a specific person or persons but a dispute related to the collective rights or concerns of the common people of kingdom of Nepal or any community. Whether any dispute is of public right or concern should be decided on the basis that the dispute is related to the collective rights or concerns of general public or group of people or the rights or concerns of specific person/s.

2. PRINCIPLE of NATURAL JUSTICE

Principle is a fundamental truth or proposition that serves as the foundation for a system of belief or behavior or for a chain of reasoning. It is a means to distinguish between right and wrong it operates in a legal vacuum or when there is dispute in law. 

The term natural justice is derived from the Latin phrase 'jus naturale’ which denotes principles of natural law, justice, equity and good conscience.

According to Osborn's Law Dictionary, “Natural justice indicates rules and procedures to be followed by any person or body charged with the duty of adjudicating upon disputes between, or the rights of others.”

Principles of natural justice are those rules which have been laid down by the Courts as being the minimum protection of the rights of the individual against the arbitrary procedure that may be adopted by a judicial, quasi-judicial and administrative authority while making an order affecting those rights. The rules of natural justice do not supplant the law of the land but only supplement it. It is observed in all judicial, quasi- judicial and administrative proceedings in the absence of express provisions in any statute.

The aim of natural justice is to secure justice and prevent even the slightest chances of mis. carriage of justice It protects against arbitrary exercise of power by ensuring fair play it promotes transparency in decision making processes and enhances public's trust upon the concerned decision-making body, for e.g.:- Court. 

Basic Rules of Natural Justice

A. The Hearing Rule

The Hearing Rule is based on the Latin maxim, “audi alteram partem” which means 'listen to the other side’ or ‘hear the other party’. This rule requires that persons should be allowed an adequate and proper opportunity to present their case where certain interests and rights may be adversely affected by an impending decision. 

A corollary has been deduced from the audi alteram partem rule, namely qui aliquid statuerit parte inaudita alteram actquam licet dixerit, haud acquum facerit meaning “he who decides anything without hearing both sides, though he may decide justly cannot be considered just”. In other words, as it is now expressed, justice should not only be done but should manifestly be seen to be done.

The principle of hearing embraces following essential aspects:

1. Issuance of notice: Notice is the first limb of this principle. Giving a valid notice to the proper or concerned person and the facts of the matter and nature of the action proposed to be taken is a sine qua non of a fair hearing. The person against whom proceedings are held cannot be punished for a charge different from the one for which notice had been given. Notice must clearly indicate material on the basis of which the proposed action is being taken. It must be precise and unambiguous. Adequate time should be given. It must clearly mention date, time and place to be present. It must fulfill all the necessary formalities.
    
2. Reasonable time to file rejoinder: After the notice has been received by the person, he must be given opportunity to make a representation in reply. This right to make representation also involves grant of sufficient time to prepare the reply. In criminal cases, the accused must be presented before the court to present his statement. 
    
3. Right to rebut adverse evidence: The right to rebut adverse evidence presupposes that the person has been informed about the evidence against him. it allows a party to present evidence in response to evidence presented by the other party. it also includes right to cross examination.
    
4. Right to present caseand evidence: Parties to the case should get the chance to present their arguments and submit evidences.
    
5. Right to legal representation: Parties to the case have the right to legal representation. Free legal aid should be provided to those who cannot afford a lawyer to represent them in the court. Similarly, every person who is arrested shall have the right to consult a legal practitioner of his/her choice at the time of arrest.
    
6. One who hears must decide: The person who hears must decide the case. Only the individual who has heard the arguments and facts, acts, as well as observed the demeanor of witness should decide the case.
    
7. No Decision inpost haste: Decision should not be made in post-haste. Justice hurried is justice buried. Decision should be given only after completing all necessary procedure and formalities.
    
8. Reasoned decision: Judge should make the verdict on the basis of reason and proper logic. While deciding the case, the judge should evaluate all the available evidences.

B. The Bias Rule 

The rule against bias is a fundamental principle of natural justice, which requires that decision -makers or judges be impartial and unbiased in the exercise of their functions. There must be the absence of inclination or prejudice towards party of the case. The judge must decide the case objectively on the basis of evidence. The decision of the judges should not be driven or influenced by his/her self-interest.

There are various forms of biases:

1. Personal bias: Personal bias arises from a certain relationship equation between the deciding authority and the parties which incline him /her unfavorably or otherwise on the side of one of the parties before him/her. There are two types of personal bias : Positive bias and Negative bias Due to positive bias, judge may favor to the party whereas s/he may decide against the favor of the party due to negative bias. Thus, personal bias may arise out of friendship, relationship, professional grievance or even enmity.
    
2. Pecuniary bias: If judge makes the decision by accepting economic benefit or by accepting the assurance of economic benefit then it is called pecuniary bias.
    
3. Pre-conceived notion bias: It refers to the inclination or pre- disposition of judges involved in legal proceedings to hold pre-existing beliefs, opinions or assumptions that can influence the judgment. A judge is supposed to sit as a blank sheet of paper.
    
4. Subject- matter bias: Those cases fall within this category where the deciding officer is directly or otherwise involved in the subject matter of the case. If somebody has expressed his/ her opinion in any matter or report and later become a judge in the case of such matter, there occurs subject matter bias. 
    
5. Departmental bias: Departmental bias is mostly found in administrative bodies, or administrative process. It arises when the functions of a judge and prosecutor are combined in the same department as it isn’t uncommon to find that the same department which initiates the matter.

Similarly, under the bias rule, there lies a principle that no man should be a judge in his own case (Nemo judex in causa sua). The underlying principle is that no person can objectively judge a dispute in which s/he is a party, has substantial interest or has a substantial connection to any of the parties to the dispute where the person's interest may influence the outcome or to be seen to have influenced the outcome of the decision.

Sec 176 of Muluki Criminal Procedure Code, 2074 and Sec 271 of Muluki Civil Procedure Code, 2074 mentions that no judge shall proceed, hear and adjudicate any of the following cases: 

• A case involving right, interest or concern of his/her or his/her close relatives.
• A case in which s/he has become an attorney, law practitioner or witness on any occasion. 
• A case which s/he, in capacity of the judge, has decided or made a final order therein in any court.
• A case in which s/he has given opinion as to whether or not to institute it on any occasion. 

• A case involving, for any other reason, a substantial interest of him /her or any of his /her joint family members. 

   

Similarly, Sec 4 of Code of Conduct of Judges, 2074 mentions:

• The judge should perform his/her judicial duty without any malice, bias, favoritism or prejudice. 
• The judge should behave fairly with the parties to a case and should be active to enhance public trust. and confidence of the litigants, legal professionals and general public towards the judge and the judiciary. 
• Judge should not maintain unnecessary relationship or contact with any person that may negatively affect the administration of justice. 
• Judge should not make any statement in public or social networks or intentionally make any kind of commentary in a way that affects the result of the dispute that has come or may come before the judge or that affects fairness to be adopted in judicial process or that affects the fair hearing.

• A judge should not decide the cases in which the situation arises that the judge is inclined or biased to any party of the case, if the judge has prior information personally in regards to fact relating to evidence of disputed matter, if the judge has previously acted as a legal practitioner or as a witness in the matter of dispute and if the judge or his/her family has direct pecuniary interest in the result of the dispute. 

   

C. Reasoned Decision 

The third aspect of natural justice requires speaking orders or reasoned decisions. It is now universally recognized that giving reasons for a certain decision is one of the fundamentals of good administration and a safeguard against arbitrariness. The refusal to give reasons may excite the suspicion that there are probably no good reasons to support the decision. Hence, reasons are useful as they may reveal an error of law, the grounds for an appeal, or simply remove what might otherwise be a  lingering sense of injustice on the part of the unsuccessful party When the order to be passed is an appealable order, the requirement of giving reasons would be a real requirement. Thus, reasons are also required to be giver when the appellate or revisionary authority affirms the order of the lower authority. Therefore, 'Ces- sante ratione legis cessat Ipsa lex’ meaning reason is the soul of the law, and when the reason of any particular law ceases, so does the law itself. 

Exceptions to the Rule of Natural Justice 

Exceptions to Bias 

1. Doctrine of Necessity: The doctrine of necessity car be invoked in cases of bias where there is no authority to decide the issue. If the doctrine of necessity is not allowed full play in certain unavailable situations, it would impede the course of justice itself and the defaulting party would benefit from it. If the choice is between either to allow a biased person to act or to stifle the action altogether, the choice must fall in favor of the former as it is the only way to promote decision making. Where substitution is possible, this doctrine does not apply.
    
2. Contempt of courts: It is an exception to the principle that Ho man can be judge in his own case. The court decides the case related to contempt of court in order to maintain the dignity of the court, not to protect the judge.
    
3. Departmental action: A department can make a verdict against its own employee.
    
4.  Case related to royalty and tax: Department of royalty can investigate and make verdict.
    
5. Disciplinary proceeding: These proceedings are typically conducted in order to maintain discipline, uphold standards and ensure free treatment within the institution or organization, and to investigate and address alleged misconduct or violation of rules committed by individuals within their jurisdiction. It is prevalent in Armies and police. 

Exceptions to Audi Alteram Partem 

1. Work done as per contract service. 
2. Work done as per an agreement. 
3. Service of an employee can be terminated without hearing probation period.
4. Principle of fair hearing cannot be applied to maintain public health, security and morality.
5. Emergency: In cases of extreme urgency, where interest of the public would be jeopardized by the delay or publicity involved in hearing, a hearing before condemnation would not be required by natural justice or in exceptional cases of emergency where prompt action, preventive or remedial is needed, the requirement of notice and hearing may be obviated. 
6. Confidentiality: Exclusion of natural justice can also take place when confidentiality is demanded and is necessary to be maintained. 
7. Useless formality theory: It can be applied only when the admitted or undisputed facts provides just one conclusion, and under the law only one penalty is permissible. The Court may not insist on the observance of principles of natural justice because it would be futile to order its observance.
8. Rules of natural justice may be excluded on the grounds of administrative impracticability.
    

Importance of Principles of Natural Justice

• It protects individual rights. 
• It contributes in upholding rule of law. 
• It ensures impartiality and fairness. 
• It encompasses due process of law. 
• It prevents arbitrary decision making.
• It protects justice during vacuum of law and ambiguity.

• It addresses the lack of written procedures.

   

Case Laws

1. Shatrughan Kumar Nepal vs Srijana Nepal, NKP: 2073, DN-9606 

   Supreme Court held that decision cannot be made against the petitioner without examining the concerned person and without affording her an opportunity of defense. Such decision cannot gain validity within judicial process. 

2. Mohan Laxmi Maskey vs finance Ministry, NKP 2067, DN-8294 
   
   Supreme Court held that giving notice of allegation only is not sufficient. The defendant should be provided ample time to rebut the adverse evidence against him/her, defend and counter-claim.
    
3. Advocate Achyut Prasad kharel vs Government of Nepal, NKP 2067, DN-8364 
   
   Supreme court held that the decision maker should determine through his reason with regard to what relation s/he has with the party to the case and if s/he can be neutral and fair or. not while deciding the case. 
    
4. Yagya Murti Banjade vs Bagmati Special Court, NKP 2037, DN- 547 
   
   Supreme Court held that no man can be a judge in his own case. It means even the Government cannot be a judge in its own case. 
    
5. Supreme Court vs Kushum Shrestha, NKP 2023
   
   Supreme court held that the principle of nemo judex in causa sua cannot be applied in the case of contempt of court. The Court decides contempt of court in order to maintain the dignity of the court, not to protect the judge.

3. Principle of Res Judicata

Introduction

‘Res Judicata’ is a latin term made up of two words ‘res’ meaning subject-matter and ‘judicata’ meaning adjudged or decided. Therefore, Res judicata means ‘matter already adjudged’ or ‘a dispute decided’. The doctrine of res judicata is based on 3 Roman maxims, they are:-

1. Nemo debet lis vaxari pro eadem causa: No person should be annoyed twice for the same cause.
2. Interest republicae ut sit finis litium: It is in the interest of the state that there should be an end to the litigation.
3. Re judicata pro veritate occipitur: A judicial decision must be accepted as correct.

The general rule is that a plaintiff who instituted a suit against defendant and obtained a valid final judgement is not able to bring up another suit against the same person. ‘Rule of conclusiveness judgement’ is applied in civil suits as well as criminal proceedings. In civil cases, it is known as res judicata whereas in criminal cases it is known as double jeopardy. Pre-conditions to be met for the invocation of Res judicata doctrine are:-

1. The claims must be the same in the first and second lawsuits.
2. The parties in the second action must be the same as those in the first.
3. Reason behind filing the case and remedy sought must same as before.
4. There must be a final judgement by a competent court.
5. The judgement must be based on merits of the case.
6. The case must be filed in the same court without filing an appeal.

Res Judicata is derived from Roman Law which means ‘one suit and one decision is enough for single dispute.’ The principle of res judicata not only prevents future judgements from contradicting earlier ones, but also bars litigants from multiplying judgements and thereby confusion. It prevents uncertainty. It seeks to promote fair administration of justice and honesty and to prevent law from abuse. It restricts either party to ‘move the clock back’. Its primary purpose is to assure an efficient judicial system. It is applied to uphold the effect of the first judgement. The rationale for res judicata is that there must be an end to a litigation. It aims to strike a balance between the competing interests of the parties. It arose as to avoid unnecessary waste of resources in the court system. Res judicata is often used to affirm that repeated re-examination of adjudicated disputes is not in any society’s interest.

Exceptions of Res Judicata

1. If the former case has been decided through fraud.
2. If the former case has was fictitious.
3. If the former case has been decided through incompetent court i.e. beyond jurisdiction.
4. If the former case was not heard and finally decided.
5. Administrative decision, domestic and departmental investigation cannot work as res judicata.

Legal Provision

1. Sec 14 of Muluki Civil Procedure Code, 2074: Once a case is filed and adjudged, the court shall not hear and adjudge the case involving the same matter and the same plaintiff and defendant more than once, except for an appeal made in the case or non-execution of the deed of compromise.
2. Sec 89 of Muluki Civil Procedure Code, 2074: Plaint (Firadpatra) should be filed only once.
3. Sec 94 of Muluki Civil Procedure Code, 2074: Plaint should not be filed on a matter already adjudicated.
4. Schedule 1 of Muluki Civil Procedure Code, 2074: To mention whether another plaint has been filed or not (Format of Firadpatra).

Difference between Res Judicata and Estoppel

Case Laws

1. Dilliraman Sharma vs. Rupandehi District Court, NKP 2075, vol-10, DN-10123
   
   Supreme Court held that as per the principle of res judicata, a case with the same plaintiff, same defendant and same subject or issue should not be heard or decided more than once by the same court.
    
2. Yubaraj Ghaadewa vs Sanjay Kumar Ghaadewa, NKP 2062, vol- 1,  DN-7489
   
   Supreme Court held that f a competent court has already delivered a decision on a matter, a plaint (firad) filed by the same party concerning the same dispute cannot be entertained, and even if the plaint has been registered, it must be dismissed. For this provision to be applicable, a decision must have been made in the earlier case. If no decision has been rendered, the provision of Section 85 of Chapter on Abam of Muluki Ain 2020 cannot be invoked.

4. Principle of Stare Decisis

Introduction

Stare decisis is a Latin term meaning to stand by the things decided. It is a legal principle emanating from the common law system that obligates courts to follow historical cases when ruling on a present case with similar facts. In short, it is the doctrine of precedent. 

The term stare decisis originate from the phrase ‘stare decisis et non quieta movere’ which means to stand by decisions and not disturb the undisturbed. In legal context, this is understood to mean that courts should abide by precedent and not disturb the settled matters. This principle dictates that courts cannot disregard the standard and must uphold prior decisions. It is developed from Common law and the Anglo-American common law tradition is built on the doctrine of common law. 

Precedent and stare decisis are used interchangeably as synonymous to each other. Although they are related concept they have a slight distinct meaning and function. Precedent refers to the specific legal ruling or decision in a previous case while stare decisis is the doctrine that instructs courts to follow and give weight to those precedents.

Sec 31 of Pradhan Nyayalaya Ain was the first Nepalese law to embrace the doctrine of stare decisis. Sec 12 of the Supreme Court Act, 2013 BS also provided that the precedents established by Supreme Court is mandatory for subordinate court. This principle was given constitutionality for the first time by Art. 73 of Constitution of Nepal in 2019. Later, Art. 96(2) of Constitution of the Kingdom of Nepal, 2047 acknowledged the principle of Stare decisis. Constitution of Nepal in Art. 128(4)  provides that all must abide by any interpretation of the Constitution or law made by or any legal principle laid down by the Supreme Court in the course of trying a lawsuit. Similarly, since 2015 BS, the Supreme Court of Nepal is regularly publishing Nepal Kanoon Patrika which publishes the precedents.

The doctrine of Stare decisis operates both horizontally and vertically. Horizontal stare decisis refers to a top court adhering to its own precedent whereas vertical stare decisis refers to the application of precedent established by a higher court.

In context of Nepal, Supreme Court establishes the precedent and other courts are bound to abide by it. Similarly, precedent established by lower bench of Supreme Court is not binding to higher bench but precedent established by higher bench of Supreme Court is binding to lower bench.

Merits of Doctrine of stare decisis

1. It saves time and prevents needless lawsuits.
2. It ensures uniform justice and continuity in court decisions.
3. It helps both judges and lawyers in the process of consistent application of law.
4. Following judicial precedents helps to make legal and judicial system more efficient.
5. It reduces the chances of a judge making an error while assessing the principle in question.
6. It prevents judges of lower court from making decisions that are out of line with what higher courts have determined as established law.
7. It prevents judicial anarchy which helps to maintain people’s faith over judges and judgement intact.

Demerits of Doctrine of Stare decisis

1. It impedes the free evolution of law.
2. It leads to rigidity and hair-splitting.
3. Over the time, legal precedents may become outdated or no longer reflect current values and beliefs of the society.
4. If a precedent is based on incorrect reasoning or flawed legal principles, subsequent cases will still have to follow that precedent.

Case Law

1. Kamal Mohan Chapagain vs Government of Nepal, NKP 2068, DN- 8716
   Supreme Court of Nepal held that stare decisis is important and necessary for judicial consistency, clarity and judicial discipline.
    

AMICUS CURIAE

Introduction

Amicus Curiae is a Latin term which means ‘friend of the court’. Amicus Curiae can be lawyer and not necessarily be a lawyer. S/he is not party to the case and may or may not have been solicited by the party. S/he assists the court by offering information, expertise, or insight on the issues in the case being heard. A person who is not a party to the case but have an interest in an issue before the Court may file a brief or participate in the argument as a friend of the court. This leads to the appointment of an amicus curiae. Sometimes, the Court itself may invite an Amicus Curiae by its own accord and may gain rare knowledge on the details of a dispute.

An Amicus Curiae informs the court on points of law that are in doubt, gathers information or raises consciousness on some aspect of the case that the Court might otherwise miss. However, a decision on whether to agree with an amicus brief in its judgement lies within the discretion of the given Court. 

The most common arena for Amicus Curiae is in cases that are under appeal or being reconsidered by a court and where issues of public interest such as social and political questions or civil liberties are being debated. Amicus Curiae cannot raise issues that the parties themselves do not raise, since that is the task of the parties and their attorneys. As a non-party to the case, amicus curiae do not exercise the rights that parties in a lawsuit have, such as the right to obtain discovery from other parties.

Legal Provisions

• District Court Regulation 2075, Rule 105
• High Court Regulation, 2073, Rule 157(d)
• Supreme Court Regulation, 2074, Rule 147
• Supreme Court (Constitutional Bench Operation) Regulation, 2072, Rule 13

Cases in which Amicus Curiae had assisted the Judges

1. Annapurna Rana vs Kathmandu District Court (Amicus Curiae: Senior Advocate Balaram KC)
2. Tara Devi Poudel vs Kaski District Court (Amicus Curiae: Adv. Satish Krishna Kharel)
3. Meera Dhungana vs HMG (Amicus Curiae: Adv. Balkrishna Neupane)
4. KP Oli House Dissolution Case. 

                Prepared by Sujina Dhonju.