Motor Vehicles Act – Compensation for Disability – Appellant, a 12-year-old child, suffered permanent disability due to a motor accident – Tribunal awarded Rs. 63,500, later enhanced by the High Court to Rs. 109,500 – Supreme Court emphasized proper assessment of medical evidence and non-pecuniary damages for children – Compensation for child victims should consider long-term impact on life and non-pecuniary damages in addition to treatment costs [Paras 1-25].

Assessment of Compensation – For permanent disability to the whole body, compensation guidelines established as follows:

Disability above 10% and up to 30%: Rs. 3 lakhs

Disability up to 60%: Rs. 4 lakhs

Disability up to 90%: Rs. 5 lakhs

Disability above 90%: Rs. 6 lakhs

For permanent disability up to 10%: Rs. 1 lakh unless exceptional circumstances apply [Paras 12-19].

Precedents – Various precedents considered to establish compensation amounts:

Sapna vs. United India Insurance Co. Ltd. and Another: Rs. 2,00,000 for 90% disability

Iranna vs. Mohammadali Khadarsab Mulla and Another: Rs. 4,00,000 for 80% disability

Kum. Michael vs. Regl. Manager Oriental Ins. Co. Ltd. and Another: Rs. 3,80,000 for 16% disability [Paras 9-11].

Decision – Appeal allowed – Compensation enhanced to Rs. 3,75,000 with 6% interest from the date of petition – Emphasized the need for compensation to cover non-pecuniary damages and long-term impact on child victim’s life [Paras 13-14].

Motor Vehicles Act – Breach of Conditions – Appellant challenged the absolution of insurer’s liability under Section 149(2) for driver possessing a fake licence – Contention on insurer’s obligation to prove willful breach by insured – Supreme Court held that merely showing licence was fake is insufficient – Insurer must prove insured’s negligence in verifying licence authenticity – Emphasized that insurer remains liable to third parties even if driver’s licence is fake, with potential recovery from insured [Paras 1-10].

Verification of Licence – Owner's Responsibility – Clarified owner's duty is to verify the existence and facial validity of licence, not its authenticity from issuing authority – Exception when owner is made aware of licence’s potential falsity and fails to act – Liability of insurer in absence of owner's willful negligence [Paras 4-9].

Precedents – Considered several precedents to establish insurer's liability:

United India Insurance Company Ltd. vs. Lehru and Others (2003): Established insurer's inability to avoid liability solely on grounds of invalid licence without proving willful breach by insured.

National Insurance Co. Ltd. vs. Swaran Singh and Others (2004): Affirmed insurer must establish insured's willful negligence to deny liability.

National Insurance Co. Ltd. vs. Laxmi Narain Dhut (2007): Reiterated insurer’s burden to prove insured’s failure to exercise reasonable care in verifying licence [Paras 5-8].

Decision – Appeal allowed – Held – Insurer liable to indemnify appellant despite driver possessing fake licence – Rejected insurer’s defence due to lack of proof of insured's willful negligence – Directed insurer to cover compensation already paid to claimants [Paras 10-11].

Motor Vehicles Act – Compensation for Death of Minor – Appellants, parents of a 10-year-old boy, claimed compensation under Section 166 for death caused by rash and negligent driving – Tribunal denied compensation; High Court affirmed – Supreme Court reversed, emphasizing compensation assessment for minors based on potential future earnings and contribution to family – Recognized notional income for non-earning persons, multiplier method applied [Paras 1-19].

Negligence – Driver’s Responsibility – Appellant successfully demonstrated accident occurred due to negligent driving – Court emphasized importance of thorough examination of evidence and the necessity for driver to have valid licence – Absence of rebuttal evidence from insurer highlighted [Paras 5-9].

Assessment of Compensation – Multiplier Method – Applied notional income of Rs. 30,000 per annum for deceased child, applying multiplier of 15 considering parents' age – Additional Rs. 50,000 awarded under conventional heads (loss of love and affection, funeral expenses) – Total compensation fixed at Rs. 5,00,000 with 9% interest from application date [Paras 18-19].

Decision – Appeal allowed – High Court and Tribunal judgments set aside – Compensation of Rs. 5,00,000 awarded to appellants with 9% interest per annum from date of claim application until payment [Para 19].

Constitutional Law – Promotion and Service Regularization – Respondent, initially appointed on ad-hoc basis as Engineering Assistant (Mechanical) and subsequently promoted to Inspector of Works and then Junior Engineer, contended for regularization of his ad-hoc service for promotion purposes – Supreme Court emphasized that 8 years of regular service as Assistant Engineer is mandatory for promotion to Executive Engineer as per Recruitment Rules – Ad-hoc service not to be counted towards this requirement – High Court's sympathetic direction to appoint respondent despite non-fulfillment of statutory requirements deemed unsustainable [Paras 1-9].

Ad-hoc Appointments – Legal Implications – Clarified that continuous ad-hoc service, even if necessitated by administrative exigencies, does not equate to regular service under Article 309 – Court stressed adherence to recruitment rules and statutory provisions for public service promotions [Paras 2-5].

Judicial Review – Limitations – High Court's order based on judicial sympathy, directing respondent’s promotion as a special case without setting a precedent – Supreme Court highlighted the need for strict compliance with statutory requirements, setting aside High Court's decision for contravening established recruitment rules [Paras 7-9].

Decision – Appeal allowed – High Court judgment set aside – Tribunal's decision dismissing the respondent's claim upheld – Emphasized that judicial sympathy cannot override statutory provisions for public service promotions [Para 9].

Criminal Law – Murder vs. Culpable Homicide – Appellant State challenged alteration of conviction from Section 302/34 to Section 304 Part II IPC – Convicts accused of killing deceased during a molestation attempt – High Court reduced conviction considering the act was in heat of passion without premeditation – Supreme Court disagreed, emphasized evidence showed planned act, sufficient time to cool off before fatal assault – Held convicts acted with common intention, shared responsibility under Section 34 IPC [Paras 1-14].

Exception to Murder – Applicability – Examined Exception 4 to Section 300 IPC – Not applicable as act lacked sudden fight or provocation elements – Convicts had sufficient time after initial provocation before assault, negating heat of passion defense – Reinforced requirement for all Exception 4 ingredients to be met simultaneously for culpable homicide classification [Paras 8-11].

Judicial Review – High Court's Error – Highlighted High Court's error in applying judicial sympathy over statutory requirements – Stressed strict adherence to IPC provisions for maintaining rule of law – Emphasized need for consistent application of legal principles in criminal justice system [Paras 10-14].

Decision – Appeal allowed – High Court’s alteration of conviction set aside – Original conviction under Section 302/34 IPC restored – Convicts to serve remainder of sentence as per trial court's judgment [Para 14].

Service Law – Promotion – Seniority – Respondents appointed in Group III posts of Subordinate Agricultural Services claimed promotion with effect from the date junior was promoted ad-hoc – Tribunal and High Court directed promotions with retrospective effect and notional benefits – Supreme Court held claims hit by delay and laches, as respondents challenged promotion after two decades – Emphasized that stale claims without satisfactory explanation for delay cannot be entertained [Paras 1-23].

Doctrine of Delay and Laches – Representations – Not a Fresh Cause of Action – Court clarified that mere representations or tribunal’s direction to consider representations do not extend limitation period or revive stale claims – Reiterated settled principle that promotion disputes must be addressed promptly – Judicial directions for considering representations cannot furnish new cause of action for delayed claims [Paras 10-15].

Judicial Review – High Court’s Error – Highlighted High Court's error in ignoring significant delay – Stressed on the principle of timely assertion of rights in service matters to prevent unsettlement of settled positions – Emphasized maintaining judicial discipline and avoiding sympathetic but legally untenable orders [Paras 16-22].

Decision – Appeal allowed – High Court and tribunal orders set aside – Tribunal’s direction for retrospective promotion and benefits declared unsustainable – Directed no costs [Para 23].

Constitutional Law – Juvenile Justice – The appellants sought a reinterpretation of Sections 2(l) and 2(k) of the Juvenile Justice Act to exclude juveniles committing heinous crimes from the Act’s protective purview – Petitioners argued for trying such juveniles in regular courts – Supreme Court maintained that established legal principles do not permit third-party intervention in criminal prosecutions, which are primarily state functions – Upheld state responsibility in criminal justice administration [Paras 1-13].

Juvenile Justice Act – Interpretation – Petitioners requested categorization of crimes under Section 2(p) of the JJ Act and trial of juveniles for severe offences in ordinary criminal courts – Court emphasized that juveniles’ culpability should not be determined solely on crime severity – Emphasized the Act’s rehabilitative aim and need for age-appropriate justice – Dismissed plea for alternative punishment under Section 28 for serious crimes [Paras 3-7].

Maintainability – Third-Party Intervention – Addressed whether petitioners have locus standi to challenge statutory provisions affecting juveniles – Reiterated that public interest litigants cannot partake in criminal trials – Court declined to entertain PIL for statutory reinterpretation, directing focus on maintaining established jurisprudence without legislative encroachment [Paras 5-11].

Decision – SLP dismissed – Held – Juvenile Justice Board to proceed with existing statutory framework – Supreme Court underscored necessity for legislative reforms through proper channels rather than judicial overreach – Court declined to reinterpret JJ Act provisions, affirming juvenile protective measures [Para 14].

Land Acquisition – Delay and Condonation – Appellants’ lands acquired under Section 4(1) notification dated 23.4.1994 – Award u/s 11 made on 23.10.1997 – Appellants sought enhanced compensation u/s 18(1), reference court awarded increased compensation on 28.2.2002 – High Court appeals filed after 5½ years, condonation of delay sought due to one appellant’s illness – High Court dismissed appeals for lack of sufficient cause for delay – Supreme Court emphasized strict application of limitation laws, found no justifiable grounds to condone significant delay [Paras 1-16].

Constitutional Law – Article 14 – Doctrine of Equality – Appellants argued discriminatory treatment as similar delays had been condoned in other cases – Court clarified Article 14 does not perpetuate illegality or mistake – Highlighted principle that each case must be assessed independently on merit of “sufficient cause” for delay, previous erroneous condonations do not establish a right [Paras 7-8].

Judicial Interpretation – Sufficient Cause – Court reiterated that "sufficient cause" must be adequate, bona fide, and not due to negligence – Emphasized requirement for detailed explanation and active pursuit of legal remedies without undue delay – Cited precedents underscoring that limitation laws aim to ensure legal certainty and diligence in litigation [Paras 9-13].

Decision – Appeals dismissed – High Court’s rejection of condonation upheld – Reaffirmed strict adherence to statutory limitation periods unless substantial and adequate reasons justify delay [Para 16].

Land Acquisition – Limitation for Re-determination – Appellants' land acquired under Sections 4 and 6 in 1994-95; award made on 14.12.1995 – Appellants filed applications under Section 28A after the reference court’s award dated 3.4.2006 – Application for re-determination filed on 18.7.2006 rejected for being 4 days late – Supreme Court affirmed strict adherence to statutory limitation periods, rejecting argument for extension based on date of knowledge of award [Paras 1-14].

Statutory Interpretation – Strict Construction – Section 28A requires application within 3 months from the date of the court's award, excluding time for obtaining a copy – Court emphasized literal interpretation of unambiguous statutory language – Rejected arguments for liberal interpretation or extension of limitation based on personal hardship or equitable grounds [Paras 8-13].

Precedent – Consistent Application – Affirmed previous rulings that limitation for filing under Section 28A starts from award date, not from the date of knowledge – Reiterated that law of limitation aims to ensure legal certainty and diligence, and courts have no discretion to extend statutory periods on equitable grounds [Paras 10-13].

Decision – Appeals dismissed – High Court’s decision to reject applications for re-determination under Section 28A upheld – Reaffirmed the principle that inconvenience or hardship cannot override clear statutory mandates [Para 14].