Consumer Protection Act – Uniform Service Conditions – Judicial Directions Issued – Disparities in salary and allowances across different States for members and presidents of Consumer Commissions noted – Court invoked powers under Article 142 to ensure standardization – Directions issued aligning remuneration with judicial pay scales and protecting last drawn pay [Paras 5–9].

Model Rules 2020 – Application of Rules 3 and 4 – Interpretation and Modification – Supreme Court directed that Rules 3 and 4 of the Model Rules shall be followed with certain modifications – Pay scales of District and State Commission members aligned with judicial pay grades including super-time and selection grades – Allowances attached to respective judicial posts to apply [Paras 3–4, 9].

Retrospective Effect – Effective from 20 July 2020 – Uniform Pay Implementation – Court held that the revised pay structure shall be effective retrospectively from 20.07.2020 – Directed arrears to be paid within six months – Compliance to be monitored in next hearing [Para 9(viii)].

Legal Status – No Distinction in Appointment Type – Clarified that artificial distinctions such as part-time/full-time or judicial/non-judicial were not envisaged under the 2019 Act – All appointees performing adjudicatory roles to be treated uniformly for pay and service benefits [Para 9(vi)].

Decision: Directions Issued – Uniform pay and service conditions mandated across all States and UTs for Presidents and Members of Consumer Commissions – Orders to take effect from 20.07.2020 with arrears to be paid within six months – All distinctions in appointment status removed – Compliance to be reported by 22.09.2025 [Paras 9–11].

Insurance Law – Section 23 of the Consumer Protection Act - Flood Damage – Repudiation Based on Seepage – Held Invalid – Appellant’s premises suffered damage due to heavy rainfall between 25–31 August 2016—First surveyor attributed damage to flooding from rainwater—Insurer rejected claim citing “seepage,” based on a second survey—Held: Second survey arbitrary and unsupported—First survey and expert reports confirmed flood damage—Repudiation unjustified [Paras 3–9, 27–30].

Survey Report – Preference for First Survey Conducted Promptly – First survey conducted on 03.09.2016 concluded rainwater entered through flooring—No flaws cited—Second survey conducted after delay without justification contradicted earlier findings—Held: First report valid and reliable—Second report set aside [Paras 27–30].

Expert Evidence – Structural Engineer Reports Confirmed Flooding – Reports from M/s International Consultants & Technocrats and M/s Chordia Engineering Consultancy confirmed flooding due to rainfall—Unique Consulting Engineers’ report referred to unrelated seepage in structural elements—Held: No basis to infer seepage caused basement damage—NCDRC erred in relying on irrelevant structural data [Paras 14–17, 27–28].

Consumer Protection – Wrongful Repudiation – Arbitrary Conduct by Insurer – Insurer failed to address first survey or trace water source—Multiple surveys used to evade liability—Court found insurer’s approach mala fide and unfair—Set aside repudiation and remanded for quantum determination [Paras 19, 30–31].

Decision – Appeal allowed – Repudiation of claim set aside – Matter remanded to NCDRC for computation of compensation as per policy – Second survey report dated 18.10.2016 quashed – No costs [Paras 31–32].

Criminal Law - Bail – Section 302, 323, 427, 34, 120B of the Indian Penal Code (IPC) - Grant of Bail in Heinous Crime – Parameters of Judicial Discretion – Bail Cancelled – The Supreme Court set aside the High Court’s order granting bail to the accused in a case involving murder charges under Section 302 IPC – The Court found that the High Court had failed to adequately consider the heinous nature of the offence and the criminal antecedents of the accused, especially when the trial court had rightly refused bail for valid reasons – Held: The cryptic reasoning by the High Court warranted interference, and the Sessions Court’s denial of bail was restored [Paras 13–15, 19–20].

Investigation Stay and Bail – Incompatibility – Prejudice to Trial Process – The accused were granted bail by the High Court even while the trial proceedings remained stayed due to pending proceedings under Section 482 CrPC – The Court found that such simultaneous stay of trial and grant of bail created imbalance and potential prejudice – Held: Continuation of bail in these circumstances was unwarranted and legally untenable [Para 15].

No Reformatio in Peius – Safeguard in Appeal Proceedings – Relevance in Bail Orders – Though not directly reversing an appeal against acquittal or conviction, the Court emphasized that altering status of an accused beneficially without compelling grounds while higher judicial scrutiny is pending undermines fair process – Held: Criminal antecedents and gravity of offence should not have been diluted without detailed justification [Paras 14–15, 19–20].

Appellate Interference – High Court’s Bail Order – Cryptic Reasoning – Supreme Court held that the High Court’s order granting bail lacked reasoned analysis and failed to deal with the gravity of the allegations – The Court reiterated that bail in serious offences must be granted only with due diligence – Held: High Court order set aside and Sessions Court’s order denying bail restored [Paras 19–20].

Final Disposition – Supreme Court Directions – Accused Ordered to Surrender – Supreme Court directed the accused to surrender before the jurisdictional Magistrate or concerned Police Station by 16.06.2025 – Ordered deposit of passports at Police Station Nangal by 19.05.2025 – Held: Appeals allowed and High Court’s order granting bail set aside [Paras 21–23].

Civil Law - Execution of Decree – Successive Execution Petitions – Satisfaction Recorded in Prior EP Not a Bar – Fresh EP Maintainable on Subsequent Interference - Held: Recording of satisfaction in an earlier EP due to absence of decree-holder and written statement by judgment-debtor cannot bar future EP if fresh breach is alleged – Res judicata not attracted where new cause arises [Paras 2–4, 6].

Limitation – No Bar to Execution of Decree Granting Perpetual Injunction – Article 136 of Limitation Act – Perpetual Right of Decree-Holder - Supreme Court held that there is no limitation for execution of a decree granting permanent injunction – Right to seek enforcement survives perpetually against judgment-debtor, their assignees or successors whenever breach occurs [Para 7].

Civil Procedure – Objection under Section 47 CPC – Consideration Deferred to Executing Court – Only Prima Facie Observations Made - Apex Court clarified that its observations regarding objections under Section 47 CPC are prima facie – Objections can be re-agitated before Executing Court which shall decide afresh including claims about cancellation proceedings [Para 8].

Decision – High Court and Lower Courts’ Orders Set Aside – Execution Petition Restored - Supreme Court set aside all impugned orders and restored EP No. 2 of 2012 – Matter remanded to Executing Court for fresh consideration on merits, except on validity of decree which stands untouched [Paras 8–9].

Criminal Procedure – Inherent Powers under Section 482 CrPC – High Court Cannot Recall Quashing Order – Held Without Jurisdiction - The Supreme Court held that once a final judgment quashing an FIR is passed, it cannot be recalled under Section 482 CrPC due to the bar under Section 362 CrPC – High Court exceeded jurisdiction by reviving a quashed FIR on grounds of compromise violation – Review or recall of final orders not permissible except for clerical or arithmetical errors [Paras 9–12, 14].

Criminal Law – Compromise Between Parties – Breach of Terms No Ground for Criminal Revival – Alternate Legal Remedies Available - Breach of compromise terms does not justify revival of quashed criminal proceedings – Held: Remedy for enforcement lies in civil proceedings or appropriate forums, not through recall of a concluded criminal order [Para 12].

Judicial Discipline – Section 362 CrPC – Recall Power Limited to Clerical Corrections – Law Reiterated - Court reiterated that once a final judgment is signed, courts become functus officio – Inherent power cannot override express prohibition in Section 362 CrPC – Exceptions allowed only in cases involving jurisdictional error, natural justice violations, or fraud [Paras 9.3.2–9.3.4, 10.1, 14].

Decision – Appeals Allowed – High Court’s Orders Recalled – Quashing Restored - Held: High Court acted without legal authority in reviving FIR – Supreme Court set aside all impugned orders and restored original quashing – Registry directed to circulate judgment to High Courts to prevent such procedural errors in future [Paras 13–16].

Civil Writ - Judicial Administration – Creation and Role of Court Managers – Thirteenth Finance Commission Recommendation – Approved - The Court Managers were introduced to improve court efficiency by supporting administrative functions, allowing judges to focus on adjudication – The Finance Commission allocated Rs. 300 crore for the scheme – Guidelines were issued by the Ministry of Finance prescribing the roles, qualifications, and functions of Court Managers – Implementation varied widely across States and High Courts, leading to disparity and ad hoc employment practices [Paras 5–12, 28–30].

Service Conditions – Contractual Appointments and Disparity in Pay – Non-Uniform Practices – Criticized - Most Court Managers were appointed on a contractual basis with no consistent service rules or benefits – The Supreme Court had earlier directed regularization (2018 judgment) – The SNJPC reiterated this need and recommended uniformity, higher pay, and structured recruitment and promotion avenues – Found that several High Courts and State Governments failed to act on the earlier directions [Paras 12–17, 31–36].

Model Framework – Assam Rules of 2018 – Adopted as Model – Recognized - The Court endorsed the Gauhati High Court’s 2018 Rules as a comprehensive model for adoption across jurisdictions – The Rules include regular appointments, clear duties, promotional avenues, and benefit structures – Other High Courts directed to take these Rules as a base with necessary modifications [Paras 39–42].

Directions Issued – Uniformity, Regularization, and Suitability Test – Mandated - All High Courts directed to frame or amend rules for Court Managers within 3 months based on Assam Rules – State Governments to approve within 3 additional months – Suitability tests to be conducted for existing Court Managers; those qualifying to be regularized with retrospective seniority but without arrears – Registrar Generals and Chief Secretaries made personally responsible for compliance [Paras 43–44].

Decision – Writ Petitions and IAs Disposed – Directions Binding - The Supreme Court disposed of the writ petitions and applications with binding directions to ensure regularization and standardization of the Court Manager system nationwide [Para 44].

Environmental Law – Ex Post Facto Environmental Clearance – Legality of 2017 Notification and 2021 OM – Held Illegal - The 2017 Notification and 2021 Office Memorandum allowing retrospective environmental clearance were held contrary to statutory and constitutional mandates – The Supreme Court reaffirmed that ex post facto ECs are alien to environmental jurisprudence and violate Article 21 rights to pollution-free environment – Orders struck down for being arbitrary, ultra vires, and inconsistent with binding precedent [Paras 15–20, 26–31, 34–36].

Environmental Jurisprudence – Supreme Court Upholds Precautionary and Polluter Pays Principles – EC Must Be Prior and Not Retrospective - Court reiterated that ECs must be granted prior to project commencement after environmental impact assessment and public hearing – Held: Allowing ex post facto clearances undermines environmental protection and incentivises illegality, flouting principles laid down in Common Cause and Alembic Pharmaceuticals [Paras 16, 17, 29].

Fundamental Rights – Article 21 and 51A(g) – Right to Pollution-Free Environment – Infringed by Post-Facto Regularisation - Held: The 2021 OM undermines the right to life and health and fundamental duty to protect the environment – The State is constitutionally obligated to enforce EC norms strictly; any attempt to dilute such standards through retrospective regularisation is violative of fundamental rights [Paras 32–34].

Judicial Undertaking – Central Government Bound by Statement Before Madras High Court – Estoppel Applies - Union’s undertaking in Puducherry Environment Protection Association case that 2017 Notification was a one-time measure was binding – Court deprecated subsequent circulars and extensions in contravention of judicial declarations and government assurances [Paras 21–22].

Decision – 2017 Notification and 2021 OM Struck Down – Government Restrained from Future Ex Post Facto ECs - Held: 2017 Notification and 2021 OM are illegal and void – Supreme Court restrained the Central Government from issuing any future circulars or memoranda providing for ex post facto EC – However, ECs already granted under these instruments till date are not disturbed [Paras 35–36].

Education Law - Medical Education – Power of Committee to Create Corpus Fund – Not Traceable to Law – GO Dated 06.06.2018 Struck Down - The Court held that neither the Admission and Fee Regulatory Committee nor the State Government had legislative authority to mandate diversion of fees from NRI students towards a corpus fund for BPL/EWS scholarships – Such a measure, however noble, requires statutory sanction and cannot be imposed through executive fiat [Paras 16–20, 25–27].

Constitutional Law – Welfare Objective Cannot Override Statutory Limits – Absence of Legislative Backing Fatal - The Court acknowledged the intent behind the GO was laudable but emphasized that policy must operate within constitutional and statutory limits – Welfare schemes must be supported by legislation, not executive orders [Paras 26–27].

Education Law – Autonomy of Private Institutions – Article 19(1)(g) and Article 30 Rights Invoked - Self-financing medical colleges argued that diversion of fee amounts infringes their right to reasonable fee fixation and institutional autonomy – Court upheld the institutions’ right to utilize approved fees subject to reasonable regulation, but not for state-enforced welfare without statutory basis [Paras 6, 30].

Refund of Corpus Fund – NRI Students Not Entitled to Direct Refund – Court Orders Amounts Be Retained for In-House Subsidy - Though the collection was held illegal, the Court declined to refund corpus amounts to NRI students – Instead, it directed that funds be retained by respective institutions and used exclusively for subsidizing education of BPL students admitted therein [Paras 28–32].

Decision – GO Struck Down – No Further Collection Permitted – Funds Already Collected to Benefit EWS Students Only - Held: GO dated 06.06.2018 declared illegal and unsustainable – State directed not to collect any further corpus funds from NRI students – Amounts already collected to be retained in institutional accounts, to be used exclusively for BPL/EWS students within that institution [Paras 33–34].

Matrimonial Law – Transfer of Matrimonial Case – Divorce by Mutual Consent – Petition under Section 25 CPC – Allowed in part - The Supreme Court exercised its power under Article 142 to dissolve the marriage between the parties despite pending transfer petition – Mutual consent for divorce recorded, and transfer petition was accordingly disposed of [Paras 1-3, 10-11, 20-21].

Article 142 – Divorce by Mutual Consent – Settlement of Ancillary Issues – Liberty Reserved - Though mutual consent for divorce was granted, the petitioner insisted on return of stridhan or alternative monetary compensation – Liberty was reserved to the petitioner to pursue appropriate civil proceedings if Rs. 7,00,000 or stridhan articles are not returned by the respondent within 3 months – Respondent denied retaining stridhan – Court issued enabling direction for resolution while preserving petitioner’s remedies [Paras 6-13, 15-16].

Criminal Proceedings – Section 498A IPC – Quashing on Equitable Grounds – Criminal Complaint Quashed - Given the mutual consent divorce and settlement, the Court quashed the criminal complaint and proceedings under Section 498A IPC filed by the petitioner, holding there was no further purpose in prosecution [Paras 9, 18].

Jurisdiction – Article 142 – Equitable Relief and Complete Justice – Civil and Matrimonial Proceedings Disposed - The Court invoked its extraordinary jurisdiction to ensure complete justice between the parties by dissolving marriage, quashing criminal proceedings, disposing of both matrimonial suits and clarifying liberty to seek civil remedies [Paras 11, 14, 19, 22].

Decision: Transfer petition disposed – Marriage dissolved under Article 142 – Criminal complaint under Section 498A IPC quashed – Liberty granted to petitioner to pursue civil remedies for recovery of stridhan or equivalent compensation [Paras 13-16, 22].