Labour Law - Employees’ Compensation – Functional vs. Physical Disability – Liberal Interpretation – Compensation Enhanced – Appellant suffered multiple finger amputations in dominant hand while operating a forging machine – High Court restricted disability to 34% based on Schedule I – Supreme Court held that when multiple fingers are injured, functional impairment may exceed physical loss – Liberal interpretation required in beneficial legislation like Employees’ Compensation Act – Functional loss determined at 50% [Paras 6-10].

Schedule I Interpretation – Aggregated Disability – Judicial Discretion Permitted – Loss across multiple fingers warrants broader assessment – Supreme Court held that aggregation of injuries under Schedule I does not prevent judicial assessment of actual functional impairment – Statutory percentage of loss (37%) revised upward to reflect practical inability to perform skilled job – Absence of medical certificate not fatal in clear injury cases [Paras 8-10].

Compensation Calculation – Interest and Penalty – Revised Disability Accepted – Supreme Court recalculated compensation at ₹3,20,355 with 50% assessed disability – Directed payment of 12% interest from date of accident and 50% penalty (₹80,088.75) – Any excess amount due to High Court’s lower calculation to be paid with interest and penalty [Para 11].

Decision – Appeal Allowed – High Court’s reduction in disability percentage set aside – Compensation restored as per enhanced disability at 50% – Interest and penalty awarded – Directions issued for balance payment, if any, by employer [Paras 11-12].
 

Civil Law - Order VII Rule 11 CPC - Rejection of Plaint – Limitation – Mixed Question of Law and Fact – Rejection Set Aside – The plaint challenged alienation of property by appellant’s father acting beyond authority of power of attorney – High Court rejected plaint under Order VII Rule 11(d) CPC holding the suit was barred by limitation – Supreme Court held that since the appellant pleaded specific date of knowledge of alleged fraudulent transactions, limitation became a mixed question of law and fact necessitating trial – Rejection of plaint at preliminary stage was legally unsustainable [Paras 11-13].

Power of Attorney – Scope of Authority – Unauthorized Alienation – Triable Issue – The plaint averred that appellant’s father was granted limited authority to manage construction and not to alienate property – Sale executed by father in favour of granddaughter was beyond scope of power – These assertions raised serious issues of misuse and fraud – Not appropriate to reject suit at threshold without evidence [Paras 12, 14].

Specific Relief Act – Declaratory Suit with Consequential Relief – Maintainability – Court reiterated that suit seeking declaration with consequential injunction is not simpliciter – Suit cannot be dismissed solely because one relief appears barred or defective – Full pleadings and evidence required to determine maintainability [Paras 8.1, 13].

Decision – Appeal Allowed – High Court’s judgment rejecting plaint set aside – Trial Court’s refusal to reject plaint affirmed – Suit restored for trial – Trial Court directed to proceed uninfluenced by High Court's prior observations [Para 15-16].
 

Accident Claim - Motor Accident Compensation – Notional Income for Unskilled Worker – Enhanced Based on Precedent – Tribunal awarded compensation assuming monthly income of ₹15,000; High Court reduced it to ₹3,700 based on minimum wages – Supreme Court held ₹7,500/month as reasonable notional income for a coolie in 2010 based on Ramachandrappa v. Royal Sundaram Alliance principle with future prospects at 40% – Loss of dependency recalculated accordingly [Paras 7-9].

Consortium – Entitlement to All Dependents – Pranay Sethi and Somwati Followed – Court reiterated that in addition to spousal consortium, parental and filial consortium must be granted – ₹40,000 awarded to each parent and child – Total consortium compensation revised to ₹2,00,000 for five dependents [Paras 10-11].

Insurance Liability – Driver’s License Invalid for Transport Vehicle – Recovery Permitted – Though license was valid for non-transport vehicles, it was not valid for transport vehicle (Eicher/Canter) on date of accident – Insurance Company directed to pay but granted right to recover from vehicle owner – Pranay Sethi and IFFCO Tokio v. Geeta Devi principles discussed [Paras 5-6, 12].

Decision – Appeals Partly Allowed – Total compensation enhanced to ₹18,36,500 – Right of insurer to recover from owner upheld – Cross-objections and pending applications disposed of [Paras 13-14].

Consumer Law - Consumer Jurisdiction – Pecuniary Limits Based on Consideration – Constitutional Validity Upheld – Challenge to Sections 34, 47, and 58 of the Consumer Protection Act, 2019 dismissed – Court held that classification based on consideration paid (not compensation claimed) for determining jurisdiction of Consumer Commissions is constitutionally valid and not violative of Article 14 – It has rational nexus with object of timely and efficient consumer dispute resolution [Paras 1-11].

Article 14 – Reasonable Classification – Judicial Hierarchy and Access to Forums – Justified Shift – Court held that consideration paid is core to contractual relationship and valid for jurisdictional classification – Provisions not arbitrary as they streamline filing, reduce inflated claims, and distribute cases effectively across District, State, and National Commissions – No loss of judicial remedy proven [Paras 10.1–11.1].

Judicial Review – Performance Audit of Statutes – Executive’s Duty – Role of Regulatory Bodies – Supreme Court highlighted necessity of statutory performance audits to assess impact of legislative policy – Directed Central Consumer Protection Council and Central Consumer Protection Authority to evaluate functioning of provisions and advise reform if needed – Recognised judicial role in ensuring institutional efficacy of regulatory frameworks [Paras 12–12.17].

Decision – Writ Petition and Civil Appeal Dismissed – Sections 34, 47, and 58 held constitutional – Statutory authorities directed to audit, review, and advise government on implementation of Consumer Protection Act, 2019 for enhanced consumer access and redressal efficiency [Para 13].

Criminal Procedure Code – Quashing of FIR – Exercise of Power under Section 482 Cr.P.C. – FIR challenged relating to contract between parties and alleged suppression of restrictive covenant – Held: Allegations, even taken at face value, disclose purely civil dispute regarding payment of money and not criminal offence – No dishonest intention at inception shown – Quashing warranted [Paras 2, 5-7, 9-12].

Contract Law – Sub-contract without Principal's Consent – Effect – Suppression of restrictive covenant regarding subletting without consent – Held: Dispute between sub-contractor and main contractor is purely contractual – Principal (NBCCL) has no privity with sub-contractor – Suppression, even if assumed, does not constitute criminal offence [Paras 8-11].

Principles of Criminal Law – Commercial Transactions – Scope for Criminal Proceedings – Court reiterated that criminal law should not be used to settle civil or commercial disputes – Filing of FIR in present case found to be a tactic to exert pressure for recovery of money – Abuse of criminal process [Paras 6, 11].

Decision – Appeal allowed – FIR quashed – No further proceedings to continue against appellants – Pending applications disposed of [Para 12-13].
 

Excise Duty – Re-classification of Products – Violation of Natural Justice – Appeal against CESTAT order upholding re-classification of Benzene and Toluene from Chapter 29 to Chapter 27 based on test reports not furnished to the appellant – Held: Only gist of test reports communicated through show-cause notices insufficient – Full test reports must be provided under Rule 56 of Central Excise Rules – Non-furnishing of test reports violated principles of natural justice – Re-classification and consequential differential duty demand set aside [Paras 34-40].

Central Excise – Provisional Assessment – Requirements under Rule 9B – CESTAT erroneously held assessments for January and February 1993 as provisional – Held: No provisional assessment order passed, no execution of bond, mere endorsement on RT-12 returns insufficient – Assessments held final – Consequently, demand for duty barred by limitation [Paras 42-49].

Principles of Natural Justice – Obligation to Furnish Complete Test Reports – Only furnishing gist amounts to breach of Rule 56(2) and violates the right to seek re-test under Rule 56(4) – Breach of procedural fairness vitiates subsequent duty demand – CESTAT’s contrary findings unsustainable [Paras 36-39].

Approval of Classification List – Legal Sanctity – Delay in Drawing Samples – Department’s failure to challenge classification promptly – Samples drawn after five months of approval – Department’s belated action casts doubt on procedure followed – Held: Classification approval under Rule 173B not an empty formality and entitled to respect unless procedurally challenged [Para 40].

Central Excise Act – Limitation under Section 11A – Impact of Non-Provisional Assessments – Without valid provisional assessments, normal limitation period applies – Demand raised by department for 1989-1993 period time-barred – Differential duty demands unsustainable [Paras 43-49].

Decision – Appeals allowed – CESTAT order dated 21.05.2010 set aside to the extent challenged – Orders of Assistant Commissioner and Commissioner (Appeals) quashed – Re-classification annulled – No order as to costs [Paras 50-51].
 

Criminal Law – Murder of Children – Mental Instability and Absence of Motive – Conviction Converted – Appellant, mother of two deceased children, claimed to be under influence of "invisible power" during incident – Prosecution evidence established actus reus (physical act) but not mens rea (intention) beyond reasonable doubt – Absence of motive, normal family relations, and peculiar behaviour at scene raised doubt about intention – Conviction under Section 302 IPC altered to Section 304 Part II IPC [Paras 1-6, 14-18, 22-25, 36-47, 57-60].

Criminal Procedure – Burden of Proof and Benefit of Doubt – Sections 105 Evidence Act and 84 IPC – Burden on accused to prove legal insanity is on preponderance of probability – However, even prosecution evidence can raise doubt about existence of intention – Plea of insanity considered despite lack of defence witnesses – Court must scrutinize such pleas seriously especially when motive is absent [Paras 25, 30-31, 33-36, 54-55].

Evidence Act – Duty of Court under Section 165 – Active Role to Discover Truth – When faced with strange or inexplicable circumstances, Trial Court and High Court must proactively invoke Section 165 Evidence Act to clarify mental state of accused – Failure to explore such crucial aspects can affect fairness of trial [Paras 54-56, 63-64].

Mens Rea – Inference from Circumstances – Court held that in absence of established motive, existence of guilty intention cannot be presumed solely based on act – Circumstantial evidence showed remorse, absence of attempt to flee, cordial domestic life – These pointed towards lack of requisite mens rea for murder [Paras 37-45, 47-49].

Decision – Conviction under Section 302 IPC set aside – Conviction modified to Section 304 Part II IPC – Sentence limited to period already undergone (9 years 10 months) – Appellant directed to be released forthwith – Appeal partly allowed [Paras 60-62].
 

Criminal Law – Honour Killing – Caste Bias – Brutal Murder of Inter-caste Couple – Convictions Upheld – Victims, a Dalit boy and a Vanniyar girl, were forcibly administered poison by family and community members due to opposition to their marriage – Deaths concealed initially with police connivance – Trial Court convicted 13 accused including 2 police officers – High Court modified certain sentences but upheld majority convictions – Supreme Court found sufficient corroborated evidence despite some witnesses turning hostile – Delay in trial not fatal – Strong reliance placed on testimonies of PW-1, PW-2, PW-3, PW-15 and PW-49 – Appeal dismissed [Paras 3-10, 7-9, 14, 40-45, 57-61].

Evidence Law – Hostile Witness – Scope and Evidentiary Value – Hostile testimony not wholly discarded – Court reaffirmed that creditworthy portions of hostile witness evidence can be accepted – Section 154(2) Evidence Act and decisions in Sat Paul and Neeraj Dutta cited – Witness PW-49 treated as credible despite hostile elements – Distinction drawn between interested and natural witnesses – Long delay and hostile witnesses explained and accommodated by careful judicial scrutiny [Paras 15-39].

Criminal Procedure – Summoning of Additional Witness – Power under Section 311 CrPC and Section 165 Evidence Act – Trial Court rightly summoned PW-49 during trial to uncover essential facts – High Court justified in dismissing objection to treating PW-49 as prosecution witness – Courts reminded of proactive role under Section 165 Evidence Act to extract truth – Concept of Court witness clarified with restrictions on cross-examination noted [Paras 46-54].

Criminal Law – Police Misconduct – Fabrication of Evidence and Malafide Investigation – Conviction Justified – Accused police officer A-15 found guilty of manufacturing extra-judicial confessions, falsely implicating Dalits, and framing incorrect records – Violations of Sections 217 and 218 IPC and Section 4 and 3(2)(i) SC/ST Act established – A-14 acquitted of harsher charges but convicted under Section 217 IPC and Section 4 SC/ST Act – False implication and caste discrimination condemned – Court highlighted mandatory duties of police under Sections 154, 156, and 157 CrPC, Lalita Kumari principles applied [Paras 55-74].

Criminal Law – SC/ST (Prevention of Atrocities) Act – Neglect of Duties – Applicability – Police officers liable for wilful dereliction of duty under Section 4 – Fabrication of evidence to implicate Dalits attracted harsher punishment under Section 3(2)(i) – Differential roles of A-14 and A-15 carefully examined – A-15's conduct more culpable warranting confirmation of life sentence [Paras 55-74].

Principles of Criminal Justice – Trial Delay – Systemic Problems and Dilatory Tactics – 18-year delay in conclusion of trial acknowledged – Blame partly attributed to defence's repeated petitions – Court emphasized that mere delay does not automatically entitle accused to acquittal where strong evidence exists – Role of judiciary emphasized in curbing delay and ensuring witness protection [Paras 14-18, 37-39].

Victim Compensation – Responsibility of State – Victims' Families Entitled – Compensation of ₹5 lakhs awarded to parents of deceased, payable by State of Tamil Nadu – Compensation in addition to amounts already directed by lower courts – Recognition of systemic caste injustice and State’s duty to victims highlighted [Para 75].

Decision – Appeals dismissed – Convictions and sentences upheld with minor modifications – Appellants on bail directed to surrender within two weeks – Interim orders vacated – Applications disposed of [Paras 76-78].
 

Arbitration – Challenge to Arbitral Award – Scope of Interference – Appeal against High Court Division Bench judgment setting aside Single Judge’s decision under Section 34 of the Arbitration and Conciliation Act, 1996 – Appellant awarded construction contract, delayed completion by about 10 months – Liquidated damages deducted by respondent – Arbitral tribunal upheld deductions – Single Judge set aside award considering extension of time granted – Division Bench restored arbitral award, emphasizing limited grounds for interference under Section 34 [Paras 1-2, 5-6, 8-9, 23-24, 28].

Contract Law – Liquidated Damages – Extension of Time – Contract clauses 26, 27, and 28 examined – Despite extension of time, respondent reserved right to impose liquidated damages – Arbitral tribunal found financial loss to respondent due to delay – Held: Mere extension of time does not bar claim for liquidated damages if notice reserving right was given – Clause 26 not overridden by Clause 27 [Paras 12-17].

Arbitration and Conciliation Act, 1996 – Section 34 and 37 – Limited Review – Court reiterated that Section 34 proceedings are not appellate in nature – Award can be set aside only on specific grounds under Section 34(2) and (2A) – Single Judge exceeded jurisdiction by reassessing evidence and interpretation of contract – Division Bench rightly intervened under Section 37 to uphold arbitral award [Paras 21-24, 28].

Contract Law – Relevance of Sections 55, 73, and 74 of the Indian Contract Act, 1872 – Delay causing loss to employer justified imposition of liquidated damages – Actual proof of damage not necessary if loss is established and quantum is reasonable – Acceptance of delayed performance with reservation of rights permissible [Paras 18-20].

Decision – Appeal dismissed – Division Bench judgment restoring arbitral award upheld – No order as to costs [Para 29].