Maternity Leave – Section 5 and 27 of the Maternity Benefit Act, 1961 - FR 101(a) and Constitutional Interpretation – Maternity Leave Granted – The appellant, a government teacher in Tamil Nadu, sought maternity leave for her first child born from her second marriage – The leave was denied on the ground that she already had two children from her first marriage – Supreme Court held that since the two children are in custody of her ex-husband and the present childbirth is from her subsisting marriage, the appellant is entitled to maternity benefits – Restriction under FR 101(a) must be interpreted liberally in light of constitutional rights and reproductive autonomy [Paras 4.1, 6, 9-11, 34-37].

Reproductive Rights – Article 21 of the Constitution – Maternity Leave as Reproductive Right – Recognized as a facet of the right to life – The Court emphasized that reproductive autonomy includes the right to bear children and access maternity benefits – Maternity leave is not merely a statutory right but part of the broader right to dignity and health under Article 21 [Paras 13-14, 28-31].

Maternity Benefit Act – Guidance in State Service Rules – Though not directly applicable to State Government employees, the provisions of the Maternity Benefit Act provide beneficial guidance – Supreme Court acknowledged that the Act allows maternity benefits even for more than two children, though with a reduced leave period, reinforcing the liberal interpretation required for FR 101(a) [Paras 18-20, 33].

International Norms – Relevance of CEDAW and International Covenants – The judgment draws heavily on international instruments such as CEDAW and the Universal Declaration of Human Rights to underscore that maternity protection is a human right – Reinforces the obligation of the State to provide maternity benefits as part of respect for international law [Paras 22-27].

Final Decision – Division Bench Judgment Set Aside – Maternity Leave Granted – Supreme Court set aside the Division Bench’s judgment of the Madras High Court and directed the State to release maternity benefits under FR 101(a) to the appellant within two months [Paras 36-38].

Contract Law – Electricity Act - Change in Law – Evacuation Facility Charges – Restitution Principle – Compensation Upheld – Coal India Limited issued a notification dated 19.12.2017 imposing Evacuation Facility Charges (EFC) – Adani Power informed the appellants the next day, claiming this constituted a change in law – APTEL affirmed change in law status and awarded compensation from the date of the notification along with carrying cost at LPS rates – Supreme Court upheld the finding and reaffirmed that the compensation must be provided based on restitutionary principles to restore the economic position of the generator as if the change in law had not occurred [Paras 3–7, 18–21].

Supplementary Bill – Necessity for Prior Issuance – Not a Prerequisite for Compensation – The appellants contended that relief could not be claimed without first raising a supplementary bill – Supreme Court rejected the argument, holding that a supplementary bill is to be raised after adjudication of the change in law event, and cannot preclude entitlement – Held: The absence of a prior supplementary bill does not affect the generator's right to compensation [Paras 24–26].

Interpretation of Article 10.5.1 of PPA – Change in Law via Notification vs Judicial Interpretation – Dispute centered on whether Article 10.5.1(i) or (ii) applied – Court clarified that since the change arose directly from a governmental notification (and not judicial interpretation), Article 10.5.1(i) applied – Held: Notification by Coal India Ltd. triggered compensation from its effective date, not from adjudicatory recognition [Paras 22–25].

Carrying Cost – Compound Interest Justified – Follows Restitutionary Principle – The Court upheld APTEL’s direction to award carrying cost at Late Payment Surcharge (LPS) rates, on a compound interest basis – Found consistent with prior judgments and the economic rationale behind restoring the generator’s position – Reaffirmed that contractual interpretation must reflect the intention of the parties and established jurisprudence [Paras 27–28].

Final Decision – Appeal Dismissed – APTEL’s Award Sustained – Supreme Court held that no substantial question of law arose beyond that already settled in prior decisions – No interference warranted – Appeal dismissed with costs [Paras 28–29].

Service Law - Organised Group-A Service Status – Full Recognition of CAPFs as OGAS – DoPT OM Binding – High Court Error – The Court clarified that its earlier decision in Harananda (2019) was not limited to NFFU but affirmed full OGAS status for CAPFs – Held: Once declared OGAS, CAPFs must be treated as such for all cadre matters – High Court's failure to consider the DoPT OM dated 12.07.2019 rendered its ruling flawed [Paras 32, 36, 37].

Cadre Review and Service Rules – Mandate to Complete by Timeline – Direction Issued – The Court mandated completion of cadre review and amendment of recruitment rules within six months – DoPT to decide within three months after receiving MHA’s report – Held: Officers must be heard during review; cadre structure must reflect OGAS norms [Paras 45(1)-(4)].

Deputation of IPS Officers – Progressive Reduction Ordered – Stagnation Acknowledged – Court Recognized Need for Reform - The practice of deputation of IPS officers in senior ranks of CAPFs found to cause stagnation among cadre officers – Held: While policy matters lie within executive domain, excessive deputation undermines service mobility – Directed gradual reduction of deputation posts up to SAG within two years [Paras 15, 41, 45(5)].

Constitutional Equality – Unequal Treatment Violates Articles 14 and 16 – Mandate for Parity – Disparity in promotional norms and denial of OGAS benefits to CAPF officers despite equal standing held to violate fundamental rights – Held: Government cannot pick and choose implementation post-OGAS declaration – Parity must follow recognition [Paras 16.7, 19.2, 23, 24.1].

Policy Implementation – OM dated 12.07.2019 Has Legal Consequence – Government Bound – DoPT’s 2019 OM confirming CAPFs' OGAS status was held conclusive and binding – Held: Benefits such as NFFU, NFSG, cadre restructuring, and rule amendments are legal consequences of OGAS recognition [Paras 33-36, 43].

Decision – Civil Appeals Allowed – High Court Ruling Set Aside – Supreme Court allowed the appeals, set aside the High Court’s limited interpretation of OGAS status, and directed implementation of full OGAS benefits, cadre review, and structural changes – IPS deputation to be limited progressively [Paras 45-47].

Civil Law - Impleadment – Deletion of Name – Order I Rule 10 CPC – Deletion Denied – Appellant impleaded as legal heir during execution but raised no objection at that stage – Later attempt to seek deletion held barred by res judicata – The Court held that once a party has been impleaded after due inquiry without objection, it is not open to them to challenge it years later, particularly where they participated in proceedings without protest – The power under Order I Rule 10 cannot be used to reopen concluded decisions [Paras 46–55].

Res Judicata – Subsequent Objection to Impleadment – Barred – Doctrine Applied to Different Stages of Same Proceeding – Once impleadment order attained finality, re-agitating the issue by Order I Rule 10 application was impermissible – Trial Court's decision deemed binding absent appellate interference – Doctrine ensures finality and avoids procedural abuse [Paras 53–57].

Tenancy Rights – Protection Under Kerala Rent Control Act – Claim Rejected – Appellant claimed tenancy derived from father and sought protection from eviction – Court found no credible evidence of tenancy or possession and held such claim to be an afterthought aimed at obstructing execution – Concurrent findings below upheld [Paras 61–63].

Specific Performance – Possession Implicit in Decree – Relief of Possession Not Expressly Granted – Still Executable – Where seller was in possession, court held that decree for specific performance implicitly included delivery of possession – Follows established law under Section 55 of the Transfer of Property Act and precedents like Babu Lal v. Hazari Lal – Thus, execution could proceed without separate possession order [Paras 64–65].

Decision – Appeal Dismissed – Supreme Court affirmed High Court and Trial Court decisions – Deletion application found frivolous and part of a dilatory strategy – Decree-holder entitled to possession – Appellant directed to pay Rs 25,000 in costs – Executing Court instructed to hand over vacant possession within two months [Paras 67–68].

Civil Law - Rejection of Plaint – Order 7 Rule 11 CPC – Triable Issues Exist – Rejection Improper – High Court erroneously rejected the plaint holding that it disclosed no cause of action – Supreme Court held that revocation of power of attorney and dispute over subsequent sale deeds raised serious triable issues – Held: Rejection of plaint unwarranted at preliminary stage where pleadings disclosed a cause of action regarding title and invalidity of transactions [Paras 6-14].

Unregistered Documents – Effect on Title Transfer – Agreement to Sell and GPA – No Transfer of Ownership – Sale deeds executed on basis of an unregistered and revoked power of attorney were challenged – Supreme Court reiterated settled law that unregistered agreements to sell or GPA do not create title or transfer rights in immovable property – Held: Respondent could not rely on such documents to validate conveyance [Paras 9-9.4].

Jurisdiction of Civil Court – Dispute Over Title – Not Barred by Revenue Law – Appellants sought declaratory reliefs including title and possession – Revenue court jurisdiction under Section 207 of Rajasthan Tenancy Act held inapplicable – Held: Title disputes lie within exclusive jurisdiction of civil courts; mutation entries do not confer ownership [Paras 10-10.1].

Cause of Action – Distinct Reliefs – Partial Defect Does Not Warrant Full Rejection – Supreme Court reiterated that if even one cause of action is maintainable, the plaint must be tried – High Court erred in treating secondary reliefs as academic and rejecting entire suit – Held: Proper approach is to proceed with suit on triable issues rather than reject in entirety [Para 9.6, 9.7].

Final Decision – High Court Order Set Aside – Plaint Restored – Appeal allowed – Impugned High Court order rejecting plaint quashed – Order of Additional District Judge, Jodhpur restored – Trial Court directed to proceed with suit on merits [Para 14].

Criminal Law - Bail – Custodial Period Considered – Serious Charges under IPC and IT Act – Bail Granted - Petitioner in custody since 05.03.2024 in relation to offences under IPC, IT Act, and Public Examination Act – Supreme Court considered prolonged custody and allowed bail with conditions – Trial Court directed to impose appropriate terms [Paras 2–4].

Conditions of Bail – Cooperation and Conduct Mandated – Petitioner Directed to Comply - Petitioner to cooperate with investigation, avoid influencing witnesses, and not seek adjournments – Directed to provide residence and contact details, and report monthly to Investigating Officer until filing of charge sheet [Paras 5–8].

Request to Restrict Residency – Rejected – No Ban on Staying in Rajasthan - State requested court to prohibit petitioner from residing in Rajasthan during trial – Supreme Court declined to impose such restriction [Para 11].

Final Relief – Bail Granted – SLP Disposed – Court interfered with High Court’s denial of bail and directed release of petitioner on terms set by the Trial Court – SLP disposed accordingly [Paras 4, 12].

Criminal Law  – Sections 303, 307 & 34 of the IPC – Appeal Against Conviction - Suppression of Exculpatory Evidence – Violation of Fair Trial – Acquittal Ordered – Appellants convicted of murder and attempted murder under IPC Sections 302 and 307 based on eyewitness testimonies of PW-4, PW-5, and PW-6 – However, affidavits submitted by PW-5, PW-6, and injured PW-7 during bail proceedings contradicted their court testimonies and exonerated the accused – Investigating Officer admitted knowledge of these affidavits but failed to record supplementary statements or conduct verification – Such non-investigation and suppression violated the right to fair trial guaranteed under Article 21 of the Constitution – Held: Conviction based solely on PW-4's testimony, in absence of corroboration and amid investigative lapses, is unsafe – Conviction and sentence set aside; appellants acquitted [Paras 17-24].

Investigation – Duty of Police – Failure to Conduct Supplementary Investigation – Despite knowledge of contradictory affidavits by eyewitnesses, Investigating Officer did not take steps to verify or rebut them nor documented any attempts to locate the witnesses – This omission compromised the integrity of the investigation and prosecution – The suppression of material evidence affected the fairness of the trial and cast doubt on the credibility of key witnesses [Paras 18-20].

Judicial Practice – Reference to Lower Court Records – Directive Issued – Supreme Court reaffirms that trial court records must not be referred to as “Lower Court Record” – High Courts directed to comply with earlier circular replacing such terminology in court documentation and communication [Para 25].

Decision – Appeal allowed – Judgments of Trial Court and High Court set aside – Appellants acquitted of all charges – Bail bonds cancelled [Para 26].

Mining Leases – Validity of DMF Contribution Policy – Sections 9B & 15A of MMDR Act – Demand Upheld – The appellant, a sand mining lessee, challenged a Demand Notice requiring payment of 10% of the bid amount to the DMF Trust, asserting violation of Section 9B of the 1957 Act – The Supreme Court held that Section 9B is inapplicable to minor minerals due to Section 14 – Further, State power under Sections 15 and 15A to prescribe DMF contributions is valid – The 2017 State Policy was properly exercised under Rule 68 of the 1963 Rules and was binding – Demand found to be in conformity with Rule 10(2) of the 2017 DMF Rules – Appeals dismissed [Paras 5–26].

Environmental Law – Classification of Zudpi Jungle as Forest – Historical Usage vs. Legal Interpretation – Forest Status Upheld – Despite historical non-forestry use and poor vegetative quality, Zudpi Jungle lands recorded as forest in revenue records must be treated as ‘forest’ for the purpose of Section 2 of the Forest (Conservation) Act, 1980 in view of the 12.12.1996 Godavarman order – Held: All such lands, unless de-notified in compliance with legal procedure, continue to attract forest conservation laws [Paras 29, 48, 55, 90].

Environmental Protection – CEC’s 2025 Report – Recommendations Accepted – Extensive data collection and district-wise analysis by CEC validated – Court accepted CEC’s findings and ordered conditional declassification of certain Zudpi lands, while maintaining protection over ecologically sensitive areas – Held: Recommendations in Paras 46(i)–(xii) of 2025 CEC Report accepted in full [Paras 47, 91, 93, 95].

Encroachments and Illegal Use – Regularisation of Post-1980 Allotments Denied – State directed to remove all commercial allotments and encroachments made after 25.10.1980 – Task Forces to be constituted in each district with mandate to act within two years – Held: Post-1980 encroachments and illegal commercial uses of Zudpi Jungle land to be treated as violations requiring eviction [Paras 91(viii)–(ix), 93(viii)–(ix)].

Revenue Records – Correction Allowed for Pre-1996 Allotments – Subject to Conditions – Court permitted reclassification of Zudpi Jungle lands used for non-forest purposes prior to 12.12.1996 via consolidated proposals under Section 2(i) of FC Act – No NPV or compensatory afforestation required – Held: Revenue entries may be updated for such lands, but future use must remain unchanged and hereditary only [Paras 43(A), 47(ii), 91(ii)].

Administrative Procedure – Simplified Framework for Proposal Processing – MoEF&CC and State to develop streamlined application format for diversion proposals in consultation with CEC – Held: Simplified process to be created within three months; CEC empowered to resolve any disputes [Paras 47(iii), 91(iii)].

Sustainable Development – Balancing Ecology and Local Needs – Zudpi Jungle lands provide crucial local community support – However, environmental conservation cannot be compromised – Held: Framework permits limited, justified deletions without precedent effect, balancing Article 48A and Article 21 [Paras 48, 55, 93].

Protected Forests – Unallotted Fragmented Parcels – Mandatory Protection – All unallotted Zudpi Jungle land under 3 hectares not adjoining any forest to be declared ‘Protected Forests’ under Section 29 of Indian Forest Act, 1927 – Held: Fragmented parcels protected from alienation; diversion only possible with Central Government approval under FC Act [Paras 91(v), 93(v)].

Forest Rights – Determination Using Satellite Data – Historical imagery permitted as supporting evidence in Forest Rights Act determinations – Held: Satellite data to assist in identifying traditional use and tenure [Para 91(vii)].

Compensatory Afforestation – Flexibility in Vidarbha Region – Court allowed double-area Zudpi Jungle lands to be used in lieu of non-forest land for compensatory afforestation in five districts – Held: Chief Secretary certificate of non-availability not required; afforestation must comply with MoEF guidelines [Para 91(xi)].

Judgment – Final Order – Applications Disposed – CEC directed to monitor progress of implementation, including forest transfers, eviction drives, and proposal approvals – Held: Applications disposed of in terms of accepted recommendations with liberty to CEC to submit reports and intervene in case of non-compliance [Paras 93–96].