In Bar Council of Maharashtra and Goa v. Rajiv Nareshchandra Narula & Ors., the Supreme Court, per Justices Vikram Nath and Sandeep Mehta, quashed disciplinary proceedings against advocate Rajiv Narula initiated by the Bar Council of Maharashtra and Goa. The Court held that a professional relationship between the complainant and the advocate is ordinarily essential to invoke Section 35 of the Advocates Act, 1961. It observed that the Bar Council’s reference order was “cryptic and unreasoned,” lacking prima facie satisfaction of misconduct. The Court clarified that mere identification or attestation of affidavits does not amount to professional misconduct. Emphasizing the need for reasoned orders while referring complaints, the Court condemned frivolous complaints as malicious harassment of advocates and imposed ₹50,000 costs each on the Bar Council and complainant for abuse of process and causing undue mental agony to the lawyer.