The Madhya Pradesh High Court has held that an advocate’s duty to maintain client confidentiality does not end when their employment is terminated. A Division Bench comprising Chief Justice Alpesh Y. Kogje and Justice Vivek Rusia dismissed a writ petition filed by former Sasan Power Limited legal head Dr. Krishna Kumar Tripathi, imposing costs of ₹20,000.
Background
Dr. Tripathi approached the High Court seeking records relating to beneficiaries under the Rehabilitation and Resettlement (R&R) Policy, including the amounts disbursed to them. He also sought directions for an inquiry into alleged irregularities in the preparation of beneficiary lists.
The petitioner claimed that the number of beneficiaries had increased by 300 in a subsequent list and alleged that ineligible persons had been included. He submitted that although the Collector, Singrauli, had forwarded his complaint to the Sub-Divisional Officer for appropriate action, no action had followed.
The Division Bench questioned the petitioner’s claim that he had no personal interest in the matter, noting that he had previously worked as the legal head of the company and handled land acquisition matters.
The Court observed,
“An advocate owes an uncompromising duty of loyalty and confidentiality. An advocate is statutorily barred from disclosing communications made to them in the course and for the purpose of their employment by or on behalf of their client, as well as the advice given thereon, unless there is express consent.”
It further clarified that the obligation survives the end of employment, stating,
“This obligation does not cease upon termination of employment - it remains perpetual.”
The Bench also noted that the petitioner, having served as the company’s legal head, was required to maintain the secrecy of facts and material gathered during his employment. It described his conduct as “highly objectionable and reprehensible.”
Finding the writ petition devoid of substance, the High Court dismissed it and directed Dr. Tripathi to deposit ₹20,000 in costs with the Madhya Pradesh State Legal Services Authority.
Case Details
Case Title: Dr. Krishna Kumar Tripathi v. The State of Madhya Pradesh and Others
Case Number: Writ Petition No. 14704 of 2025
Judges: Chief Justice Alpesh Y. Kogje and Justice Vivek Rusia
Decision Date: September 18, 2026
