New Delhi, Nov. 21 -- The Supreme Court on Thursday held that not only did the two-judge bench order in April in the Tamil Nadu governor case create "confusion and doubt" on the issue of gubernatorial and presidential assent to state bills, but also held that the apex court's 2023 ruling in the Punjab governor case departed from binding larger-bench precedents. The Punjab ruling was authored by then Chief Justice of India (CJI) Dhananjaya Y Chandrachud; that bench also comprised justice JB Pardiwala, who penned the Tamil Nadu ruling earlier this year. Underscoring principles of judicial discipline, the five-judge Constitution bench on Thursday declared that neither judgment had engaged adequately, or at all, with earlier decisions of larger benches in Kameshwar (1952), Valluri (1979) and Hoechst (1983) cases, all of which clearly delineated the limited constitutional options available to governors when presented with bills passed by state legislatures. The Constitution bench, comprising Chief Justice of India Bhushan R Gavai and justices Surya Kant, Vikram Nath, PS Narasimha and Atul S Chandurkar, noted that the 2023 Punjab ruling, which emphasised that governors "cannot keep bills pending indefinitely" and must act "as soon as possible", did not cite or analyse the previous judgments. "On that count it fails to engage with the logic in those judgments," noted the bench, adding that Kameshwar, Valluri and Hoechst were all delivered by larger benches and were binding. "The precedential value of State of Punjab is dented on this count," held the court, pointing out that the Tamil Nadu ruling, while discussing these earlier judgments, ultimately placed the 2023 Punjab decision in tension with them rather than adhering to the settled position. "With due respect, both the Punjab and Tamil Nadu decisions could not have deviated from the binding precedents of larger bench decisions," it declared. The court emphasised that Kameshwar, Valluri and Hoechst had long made clear that a governor has only three constitutional options - assent, withholding assent (with a return message, except in the case of money bills), or reserving the bill for the President. In the Punjab case, the bench -- comprising then CJI Chandrachud and justices Pardiwala and Manoj Misra -- had taken a strong view against gubernatorial inaction, holding that the phrase "as soon as possible" in Article 200 imposed an implicit obligation of promptness. Governor Banwarilal Purohit, who had kept several bills pending since June 2023, including fiscally significant legislation and amendments concerning the management of gurdwaras....