Limitation Law - Delay Condonation – Re-litigation on Identical Grounds – Delay Not Condoned – Respondents' explanation for 1116 days delay in filing appeal under Order XLI CPC was previously adjudicated under Order IX Rule 13 CPC and dismissed by High Court and Supreme Court – Re-urging same grounds held to be impermissible and an abuse of process – Repetition of insufficient cause cannot warrant fresh consideration under a different provision [Paras 27-30].

Applicability of Precedent – Misapplication of N. Mohan Case – Condonation Set Aside – High Court erroneously relied on N. Mohan v. R. Madhu (2020) 20 SCC 302 to condone delay – Distinguished on facts as defendants in present case had appeared, filed written statements, and later defaulted, unlike in N. Mohan where summons were not served – Hence, reliance misplaced [Paras 25-26].

Concurrent Remedies – Section 96(2) Appeal and Order IX Rule 13 Application – Not Mutually Exclusive but No Duplication of Grounds – Though legally maintainable to file appeal under Section 96(2) post Order IX Rule 13 rejection, same explanation for delay cannot be recycled without new material – Filing under another provision does not reset limitation clock without distinct cause [Para 30].

Limitation Law – Strict Interpretation – Generosity Not Permitted – Limitation law requires strict adherence and cannot be relaxed merely for equity – Absence of bona fide explanation bars condonation – Reference made to Popat Bahiru Goverdhane (2013) 10 SCC 765 and Maniben Devraj Shah (2012) 5 SCC 157 – Delay must be justifiable on record and not based on liberal approach [Paras 28-32].

Decision – Delay Not Justified – Appeal Allowed – Impugned High Court order dated 25.04.2023 condoning delay set aside – Civil Appeal allowed and delay condonation rejected – Appeal disposed with no costs [Paras 34-36].

Criminal Law – Bail – NDPS Act and UAPA – Bail Denied – Appellant accused of coordinating smuggling of Afghan-origin heroin via fictitious firm – Despite absence of contraband recovery from the appellant’s consignment, evidence of meetings, proxy control of firm, and documentary manipulation established prima facie complicity – Court held that the cumulative material justified continued custody under Section 43D(5) of UAPA [Paras 5-16, 26-28].

Liberty – Preventive Detention – Article 21 – No Automatic Bail for Long Incarceration – Though pre-trial detention cannot be punitive, continued custody upheld due to nature of offence, flight risk, and pending examination of key witnesses – Court permitted renewal of bail plea after six months or upon substantial progress in trial [Paras 24, 30, 33].

Witness Protection – Risk of Tampering – Bail Refused – One witness found dead on date of deposition; two untraceable – High risk of witness influence or elimination justified rejection of bail at interim stage – Directions issued for accelerated witness examination [Paras 30-31, 35(ii)-(iii)].

UAPA – Section 43D(5) – Prima Facie Satisfaction Sufficient – Bail denied under UAPA does not require proof beyond reasonable doubt – Material must demonstrate plausible complicity without being inherently unreliable – Held: Prosecution narrative not improbable at current stage [Paras 23-24, 27].

Terror Financing – Allegation Deferred – No Conclusive Evidence – Though UAPA invoked, Court declined to classify appellant’s actions as terror financing without strong evidentiary foundation – Allegations too premature to attract such a finding [Para 34].

Decision – Bail Rejected – Appellant not entitled to regular bail presently – Liberty granted to reapply after six months or significant trial progress – Trial court directed to expedite proceedings and examine core witnesses without interruption [Paras 33, 35(i)-(iv)].
 

Criminal Law - Cruelty and Dowry Demand – Conviction under Section 498A IPC and Section 4 of DP Act – Conviction Set Aside – The appellant was convicted based on vague allegations of mental and physical cruelty and dowry demands – The complainant failed to substantiate claims with specific instances or medical evidence – No corroborative or independent testimony beyond statements of complainant and her father – Held: General and omnibus allegations insufficient to sustain conviction under criminal law – Conviction under Section 498A IPC and Section 4 of the DP Act set aside [Paras 3.4, 4, 9-11].

Abuse of Protective Legislation – Caution Against Misuse – Judicial Concern Noted – The Court noted with concern the trend of implicating entire families of husbands without specific allegations – Held: Courts must guard against misuse of Sections 498A IPC and 3/4 of the DP Act – Observed tendency to criminally prosecute distant relatives and aged parents without evidence [Para 13].

Scope of Revisional Jurisdiction – Duty to Re-examine Evidence – High Court's Summary Dismissal Criticized – The Supreme Court found that the High Court, while exercising revisional powers, failed to apply judicial mind or consider evidence on record – Held: The High Court should have scrutinized the correctness of lower court judgments more thoroughly [Paras 7, 12].

Decision – Appeal Allowed – Conviction Set Aside – The Supreme Court allowed the appeal, acquitted the appellant of all charges under Section 498A IPC and Section 4 of the DP Act – Held: Continuing prosecution would amount to abuse of process of law [Paras 14-15].
 

PIL - Environmental Protection – Illegal Tree Felling in TTZ – Court-Mandated Penalties – Enforced - The Court exercised powers under Article 142 of the Constitution to impose graded penalties for illegal felling of trees in the Taj Trapezium Zone – Directed recovery of fines ranging from ₹5,000 to ₹25,000 per tree, seizure of timber, and mandatory compensatory plantation – Lok Adalats and District Courts also directed to adopt same measures – Held: Deterrent legal mechanism essential for preserving ecological sanctity of TTZ area surrounding the Taj Mahal [Paras 4–6].

Tree Census – Monitoring and Funding – Time-Bound Compliance Ordered - Forest Research Institute directed to file progress affidavit by August 2025 – Ordered to approach the State of Uttar Pradesh and Rajasthan for phased funding – States directed to act without delay – Held: Tree census essential to sustainable forest management and monitoring illegal tree removals [Paras 7–11].

Court Monitoring – Enforcement of CEC Recommendations – Applicant’s Plea Rejected - The Court declined to entertain deviations from Central Empowered Committee’s recommendations – Directed full compliance from the applicant concerned – Held: Judicial deference to expert bodies crucial in environmental governance [Para 12].

Decision – Tree Felling Penalties Enforced – Tree Census Continued – Case Adjourned - Directed District Courts under Allahabad and Rajasthan High Courts to implement penalty framework – Tree census to be monitored closely – All connected interlocutory applications listed for follow-up [Paras 6, 11–15].

Service Law – Absorption of Employees – Right to Pension – Functional Integration – Absorbed Employees Entitled to Pension – Absorbed employees from dissolved electricity co-operative societies claimed parity in pension benefits with regular MPSEB employees – Supreme Court held that once absorbed, these employees are entitled to pension under MPSEB from date of absorption – Pre-absorption service not countable towards qualifying pensionable service – Functional integration post-merger mandates uniform treatment – Denial of pension to similarly placed employees violates equity and parity principles [Paras 4-6, 18-23].

Pension – Qualifying Service – Interpretation of Rules – Pre-Absorption Service Not Pensionable – Under MP Civil Services (Pension) Rules, 1976, only service rendered under government-regulated terms qualifies – Thus, pre-absorption service in co-operative societies, which were not under state regulation, cannot be counted – Court applied Rule 3(p), 12(2), and 13(1) to hold that pension is admissible only from date of absorption [Paras 24-25].

Article 142 – Equitable Relief – Uniformity Mandated – Apex Court exercised Article 142 to ensure no discrimination among similarly placed employees – Despite High Court Full Bench judgment denying pension to some absorbed employees, Court granted parity to all absorbed society employees w.e.f. date of absorption – Ensured uniform and equitable resolution of complex and long-pending litigation [Paras 17, 26].

Decision – Appeals Partially Allowed – Appellants entitled to pension from date of absorption into MPSEB, but pre-absorption service not to be counted for qualifying period – Impugned orders modified accordingly – Respondents directed to implement and pay arrears within four months [Paras 25-26].

Consumer Law – Flat Allotment Dispute – Execution of Agreement – MOFA – Supreme Court Upholds Alternate Flat Possession – Builder cancelled allotment despite part payment and failed to execute agreement – NCDRC directed execution with compensation, later apartment found alienated in violation of stay – Supreme Court allowed substitution with similar flat, directed execution under MOFA – Non-compliance remedied through quantified financial directions – Builder to receive specified payment in full satisfaction of claims [Paras 1-6, 13-14].

Real Estate – Breach of Interim Orders – Apartment Alienated Despite Stay – Appellant alienated flat after stay against third-party rights – NCDRC rejected modification citing contempt – Supreme Court allowed alternate allotment due to absence of contempt petition, stressing equity over technicality [Paras 2, 4, 6].

Equitable Relief – Adjustment of Dues – Final Settlement Ordered – Due to builder’s delays, nondisclosure of carpet areas, and unilateral action, Court quantified dues at Rs. 1.40 crore – Included interest, taxes, and miscellaneous charges in lieu of further claims up to possession date – Post-possession dues to be borne by buyer [Paras 10-14].

Decision – Miscellaneous Application Disposed – Respondent directed to pay Rs. 1,40,71,000 within eight weeks – Parties to execute sale deed within two months thereafter – Costs of registration to be borne by respondent – Structural modification restrictions lifted [Paras 14-15].

Writ - Designation of Senior Advocates – Validity of Indira Jaising Guidelines – Guidelines Partially Overruled – Supreme Court revisits framework laid down in Indira Jaising-1 and Indira Jaising-2 – Held: 100-point assessment and interview system found unworkable and subjective – Paragraph 73.7 of Indira Jaising-1 deleted – New rule-based regime to be framed by all High Courts and Supreme Court [Paras 74-77, 87(i)-(v)].

Interview System – Constitutionality and Practicality – Interview Abolished – Interview/interaction allocating 25 points deemed insufficient to assess personality and dignity of senior advocates – Held: Brief interviews fail to uphold professional dignity and cannot reliably determine integrity or competence [Paras 67-70].

Inclusivity and Trial Court Advocates – Designation Should Not Be Monopolized – Emphasis on Diversity – Court highlights the need to include advocates from Trial and District Courts and specialized tribunals – Held: Standing at Bar not limited to appearances in Constitutional Courts – Full Court must ensure diverse and equitable designations [Paras 55, 78-79].

Role of Bar Members in Assessment – Committee Composition Modified – Participation of Advocates in Decision-Making Removed – Court disapproves inclusion of bar members in Permanent Committee’s scoring – Held: Decision-making must rest solely with the judiciary as per Section 16(2) of Advocates Act [Paras 63-64].

Applications for Designation – Permissible Practice – Consent Sufficient – Court upholds application-based system for practical reasons – Held: Filing application amounts to implied consent; deserving advocates may still be designated suo motu with consent [Para 77].

Secret Ballot – Discretion of Full Court – Use Not Prohibited – Held: Voting by secret ballot is neither mandatory nor barred – Full Court empowered to decide voting method as per facts of each case [Para 81].

Rule-Making Mandate – Uniform Framework Required – High Courts Directed – All High Courts directed to frame rules within four months – Rules must ensure transparency, fairness, periodic review, and bar-wide consultation [Paras 83-84, 87(ii)].

Decision  – Indira Jaising-1 Para 73.7 Deleted – New Rules Required – Existing processes under Indira Jaising regime may continue; no new applications to be processed without rules framed under this judgment – Applications in current matters allowed and disposed [Paras 87-90].

Criminal Law - Forgery of Court Record – Tampering After Conclusion of Proceedings – Section 195 CrPC Not Applicable – Appellant accused of fabricating and replacing court records in a civil suit after it was withdrawn – Documents were altered from the record room post-disposal – Held: Since forgery was committed after withdrawal of suit and documents were not in “custodia legis,” Section 195 CrPC does not apply – FIR and prosecution not barred [Paras 12-17].

Jurisdiction to Prosecute – Court's Power to Take Cognizance – Valid Despite Absence of Presiding Officer's Complaint – Appellant argued that no court complaint was filed under Section 340 CrPC – Supreme Court held that FIR was lodged at behest of High Court following vigilance inquiry and hence satisfies requirement under Section 340(3) – Filing by administrative authority valid in such context [Paras 11, 17].

Separate Offences – Distinction Between Pre- and Post-Proceeding Forgery – Alleged offences bifurcated into two: (1) tampering with suit records post-withdrawal, and (2) using forged decree in execution – Held: Tampering after case closure does not impact justice administration – Use of forged decree in execution also occurred prior to production, thus outside Section 195 bar [Paras 10, 13-14].

Misuse of Civil Process – Execution Petition Based on Fabricated Decree – Fraudulent Intent Evident – Appellant withdrew civil suit unconditionally but later filed execution petition based on falsified decree – Bogus documents inserted into record; cheques dishonoured – Court found clear intent to harass and extort money from defendant by fraudulent legal process [Paras 2-6, 12-15].

Decision – Appeal Dismissed – Criminal Proceedings Valid – High Court Ruling Affirmed – Supreme Court upheld High Court's refusal to quash FIR and proceedings – Held: Section 195 CrPC not a shield for post-proceeding forgery – Appeal dismissed as devoid of merit [Paras 18-19].

Accident Claim - Compensation for Motor Accident – Assessment of Income – Reasonable Estimate for Unskilled Worker – Compensation Enhanced - The claimant, a 25-year-old unskilled worker, became bedridden due to an accident while traveling in his employer’s truck – Tribunal assessed income at Rs. 4,500 per month and awarded Rs. 16 lakhs – High Court enhanced income to Rs. 6,000 and compensation to Rs. 25.83 lakhs – Supreme Court applied the principle from Ramachandrappa and Pranay Sethi and accepted Rs. 9,000 as monthly income, applying 140% future prospects and a multiplier of 18 – Held: Loss of future income computed at Rs. 27,21,600, medical expenses of Rs. 2,70,000 and Rs. 6,00,000 for pain and suffering awarded – Total compensation Rs. 35,91,600 [Paras 2, 4-5].

Insurance Liability – Passenger in Goods Vehicle – Contention of Policy Exclusion Not Entertained – No Appeal by Insurer – The insurer argued policy exclusion for goods vehicle passengers – Held: Argument rejected as insurer did not challenge the Tribunal’s finding and no appeal was filed by the insurer – Supreme Court declined to entertain the contention in an appeal for enhancement filed by the claimant [Para 3].

Permanent Disability – Assessment Based on Medical Evidence – 100% Functional Disability Accepted - Medical expert testified disability at 90%, but functionally declared 100% disabled due to vegetative state – Doctor’s cross-examination did not discredit the evidence – Held: High Court right in treating disability as 100% functional for compensation purposes [Para 4].

Final Relief – Modification of Award – Interest and Disbursement Direction - Supreme Court allowed the appeal and modified the award – Directed disbursal of enhanced compensation with 8% interest after deducting previously paid amounts – Payment to be made to claimant's account within two months [Paras 6-7].