Land Acquisition – Determination of Market Value – Uniformity and Parity – Lands acquired for establishment of Government Cement Factory under TANCEM – Reference Court enhanced compensation from Rs.200/- per cent to Rs.1,200/- per cent – Acquiring authority challenged enhancement as excessive – Held: Subsequent common judgment of High Court in appeals arising from same acquisition fixed market value at Rs.1,500/- per cent – Principle of parity requires uniform compensation to all landowners – Lower rate cannot be sustained [Paras 3, 6–9].

Land Acquisition – Effect of Subsequent Judgments – Binding Nature – Common judgment dated 29.01.2024 in A.S. No.916 of 2019 and connected cases enhanced compensation to Rs.1,500/- per cent – Followed by later orders recording TANCEM’s resolution to uniformly pay compensation at said rate – Held: Issues relating to comparability of sales, belt system and valuation stand concluded and cannot be reopened [Paras 6–9].

Land Acquisition – Development Deduction – Industrial / Mining Purpose – Acquisition not for housing layout but for industrial and mining activity – Subsequent batch decisions fixed flat rate without development deduction – Held: No deduction towards development charges warranted – Any deduction would disturb settled uniformity [Para 10].

Land Acquisition – Statutory Benefits – Entitlement on Enhanced Compensation – Claimant entitled to additional amount, solatium and interest under Sections 23(1-A), 23(2) and 28 of the Land Acquisition Act on enhanced market value – Direction to deposit balance compensation within stipulated time [Paras 11–12].

Decision: Appeal dismissed on merits – Award of Reference Court modified by enhancing market value from Rs.1,200/- per cent to Rs.1,500/- per cent – No deduction towards development charges – Claimant entitled to statutory benefits under Sections 23(1-A), 23(2) and 28 of the Land Acquisition Act – Acquiring authority directed to deposit balance compensation within eight weeks – No costs – Connected miscellaneous petition closed.

Service Law – Age of Superannuation – Employees of State-Controlled Society – Parity with Government Employees – Petitioners employed in MJPAPBCWRIS sought continuation in service till 62 years based on G.O.Ms.No.15 dated 31.01.2022 enhancing superannuation age of Government employees – Society contended that Government consent required and relied on Finance Department Circular dated 23.09.2022 – Held: Petitioners entitled to enhanced age of superannuation [Paras 1–3, 19].

Statutory Service Regulations – Rule 14 – Application of Government Rules – Legislation by Reference – Rule 14 of MJPAPBCWRIS Service Regulations, 2018 provides that age of superannuation shall be on par with respective Government employees – Held: Rule amounts to legislation by general reference – Subsequent amendment enhancing superannuation age of Government employees automatically applies to Society employees [Paras 10–12].

Circular vs Statutory Rules – Executive Instructions Cannot Override Statutory Service Regulations – Circular Memo dated 23.09.2022 excluding non-Government employees from benefit of enhanced superannuation age cannot prevail over Service Regulations framed with Government approval – Action of respondents retiring petitioners at 60 years held illegal and unsustainable [Paras 3, 12, 18].

Consent of State Government – Not Required Where Statutory Parity Exists – Distinction between Corporation Bye-laws and Statutory Service Rules – Reliance on Division Bench decision in G. Rama Mohan Rao case held inapplicable – Where service conditions are statutory and approved by Government, separate consent for enhancement of superannuation age not required [Paras 18–19].

Precedents – Supreme Court on Parity Clauses – Kerala SRTC v. K.O. Varghese and Harwindra Kumar v. Chief Engineer – Applied – As long as parity clause in Service Regulations remains unamended, benefit of enhanced age of superannuation cannot be denied to Society employees [Paras 11–15].

Decision: Writ Petitions allowed – Petitioners entitled to continue in service till attaining age of 62 years on par with Government employees – Circular Memo dated 23.09.2022 set aside insofar as petitioners are concerned – No order as to costs – Pending applications closed.

Bail – Corruption Case – Advocate Accused of Influencing Judiciary – Rejection of Bail – Petitioner, an Advocate practicing before the High Court, sought regular bail under Section 439 Cr.P.C. in FIR registered by CBI for demanding ₹30 lakhs as illegal gratification for securing a favourable judicial order in a matrimonial dispute – Allegation that petitioner claimed personal influence over a judicial officer and accepted part bribe through co-accused – Held: Bail declined in view of gravity of allegations and prima facie material [Paras 1–2, 8–9].

Prevention of Corruption Act – Section 7A – Applicability to Non-Public Servant – Contention that petitioner is not a public servant rejected – Section 7A covers any person who accepts or obtains undue advantage to influence a public servant by corrupt or illegal means – Prima facie applicability of provision established at bail stage [Para 8].

Bail Jurisprudence – Parameters Reiterated – While deciding bail, Court must consider prima facie involvement, nature and gravity of offence, severity of punishment, likelihood of tampering with evidence or influencing witnesses, antecedents and impact on administration of justice – Corruption offences, particularly those affecting institutional integrity, require a cautious and stringent approach [Paras 7–8].

Corruption Affecting Judicial Process – Seriousness Emphasised – Allegations of bribery by an advocate to influence judicial outcome strike at the core of public confidence in justice delivery system – Such acts treated as grave threat to sanctity of judiciary – Professional standing or age cannot dilute seriousness of offence [Paras 6, 8, 8.1].

Investigation Completed – Custody Period – Not Sole Ground for Bail – Filing of challan and custody of about 5½ months for offence punishable up to seven years considered but held not decisive – These factors cannot outweigh gravity and societal impact of allegations [Para 8.1].

Medical Grounds – Not Established – Medical assessment did not reveal any condition warranting bail on health grounds – Rejection of bail by Special Judge, CBI, found justified in absence of change in circumstances [Para 8].

Antecedents – Relevant Consideration – Pendency of another FIR under NDPS Act and IPC against petitioner taken into account while declining bail [Para 9].

Decision: Bail application dismissed – Liberty granted to petitioner to apply afresh for regular bail after examination of complainant and victim witnesses – Observations confined to bail adjudication and not to affect merits of trial.

Criminal Law – Kidnapping and Aggravated Penetrative Sexual Assault – Conviction under Section 366 IPC and Section 6(1) POCSO Act – Victim allegedly aged 17 years and 10 months – Trial Court convicted A1 while acquitting A2 – On appeal, High Court found serious infirmities in prosecution case – Held: Conviction unsustainable [Paras 1–2, 13–14].

Evidence – Proof of Age of Victim – Essential Requirement under POCSO Act – Prosecution relied on school certificate issued by Headmaster (PW8) – PW8 admitted that birth certificate and admission register were not verified before issuing certificate – Victim admittedly studying in college at relevant time – No matriculation certificate, birth certificate or college records produced – Held: Prosecution failed to establish age of victim in manner known to law – Benefit of doubt must go to accused [Paras 8–9, 13].

Delay in Lodging FIR – FIR lodged nearly two months after alleged occurrence – Victim claimed she informed her mother on same day – Mother (PW11) gave contradictory version regarding disclosure and complaint – No satisfactory explanation for delay – Delay coupled with contradictions created serious doubt about prosecution story [Paras 10–11].

Consent – Consensual Relationship – Evidence of victim revealed long-standing love affair of about two years – Victim admitted accompanying appellant voluntarily and refusing to return with grandmother – Conduct inconsistent with allegation of forcible kidnapping and sexual assault – Held: Evidence indicates consensual relationship which later turned sour – Prosecution version unreliable [Paras 7, 12].

Benefit of Doubt – Failure to Prove Date of Birth and Date of Occurrence – Serious inconsistencies between testimony of victim and her mother – Possibility of false projection of age and occurrence to attract POCSO provisions – Prosecution failed to prove guilt beyond reasonable doubt – Accused entitled to acquittal [Paras 11–13].

Decision: Criminal Appeal allowed – Judgment of conviction and sentence dated 22.02.2023 in Spl.SC.No.37 of 2020 set aside – Appellant acquitted of all charges under IPC and POCSO Act – Fine amount, if paid, to be refunded – Bail bond discharged.

Medical Termination of Pregnancy – Minor Rape Victim – Constitutional Jurisdiction – Applicant aged 14 years and 6 months, victim of rape, sought permission for termination of pregnancy – FIR registered under Sections 137(2), 87 BNS – Medical Board opined pregnancy of about 15 weeks and found termination permissible under MTP Act – Held: In cases of rape of a minor, continuance of pregnancy presumed to cause grave injury to mental health – Termination allowed in exercise of powers under Articles 226 and 227 of Constitution [Paras 1–6, 11].

MTP Act – Sections 3 and Rule 3B – Pregnancy up to 24 Weeks – Survivors of Sexual Assault and Minors – Rule 3B expressly permits termination up to 24 weeks for minors and survivors of rape – Opinion of Medical Board confirmed safety of procedure – Statutory framework recognizes autonomy, dignity and bodily integrity of pregnant woman – Court relied on Supreme Court exposition in X v. Union of India [Paras 6–9].

Right to Reproductive Choice – Article 21 – Bodily Autonomy and Dignity – Forcing a minor rape victim to continue pregnancy would violate her right to life with dignity – Reproductive choice is inseparable from personal liberty under Article 21 – Best interest of the victim is paramount consideration – Continuation of pregnancy would aggravate trauma, mental agony and social harm [Paras 9–11].

Best Interest Doctrine – Victim-Centric Approach – Court emphasized “best interest” theory while dealing with pregnancy of minor rape survivor – Psychological trauma, social ostracism and long-term impact on minor taken into account – Termination directed without delay to prevent further aggravation of victim’s suffering [Paras 11–13].

Procedure and Safeguards – Medical Board – DNA Preservation – Court directed constitution of team of senior gynaecologists and psychologist for conducting termination – Hospital directed to ensure pre and post-operative care – Directions issued for scientific collection and preservation of fetal tissue for DNA profiling to aid investigation – If child born alive, best medical care and State responsibility ensured under JJ Act [Paras 12–13].

Decision: Petition allowed – Medical termination of pregnancy of minor rape victim permitted – Detailed directions issued to Zydus Medical College and Hospital, Dahod – Petition disposed of with safeguards and compliance directions.

Indian Succession Act – Succession Certificate – Christian Intestate – Deceased leaving widow and lineal descendants – Trial Court refused certificate on ground that mother of deceased is also legal heir – Held, erroneous – Under Sections 32 and 33, where intestate is survived by widow and lineal descendants, mother does not inherit – Estate devolves upon widow and children – Refusal of succession certificate unsustainable in law [Paras 6-7].

Indian Succession Act – Distribution of Estate – Section 33 – Intestate leaving widow and lineal descendants – One-third of property to widow and remaining two-thirds to lineal descendants – Mother excluded when direct lineal descendants exist – Trial Court misconstrued statutory scheme – Impugned order liable to be set aside [Paras 6-7].

Succession Certificate – Shares in Company – No nomination – Requirement of certificate by company for transmission – Appellants, being widow and sons of deceased, entitled to seek certificate under Section 372 – Dismissal despite prima facie entitlement improper – Appellate Court directed issuance of certificate within specified time [Paras 3, 8].

Decision: Appeal allowed – Order dated 08.11.2019 in P & S.C. No.532/2018 set aside – Trial Court directed to grant succession certificate in favour of appellants forthwith in accordance with law.

Limitation Act, 1963 – Condonation of Delay – Review Petition – Delay of 645 days beyond prescribed period of 30 days under Article 124 – Applicants sought condonation citing time spent in identifying specialised counsel, intervening summer vacations, family wedding and attempts at amicable settlement – Held: Reasons vague, general and unsupported by material particulars – No explanation as to when counsel was identified or how vacations and personal events prevented timely filing – Such grounds do not constitute “sufficient cause” under Section 5 of the Limitation Act [Paras 5–8, 13].

Limitation – Settlement Talks – Effect on Limitation Period – Attempts at amicable settlement initiated more than one year after impugned order and well beyond limitation period – Held: Efforts at settlement made after expiry of limitation cannot justify delay in filing review petition – Cause shown must cover entire period of delay [Para 8].

Delay Condonation – Pendency of Proceedings – Irrelevance – Argument that original dispute was pending since 2004 and appeal decided in 2024, hence delay of 645 days is insignificant – Held: Time taken by Court to decide earlier proceedings is irrelevant for condonation of delay after judgment – Delay must be explained with reference to period post-order sought to be reviewed [Para 9].

Review Jurisdiction – Important Question of Law – Effect on Limitation – Contention that review raised substantial questions of law relating to appellate powers and remand – Held: Importance of legal issue is not a substitute for “sufficient cause” – If matter was urgent or involved important questions of law, applicants ought to have acted with greater promptitude – Submission held self-contradictory [Para 10].

Statutory Limitation – Review Petition – Thirty Days’ Period – Challenge to Adequacy – Submission that limitation period of 30 days is too short – Held: Period prescribed by Article 124 is legislative mandate – Legislature has consciously fixed limitation considering time required for consultation – Limitation cannot be diluted merely by invoking Section 5 – Argument rejected [Para 11].

Supreme Court Precedent – Sufficient Cause – Reliance placed on Shivamma (Dead) by LRs v. Karnataka Housing Board, 2025 SCC OnLine SC 1969 – Held: Liberal approach does not mean accepting unsubstantiated excuses – Courts must distinguish between genuine cause and mere explanations to cover negligence [Paras 12–13].

Decision – Interim Application for condonation of delay dismissed – Review Petition does not survive and disposed of accordingly [Paras 14–15].

Medical Reimbursement – Emergency Treatment – Non-Empanelled Hospital – Petitioner, a retired Chief Engineer, suffered viral meningoencephalitis, went into coma and was admitted in Emergency ICU at Fortis Hospital – Total expenditure ₹3,54,647/- – Reimbursement restricted to ₹1,38,422/- as per PGI/AIIMS rates under policy dated 06.05.2005 – Held: In admitted life-threatening emergency, reimbursement cannot be mechanically restricted to notified rates solely on ground of non-empanelment – Calculation sheet quashed – Balance amount directed to be paid with interest @ 9% p.a. [Paras 16–20, 41].

Right to Health – Article 21 – Scope and Constitutional Obligation – Court reiterated that right to health and medical care is integral to right to life – Executive memoranda cannot override fundamental rights – Preservation of human life is paramount constitutional duty of State – Fiscal constraints or technicalities cannot defeat genuine emergency claims [Paras 21–25, 29].

Service Law – Medical Facilities to Retired Employees – Welfare State – State obligated to bear medical expenses of its employees and pensioners in genuine emergencies – Social security in old age is constitutional expectation, not charity – Mechanical application of policy converting constitutional entitlement into bureaucratic concession deprecated [Paras 35–36].

Administrative Policy – Interpretation in Light of Article 21 – Executive policy regulating reimbursement must be read in consonance with constitutional ethos – In certified life-threatening emergencies, empanelment status of hospital cannot be sole ground to substantially curtail reimbursement – Where two interpretations possible, one advancing preservation of life must prevail [Paras 33–34, 40].

Natural Justice – Non-Speaking Reduction – Balance claim declined without speaking order – Calculation sheet supplied only under RTI – Approach held mechanical and insensitive in context of emergency medical claim [Paras 18–19].

Decision: Writ petition allowed – Calculation sheet dated 17.05.2018 quashed to extent it restricted reimbursement – Respondents directed to reimburse remaining ₹2,16,225/- within four weeks – Amount to carry interest @ 9% per annum from 25.01.2018 (date of discharge) till actual payment – State advised to revisit policy to incorporate mechanism for full/substantial reimbursement in certified life-threatening emergencies [Paras 41–43].

Sports Law – Olympic Selection – Cross Country Skiing – Exclusion of Meritorious Athlete – Arbitrary Selection Process – Petitioner, top-ranked Indian athlete as per FIS points list dated 19.01.2026, excluded from Olympic consideration on ground of non-participation in World Championship – Held: FIS Qualification System prescribes exhaustive, objective, points-based eligibility criteria under Section C – Participation in World Championship not a mandatory eligibility condition – Selection based on extraneous criteria is manifestly arbitrary and unsustainable in law [Paras 34–45].

Sports Selection – FIS Qualification System – Distinction between Athlete Eligibility and Quota Allocation – Section C governs athlete eligibility based on age, medical fitness, and FIS points – Section D relates only to allocation of quota to National Olympic Committees – Held: Respondents impermissibly conflated quota allocation with athlete eligibility – Additional conditions cannot be read into the Qualification System by executive interpretation [Paras 38–44].

Administrative Law – Arbitrariness – Introduction of Non-Notified Selection Criteria – Respondents restricted Olympic selection to performance in March 2025 World Championship, ignoring notified assessment period from 01.07.2024 to 18.01.2026 – Held: Retrospective and selective application of criteria defeats the notified qualification framework and violates principles of fairness and transparency [Paras 46–47, 50].

Sports Governance – Long List under NOC Accreditation Manual – Scope and Effect – Long List dated 26.09.2025 relied upon to exclude petitioner – Held: Long List is only an accreditation mechanism and cannot override Final List based on FIS points – Clause 3.2.2 does not mandate World Championship participation as a precondition – Exclusion from Long List cannot defeat substantive eligibility [Paras 48–49].

Judicial Review – Sports Matters – Limits and Exceptions – While courts ordinarily defer to expert bodies in athlete selection, interference is justified where decision-making is arbitrary, unfair, or contrary to governing rules – Present case falls within exception warranting judicial intervention [Paras 31–33, 45].

Ad-hoc Committee – Selection Process – Procedural Impropriety and Bias – Selection undertaken by Ad-hoc Committee applying criteria not traceable to international qualification documents – Held: Committee acted beyond authority and contrary to binding FIS framework – Selection process vitiated [Paras 50, 52–55].

Relief – Direction to Ensure Olympic Participation – Prayer to include petitioner allowed – Respondent IOA and Ad-hoc Committee failed in supervisory duty – Ministry of Youth Affairs and Sports directed to make all reasonable efforts to facilitate petitioner’s participation in Winter Olympics, Milano Cortina 2026, with full cooperation from IOA [Paras 56–58].

Observations on Role of State and Sports Bodies – Ministry cannot act as mute spectator in matters affecting athletes’ careers and national representation – Fairness, transparency, and merit-based governance are integral to sports administration – Institutional indifference deprecated [Paras 54–59].

Decision: Writ Petition partly allowed – Exclusion of petitioner declared arbitrary and illegal – Directions issued to facilitate petitioner’s participation in XXV Olympic Winter Games, Milano Cortina 2026 – Prayer C (challenge to Ad-hoc Committee) kept pending; respondents directed to file reply – Matter listed for further hearing.