Land Acquisition – Challenge to Acquisition Proceedings – Appeals challenging the land acquisition by RIICO for industrial development – Respondent society sought release of land claiming discrimination as other similar lands were released – Supreme Court held that the Respondent society's purchase post-Section 4 notification was void – Agreement to sell did not create any title – Held that the acquisition proceedings attained finality, and the High Court's order releasing the land was erroneous – High Court's failure to consider objections and lack of comparative analysis of facts led to the reversal of its decision [Paras 1-34].

Article 14 – Discrimination Claim – Court emphasized that Article 14 cannot be used to perpetuate illegality or fraud – Discrimination must be justified with detailed comparable cases – Found that Respondent society failed to provide sufficient evidence to claim discrimination – High Court's observations were not based on the material on record [Paras 12-16, 30].

Administrative Law – Validity of Circulars and Policies – Court held that executive instructions cannot override statutory laws – Circulars issued by the state for releasing acquired land were inconsistent with acquisition laws and amounted to fraud upon statutes – Such circulars cannot be considered in the court’s decision [Paras 19, 23, 32].

Decision: Appeals allowed – High Court's order directing the release of land in favor of Respondent society set aside – Land acquisition by RIICO upheld [Paras 34].

Land Acquisition – Cancellation of Allotment – Appellant-RIICO canceled the allotment of land to Respondent due to non-completion of the project within the stipulated time – Supreme Court held that the cancellation was justified as the Respondent failed to complete construction and start production within five years – The lease deed was executed on an "as-is-where-is" basis, placing no obligation on RIICO to provide an access road – High Court's direction to provide access road and restore the canceled allotment was erroneous [Paras 1-34].

Contractual Disputes – Writ Jurisdiction – Court reiterated that contractual disputes should not be resolved through writ jurisdiction – Relief based on contract terms cannot be sought through a writ petition – Emphasized that parties must rely on remedies available under the contract, including arbitration and appeal processes [Paras 12-15, 31].

Interpretation of Contract – As-is-where-is Clause – The lease deed's terms clearly placed the responsibility of developing infrastructure, including access roads, on the Respondent – Interpretation of terms should be literal and as per the contract, not based on implied obligations or equitable grounds – High Court misinterpreted the contractual obligations and the impact of the amendment to Rule 11-A of the Rules, 1959 [Paras 16-22, 27-28].

Decision: Appeals allowed – High Court's order set aside – Order of cancellation of allotment by Appellant-RIICO restored – No costs [Para 32].

Civil Procedure – Substantial Question of Law – High Court's jurisdiction under Section 100 CPC is confined to substantial questions of law – Supreme Court emphasized that the High Court must point out material evidence ignored by the lower courts which would lead to an opposite conclusion – High Court erred in re-evaluating evidence and reversing findings without identifying substantial questions of law [Paras 6-11].

Property Law – Title and Possession – Dispute over the title and possession of land sold without specific khasra numbers – Trial and first appellate courts found the Appellants in lawful possession based on sale deeds and delivery of possession – High Court's reversal on the basis of its own assessment of evidence was beyond its jurisdiction under Section 100 CPC [Paras 3-11].

Judicial Review – Exercise of Jurisdiction – Court reiterated that High Court should exercise its jurisdiction under Section 100 CPC judiciously and within the scope of addressing substantial questions of law only – Emphasized the necessity of adhering to procedural limitations to prevent miscarriage of justice [Paras 11-12].

Decision: Appeals allowed – High Court's order set aside – Judgments and decrees of the trial court and first appellate court dismissing the Respondent's suits restored – Parties to bear their own costs [Para 13].

Land Acquisition – Successive Notifications – Court held that successive notifications under Section 4 of the Land Acquisition Act supersede previous notifications – The third notification dated 26.3.1983 and the corresponding declaration dated 30.5.1983 superseded earlier notifications – As no award was made within the stipulated period under the Act, these notifications lapsed, rendering the acquisition proceedings invalid [Paras 6-9].

Constitutional Law – Right to Property – Appellant was dispossessed from land during the period when the right to property was a fundamental right under Articles 19 and 31A of the Constitution – Court declared the dispossession without valid acquisition as a violation of the appellant's constitutional rights [Paras 9-10].

Eminent Domain – Compensation – Court directed that, given the long lapse of time and development on the land, possession could not be restored – Instead, the Land Acquisition Collector was directed to treat the Section 4 notification as issued on the date of the judgment and make an award within four months – Appellant entitled to all statutory benefits [Paras 11-12].

Decision: Appeals allowed – Judgments of the High Court set aside – Directions issued for making an award and providing statutory benefits to the appellant – In the connected appeal (C.A. No. 203 of 2004), the appeal was dismissed following the same reasoning [Para 13-14].

Motor Vehicles Act – Compensation for Injuries – Appellant, a minor at the time, sustained significant injuries resulting in a permanent disability of 16% to the whole body – Tribunal awarded compensation of Rs. 77,000, which was enhanced to Rs. 1 lakh by the High Court – Supreme Court considered the age, nature of injuries, and long-term impact on the Appellant’s life – Held that higher compensation was warranted [Paras 4-15].

Pecuniary and Non-Pecuniary Damages – Court assessed compensation under various heads including pain and suffering, loss of amenities, and medical expenses – Emphasized the need to adequately compensate for long-term physical and mental anguish, especially given the Appellant’s young age and the impact on future prospects [Paras 8-11, 15].

Judicial Review – Enhanced Compensation – Supreme Court enhanced compensation to Rs. 4 lakhs, considering the lifelong impact of the injuries on the Appellant – Directed the Respondent-Insurance Company to deposit the enhanced amount with interest at 6% per annum from the date of petition till realization [Paras 15-16].

Decision: Appeals allowed – Compensation enhanced to Rs. 4 lakhs with 6% interest – Directions for the release of the amount to the Appellant, who was declared a major by the Court [Paras 15-16].

Recovery of Debts – Tribunal's Rejection of Applications – Canara Bank filed an application before the Debt Recovery Tribunal for the recovery of debts – Appellant sought production of documents which the Tribunal rejected as attempts to delay proceedings – Tribunal's order was challenged under writ jurisdiction instead of the statutory appeal provided by the Act – High Court erred in interfering under Article 226 when an alternative remedy was available under Section 20 of the Recovery of Debts Due to Banks and Financial Institutions Act [Paras 1-9].

Jurisdiction of High Court – Article 226 and Statutory Remedies – Supreme Court held that powers under Article 226 should not be invoked when a statutory remedy is available unless there is a statutory violation or the action is arbitrary and unreasonable – Emphasized the purpose of Debt Recovery Tribunals for expeditious resolution and noted the delays caused by unwarranted writ petitions [Paras 7-10].

Decision: Appeals dismissed – High Court's interference under Article 226 was not justified – Emphasized reliance on statutory appeals provided under the Act for resolving such disputes [Para 10].

Representing Advocates:

S. Thananjayan for the Appellant.

Public Employment – Judicial Review of Selection Process – Appeal against the Delhi High Court’s decision finding fault with the selection process for Security Assistants Grade-II – Supreme Court emphasized the limited scope of judicial review in such matters, highlighting that courts should not impose their own standards over those set by the selecting authority – Uniform application of criteria deemed fair and non-discriminatory [Paras 1-29].

Selection Criteria – Marks Allocation – Court upheld the splitting of interview marks (25 marks in total) to include marks for desirable qualifications such as NCC/Sports and Computer certificates – Call letters had informed candidates about the importance of these certificates, negating any claims of arbitrariness or prejudice [Paras 8-25].

Precedent and Consistency – Earlier High Court decisions in similar cases (e.g., Mahesh Kumar case) upheld similar selection processes – Supreme Court reiterated the importance of consistency and the need to avoid re-evaluating settled procedural norms unless there is a clear statutory violation [Paras 19-20, 28].

Decision: Appeals allowed – High Court’s judgments set aside – Original selection process upheld as fair and consistent with advertised requirements – No costs awarded [Para 29].

Promotion – Seniority-cum-Merit – Appellant’s claim for promotion to the post of Battalion Commander rejected – Court upheld the principle that promotion based on "seniority-cum-merit" requires the candidate to meet a minimum merit benchmark – Appellant failed to meet this benchmark due to average ACRs and ongoing criminal proceedings during the relevant period [Paras 1-19].

Criteria for Promotion – Executive Instructions – Validity of executive instructions fixing a benchmark for promotion – Instructions applied retrospectively to vacancies arising before their issuance – Court held such criteria to be valid and within the employer’s policy-making domain – Appellant’s challenge to the instructions was dismissed as they codified existing legal principles [Paras 16-18].

Judicial Clean Hands Doctrine – Court noted appellant’s failure to disclose ongoing criminal proceedings, affecting the credibility of his claims – Emphasized the importance of clean hands for equitable relief [Para 19].

Decision: Appeals dismissed – High Court’s order upheld – Appellant’s challenge to promotion process and executive instructions found meritless [Para 20].

Criminal Law – Conviction and Sentencing – Appellant convicted under Section 324 IPC for causing injuries with a gunshot – High Court acquitted appellant under Sections 307 and 380 IPC but maintained conviction under Section 324 IPC – Appellant’s contention that the conviction under Section 324 IPC was not proven beyond reasonable doubt due to non-recovery of the weapon was rejected – Evidence including witness testimonies and medical reports supported conviction [Paras 3-13].

Sentencing – Appropriate Sentence – Supreme Court emphasized the principle of proportionality in sentencing – Considering the nature of the injury, the appellant's age, and the lapse of time since the incident, the Court reduced the sentence from three years to one year rigorous imprisonment and imposed a compensation of Rs. 20,000 to be paid to the victim under Section 357(3) CrPC [Paras 14-24].

Decision: Appeal disposed of with modification in sentence – Conviction under Section 324 IPC upheld – Sentence reduced to one year rigorous imprisonment – Compensation of Rs. 20,000 to be paid to the victim [Para 25].