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Ujjal Bhuyan
Ujjal Bhuyan
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Ujjal Bhuyan (Assamese: উজ্জ্বল ভূঞা; born 2 August 1964) is a judge of the Supreme Court of India. He is a former chief justice of the Telangana High Court. He has also served as judge of the Telangana High Court, Bombay High Court and Gauhati High Court.

Key Information

Career

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Bhuyan was born on 2 August 1964 at Guwahati. He did his schooling in Don Bosco High School, Guwahati, and studied in Cotton College, Guwahati. He obtained his Bachelor of Laws degree from Government Law College in Guwahati and his Master of Laws degree from Gauhati University. On 20 March 1991, he was enrolled with the Bar Council of Assam, Nagaland, Meghalaya, Manipur, Tripura, Mizoram and Arunachal Pradesh. On 6 September 2010, he was designated as senior advocate by Gauhati High Court. He was appointed as additional advocate general, Assam on 21 July 2011. He was elevated as an additional judge of the Gauhati High Court on 17 October 2011 and made a permanent judge on 20 March 2013. He was transferred as a judge of the Bombay High Court on 3 October 2019. He was transferred as a judge of the Telangana High Court on 22 October 2021.[1] He was elevated as chief justice of the Telangana High Court on 28 June 2022 and appointed a judge of the Supreme Court of India on 14 July 2023.[2]

References

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from Grokipedia
Ujjal Bhuyan (born 2 August 1964) is an Indian jurist serving as a of the since 14 July 2023. Previously the Chief Justice of the , he has a judicial career spanning appointments in the Gauhati, Bombay, and High Courts, with expertise in constitutional, , and civil law matters. Born in Guwahati, Assam, to Suchendra Nath Bhuyan, a senior advocate and former Advocate General of Assam, Bhuyan completed his schooling at Don Bosco High School, Guwahati, and earned a B.A. from Cotton College, Guwahati, and Kirori Mal College, Delhi. He obtained his LL.B. from Government Law College, Guwahati, and LL.M. from Gauhati University before enrolling as an advocate on 20 March 1991. His legal practice focused on direct taxes, constitutional law, and service matters across northeastern states, including roles as standing counsel for the Income Tax Department, Additional Government Advocate for Meghalaya, and Special Counsel for Arunachal Pradesh's Forest Department; he was designated a Senior Advocate in 2010. Elevated as an Additional Judge of the on 17 October 2011 and confirmed in 2013, Bhuyan was transferred to the in 2019 and then to the in 2021, where he became on 28 June 2022. In his high court tenures, he authored judgments emphasizing constitutional protections, including rulings on privacy rights under Article 21 and striking down provisions deemed manifestly arbitrary under Articles 14 and 21. At the , he has contributed to benches addressing maternity benefits, location-sharing conditions in , and procedural reforms like senior advocate designations, underscoring a commitment to rule-of-law principles.

Early Life and Education

Family and Upbringing

Ujjal Bhuyan was born on 2 August 1964 in , , into a family with deep roots in the region's legal community. His father, Suchendra Nath Bhuyan, was a prominent senior advocate who also served as of , holding a position that involved representing the in proceedings. This paternal legacy provided Bhuyan with early immersion in legal discourse and professional networks centered in , the hub of 's . No public records detail his mother's background or siblings, reflecting the limited personal disclosures typical of judicial biographies from official Indian court sources. Bhuyan's upbringing occurred amid 's post-independence socio-political landscape, including ethnic tensions and state-building efforts, though specific family influences beyond his father's career remain undocumented in verifiable legal profiles.

Academic Background

Ujjal Bhuyan completed his early education at Don Bosco High School in before pursuing further studies at Cotton College, also in Guwahati. He obtained a in Arts from , University of . Bhuyan then pursued legal education, earning his (LL.B.) degree from Government Law College in . He subsequently completed a (LL.M.) degree from . These qualifications laid the foundation for his enrollment at the Bar on March 20, 1991.

Bar Enrollment and Specialization

Ujjal Bhuyan enrolled as an advocate on 20 March 1991 with the Bar Council of , , , , , , and . He commenced practice before the , focusing on civil, constitutional, service, and taxation law. Throughout his legal career, Bhuyan specialized in revenue, labour, and taxation matters, serving as Standing Counsel for the Income Tax Department from 1995 to 2011. He represented the department in numerous direct tax cases, including appeals before the and, on occasion, the . Additionally, he acted as Additional Government Advocate for at the from April 2002 to October 2006, handling state government litigation. Bhuyan was designated a Senior Advocate by the on 6 September 2010, reflecting his expertise in complex fiscal and administrative disputes. His practice extended to advisory roles for public sector undertakings and private entities in taxation and , accumulating over two decades of experience prior to his judicial elevation.

Key Roles in Litigation and Counsel

Bhuyan enrolled as an advocate at the in 1991 and commenced practice at its principal seat in , appearing before benches in , , , and . His practice specialized in revenue, taxation, labour, and matters. From May 1995 to 2011, he served as Standing Counsel for the , initially as Junior Standing Counsel and later elevated to Senior Standing Counsel on December 3, 2008, handling tax litigation for 16 years. Between April 2002 and October 2006, Bhuyan acted as Additional Government Advocate for at the . The designated him a Senior Advocate on September 6, 2010, recognizing his expertise in complex litigation. On July 21, 2011, he was appointed Additional Advocate General for , advising on government matters until his elevation to the bench.

Judicial Appointments and Career

Gauhati High Court Tenure

Justice Ujjal Bhuyan was appointed as an Additional Judge of the on 17 October 2011. His appointment followed a distinguished career in legal practice, including designation as Senior Advocate by the same court in 2010. He was confirmed as a Permanent on 20 March 2013, after demonstrating commendable performance during the initial period. During his tenure at the , which serves the states of , , , and , Bhuyan presided over cases spanning constitutional, civil, criminal, and taxation matters. He maintained a close association with the Judicial Academy, Assam, where he delivered multiple lectures on legal topics. Additionally, he served as Executive Chairman of the Mizoram State Legal Services Authority, contributing to access to justice initiatives in the region. Bhuyan's judgments from this period emphasized procedural fairness and statutory interpretation, as seen in cases such as Jamuna Gogoi Phukan v. State of Assam, where he addressed issues related to judicial service matters. His work laid foundational experience for subsequent elevations, with the tenure concluding upon transfer orders issued in September 2019.

Transfer to Bombay High Court

Justice Ujjal Bhuyan, a judge of the Gauhati High Court since March 3, 2011, was transferred to the Bombay High Court as per a recommendation by the Supreme Court Collegium on August 28, 2019. The transfer order was issued by the President of India in consultation with the Chief Justice of India on September 20, 2019, and cleared by the Central Government shortly thereafter. Bhuyan assumed office as a judge of the Bombay High Court on October 3, 2019, following his oath-taking. The move drew protests from bar associations and advocates at the Gauhati High Court, who argued against relocating a judge of Assamese origin—Bhuyan having been born in Guwahati and elevated from the Gauhati bar—citing regional representation concerns in the northeastern state's high court. Despite such opposition, the transfer proceeded under Article 222 of the Constitution of India, which empowers the President to transfer judges between high courts to address judicial workload distribution or administrative needs, without publicly detailed specific rationale in this instance. During his approximately two-year tenure at Bombay, Bhuyan handled a range of cases, contributing to the 's caseload management amid its status as one of India's busiest high courts. The transfer exemplified routine inter-high court movements aimed at national judicial equity, though local sentiments highlighted tensions between such administrative decisions and regional judicial familiarity.

Chief Justice of Telangana High Court

Justice Ujjal Bhuyan was appointed as the Chief Justice of the on June 19, 2022, by the Union Government of India, succeeding Justice , who had been transferred to the . He was sworn in on June 28, 2022, at Raj Bhavan in Hyderabad by Telangana Governor , assuming charge as the fifth Chief Justice of the court. Bhuyan's elevation to stemmed from his position as the senior-most judge of the , following his transfer from the on October 22, 2021. His tenure, spanning from June 28, 2022, to July 13, 2023, was marked by administrative initiatives aimed at improving judicial efficiency. In March 2023, he announced plans to form larger benches with increased representation of women judges to handle complex litigation more effectively. As Chief Justice, Bhuyan administered oaths to newly appointed judges, including Justice Vijaya Bhaskar Reddy on August 4, 2022. He also led benches on significant matters, such as granting interim relief in high-profile cases, including quashing a lower court order in August 2022 that denied exemption from personal appearance to in a CBI case. Bhuyan's term concluded with his recommendation by the Collegium on July 5, 2023, for elevation to the Supreme Court, notified on July 12, 2023, reflecting his judicial stature and expertise, particularly in taxation and constitutional matters. During his brief but impactful leadership, the court maintained its caseload management under his oversight until his successor assumed office.

Elevation to Supreme Court

The Supreme Court Collegium recommended Justice Ujjal Bhuyan's elevation to the on July 5, 2023, citing his position as of the , his extensive experience in taxation and , and his status as the senior-most judge of his parent High Court, the . The recommendation was cleared by the Union Ministry of Law and Justice, with the government notifying his appointment on July 13, 2023, reflecting a swift process under the without reported delays or objections. Bhuyan took oath as a judge on July 14, 2023, administered by then-Chief Justice D.Y. Chandrachud, marking his transition from judiciary to the apex court alongside S.V.N. Bhatti. This elevation filled a vacancy arising from judicial retirements, maintaining the Supreme Court's strength at 33 judges, with Bhuyan's appointment emphasizing merit-based selection focused on specialized legal acumen over regional representation alone.

Notable Judicial Contributions

Rulings on Arrests and

In Annu @ Aniket Krupal Singh Thakur v. Union of India (27 June 2025), a bench comprising Justices Ujjal Bhuyan and quashed the of a 24-year-old student from , under Section 3(2) of the National Security Act, 1980 (NSA). The detention stemmed from a 2024 clash with a college professor, leading to the student's surrender and initial custody under criminal charges, followed by an NSA order on 11 July 2024 citing potential threats to public order based on antecedents. The court held the order "wholly untenable," emphasizing that requires a distinct threat to public order—not mere law and order breaches or isolated incidents—and cannot substitute for ordinary criminal processes where is feasible. Justice Bhuyan underscored procedural safeguards, noting the detaining authority's non-application of mind, failure to differentiate public order risks, and improper handling of the detainee's representation (rejected by the District Magistrate rather than forwarded to the as required under Section 14 of the NSA). The bench ordered immediate release, reinforcing precedents like v. (1966) and v. (2023) that demand to prevent arbitrary executive overreach. Bhuyan has consistently advocated distinguishing the power to arrest from the necessity for it, critiquing routine pre-trial detentions as antithetical to constitutional protections under Articles 21 and 22. In Arvind Kejriwal v. Directorate of Enforcement (CBI aspect, 13 September 2024), a split bench with Justice Surya Kant granted interim but Bhuyan, in a separate , invalidated Kejriwal's CBI in the Delhi excise policy case, deeming it unjustified after over 22 months without prior need despite interrogation. He ruled that evasive responses alone do not warrant under Section 41 of the Code of Criminal Procedure, 1973, and questioned the timing—postponed until an ED arrest stay risked frustrating —labeling it an "arrest first, inquire later" approach that erodes . In Directorate of Enforcement v. Subhash Sharma (1 February 2025), alongside Justice Abhay S. Oka, Bhuyan affirmed that courts must grant if an arrest violates , dismissing an ED challenge to a order releasing an accused whose PMLA detention was deemed unlawful due to procedural infirmities under Section 19. The ruling mandates immediate release upon finding rights infringements during or post-arrest, prioritizing Article 21's over statutory restrictions in cases. Earlier, in a May 2025 cheating case, the bench granted to a visually impaired accused after seven months' incarceration, decrying unnecessary detention in non-serious offenses where chargesheets were filed promptly. These decisions reflect Bhuyan's emphasis on proportionality, rejecting preventive measures or arrests absent compelling evidence of ongoing danger or flight risk, and cautioning against their misuse to bypass judicial oversight in criminal matters.

Opinions on Property Demolitions and Rule of Law

Justice Ujjal Bhuyan has consistently criticized the practice of " justice," whereby state authorities demolish properties of individuals accused of crimes without establishing guilt through due judicial process. In remarks delivered on March 22, 2025, he equated such actions to "running a over the ," arguing that they represent a direct negation of the by bypassing established legal procedures and presuming guilt prior to conviction. He emphasized that demolishing homes punishes not only the accused but also innocent members, including women and children, who bear no responsibility for the alleged offenses, thereby inflicting collective hardship without legal justification. Bhuyan's views align with Supreme Court rulings he participated in, which have declared punitive demolitions illegal when conducted absent notice, hearing, or verification of illegality. For instance, on March 31, 2025, a bench comprising Justices Abhay S. Oka and Ujjal Bhuyan condemned the Uttar Pradesh government's demolition of homes in Prayagraj, noting the actions occurred within 24 hours of notices, denying affected parties any meaningful opportunity to respond or challenge the orders. In the April 10, 2025, judgment in Zulfiquar Haider v. State of Uttar Pradesh, the same bench ruled a similar demolition by a development authority "completely illegal," underscoring that rule of law demands adherence to procedural safeguards rather than executive fiat, even against unauthorized constructions linked to accused persons. He has advocated for strict guidelines to prevent arbitrary demolitions, referencing prior Supreme Court directives that impose personal accountability on officials and mandate time-bound notices with rights to appeal. Bhuyan warned that unchecked "bulldozer actions" erode constitutional protections under Articles 14 (equality), 21 (life and liberty), and 300A (property rights), fostering a culture where administrative power supplants judicial authority. These opinions reflect his broader commitment to due process as foundational to governance, distinguishing lawful enforcement against illegal structures—via proper municipal procedures—from extrajudicial punishment targeting suspects.

Other Significant Decisions

In V. Vasanta Mogli v. State of (2023 SCC OnLine TS 1688), a bench led by Justice Bhuyan as of the struck down the Telangana Eunuchs Act, 1329 Fasli (enacted in 1919), declaring it unconstitutional under Articles 14 (equality before law) and 21 ( and personal liberty) of the Indian Constitution. The Act's provisions, including mandatory registration of persons, warrantless entry into residences, and of customary practices like , were deemed manifestly arbitrary and an affront to privacy and dignity, predating modern recognition of rights in National Legal Services Authority v. Union of India (2014). In Lucknow Nagar Nigam v. Custodian (decided February 1, 2024), Justice Bhuyan, sitting with Justice B.V. Nagarathna in the , held that enemy properties vested in the Custodian under the , remain subject to municipal laws, including property tax obligations. The ruling clarified that vesting does not confer from local governance requirements, such as those under the Uttar Pradesh Municipalities Act, 1916, emphasizing that the Custodian functions as a statutory bound by general laws unless explicitly exempted. In SKS Micro Finance Ltd. v. State of A.P. (2023 SCC OnLine AP 285), while at the , Justice Bhuyan upheld the constitutional validity of the Andhra Pradesh (and ) Micro Finance Institutions (Regulation of Money Lending) Act, 2011, excluding RBI-registered non-banking financial companies from its stringent licensing and interest rate caps. The decision balanced against over-regulation, reasoning that RBI oversight suffices for compliant entities, preventing dual regulatory burdens that could stifle legitimate operations serving underserved populations.

Judicial Philosophy and Public Statements

Defense of Judicial Review

Justice Ujjal Bhuyan has articulated a robust defense of as an essential constitutional mechanism, emphasizing its role in safeguarding the basic structure of the Indian Constitution against legislative overreach. In a speech delivered on June 30, 2025, at a farewell event for former judge Justice Abhay S. Oka, organized by the Bar Council of Maharashtra and , Bhuyan rejected criticisms portraying judicial intervention in policy or legislative domains as undemocratic or illegitimate. He specifically countered arguments, such as those advanced by the late regarding the 's 2015 invalidation of the 99th Constitutional Amendment and the (NJAC) Act, which labeled such rulings as the "tyranny of the unelected." Bhuyan asserted that such critiques lack any legal or constitutional foundation, as the power of is explicitly mandated by the Constitution to the to scrutinize whether parliamentary laws align with constitutional mandates, striking them down if they do not. Central to Bhuyan's position is the doctrine of the basic structure of the Constitution, established in the landmark 1973 Kesavananda Bharati v. State of Kerala case and reaffirmed in subsequent Constitution Bench decisions. He described as integral to this basic structure, enabling the judiciary to protect core constitutional values like and from erosion by elected branches. Bhuyan argued that the NJAC ruling, which invalidated the amendment for undermining judicial primacy in appointments, exemplified legitimate rather than overreach, as it preserved the judiciary's autonomy against executive and legislative encroachment. Dismissing claims that this doctrine renders judicial actions undemocratic, he underscored that an independent judiciary, staffed by bold and courageous judges, is indispensable for the sustenance of , , and democracy itself. Bhuyan's advocacy highlights a commitment to within defined bounds while firmly upholding review powers against populist or majoritarian challenges. He invoked historical precedents of independent judges throughout India's constitutional history, positing that their willingness to confront power ensures the prevails over transient political majorities. This stance aligns with his broader judicial philosophy, which prioritizes constitutional fidelity over deference to elected bodies when or structural principles are at stake, reinforcing as a counterbalance rather than a rival to democratic governance.

Critiques of Statutory Misuse and Governance Practices

Justice Ujjal Bhuyan has expressed concerns over the misuse of stringent statutes such as the Prevention of Money Laundering Act, 2002 (PMLA), cautioning that improper application undermines national interests and public confidence in enforcement mechanisms. In a March 23, 2024, address at the launch of a legal on PMLA, he warned that "if PMLA is misused, will suffer," potentially fostering negative perceptions of the (ED). He described PMLA as a potent tool against financial crimes but emphasized its potency diminishes through overuse, overapplication, or deviation from legislative intent, particularly given the statute's hotly contested cases, many of which carry political overtones. Bhuyan advocated for scrupulous adherence to constitutional safeguards, including Article 21 protections, urging stakeholders to invoke PMLA judiciously to balance prosecution of the guilty against shielding the innocent from undue hardship. He highlighted empirical shortcomings, noting that despite the ED registering approximately 5,000 cases over five years, conviction rates remained below 10%, attributing this to procedural lapses and delays exacerbated by influential accused employing legal tactics. In this context, he insisted the ED must confine operations to the "four corners of the law" and eschew conduct akin to a "crook," while proposing specialized PMLA courts to expedite trials and mitigate investigative opacity, such as non-disclosure of grounds of . On governance practices, Bhuyan has critiqued tendencies toward external pressures that erode institutional autonomy, positioning as essential to countervailing executive tendencies. During an October 19, 2025, event in , he asserted that judicial decisions must remain "completely free from external influence" to sustain , pragmatically upholding constitutional ethos amid district-level challenges. He framed the as democracy's foundation, decrying any encroachments that compromise , and in a June 30, 2025, statement, called for "more bold and courageous judges" to safeguard constitutional survival against such risks. These views underscore his broader philosophy that must prioritize procedural integrity over expediency to avert systemic distrust. Justice Ujjal Bhuyan has highlighted significant challenges in contemporary , particularly the wide disparity in student quality and teaching standards across law colleges, which he argues could adversely affect the district judiciary where most litigation occurs. He advocates addressing this gap to ensure consistent preparation for . In a March 22, 2025, address to law students at New Law College in , Bhuyan emphasized that the demands long-term commitment akin to a test match in , rather than quick successes like a T20 game, requiring technical soundness, hard work, perseverance, and dedication as is a "jealous mistress." He stressed building success through personal effort without undermining others and noted that foundational experience in trial courts, not necessarily high courts, can forge exceptional judges, citing Justice H.R. Khanna's career. Bhuyan has critiqued colonial-era terminology in the judiciary, calling for the abandonment of the phrase "subordinate judiciary" to reflect and reject outdated mindsets, as district courts handle the bulk of cases without being inherently inferior. Regarding technology, Bhuyan supports targeted applications like digital platforms to enhance judicial communication and professional bonds, expressing optimism in October 2025 about the All Assam Judges Association's new website for improving interactions among officers statewide. However, he cautions against overreliance on (AI) in legal practice and adjudication. At a April 2025 National Symposium on AI: Privacy, Security & IPR hosted by , Bhuyan asserted that AI-powered judges or lawyers cannot replace humans, particularly in 95% of cases involving natural persons, where human and individual autonomy must remain paramount. He advocates a rights-based regulatory framework for AI, balancing the fundamental —encompassing protection from state intrusion, data safeguarding, and personal choices, as affirmed in Justice K.S. Puttaswamy v. Union of India—against the right to information in India's . Bhuyan warned of AI's risks to through pervasive data use by non-state actors and stressed robust frameworks for AI-generated innovations, noting their intangible nature demands vigilant protection.

Legacy and Impact

Influence on Indian Jurisprudence

Justice Ujjal Bhuyan's judgments have reinforced procedural safeguards under anti-money laundering laws, notably in VANPIC Ports (P) Ltd. v. Directorate of Enforcement (2022), where he interpreted Sections 5 and 8 of the Prevention of Money Laundering Act (PMLA) to require substantive "reasons to believe" for provisional attachment of properties, emphasizing that mere suspicion or preliminary inquiry does not suffice, thereby curbing potential executive overreach in asset seizures. This ruling has influenced subsequent PMLA interpretations by underscoring the need for tangible evidence, aligning with constitutional protections under Article 300A against arbitrary deprivation of property. In , Bhuyan's decision in V. Vasanta Mogli v. State of (2023 SCC OnLine TS 1688) declared the Telangana Eunuchs Act, 1919, unconstitutional as manifestly arbitrary and violative of Articles 14 and 21, advancing transgender rights to , , and non-discrimination by invalidating outdated colonial-era restrictions on registration and movement. This has contributed to evolving jurisprudence on , building on precedents like NALSA v. Union of India (2014) while applying first-principles scrutiny to archaic statutes, prompting reviews of similar laws in other states. Bhuyan's Supreme Court contributions have prioritized personal liberty, as seen in Arvind Kejriwal v. CBI (2024 SCC OnLine SC 2550), where he granted by questioning the timing and necessity of arrest under Section 19 of the Prevention of Corruption Act, reinforcing that arrests cannot substitute for investigation and must adhere to under Article 21. Similarly, in a June 2025 ruling, he set aside the of a law student under the National Security Act, highlighting misuse of such powers without imminent threat, which has bolstered safeguards against arbitrary detention and echoed A.K. Gopalan lineage while critiquing post-facto justifications. His critiques of "bulldozer justice"—extrajudicial property demolitions targeting accused persons—have shaped discourse on , arguing in public addresses and obiter that such practices undermine Article 21 and presume guilt pre-trial, influencing stays and guidelines in related cases to mandate and proportionality. In taxation, rulings like Patanjali Foods Ltd. v. Union of India (2025 SCC OnLine SC 157) clarified that encashment of bank guarantees as security does not constitute payment of customs duty, rejecting claims and providing procedural clarity for revenue recovery, impacting commercial jurisprudence by favoring contractual intent over fiscal expansionism. Overall, Bhuyan's jurisprudence emphasizes empirical scrutiny of statutory application, from external pressures, and harmonization of rights—such as in K. Umadevi v. State of T.N. (2025 SCC OnLine SC 1204), balancing maternity benefits with population policies under Article 21—fostering a cautious approach to executive actions while upholding constitutional realism over expediency. His tenure has thus incrementally strengthened liberty-oriented interpretations amid rising preventive measures, though as a relatively recent appointee (May 2023), long-term doctrinal shifts remain emergent. Justice Ujjal Bhuyan's tenure on the bench has elicited respect within the legal fraternity for his steadfast advocacy of and the , as evidenced by frequent invitations to address bar associations and legal academies. On March 22, 2025, he inaugurated a lecture series at the Bar Association, underscoring his role as a sought-after speaker on and perseverance in legal practice. Similarly, on March 12, 2025, he addressed the Bar Association alongside Justice Abhay S. Oka, reflecting the community's engagement with his insights on judicial responsibilities. In public addresses to lawyers, Bhuyan has emphasized vigilance against extraneous influences such as , , or belief in judicial decision-making, urging the profession to prioritize and long-term dedication over short-term gains. He likened the legal career to a "test match" requiring sustained effort, a perspective reported as aligning with the fraternity's ideals of resilience and ethical grounding. His condemnation of a lawyer's attempted shoe attack on B.R. Gavai on October 9, 2025, further highlighted his commitment to professional decorum, stating the incident "must not be forgotten" as it undermined institutional dignity. While Bhuyan's defenses of against executive encroachments—such as in critiques of demolitions and —have resonated with advocates of constitutional checks, no organized bar resolutions or widespread dissents from legal bodies have surfaced in response to his . His participation in panels, including one chaired at the Arbitration Weekend on September 22, 2025, alongside judges, indicates collaborative esteem within specialized legal circles. This pattern of engagement suggests a reception grounded in appreciation for his calls for "bold and courageous judges" to sustain constitutional vitality, though individual lawyer opinions remain largely anecdotal absent formal surveys.

References

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