The Supreme Court on Wednesday held a Full Court Reference in memory of Late Former Justice Shri Vijay Kumar Jhanji, Late Senior Advocate Shri A.D.N. Rao, Late Senior Advocate & Additional Solicitor General (ASG) Shri Mukul Gupta and Late Senior Advocate Shri S. Balakrishnan, remembering their immense contributions to the legal profession and the justice system.

The Full Court Reference was attended by the Chief Justice of India, Justice Surya Kant, all other judges of the Supreme Court, law officers, members of the Bar and family members of the late judge and three advocates. The Court expressed condolences and honoured their enduring legacy in the legal fraternity.
Speaking during the reference, the Attorney General R Venkataramani recalled the distinguished careers and personal qualities of each of the four members of the Bar and the Bench, describing them as lawyers and judges who combined professional excellence with humility, integrity and commitment to justice.
Remembering the late former Justice Shri V.K. Jhanji, he noted his remarkable journey from civil practice in Punjab and Haryana to serving as a judge of multiple High Courts, including Jammu & Kashmir and Himachal Pradesh, before returning to practice before the Supreme Court after retirement.
On Shri A.D.N. Rao, the he highlighted his immense contribution to environmental jurisprudence and his role in landmark matters including MC Mehta, T.N. Godavarman and Goa Foundation. The Attorney General observed that the Supreme Court would deeply miss his presence in environmental matters.
Paying tribute to Shri Mukul Gupta, the Attorney General described him as a lawyer of “remarkable intellect” who handled several significant criminal and constitutional matters, including the Parliament attack case, Jessica Lal case and 2G spectrum matters, while remaining deeply humane and grounded.
Then Attorney General remembered Shri S. Balakrishnan as a senior advocate admired for his clarity, ethics and mentorship of younger lawyers. Recalling his advocacy style, the Attorney General remarked that he belonged to a generation that believed advocacy was “best advanced through substance rather than display.”
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Supreme Court Bar Association President Shri Vikas Singh described the four legal stalwarts as individuals who “fortified this institution for decades” through integrity, discipline and devotion to justice.
Remembering the late former Justice V.K. Jhanji, Mr Singh recalled his fearless judicial temperament and commitment to civil liberties, particularly during turbulent years in Punjab. Referring to threats faced by Justice Jhanji while hearing sensitive matters, he said:
“He did not seek to be a popular judge, he sought to be a just judge.”
He also highlighted Justice Jhanji’s role in the Sushila Sawhney judgment, describing it as “a silent revolution that restored dignity to thousands of women.”
On Late Sr adv Shri A.D.N. Rao, Mr Singh described him as a lawyer whose “presence was defined by a profound and echoing silence,” praising his contribution to environmental jurisprudence and his role in landmark cases including MC Mehta and T.N. Godavarman. He fondly recalled Rao’s mentoring style, saying:
“In that single soft touch, he imparted a lifetime of wisdom.”
Paying tribute to the late former Additional Solicitor General Shri Mukul Gupta, Mr Singh praised his advocacy in several major criminal and constitutional matters, including the 1993 Bombay blast appeals, 2G case and Jessica Lal matter.
He described Shri Gupta as a mentor who believed there was “no substitute for hard work” and viewed law as “a mode of service.”
Remembering late Senior Advocate Shri S. Balakrishnan, Mr Singh called him a lawyer who embodied “precision rather than volume,” noting that his advocacy relied on substance rather than theatrics.
“He proved that advocacy is best advanced through substance rather than display.”
Mr Singh also recalled Chamber No. 104 as a sanctuary for generations of young lawyers, describing Shri Balakrishnan as “a friend, philosopher and guide.”
Concluding his address, the SCBA President told younger members of the Bar that the lives of the four departed advocates reflected “the nobility of labour” and represented “the highest traditions of the bar and bench.”
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Concluding the reference, the Chief Justice of India, Justice Surya Kant, described courts as “institutions of memory,” observing that the legal system is shaped not only by judgments and statutes but also by “character, discipline, fairness, respect, courage and service.”

Paying tribute to Late Justice V.K. Jhanji, the CJI recalled his distinguished judicial career across the Punjab & Haryana, Jammu & Kashmir and Himachal Pradesh High Courts, while specifically noting his role in the landmark Susheela Sawhney judgment on permanent resident rights in Jammu & Kashmir.
“In a time when gender equality in constitutional jurisprudence was still finding its full expression, that judgment stood as both a legal landmark and a statement of principle.”
Remembering Late Sr. Adv Shri A.D.N. Rao, the CJI highlighted his immense contribution to environmental jurisprudence through cases such as T.N. Godavarman, MC Mehta and Goa Foundation, describing him as “a central figure of this court’s green jurisprudence.” The Court also reflected on his generosity and mentorship, noting that his life was marked not only by professional distinction but also by “unreported kindness.”
On Late Shri Mukul Gupta, former Additional Solicitor General, the CJI praised his advocacy in several high-profile criminal matters including the 1993 Bombay blast appeals, coal scam and 2G cases.
“He commanded exceptional capacity for sustained systemic advocacy.”
The Chief Justice further remarked that Mr. Gupta’s deepest contribution lay in the generations of lawyers and judges he mentored during his long career.
Remembering Shri S. Balakrishnan, the CJI described him as a lawyer synonymous with “precision rather than volume,” recalling his advocacy style rooted in substance over theatrics. CJI added, “He commanded the attention of the bench not by demanding it, but by earning it, sentence by sentence.”
The Court also fondly remembered Chamber No. 104, from where Shri Balakrishnan mentored generations of young lawyers. Concluding the reference, the Chief Justice observed:
“Their voices may no longer be heard in these corridors, but their influence will remain.”


