Civil Law - Land Acquisition - Land Acquisition Act 1894 - Sections 4(1), 18(1) - Compensation enhancement - Challenge against High Court's dismissal of review petition seeking compensation parity for lands acquired under same notification - Notification issued on 11.02.1999 - Reference Court enhanced compensation to Rs. 3,00,000/- per acre on 27.03.2001 - High Court further enhanced to Rs. 5,00,000/- per acre on 23.06.2011 - For other lands under the same notification, compensation was determined at Rs. 6,50,000/- per acre (Ravindra case) - Appellants' review petition seeking parity was dismissed by High Court on 07.09.2015 due to delay - Supreme Court condoned delay in Special Leave Petitions - Exercised powers under Article 142 of the Constitution - Held - Appellants entitled to compensation of Rs. 6,50,000/- per acre with statutory benefits, but not entitled to interest for two periods of delay aggregating 4,427 days - [Paras 3-11].

Writ Law - Constitutional Powers - Constitution of India 1950 - Article 142 - Doing complete justice - Land acquisition compensation parity - Despite abnormal delay and High Court's dismissal of review petition, Supreme Court invoked Article 142 to extend compensation determined in a similar case for lands under the same notification to the appellants - Held - to do complete justice, the appellants are entitled to compensation of Rs. 6,50,000/- per acre with statutory benefits - [Paras 10].

Civil Law - Land Acquisition - Interest entitlement - Land Acquisition Act 1894 - Delay in pursuing claim - Appellants' claim for enhanced compensation suffered from abnormal delay between Reference Court judgment and High Court appeal, and between High Court judgment and refiling of SLPs - Total delay of 4,427 days - Held - Appellants not entitled to interest for the period of delay - [Para 11].

Decision: Civil Appeals allowed – Appellants entitled to Rs. 6,50,000/- per acre with statutory benefits – Appellants not entitled to interest for the period from 28.03.2001 to 2008 and from 24.06.2011 to 27.01.2017.

Civil Law - Sale of Immovable Property - Transfer of Property Act 1882 - Section 54 - Execution of sale deeds for part consideration with balance retained to clear vendor debts - Plaintiffs filing suit for declaration of sale deeds as void and inoperative instead of seeking recovery of balance consideration - Trial Court and Appellate Court dismissing suit - High Court reversing in second appeal - Supreme Court holding that actual payment of entire sale price at the time of execution is not a sine qua non for completion of sale - title passes upon registration even on part payment - remedy lies in recovery of balance consideration and not cancellation of sale deed - Held - High Court judgment set aside and Trial Court decree restored - [Paras 1-18].

Civil Law - Second Appeal - Code of Civil Procedure 1908 - Section 100 - Scope of interference - High Court reversing concurrent findings of fact regarding validity of sale deeds - Supreme Court holding that High Court arrived at a wrong conclusion on available facts by treating sale as void for non-payment of balance consideration - Held - conclusion of High Court on available facts was erroneous - [Paras 6-14].

Decision: Appeal allowed - Judgment of the High Court reversed and that of the Trial Court as affirmed by the First Appellate Court restored - [Paras 1-18].

Environmental Law - Riverine Pollution - Environmental Protection - Rajasthan - Suo Moto Writ Petition (Civil) No. 8 of 2025 and connected appeals - State-wide environmental degradation including Jojari-Bandi-Luni river ecosystem contamination, untreated industrial effluent discharge, groundwater degradation, and systemic regulatory enforcement failures, revealed through reports of High-Level Ecosystem Oversight Committee and Special Investigation Team (SIT) - Court's previous interim directions included invocation of graver penal provisions under Bhartiya Nyaya Sanhita, 2023 Sections 272, 326(a), 326(c) and Prevention of Damage to Public Property Act, 1984 - State of Rajasthan submitted compliance reports detailing SIT's review of criminal cases, arrests, and preventive measures - SIT report indicated prima facie connivance amongst CETP officials and industrial units, but Court expressed concern over delayed promptness in invoking graver offences, mandating deeper probe into conspiracy and involvement of all persons including public servants - State's remedial actions noted for Jojari River, Sanganer-Dravyavati-Nevta textile units, and Morel Dam, alongside acceptance of recommendations for wastewater treatment at Ambey Valley and Khed HRTS/SEP sites and Nehda Dam - Court found severe degradation necessitated coordinated, multidisciplinary institutional response - Held - Supreme Court directed the State of Rajasthan to constitute an "Integrated Coordination Group" headed by the Chief Secretary within seven days and an independent "River Commission/River Rejuvenation Authority" under the Chief Secretary's chairmanship for integrated river management, including scientific determination of High Flood Line and protection of riverine ecosystems - Integrated Coordination Group to prepare a Comprehensive Resolution Plan within three weeks - SIT to intensify investigation; Committee to pass orders on White Category Industries' representations within seven days; State to establish Integrated Public Reporting and Environmental Grievance Redressal Mechanism using a QR Code-based digital platform; Chief Secretary to personally monitor compliance; details of action against RSPCB officers to be submitted - [Paras 1-33].

Environmental Law - Constitutional Law - Article 32 Constitution of India - Environmental Degradation - Suo Moto cognizance - Systemic failures - Inter-departmental coordination - Complex environmental issues necessitating integrated institutional response - Held - Supreme Court directed constitution of Integrated Coordination Group and an independent River Commission/Rejuvenation Authority - [Paras 18-19, 22, 33(A)-(G)].

Environmental Law - River Protection - High Flood Line - Ecological Buffer Zones - Indiscriminate industrial development - Encroachments on riverbeds and floodplains - Degradation of river ecosystem - Held - State directed to undertake comprehensive scientific exercise for determination and demarcation of High Flood Line and requisite ecological buffer zones for all river systems - No fresh permissions for industrial/commercial/residential development within identified river corridors until exercise completed - [Para 20].

Environmental Law - Hazardous Waste Management - Effluent Treatment Plants - HRTS facilities - Ambey Valley and Khed - Temporary arrangements used as repositories for accumulated industrial wastewater - Held - Entire accumulated wastewater to be scientifically treated and disposed of - All RCC storage tanks and associated infrastructure at HRTS sites to be dismantled and land restored through ecological restoration measures under Committee's supervision, developed as green ecological zone/urban forest - [Para 21].

Environmental Law - River Basin Management - Institutional Framework - Rajasthan River Basin and Water Resources Planning Authority - Became largely defunct and failed to discharge functions - Held - State directed to constitute an independent and adequately empowered River Commission/River Rejuvenation Authority for integrated management of rivers and river basins, including scientific determination of High Flood Line - Commission to function under chairmanship of Chief Secretary - [Para 22, 33(G)].

Environmental Law - Industrial Effluents - Centralized Effluent Treatment Plants (CETPs) - Operational overload - Transportation risks - Need for decentralized treatment - Held - State Government to examine feasibility of encouraging Captive Effluent Treatment Plants (ETPs) for industries generating 100 KLD or more - Expedite pending applications - Formulate policy to incentivize ETPs for smaller units - Maximize capacity utilization of existing CETPs - Establish additional CETPs - [Paras 23-24].

Environmental Law - Industrial Development - Proximity to River - RIICO Industrial Area, Kakani - Developed in close proximity to Luni River - Portions falling within apparent High Flood Area - Absence of scientifically determined ecological buffer - Risk of river contamination - Held - Integrated Coordination Group to review layout after scientific determination of High Flood Line and buffer - Corrective measures including modification/relocation of plots if within High Flood Line/floodplains/buffer - No untreated effluent discharge into river system - [Paras 25-26].

Environmental Law - Land Use Regulation - Industrial Parks - Ambey Valley Industrial Park - Irregularities concerning conversion of agricultural land, deviation from Master Plan, issuance of pattas for industrial purposes in residential area, development of plots within riverbed/high flood area - Serious deficiencies in official records - Held - Chief Secretary to undertake inquiry into legality of land-use conversions/approvals/allotments and direct remedial/corrective measures - [Para 27].

Environmental Law - Groundwater Resources - Sustainable Management - Excessive dependence on groundwater for industrial purposes - Contamination of surface water - Depletion of water table - Held - State Government to formulate comprehensive strategy for sustainable groundwater management including regulation of extraction, reuse/recycling, augmentation of recharge, monitoring levels and quality - No water-intensive industries in dark zones (over-exploited zones) - [Para 28].

Criminal Law - Environmental Offences - Enforcement - Bhartiya Nyaya Sanhita 2023 - Sections 272, 326(a), 326(c) - Prevention of Damage to Public Property Act 1984 - Non-invocation of graver penal provisions - SIT investigation - Connivance amongst CETP officials and industrial units - Held - SIT to intensify investigation process comprehensively examining role of all persons including public servants, industrial units, office-bearers of CETPs - Appropriate action strictly in accordance with law - Details of action against responsible RSPCB officers to be placed before Committee - [Paras 2, 4-6, 33(H), 33(N)].

Environmental Law - Public Grievance Redressal - Environmental Violations - Lack of effective mechanism - Held - State of Rajasthan to establish an Integrated Public Reporting and Environmental Grievance Redressal Mechanism using a QR Code-based digital platform - Platform to facilitate confidential reporting of violations with geo-tagged information, photos, videos - Immediate electronic transmission to jurisdictional authorities - Examine feasibility of incentive scheme for credible information - [Para 33(J)].

Decision: Suo Moto Writ Petition and connected appeals disposed of with comprehensive directions – State of Rajasthan directed to constitute an Integrated Coordination Group and an independent River Commission/Rejuvenation Authority, formulate a Comprehensive Resolution Plan, intensify SIT investigation, address industrial pollution, groundwater management, and establish a public grievance redressal mechanism – Chief Secretary to personally monitor compliance.

Civil Law - Jurisdiction of Civil Courts - Andhra Pradesh Civil Courts Act 1972 - Sections 1, 2(a), 3 - Scheduled Areas - Partition Suit - Non-Tribal Parties - The Supreme Court addressed a jurisdictional challenge in a partition suit involving non-tribal parties over land in Scheduled Areas - The Trial Court initially dismissed the suit finding a prior family partition and the suit to be time-barred - The First Appellate Court reversed this holding the properties were joint family properties and that Civil Courts had jurisdiction in Scheduled Areas - However the High Court in Second Appeal set aside the First Appellate Court's judgment concluding that Civil Courts lacked jurisdiction in Scheduled Areas relying on Nagarjuna Gramin Bank v. Medi Narayana and the exclusion of the Andhra Pradesh Civil Courts Act, 1972 from Scheduled Areas via a 1972 notification - The Supreme Court critically analyzed the precedent value of Nagarjuna Gramin Bank v. Medi Narayana determining it did not lay down a binding proposition of law but represented a judicial deference to executive/legislative action lacking a legal analysis of the Act's provisions - Emphasizing that the fundamental intent behind notifying Scheduled Areas and excluding the 1972 Act was to protect vulnerable tribal populations and preserve their customs - the Court reasoned that extending this protective mechanism to subject exclusively non-tribal parties to special procedures not intended for them would demonstrably lack a rational nexus with the stated object and constitute a violation of Article 14 of the Constitution - Held - the Civil Court possessed the requisite jurisdiction to entertain the partition dispute between the non-tribal parties - the High Court's finding to the contrary was erroneous and is hereby set aside - the second appeal is restored to the High Court for decision on its merits in a manner consistent with this judgment - This ruling unequivocally applies to all pending and future cases - It is clarified that if one party to a dispute is a tribal residing in the Scheduled Areas then the Agency Courts would retain jurisdiction - Nagarjuna Gramin Bank v. Medi Narayana is unequivocally not a binding precedent on this point - [Paras 3-7, 9-10, 12-15].

Civil Law - Precedent - Ratio Decidendi - Interpretation - The Court reiterated principles for identifying binding precedent - drawing from Read and others v. The Bishop Of Lincoln Respondent - Abdul Kayoom v. CIT - and State of Gujarat v. Utility Users' Welfare Assn. (Wambaugh's Inversion Test) - a decision constitutes a binding precedent only if its conclusion relies on a legal analysis of statutory provisions - not merely a deference to executive or legislative actions - Held - Nagarjuna Gramin Bank v. Medi Narayana was not a binding precedent for the proposition that Civil Courts lacked jurisdiction over non-tribal disputes in Scheduled Areas as its basis was a high-powered committee's decision not a legal analysis of the Andhra Pradesh Civil Courts Act, 1972 - [Paras 9-9.5, 9.7, 10, 15].

Constitutional Law - Article 14 - Equality before law - Rational Nexus - Scheduled Areas - The exclusion of Civil Courts from Scheduled Areas by the Andhra Pradesh Civil Courts Act, 1972 was intended to protect tribal populations and preserve their customs - When a dispute for partition involves exclusively non-tribal parties in a Scheduled Area applying special procedures meant for tribal protection to them would lack rational nexus with the object sought to be achieved by the law - Such an application would violate the principle of equality before law under Article 14 of the Constitution - Held - in disputes exclusively between non-tribal parties over land in Scheduled Areas Civil Courts retain jurisdiction as the rationale for tribal protection does not extend to non-tribals - [Paras 12.5-13, 13.4, 15].

Civil Law - Limitation - Limitation Act - Article 110 - Partition Suit - The Trial Court dismissed the partition suit citing a bar of limitation under Article 110 which mandates filing after the manager of the family attains majority - but the First Appellate Court found the trial court came to a wrong conclusion - The Supreme Court's decision primarily focused on jurisdiction and restored the appeal for decision on merits by the High Court - implying that limitation and other merits need re-evaluation consistent with the jurisdictional finding - Held - the jurisdictional finding allows for the re-examination of other aspects of the case including limitation by the High Court - [Paras 3-5, 15].

Decision: Appeal allowed – Impugned High Court judgment set aside – Second appeal restored to the file of the High Court for decision on the merits in a manner consistent with this judgment – Parties to appear before the High Court on 24.08.2026 – Hearing expedited

Civil Law - Service Tax - Finance Act 1994 - Sections 65(105)(zzd), 66, 67, 65(105)(zzzza) - Indivisible Turnkey Contracts - Commissioning or Installation Service - Artificial Vivisection - Constitutional Limitations - Respondent-assessee engaged in supplying, installing and commissioning ATMs under indivisible turnkey contracts for a composite consideration - Revenue sought to levy service tax on 33% of the gross consideration, classifying it as "commissioning or installation" service under Section 65(105)(zzd) of the Finance Act, 1994 for the period July 2003 to April 2006 - CESTAT allowed the assessee's appeals, holding that the contracts were indivisible, with the dominant object being the supply of ATMs, and installation/commissioning activities being merely incidental, thus no part of the consideration could be segregated and subjected to service tax without specific statutory authority, relying on Daelim Industrial Co. Ltd. (supra) - Supreme Court examined the statutory framework of the Finance Act, 1994, emphasizing that liability to tax must flow from the charging statute itself - Court noted the constitutional position after Article 366(29A)(b) which allowed segregation of goods component for sales tax in works contracts but not services - Court relied on Commissioner, Central Excise and Customs, Kerala vs. Larsen and Toubro Limited (2016) which held that prior to 01.06.2007, the Finance Act, 1994, lacked both the charging provision and the machinery to vivisect and tax the service element of indivisible composite works contracts - Revenue's administrative attribution of 33% value for "commissioning or installation" without statutory foundation was rejected - Held - The contracts were indivisible turnkey contracts and in the absence of an express legislative mandate in the Finance Act, 1994, during the relevant period (July 2003-April 2006), to vivisect such contracts and tax a notional service component, the levy of service tax was unsustainable - CESTAT's order was correct and consistent with settled legal principles - [Paras 1-10, 18-27, 28-35, 37-40].

Civil Law - Service Tax - Finance Act 1994 - Sections 65(105)(zzd), 66, 67 - Composite Contracts - Legislative Authority - Charging Mechanism - During the period July 2003 to April 2006, the Finance Act, 1994, did not contain any express provision authorizing the vivisection of an indivisible composite turnkey contract to isolate and tax a service element like "commissioning or installation" - A taxing statute admits of neither intendment nor equity, and the existence, extent, and incidence of a tax must be discernible from the language employed by the legislature - Machinery or valuation provisions cannot create or enlarge a charge not enacted by the charging provision - The subsequent introduction of a distinct taxable entry for "works contract service" (Section 65(105)(zzzza)) with effect from 01.06.2007, coupled with a specific valuation mechanism, constitutes a clear legislative recognition that prior existing taxable entries were insufficient to encompass indivisible composite works contracts - Held - No service tax could be levied on a notional portion of an indivisible turnkey contract under the Finance Act, 1994, as it stood prior to 01.06.2007, due to the absence of statutory authority for vivisection and a corresponding charging mechanism - [Paras 20-22, 28-29, 31, 34-36, 39].

Decision: Appeals dismissed.

Civil Law - Compulsory Retirement - Fundamental Rules - Rule 56(j) - Compulsory retirement of a CISF Inspector at 50 years of age - Internal Screening Committee and Review Committee found appellant unfit for retention due to slackening efficiency - High Court upheld the decision - Supreme Court affirmed that compulsory retirement is not punitive, serves public interest, and is based on subjective satisfaction - Judicial review is limited to cases of malafide, no evidence, arbitrariness, or perversity - Entire service record, including uncommunicated adverse remarks and pre-promotion adverse material, must be considered, with greater weight accorded to performance in the immediate preceding years - Appellant's ACRs showed a discernible decline from "Good" to "Average" in the two years preceding retirement, coupled with minor penalties and warnings for negligence and lethargy - The "washed-off theory" (adverse entries prior to promotion losing relevance) does not apply to assessment for compulsory retirement, only for promotion - Standards of efficiency, vigilance, and discipline are paramount for a disciplined force like CISF - Held - No infirmity in the decision to compulsorily retire the appellant - appeal dismissed - [Paras 1-16].

Service Law - Compulsory Retirement - Fundamental Rules - Rule 56(j) - Applicability of "washed-off theory" - Appellant contended that pre-promotion adverse material should not be considered for compulsory retirement - Supreme Court held that the "washed-off theory" where adverse entries prior to promotion are treated as wiped off, applies only to considerations for further promotion and not for assessing suitability for retention in service via compulsory retirement - For compulsory retirement, the entire service record, including old adverse entries, is relevant, though the immediate past record is to be given due credence - Held - Committee was justified in considering the appellant's entire service record including adverse material preceding his promotion - [Paras 10-11].

Service Law - Compulsory Retirement - Judicial Review - Scope - The object of compulsory retirement is to weed out deadwood to maintain high standards of efficiency and integrity in public service - It is not punitive, implies no stigma, and is in public interest - Principles of natural justice have no application - Scope for judicial review is extremely narrow and restricted, limited to grounds of arbitrariness, capriciousness, mala fides, or overlooking relevant materials - Court cannot act as an appellate authority over subjective satisfaction of the employer - Held - The High Court and Supreme Court would not examine the matter as an Appellate Court but can interfere if the order is malafide, based on no evidence, or arbitrary and perverse - [Paras 5-7].

Decision: Appeal dismissed – No specific directions.

Civil Law - Arbitration - Arbitration and Conciliation Act 1996 - Section 11 - Reference to arbitration - Appellants intended to take over Sensorise Digital Services Private Limited and its sister concern under a Memorandum of Settlement dated 09.05.2022 - Respondent No. 1 Ashiesh Shukla was not a signatory to the MoS but executed a Share Purchase Agreement on the same date as a consultant shareholder - Delhi High Court refused to refer disputes against Ashiesh Shukla to arbitration holding that Clause 16 of his Share Purchase Agreement separated his sale of shares from the MoS - Supreme Court found that identically situated parties who executed similar share purchase agreements containing the same clause were referred to arbitration - Held - the performance of obligations under the Share Purchase Agreement was fundamental to the completion of the MoS making the non-signatory a veritable party - appeal allowed - [Paras 1-21].

Civil Law - Non-signatory parties - Arbitration and Conciliation Act 1996 - Section 11 - Doctrine of veritable parties - Conduct role and involvement in the underlying contract - Principles laid down in Cox and Kings Limited and Discovery Enterprises Private Limited - Participation of a non-signatory in the performance of the underlying contract as an indicator of intention to be bound - Held - composite nature of transactions and commonality of subject matter render the claims against the non-signatory interlinked with the issues under arbitration - [Paras 19-20].

Decision: Appeal allowed - Judgment dated 21.10.2024 set aside in so far as it related to Ashiesh Shukla - Disputes pertaining to Ashiesh Shukla referred to the same learned Arbitrator - [Paras 21-23].

Civil Law - Arbitration - Micro, Small and Medium Enterprises Development Act 2006 and Arbitration and Conciliation Act 1996 - Appellant buyer challenging initiation of arbitration - Respondent MSME agreeing during proceedings to appointment of an arbitrator through the Delhi International Arbitration Centre with venue fixed at New Delhi - Supreme Court accepting the fair offer and disposing of the appeal without deciding the question of law - Held - appeal disposed of by referring disputes to arbitration under the Delhi International Arbitration Centre - [Paras 1-6].

Decision: Appeal disposed of – Delhi International Arbitration Centre requested to appoint a suitable arbitrator to resolve the disputes between the parties under the Arbitration and Conciliation Act 1996 – Venue fixed at New Delhi – Appellant to approach the Centre within two weeks – Question of law left open to be considered in an appropriate future case.

Civil Law - Central Excise - Central Excise Act 1944 - Section 2(f) - Central Excise Tariff Act 1985 - Note 6 to Section XVI - Whether kitting and grouping of imported photocopier modules in CKD or SKD condition amounts to manufacture - Assessee imported parts and modules under Tariff Heading 8471 paying customs duty and countervailing duty as complete machines - Assessee performed kitting and grouping at warehouses in Hyderabad and Rampur according to customer specifications - Revenue issued SCN demanding excise duty alleging manufacturing activity under Section 2(f) read with Note 6 to Section XVI - Commissioner confirmed demand - CESTAT set aside order holding that no physical assembly or conversion of incomplete machines took place at warehouses as goods were imported and cleared as complete machines in original packing - Supreme Court dismissed Revenue appeals holding that Revenue failed to establish transformation of goods into a new and distinct commercial product - Held - activity of kitting and pinning different parts together does not amount to manufacture under Section 2(f) or Note 6 to Section XVI - [Paras 1-21].

Civil Law - Interpretation of Statutes - Central Excise Tariff Act 1985 - Rule 2(a) of General Rules for the Interpretation of the Schedule - Scope and applicability - Revenue contended that Rule 2(a) and Note 6 to Section XVI render imported parts equivalent to completed machines - Supreme Court held that Rule 2(a) is merely a rule of classification for incomplete or unassembled articles and does not determine whether a process performed upon an article amounts to manufacture - Held - Rule 2(a) does not answer the question of manufacture - [Paras 10.1, 18, 23].

Civil Law - Burden of Proof - Central Excise Act 1944 - Section 2(f) - Requirement of establishing excisable activity - Revenue levied duty and issued SCN without inspecting assessee premises or capturing any evidence of manufacturing activity - Supreme Court observed that Revenue failed to discharge its burden of proof by presenting best evidence to establish transformation - Held - findings of fact recorded by CESTAT are not perverse and are supported by evidence - [Paras 11.5, 19, 24].

Decision: Appeals dismissed - Orders of the CESTAT setting aside the central excise duty demands and penalties affirmed - [Paras 21-22].