Criminal Law - Custodial Death – Demand for Independent Investigation – Local Police Involved – CBI Directed to Take Over – Allegations of police brutality leading to the death of Deva Pardhi in custody prompted a plea by relatives seeking transfer of investigation from local police, who were the accused themselves – Supreme Court found that no arrests were made eight months after FIR and that doctors possibly acted under pressure – Held: Investigation transferred to CBI to ensure impartiality and credibility [Paras 3–32].

Witness Intimidation – Sole Eyewitness Threatened and Implicated – Witness Protection Ordered – Gangaram Pardhi, sole eyewitness to the custodial torture, was being implicated in multiple FIRs post-incident – Court acknowledged threats and coercion and upheld High Court's order shifting him to Central Jail – Held: State authorities directed to provide witness protection as per law [Paras 7, 12, 20, 27, 35–36].

Bail Application – Direction to Approach High Court – Liberty Granted – Supreme Court refrained from directly granting bail but noted ongoing persecution of the eyewitness – Held: Gangaram Pardhi permitted to approach High Court for bail in all implicated cases post-incident; High Court to decide considering present observations [Paras 33–34].

Decision – CBI to Investigate – Witness Protection and Bail Liberty Granted – Supreme Court allowed the appeal in part by transferring the investigation to CBI, directing protection for Gangaram Pardhi, and permitting him to seek bail from High Court with due consideration to the case circumstances [Paras 31–37].

Civil Law - Commercial Suit – Section 12A of Commercial Courts Act – Mandatory Nature – Rejection of plaint not justified – The suit was filed in 2019 without pre-institution mediation as mandated by Section 12A of the Commercial Courts Act – Relying on the prospective applicability of the Patil Automation decision, the Court held that suits filed prior to 20.08.2022 are not liable for rejection under Order VII Rule 11 CPC – Held: Rejection of plaint was unjustified; the High Court rightly directed the matter for mediation [Paras 5-13, 34-38, 46-48].

Doctrine of Prospective Overruling – Application to Section 12A Compliance – Relief sustained – The Court affirmed that the mandate laid down in Patil Automation applies prospectively – It ruled that suits instituted prior to 20.08.2022 without pre-institution mediation cannot be dismissed solely on that ground – The rejection would otherwise result in hardship and procedural prejudice [Paras 47-48, 54].

Urgent Interim Relief – Interpretation under Section 12A Proviso – Non-Applicability in Facts – The Court clarified that the proviso to Section 12A permitting bypass of mediation only applies where urgent interim relief is sought – In the instant case, no such relief was prayed – However, since the suit was instituted before the enforcement of the mandate, rejection was not warranted [Paras 35, 42-45].

Infrastructure Deficiency – Principle of Lex Non Cogit Ad Impossibilia – Applied in Favour of Appellant – The Court acknowledged that mediation infrastructure was lacking at the time of suit filing – Applied equitable maxim that law does not compel a man to do the impossible – Held: Procedural lapse excused in view of institutional shortcoming [Paras 15, 18-19, 49-53].

Decision – Appeal Dismissed – High Court Order Affirmed – The Supreme Court upheld the High Court’s direction to keep the suit pending and refer the matter for pre-institution mediation – Held: The approach of the High Court was proper and the appeal warranted no interference [Paras 4, 26, 55].

Motor Accident Claim – Liability of Insurer – Duty limited to monetary compensation – High Court’s directive for lifetime support set aside – The High Court directed the insurer to provide prosthetic limbs, motorized wheelchair, travel expenses, and ensure ongoing support – Held: Insurer’s statutory role is limited to indemnifying loss in monetary terms, and not to maintain lifelong support infrastructure – Directions contrary to statutory framework and unsustainable [Paras 2-4, 6].

Compensation – Disability and Future Needs – Additional Rs.12 lakhs awarded – Expenses quantified for future wellbeing – The victim suffered 100% functional disability due to loss and impairment of both lower limbs at age 22 – Held: A prosthetic limb costing approx. Rs.2 lakhs, replaced every 5 years, and wheelchair costing Rs.40,000 require long-term provision – Court awarded Rs.12 lakhs with 6% simple interest to cover future expenses and mobility needs [Paras 5, 7-8].

Appeal by Insurer – No bar on grant of just compensation – High Court’s enhancement restructured – Though the appeal was filed by the insurer and not the claimant, the Supreme Court upheld the right to restructure compensation in monetary terms, in lieu of specific services previously directed – Held: The Court is merely converting non-monetary directions into quantified award and not increasing compensation beyond High Court’s intent [Paras 8-9].

Final Directions – High Court Order Set Aside – Award modified and appeal disposed – The Supreme Court set aside the High Court’s directions and substituted them with quantified compensation payable within two months – Directions given to respondent to furnish account details for online transfer – Pending applications also disposed [Paras 9-12].

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].

Family Law - Child Custody – Repetitive IA Requirement – Procedural Burden Criticized – Modified - The Family Court required the father to file fresh interlocutory applications for custody every time he visited India – Held: Such repetitive litigation imposes undue burden on non-custodial parent and child, disrupts planning, and hinders bonding – Supreme Court substituted a structured interim visitation schedule to ensure predictability and preserve parental relationship [Paras 2, 6, 15–17].

Child Welfare – Shared Parenting Principles – Interim Custody Balanced - The Court recognized the importance of regular meaningful contact with both parents – Held: Even while trial is pending, structured parenting time is essential for the child’s emotional well-being – Interim custody split during vacations and alternate weekends, with structured video interaction during the appellant’s overseas postings [Paras 16–20].

Family Court Jurisdiction – Interim Access Orders – Judicial Discretion Guided - High Court’s refusal to grant structured schedule was reversed – Held: Interim arrangements must account for practicalities of international employment and avoid repetitive litigation – Family Court may vary logistics only upon material change, but not reduce access granted [Paras 17–20].

Decision – Appeal Allowed in Part – Permanent Interim Visitation Framework Issued - Supreme Court replaced piecemeal interim custody system with a standing schedule – Directed equal division of vacation time (if appellant present), alternate weekends, routine video contact, and streamlined coordination procedures – Directed Family Court to adjudicate main custody case expeditiously [Paras 19–21].

Criminal Law - Wild Life (Protection) Act, 1972 (Wildlife Act) - Wildlife Offences – Possession of Scheduled Animal Parts – Conviction Justified – The appellants were caught red-handed with tiger skins, claws, bones and antlers in a car at a petrol pump by the CBI – Two independent witnesses supported the seizure – Held: Recovery was convincingly established and corroborated by witness testimony, justifying conviction under the Wildlife Act and IPC Section 120-B [Paras 3-8, 22].

Investigation Gaps – Failure to Trace Full Chain – No Ground for Acquittal – Investigation failed to trace source or intended buyer of the wildlife items and did not establish age of the articles – Held: These shortcomings do not dismantle the prosecution's core case, which is based on direct recovery and seizure from the accused [Paras 20-21].

Sentencing – Youth of Accused and Lack of Evidence of Poaching – Sentence Reduced – Accused were young at the time of incident and there was no direct evidence they killed the animals – Held: Sentence of six years reduced to three years' simple imprisonment with increased fine, considering mitigating factors [Paras 23-24].

Final Decision – Conviction Maintained, Sentence Modified – Supreme Court confirmed guilt of the appellants but reduced their sentence to three years’ simple imprisonment and fine of Rs.25,000 each – Failure to pay fine will result in an additional three months’ simple imprisonment [Paras 24-26].

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].

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].

Employment Law - Public Employment – Format of Caste Certificate – Format compliance mandatory – Rejection of candidature upheld – Petitioners submitted OBC-NCL certificates in Central Government format rather than in the format required by the State of Uttar Pradesh – Clause 5.4(4) of recruitment advertisement clearly specified the required format and the consequence of non-compliance – Held: Non-submission in the prescribed State format rendered petitioners ineligible for OBC reservation – Authority acted within jurisdiction by excluding petitioners from consideration under OBC category [Paras 14–17].

Recruitment Rules – Non-discretionary application – Procedural fairness does not override explicit requirements – Plea that the Board should have granted a chance to correct the certificate format rejected – Held: Opportunity already existed at the time of application – Procedural fairness does not mean condoning clear procedural defaults – Equal treatment requires adherence to rules by all [Paras 19–21].

Judicial Review – Limited role of Courts – No interference when recruitment norms are unambiguous – Held: Recruitment authority is entitled to frame and implement rules unless proven to be arbitrary or violative of constitutional rights – Courts will not dilute terms of advertisement by equitable considerations unless warranted by exceptional circumstances [Paras 19–20].

Article 141 – Precedent – Summary dismissal of SLPs does not constitute binding law – Reference to previous reliefs granted to similarly situated candidates not helpful – Held: Dismissal of Special Leave Petitions in limine without reasons does not have precedential value – Does not create binding precedent under Article 141 of the Constitution [Para 23].

Decision of the Court – Appeals decided accordingly – Civil Appeal No. 5233 of 2025 (Mohit Kumar) dismissed – Civil Appeal No. 5234 of 2025 (State of U.P.) allowed – Held: Requirement of caste certificate in prescribed State format is justified and non-arbitrary – Rejection of candidature sustained [Paras 24–25].