Ex-Parte Injunction – Delay in Seeking Relief – Non-Commercial Suit – Interim Relief Denied – Plaintiff filed suit nearly two years after accepting defendants’ resignation and receiving their clarificatory responses – Court held that such delay defeated claim for urgent, ex-parte relief – Trial Court rightly observed no exceptional urgency warranting ex-parte injunction – Held: Discretion exercised by Trial Court is proper; no perversity found to warrant appellate interference [Paras 12–14.2].

Appointment of Receiver and Commissioner – Ex-Parte Relief – Balance of Convenience – Rejected – Trial Court refused ex-parte appointment of receiver and commissioner, noting plaintiff’s delay and absence of urgent risk of destruction of evidence – Liberty granted to seek such reliefs after serving notice to defendants – Held: Proper exercise of discretion; no exceptional circumstance shown – Appellate Court declined interference under Order 43 and Article 227 [Paras 15–16.2].

Scope of Appellate and Supervisory Jurisdiction – Order 43 and Article 227 – Judicial Discipline Reaffirmed – Appellate court reiterated limited scope to interfere with discretionary orders unless patently perverse or arbitrary – Cited precedents like Wander Ltd., Ramakant Choksi, and Sameer Suresh Gupta – Held: Trial Court's decision within bounds of law; no gross failure of justice made out [Paras 11–11.4].

Decision – Appeals and Writ Dismissed – No error, perversity, or arbitrariness found in Trial Court’s discretionary orders refusing ex-parte reliefs – All appeals and writ application dismissed accordingly [Paras 14.2, 16.2].

Civil Law – Injunction - Right to Privacy – Unauthorized Recording in Private Space – Consent Required – Partial Relief Granted – Plaintiff had consented to being recorded during the live debate but not after she exited the debate frame – Court held that the recording of the additional 18 seconds after Plaintiff withdrew was done without consent, violating her privacy under Article 21 – Video segment barred from public circulation – Interim relief granted [Paras 19-20].  

Defamation – False Attribution in Quote Tweet – Partially Defamatory – Quote Tweet by Defendant No. 1 accusing Plaintiff of “chucking the mic” and “throwing out” cameraman held untrue and lacking factual basis – Such assertions not protected by the defence of truth and must be deleted – However, statement about “abusing” the cameraman held substantially true – Partial protection granted under fair comment [Paras 22.4-22.7].

 Doctrine of Clean Hands – Suppression of Plaintiff’s Tweets – Cost Imposed – Plaintiff failed to disclose two tweets forming part of the conversation thread relevant to the case – Court held this to be suppression of material facts – Plaintiff directed to pay Rs. 25,000/- in costs to the Delhi High Court Bar Clerks’ Association [Paras 14, 28].  

Doctored Video Allegation – Not Substantiated – Plaintiff’s claim that the impugned video was doctored found to be unsubstantiated – Local Commissioner report found no conclusive evidence of tampering – Allegation held to be an afterthought [Para 24].  

Norms of Journalistic Conduct – Personal Comments Not Covered – Quote Tweet not a journalistic article but a personal comment of Defendant No. 1 – Norms of journalistic conduct not applicable to Defendant No. 1, but applicable to Defendants 6–10 who reposted and amplified the video without verification – Take-down orders confirmed against those defendants [Paras

23.2-23.4].

 Decision – Interim Injunction Partially Allowed – Video with post-debate 18second segment barred – Defendants 1 and 2 restrained from publishing or circulating impugned segment – Defendants 6 to 10 also directed to remove same – Some parts of tweet text to be retained while defamatory phrases to be taken down – Suit to proceed on merits [Paras 25-30].

Civil Law - Relocation & Rehabilitation Policy – Eligibility for alternate shop – Scope restricted to licensees, lessees, or Tehbazari holders – The appellant, not being a licensee, lessee, or Tehbazari holder, was not eligible for relocation benefits under the Delhi MRTS Project Policy – Held: Scheme was only applicable to shopkeepers having valid legal rights conferred by MCD/NDMC, not to encroachers [Paras 8-15].

 Promissory Estoppel – Applicability – Absence of unequivocal promise or representation – DMRC's proposal for rehabilitation was restricted to license holders – Appellant, lacking any license or recognized right, cannot invoke promissory estoppel against DMRC – Mere participation in the draw of lots and deposit of money did not create an enforceable right – Held: Appellant cannot claim benefit under promissory estoppel [Paras 15-33].  

Administrative File Notings – Value in judicial proceedings – DMRC's internal note of 20.04.2011 suggesting appellant's eligibility is merely an opinion – Held: Eligibility must be determined strictly under the policy and applicable law, not based on internal office notings – Such notings do not bind the corporation or confer any legal right [Para 37].  

Decision – Appeal dismissed – Appellant held ineligible under Relocation and Rehabilitation Policy – Principles of promissory estoppel and legitimate expectation held inapplicable – Findings of the learned Single Judge upheld – No interference warranted [Paras 38-40].

Constitutional Law - Electricity Connection – Valid Sale Deed in Unauthorized Colony – Cut-off Date for Regularization Arbitrary – Clause Quashed – The petitioner’s request for permanent electricity connection was denied due to a policy restricting registrations to documents executed before 31.07.2024 – Held: The cut-off date fixed in Clause 2.0 of the notification dated 25.11.2024 was arbitrary, lacking intelligible differentia or nexus with the objective of regulating unauthorized colonies – Clause read down and quashed to extent it barred owners with valid sale deeds and sanctioned buildings from receiving basic services like electricity [Paras 1-23].

Fundamental Rights – Article 21 – Denial of Electricity – Notification Held Unconstitutional – The petitioner’s electricity connection was disconnected without cause, and her right to life was compromised – Held: Right to electricity as a basic amenity falls within Article 21 – Authorities directed to release permanent electricity connection and provide other necessary amenities [Paras 7, 22-23].

Regulatory Overreach – Re-Registration Requirement – Unauthorized Colonies – Not Applicable to Validly Registered Sale Deeds – The notification required even those with existing valid sale deeds to re-register to avail services – Held: Such a requirement exceeds statutory power and undermines lawful conveyances – Rescission of registered deeds lies within civil court jurisdiction, not executive action [Paras 18-20].

Administrative Discrimination – Similar Plot Owners Granted Electricity – Unjustified Denial to Petitioner – In the same locality, others were granted connections while petitioner was denied – Held: Unequal treatment without rationale is violative of constitutional equality – Action of respondents unjust and unsustainable [Paras 8-9].

Decision – Petition Allowed – Impugned Clause Quashed – Permanent Electricity Directed – The Court held Clause 2.0 of the notification dated 25.11.2024 as arbitrary and discriminatory – Ordered its quashing and directed the respondent authorities to release the permanent electricity connection and other basic amenities to the petitioner’s house in light of Article 21 of the Constitution [Paras 22-23].
 

Compounding of Offence – Section 138 NI Act – Consent of Complainant Mandatory – Application Dismissed - The petitioner sought compounding of the offence on the basis of partial deposit of compensation – The complainant opposed the request and refused to consent – Held: Compounding under Section 138 read with Section 147 NI Act requires consent of complainant; Courts cannot override this requirement – Petition dismissed [Paras 1-9, 15].

Inherent Powers of High Court – Section 482 CrPC – Not Substitutable for Consent – Court Cannot Compel Compromise - Citing JIK Industries v. Amar Lal V. Jumani and Raj Reddy Kallem v. State of Haryana, the Court held it cannot invoke Section 482 CrPC or Section 147 NI Act to compound an offence in absence of complainant’s consent – Compounding without consent not permissible even if compensation is paid [Paras 6-8, 17-19].

Quantum of Compensation – Inadequate Payment – No Basis for Quashing - The Court found that the cheque amount was ₹1,65,525 dated 17.03.2004 and calculated interest at 9% per annum over 21 years to ₹3,12,842 – Against this, only ₹50,000 had been deposited by the accused – Held: Compensation inadequate, and petitioner's plea for quashing based on partial payment cannot be entertained [Paras 11-13].

Litigation Abuse – Delay and Forum Shopping – Premium on Dishonesty Not Permitted - The Court cautioned against the misuse of judicial process where accused protracts litigation and later seeks quashing based on partial compliance – Held: Law cannot allow litigants to harass complainants and then claim relief under guise of justice [Para 14].

Decision – Application for Compounding Dismissed – Final Hearing Directed - The compounding application was rejected – Court scheduled the main criminal revision for final hearing in due course [Paras 15-16].
 

Criminal Law - Murder  – Appeal against conviction - Circumstantial Evidence – Benefit of Doubt – Acquittal – Accused convicted of murder under Section 302 read with Section 34 IPC based on circumstances after eyewitnesses turned hostile – Court found that circumstances such as previous enmity, presence near the scene prior to the occurrence, and recovery of blood-stained shirt were insufficient to form a complete chain of evidence – Held: Mere presence at the scene and previous enmity without direct evidence or clinching circumstantial evidence cannot sustain conviction – Accused entitled to benefit of doubt and acquitted [Paras 16-25]. 
 
Recovery Evidence – Section 27 of the Evidence Act – Reliability – Recovery of MO1 series choppers and MO2 iron rod at the instance of the accused doubted as weapons did not have traces of blood – Delay in producing recovered weapons before the Court – Held: Recovery not reliable to link accused to crime beyond reasonable doubt [Paras 19-20]. 
 
Ocular Evidence – Hostile Witnesses – Value – PW3 who claimed to be an eyewitness was suffering from psychiatric illness and his statement was inconsistent with prior police statement under Section 161 CrPC – Court refused to accept his version – Other witnesses turned hostile – Held: Conviction cannot be based on the testimony of PW3 or hostile witnesses [Paras 16-17]. 
 
Motive – Proof of Previous Enmity – Absence of Supporting Material – Prosecution failed to produce records of the prior incident that allegedly motivated the accused to commit the offence – Held: Motive not satisfactorily proved [Para 18]. 
 
Decision – Appeals Allowed – Conviction and sentence of accused set aside – Accused acquitted and directed to be released forthwith unless required in other cases [Para 25]. 
 

Civil Law – Suit for Declaration and Recovery of Possession - Settlement Deed – Title Based on Registered Gift – Decree Upheld – Appeal Dismissed – Plaintiff filed suit for declaration of title and recovery of possession on basis of Ext.A1 registered settlement deed – Defendants claimed title through sale from alleged legal heirs of original owner Ramachandran – High Court held Ext.A1 validly executed and accepted by donee – Original document produced; document writer examined; attesting witnesses deceased – Proof of execution accepted – Trial court decree affirmed [Paras 3–8, 12–14, 18–19].

Gift and Acceptance – No Specific Denial of Execution – Document Writer’s Testimony Sufficient – Court held that where attesting witnesses are deceased and execution is not specifically denied, proof by document writer and donee’s possession suffices – Plaintiff produced original deed and established enjoyment of property – Section 68 of Evidence Act and Section 123 of TPA complied with [Paras 12–14].

Possession and Cause of Action – Constructive Possession Lost Upon Trespass – Letters from neighbor warning of trespass held to trigger cause of action – Defendant’s possession found unauthorized post-sale deeds – Plaintiff's ownership remained intact under Ext.A1 [Paras 17–18].

Bona Fide Purchaser – Encumbrance Ignored – Not Protected – Defendants 1 and 2 claimed status of bona fide purchasers – Held: No encumbrance certificate produced; deed registered and discoverable – Purchasers failed to exercise due diligence – Not entitled to protection as bona fide purchasers [Paras 20].

Decision – Appeal Dismissed with Costs – Decree for recovery of possession, injunction, damages and mesne profits upheld – Appeal dismissed with cost to plaintiff – All pending IAs dismissed, interim orders vacated [Paras 21–22].

Civil Writ - Education Law - Sports Quota – Horizontal vs Vertical Reservation – Compartmentalization Upheld - Petitioner contended that sports quota should be a standalone reservation and sub-division of seats based on community within sports quota amounts to reservation within reservation which is impermissible – Held: Sports quota is a horizontal reservation, and G.O.Ms.No.231 validly provides for distribution of sports seats among OC, BC, SC, ST categories – High Court upheld the compartmentalized horizontal reservation system following P. Srividya vs. State of AP and Indra Sawhney case [Paras 7-14]. 
 
Allotment of Seat – Comparative Merit – Petitioner’s Claim Rejected - Petitioner belonging to OC category could not claim the seat allotted to respondent No.18 belonging to BC-A category under sports quota – No seat was available for OC candidates under sports quota in respondent No.21-college – Further, petitioner failed to show that any less meritorious OC candidate was allotted a sports quota seat – Writ petition dismissed [Paras 15-17]. 

Service Law - Payment of Gratuity – Abandonment vs. Resignation – Validity of Resignation Proven – Appellant claimed that respondent abandoned service and thus was not entitled to gratuity – Held: Resignation letter dated 10.04.2013 was duly received and acknowledged by petitioner – Plea of abandonment rejected – [Paras 10-12]. 
 
Jurisdiction – Controlling Authority and Appellate Authority – Earlier litigation confirmed Central Government as the competent authority under the Act – Appeal rightly decided by Deputy Chief Labour Commissioner (Central) – [Paras 2(v), 13]. 
 
Forfeiture of Gratuity – Applicability of Section 4(6) – No proven loss, damage, or misconduct – Held: Employer failed to prove any conditions attracting forfeiture under Section 4(6) of the Payment of Gratuity Act – Mere resignation does not disentitle an employee from gratuity – [Para 5]. 
 
Interest on Gratuity – Delay since 2013 – Private respondent entitled to statutory interest on the gratuity amount from the date it became due until payment – [Paras 8, 15]. 
 
Decision – Writ Petition Dismissed – Controlling and Appellate Authority’s orders upheld – Petitioner directed to pay Rs.3,63,461/- with statutory interest within 30 days – Application for stay rejected considering the long delay and social welfare nature of the legislation – [Paras 14-18].