Land Ownership – Title and Possession – Appellant contested the Respondent's title over the disputed land, arguing that the courts below misdirected themselves in determining the issue – Supreme Court held that the lower courts failed to consider whether the vendor had valid title, which was necessary to determine the validity of the sale deed in favor of the Respondent [Paras 3-10].

Evidence Act – Section 90 – Presumption of Genuineness – Supreme Court criticized the High Court for incorrectly applying Section 90 of the Evidence Act, which presumes the genuineness of documents after 30 years, to the sale deed dated 11.11.1959 – The correct period for consideration is from the date the document is offered, not the date of the appeal decision [Paras 6-7].

Revenue Records – Not Conclusive Proof of Title – Mere entries in revenue records do not confer title – Courts below erred in holding that such records constituted ownership evidence – Revenue records merely raise a presumption of possession, not title [Paras 10-14].

Admission Against Interest – Supreme Court emphasized that the Respondent's letter admitting that it had been cheated by the vendor, who had no title over the land, should have been given due weight – Such admissions weaken the Respondent's claim [Paras 8, 15].

Estoppel – No Estoppel Against Statute – Acceptance of municipal or agricultural tax payments by a person does not estop the State from challenging ownership – There can be no estoppel against the statute [Para 14].

Decision:

Appeal allowed – Judgments of the lower courts set aside – Respondent's suit for declaration of title and injunction dismissed [Para 17].

Review Petition – Maintainability – Order 47 Rule 7 CPC – Appellant challenged the High Court's order dismissing their review petition of the main judgment which was not itself challenged – Supreme Court dismissed the SLP, reiterating that without challenging the main judgment, an SLP against the order rejecting the review petition is not maintainable [Paras 5-8, 11].

Merger Doctrine – Eastern Coalfields Ltd. Case – Appellant's reliance on Eastern Coalfields Ltd. Vs. Dugal Kumar was dismissed, with the Supreme Court stating that the judgments in Shanker Motiram Nale and other similar cases, which were not considered in Eastern Coalfields, still hold precedence – The principle that the main order and review order merge was not upheld in Eastern Coalfields, making it non-precedential [Paras 9-11].

Previous Precedents – Reaffirmed the rulings in Shanker Motiram Nale, Suseel Finance and Leasing Co. v. M. Lata, and M.N. Haider and Ors. v. Kendriya Vidyalaya Sangathan that an SLP challenging only the order rejecting a review petition is barred under Order 47 Rule 7 of CPC [Paras 7-8].

Decision:

SLP dismissed – Application for impleadment as party respondent also dismissed [Paras 12-13].

State Definition – Article 12 – Appellant contested being classified as a 'State' under Article 12 of the Constitution – Supreme Court upheld that Balmer Lawrie and Company Ltd., a government company with pervasive government control, is a State for purposes of Article 12 – Company is subject to writ jurisdiction [Paras 1-27].

Employment Termination – Unconscionable Clauses – Supreme Court held that Clause 11(a) of the appointment letter allowing termination without cause is unconscionable and violates Article 14 of the Constitution – Such a hire-and-fire policy is unjust and arbitrary [Paras 28-29].

Public Authority – Criteria and Control – Court applied criteria including administrative, financial, and functional control by the government to determine that the company operates as a public authority – Factors such as monopoly status, government directives, and government-appointed directors indicated significant government control [Paras 6-17, 27].

Judicial Review – Public Character and Unfair Terms – Supreme Court emphasized that public authorities cannot impose unfair or unreasonable contract terms – Actions bearing public character and public interest are subject to judicial review – Employment terms must be equitable and just [Paras 19-20].

Subsequent Developments – Impact on Rights – Court considered the impact of subsequent developments on rights and remedies, emphasizing the need for just and updated relief based on current circumstances [Para 20].

Decision:

Appeals dismissed – Orders of the High Court upheld – Respondents entitled to arrears of wages, terminal benefits, and statutory entitlements – Terms and conditions in employment contracts to be non-arbitrary and equitable [Paras 28-30].

Substitution of Legal Representatives – Exemption under Order 22 Rule 4(4) – Appellant challenged abatement of suit for not substituting legal representatives of a deceased defendant – Trial court dismissed the suit, but First Appellate Court and High Court reversed, finding exemption applicable – Supreme Court affirms, holding that substitution was unnecessary as the deceased was ex parte [Paras 1-11].

Amendment History – Order 22 Rule 4(4) – Historical context of the 1976 amendment to CPC discussed – Legislative intent to expedite proceedings by exempting substitution for non-contesting defendants emphasized – Courts below rightly exercised exemption to prevent abatement [Paras 5-9].

Contempt Petitions – Allegations of contempt between parties – Supreme Court finds no merit in contempt petitions, dismissing them while urging focus on merits of the main suit [Paras 12].

Decision: Appeal dismissed – Abatement set aside – Suit to proceed on merits – Contempt petitions dismissed.

Criminal Procedure – Evidence for Framing Charges – Appeal concerning whether depositions recorded under Chapter XV CrPC before Magistrate's cognizance constitute evidence for framing charges under Chapter XIX – Magistrate’s initial enquiry found the dispute civil, but dissatisfaction led to issuing process under Section 202 CrPC – High Court’s erroneous consideration of Chapter XV depositions as evidence for framing charges [Paras 1-12].

Right to Cross-Examination – Essential for Fair Trial – Accused entitled to cross-examine witnesses under Section 244 CrPC – Evidence recorded in presence of accused necessary for framing charges – High Court wrongly assumed opportunity for cross-examination existed at initial stage [Paras 13-19].

Judicial Interpretation – Section 246 CrPC – Requires framing charges based on evidence presented in the presence of accused – Cross-examination crucial to ensure reliability and fairness – Precedents affirm accused’s right to cross-examine before charge framing [Paras 20-23].

Decision: Appeal allowed – High Court order set aside – Sessions Judge order restored – Costs imposed on Respondent No. 2-company to be deposited in SCBA Lawyers' Welfare Fund within two weeks [Para 24].

Regulatory Compliance – SEBI Regulations – Respondent's application for registration as CRA rejected by SEBI for not providing audited annual accounts of promoters – SAT directed SEBI to reconsider application without requiring two additional years’ accounts – SEBI’s appeal focuses on regulatory interpretation and the necessity of audited accounts for verifying net worth [Paras 1-14].

Eligibility Criteria – Audited Accounts – Regulation 4(e) and Form A require evidence of continuous net worth of Rs. 100 crores – SAT ruled Chartered Accountant’s certificate sufficient, SEBI contended that audited accounts are necessary – SEBI Act and CRA Regulations mandate strict adherence to criteria [Paras 15-23].

SEBI’s Authority – Verification of Information – SEBI's right to request further information or clarification under Regulation 7 – Court upholds SEBI's authority to seek audited accounts for proper assessment – Delay in rejection of application beyond regulatory timelines addressed [Paras 24-28].

Decision: Appeal dismissed – SAT order upheld – SEBI to process Respondent’s application based on existing submissions, including audited accounts for additional years – Costs not imposed [Paras 29-30].

Disciplinary Proceedings – Imposition of Penalties – Appeal concerns whether the disciplinary authority's order imposing two major penalties on the respondent was in accordance with the Andhra Pradesh Civil Services Rules – High Court found the imposition of two major penalties impermissible – Appeal addresses the interpretation of Rules 9 and 11 of the Andhra Pradesh Civil Services Rules [Paras 1-14].

Amendment of Rules – Retrospective Effect – Consideration of whether amended rules have retrospective effect – Respondent argued that disciplinary proceedings initiated under unamended rules should not impose penalties as per amended rules – Court examined whether amendment should be considered retrospective [Paras 15-27].

Accrued Rights – Vested Rights in Service Jurisprudence – Analysis of whether the respondent had vested or accrued rights under unamended rules – Court examined the distinction between penalties under unamended and amended rules – Impact of amendments on disciplinary proceedings initiated prior to amendment [Paras 28-45].

Judicial Precedents – Examination of relevant case law on retrospective application of rules and imposition of penalties – References to Supreme Court judgments on vested rights and penal consequences in service law [Paras 46-50].

Decision: Appeals allowed – High Court orders set aside – Order of punishment imposed by disciplinary authority restored – No costs [Paras 51-52].

Criminal Law – Extra-Judicial Confession – Appeal questions the validity of appellant's conviction for murder based on an extra-judicial confession – Appellant argued confession was improbable, unsupported, and uncorroborated – Courts below found confession voluntary and truthful [Paras 1-4].

Legal Standards – Admissibility of Extra-Judicial Confession – Established that an extra-judicial confession can support a conviction if voluntary and truthful – Courts must cautiously approach such evidence, seeking corroboration as a measure of abundant caution – Judicial precedents affirm that corroboration, though not always necessary, enhances credibility [Paras 5-7].

Case Analysis – Corroborative Evidence – Examination of prosecution’s evidence, including the extra-judicial confession recorded by the Village Administrative Officer (VAO), medical evidence, and depositions of other witnesses – Confession found reliable and corroborated by medical evidence indicating drowning as the cause of death and by other witness testimonies [Paras 8-18].

Decision: Appeal dismissed – Conviction and sentence upheld – Confession found voluntary, truthful, and sufficiently corroborated – No miscarriage of justice identified [Para 19].

Leave to Appeal – Requirement of Reasoned Orders – Appeal concerns the High Court’s refusal to grant leave to appeal without providing reasons – Emphasized the obligation of courts to give reasons when denying leave, ensuring clarity and demonstrating application of mind – Court reiterated that absence of reasons renders orders unsustainable [Paras 1-5].

Judicial Precedents – Consistency in Providing Reasons – Examination of precedents where Supreme Court insisted on reasoned orders – Highlighted that cryptic orders with mere statements of non-infirmity in trial court judgments are insufficient – Courts must address prima facie case or arguable points while granting or denying leave [Paras 6-12].

Restoration and Remand – Appeal allowed due to lack of reasoning in the High Court’s order – Matter remitted to the High Court for a reasoned decision on the grant or refusal of leave – No opinion expressed on the merits of the case [Para 13].

Decision: Appeal allowed – High Court order set aside – Case remanded to High Court to pass a reasoned order regarding the grant or refusal of leave [Para 13].