Discuss the scope and limitations of Article 142 of the Constitution. Examine its recent invocation to quash FIRs against protesters in light of the doctrine of 'complete justice'.

Article 142 empowers the Supreme Court to pass any decree or order "necessary for doing complete justice" in a cause pending before it, enforceable throughout India [1]. Its September 2026 use to quash FIRs against student protesters revives an old question: how far can equity travel without displacing law?

Scope of the power

• Textual breadth: any order for complete justice; Article 142(2) additionally covers attendance of witnesses, discovery of documents and contempt [1].
• Gap-filling equity: used to grant relief where statutes are silent or procedure would defeat justice — mass-tort settlements, dissolution of irretrievably broken marriages, and closure of protracted litigation.
• Remedial reach: binds parties across States, allowing a single order to settle multi-State proceedings.

Limitations

• Cannot supplant substantive law: in Supreme Court Bar Association v. Union of India (1998), the Court held Article 142 cannot create jurisdiction that Parliament has vested elsewhere [2].
• Only in a pending cause; it is supplementary, not a free-standing appellate power.
• Separation of powers: absence of codified standards invites charges of judicial legislation and unpredictable, case-specific outcomes.

The recent invocation examined

• The Union government itself moved the Court to quash FIRs arising from the July 2026 nationwide protests over NEET paper leaks; the Court also barred fresh FIRs [5].
• Justification: participants exercised assembly and speech rights, while the underlying failure was administrative — leaks persisting despite the Public Examinations (Prevention of Unfair Means) Act, 2024, enacted precisely to curb NEET/JEE malpractice [3][4]. Prosecuting protesters for a State failure would be disproportionate.
• Concerns: relief secured through executive request resembles negotiated accommodation rather than adjudicated justice; if similar leniency is not extended to other movements, "complete justice" risks becoming selective, straining equality before law.

Article 142 remains an indispensable safety valve, but its legitimacy depends on consistency. Self-imposed judicial guidelines on when it is invoked, coupled with genuine examination-system reform, would let complete justice serve constitutional morality rather than convenience.