MP High Court Directs State Bar Council To Frame Minimum Stipend Guidelines For Junior Advocates Within Six Months

The Madhya Pradesh High Court has asked the State Bar Council to frame guidelines on a minimum stipend for junior advocates within six months, after a junior lawyer appearing in a two-decade-old writ petition told the Court that she was not being paid anything for her work.

Justice Vishal Dhagat passed the order at Jabalpur on September 28, 2026, in WP No. 7749 of 2005, titled Vipin Pandey vs Rani Durgavati University, Jabalpur and Others. The order does not detail the underlying dispute; it deals almost entirely with a question that surfaced in open court on a routine adjournment day.

Ms. Ayushi Mishra, appearing for the petitioner, sought an adjournment on the ground that the arguing counsel was "adjusted today". Shri Divy Krishna Bilaiya appeared for the respondent. When the Court asked about her position in the matter, the junior counsel replied that "no stipend is being paid to her".

That answer changed the course of the hearing. The Court turned to the Bar Council of India's circular dated October 15, 2024, which, as recorded in the order, directs all State Bar Councils to ensure that junior advocates receive a minimum stipend for at least three years from the date of their engagement. The Bar Council of India has recommended Rs 20,000 per month in urban areas and Rs 15,000 per month in rural areas.

The Bench, however, pointed to the limits of that circular. "Circular is only recommendatory in nature," the Court observed. Because it carries no binding force, the Bench directed the Madhya Pradesh State Bar Council, in consultation with the M.P. High Court Bar Association and the M.P. High Court Advocates' Bar Association, to lay down its own guideline. The guideline must fix a minimum stipend for junior advocates for a period of three years, separately for urban and rural areas.

The Court also set a deadline. The decision, it said, must be taken "within a limited time frame of six months", and the guidelines issued through the Bar Association in the State of Madhya Pradesh.

Notably, the Bench placed the responsibility squarely on the regulator. The State Bar Council, it said, has a "heavy burden to see that junior advocates are paid stipend" so that they can meet their expenses and transportation costs.

The Court directed the Madhya Pradesh Bar Council to hold an enquiry into why Advocates Rajesh Dubey, Aniruddh Kumar Mishra, Chandrika Prasad Dwivedi, Dhananjay Chaturvedi and Naveen Kumar Pathak, all advocates in the case, are not paying a stipend to Ms. Ayushi Mishra.

In a wider direction, the State Bar Council and both High Court bar associations were told to take note of the facts and ensure that all junior advocates are paid a stipend "for doing the work of their senior counsel". The Court explained the purpose plainly: young lawyers must be able to bear their "day to day expenses for learning" in the initial phases of practice, "when they do not have their own work".

A copy of the order has been directed to be supplied to all three bodies for necessary compliance.

The matter itself did not proceed. As the arguing counsel was unavailable, the case was adjourned, and the Registry was directed to list it for final hearing.

Case Title: Vipin Pandey v. Rani Durgavati University, Jabalpur and Others

Order Date: September 28, 2026

Bench: Justice Vishal Dhagat