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].

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].

Society and Trust Law – Religious Property Ownership Dispute – ISKCON Bangalore vs. ISKCON Mumbai – Long-standing dispute over title and management of ISKCON Bangalore resolved – Supreme Court held that ISKCON Bangalore, a registered Karnataka society, is the absolute titleholder of Schedule ‘A’ land allotted by Bangalore Development Authority (BDA) – Held: No legal basis to the claim of ISKCON Mumbai over said property via an unincorporated branch – High Court’s findings contrary to documentary evidence and thus set aside [Paras 33–51, 55–57].

Documentary Evidence – Land Allotment and Registered Sale Deed – Application for BDA allotment (Exh. P-51) made in name of ISKCON Bangalore, signed by its President – Sale deed dated 3rd August 1988 executed in favour of ISKCON Bangalore – All communications, payments, and ULC exemption corresponded to ISKCON Bangalore – No competing application from ISKCON Mumbai or proof of benami transaction produced – Held: Valid title passed to ISKCON Bangalore [Paras 44–51].

Statutory Interpretation – Section 38B BDA Act – Only societies registered under Karnataka Societies Registration Act or trusts under MPT Act eligible for BDA allotment – ISKCON Bangalore, being a registered society, legally eligible – No evidence of ISKCON Mumbai applying under trust provisions – High Court erred in overlooking statutory eligibility and clear application trail [Paras 52–54].

Branch Status and Legal Entity – No Independent Existence of “ISKCON Mumbai, Bangalore Branch” – ISKCON Mumbai failed to produce incorporation documents or authority letters – Application, sale deed, and ULC exemption made only by ISKCON Bangalore – Held: Mere reference to branch functioning does not confer legal title or ownership – Branch lacked legal personality to hold property [Paras 50–51].

Adverse Inference – Key Witness Withheld – ISKCON Mumbai did not produce Stoka Krishna Dasa, alleged source of manipulation claims – Court held that non-examination of material witness warranted adverse inference – Held: Allegations of fraud and manipulation unsubstantiated in absence of direct testimony [Para 47].

Procedural History – Trial Court Decree in Favour of ISKCON Bangalore Restored – High Court Judgment in RFA No. 421 of 2009 reversed – All related appeals rendered infructuous – Oversight Committee managing temple to be dissolved after one month [Paras 56–58, 73(d)].

Internal Governance Dispute – Governing Body of ISKCON Bangalore – Suit No. 1758 of 2003 by members claiming to be rightful management dismissed – Concurrent findings by Trial Court and High Court accepted – Annual General Meeting of 1 July 1984 validly elected new governing body – Plaintiffs’ evidence found weak, contradictory and largely withdrawn – Held: No interference warranted in findings of fact [Paras 59–70].

Decision: Civil Appeal Nos. 3821–3822 of 2023 dismissed – Civil Appeal No. 9313 of 2014 allowed – High Court findings in RFA No. 421 of 2009 set aside – Decree in Suit No. 7934 of 2001 in favour of ISKCON Bangalore restored – Oversight Committee dissolved after one month – All connected appeals disposed of as infructuous – No order as to costs [Paras 73–74].

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].

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].

Suo Motu - POCSO Cases – Setting Up of Exclusive Courts – Implementation of Judicial Directives – Compliance Directed - The Court directed that each district with more than 100 POCSO cases must establish exclusive courts under a Central scheme with appropriate staffing and child-friendly infrastructure – Majority of States complied but high-pendency States (UP, WB, Bihar, TN, Orissa, Maharashtra) were found lacking – Held: Union and State governments must prioritise timely establishment of such courts [Paras 1, 3, 5-6].

Forensic Delay – Effective Functioning of FSLs – Expedited Processing Ordered – Court acknowledged forensic delays as key bottleneck in trial completion – Directed State Forensic Labs to ensure swift analysis and reporting in POCSO cases – Mandated Chief Secretaries to ensure compliance [Para 1].

Child Sensitisation and Support – Appointment of Trained Support Persons and Prosecutors – Awareness Measures – Directions were issued to appoint child-sensitive support persons and prosecutors, and to run public awareness campaigns in cinemas and media with helpline information prominently displayed – Responsibility assigned to Ministry of Women and Child Development [Paras 1, 4].

Timely Trial – Adherence to Statutory Deadlines – States Reminded of Duty – Despite POCSO Act’s time-bound process for investigation and trial, delay persists due to inadequate infrastructure – States instructed to strictly follow the law and ensure completion of investigations and trials within statutory periods [Paras 2, 6].

Closure of Proceedings – Compliance Noted – Matter Concluded – Noting significant implementation of earlier directions and pending areas requiring attention, the Court closed the suo motu proceedings with appreciation for the amicus curiae and counsel – Held: Further monitoring not required at this stage [Paras 7-8].

Criminal Law - Probation of Offenders Act – Inapplicability under PoFA Act – Section 20AA prohibits probation – Probation benefit denied - Section 20AA clearly excludes the application of the Probation of Offenders Act and Section 360 of the CrPC to those convicted under the PoFA Act unless the offender is under 18 years of age – The Court held that the provision is explicit, unambiguous, and constitutionally valid – Hence, probation not applicable [Paras 40-42].

Mollification of Sentence – FSS Act Repeal and Savings Clause – Reduced punishment not permitted – Benefit denied - Despite lesser punishment under the FSS Act, the repeal and savings clause under Section 97 preserves penalties under the repealed PoFA Act – The Court held that the presence of such a clause prevents application of lighter sentence from new law – Hence, no reduction in sentence permissible under FSS Act [Paras 43-44].

Adulteration Evidence – Discrepancy in Reports – Sentence converted to fine – Lead appeal partly allowed - In the case of Nagarajan and Selvaraj, the two lab reports on curd adulteration had significant differences—one showing deficiency in fat content, the other meeting the required standard – Applying precedent in C. Mohammed, the Court converted the 6-month imprisonment to a fine of Rs. 30,000 each [Paras 45-46].

Judicial Comity – Reliance on Coordinate Bench despite disagreement – Connected appeal partly allowed - Although the Bench disagreed with the reasoning in A.K. Sarkar & Co., it followed the decision to prevent further litigation, converting Naresh Chandra’s sentence to a fine of Rs. 20,000 in the interest of equity and justice [Paras 47-48].

Decision – Convictions upheld, Sentences modified – Probation relief and sentence reduction under FSS Act denied – However, due to specific factual circumstances and prior rulings, sentences were converted to fines – Appeals partly allowed [Paras 48-51].

Accident Claim - Motor Accident Compensation – Assessment of Monthly Income – Claim of Rs.10,000 accepted – High Court’s reduction reversed – The Tribunal awarded compensation based on the deceased driver’s claimed income of Rs.10,000 per month – High Court reduced it to Rs.4,076 applying minimum wages – Held: Based on precedent in Ramachandrappa v. Royal Sundaram, even unskilled labourers earned around Rs.4,500 in 2004, making Rs.10,000 reasonable for a skilled driver in 2014 – Tribunal’s assessment restored [Paras 3-4].

Future Prospects – 40% Addition – Compensation Properly Calculated – No Interference – The Tribunal rightly added 40% of monthly income towards future prospects – High Court erred in excluding it while calculating reduced compensation – Held: The calculation by the Tribunal aligns with prevailing law and requires no interference [Paras 2-4].

Loss of Consortium – Entitlement of Family Members – Retained Despite No Cross Appeal – Tribunal granted consortium to wife, children, and parents – Held: As per New India Assurance Co. v. Somwati, all dependents are entitled to consortium – Supreme Court retained the same though no appeal was filed by the claimants seeking enhancement [Paras 4-5].

Restoration of Tribunal’s Award – High Court Order Set Aside – Tribunal’s compensation confirmed – Appeal Allowed – Held: There was no justification for the High Court’s downward revision of compensation – Tribunal’s award reinstated in full, to be disbursed within two months and apportioned equally among legal heirs – In case of minors, amount to be held in fixed deposit [Paras 5-6].

Decision – Tribunal’s Compensation Restored – Appeal Allowed – The Supreme Court restored the full compensation awarded by the Motor Accident Claims Tribunal, setting aside the reduced award passed by the High Court – Compensation to be distributed as per Tribunal’s direction [Paras 5-6].

Arbitration – Objection on Jurisdiction – MP Act Applicability Raised Late – Award Restored – The respondent failed to object to the jurisdiction of the arbitral tribunal during arbitration or in initial Section 34 petition – Only after the L.G. Chaudhary (II) decision was such a ground introduced – Held: In line with precedent, an award cannot be annulled solely on jurisdictional ground if no such plea was raised at the relevant stage – Award restored [Paras 6–9, 36–40].

Jurisdictional Plea – Not Raised Under Section 16 – Considered Waived – In absence of timely objection under Section 16 of the Arbitration Act, a jurisdictional plea is deemed waived – No valid reason shown to excuse delay in raising such a plea – Held: Respondent cannot be permitted to approbate and reprobate – High Court’s annulment of award erroneous [Paras 27–35, 39–41].

L.G. Chaudhary (II) vs. Lion Engineering – No Real Conflict – Limited Exception Carved – While Lion Engineering allows legal pleas on jurisdiction in Section 34, L.G. Chaudhary (II) clarified that MP Act applicability raised post-award without earlier objection will not annul the award – Held: L.G. Chaudhary (II) not per incuriam, reflects conscious carving of exception due to earlier inconsistent precedents [Paras 18–23, 36–37].

Decision – Civil Appeal Allowed – Arbitral Award Restored – High Court’s annulment set aside – Matter remanded to Commercial Court to adjudicate other Section 34 objections without disturbing the award on ground of jurisdiction – Held: MP Act objection cannot be raised post-award without prior challenge [Paras 40–41].