Employment Law - Public Employment – Format of Caste Certificate – Format compliance mandatory – Rejection of candidature upheld – Petitioners submitted OBC-NCL certificates in Central Government format rather than in the format required by the State of Uttar Pradesh – Clause 5.4(4) of recruitment advertisement clearly specified the required format and the consequence of non-compliance – Held: Non-submission in the prescribed State format rendered petitioners ineligible for OBC reservation – Authority acted within jurisdiction by excluding petitioners from consideration under OBC category [Paras 14–17].

Recruitment Rules – Non-discretionary application – Procedural fairness does not override explicit requirements – Plea that the Board should have granted a chance to correct the certificate format rejected – Held: Opportunity already existed at the time of application – Procedural fairness does not mean condoning clear procedural defaults – Equal treatment requires adherence to rules by all [Paras 19–21].

Judicial Review – Limited role of Courts – No interference when recruitment norms are unambiguous – Held: Recruitment authority is entitled to frame and implement rules unless proven to be arbitrary or violative of constitutional rights – Courts will not dilute terms of advertisement by equitable considerations unless warranted by exceptional circumstances [Paras 19–20].

Article 141 – Precedent – Summary dismissal of SLPs does not constitute binding law – Reference to previous reliefs granted to similarly situated candidates not helpful – Held: Dismissal of Special Leave Petitions in limine without reasons does not have precedential value – Does not create binding precedent under Article 141 of the Constitution [Para 23].

Decision of the Court – Appeals decided accordingly – Civil Appeal No. 5233 of 2025 (Mohit Kumar) dismissed – Civil Appeal No. 5234 of 2025 (State of U.P.) allowed – Held: Requirement of caste certificate in prescribed State format is justified and non-arbitrary – Rejection of candidature sustained [Paras 24–25].

Civil Law - Electricity Act - Jurisdiction of CERC – Powers under Section 79 – Regulatory Order Valid – Held: CERC has dual functions of regulation and adjudication – Even in absence of regulations under Section 178, CERC is empowered to regulate tariff matters between parties under Section 79 – Grant of liberty to claim compensation falls within such regulatory scope [Paras 43-48, 60-63].

Maintainability of Writ Petition – Alternative Remedy Available – Writ Petition Improperly Admitted – The High Court entertained the writ despite availability of appellate remedy under Section 111 – No violation of natural justice, no constitutional question involved, and no lack of jurisdiction shown – Held: High Court erred in applying Whirlpool exception – Writ petition was not maintainable [Paras 64-66].

Compensation for Delay – Transmission Charges – Regulatory Function Not Adjudication – CERC’s direction to allow appellant to claim transmission charges for unutilized assets due to respondent’s delay addressed a regulatory gap – Such order was not an adjudication on liability, but regulation to fill a lacuna in the 2014 Tariff Regulations – Held: Ad hoc regulatory action permissible and valid [Paras 55-60].

Decision – Appeals Allowed – Writ Petitions Dismissed – Supreme Court set aside the High Court’s order admitting the writ petitions – Clarified that respondent may raise factual challenge on merits before APTEL if it chooses to appeal – No determination on actual liability was made [Paras 65-66].

Civil Law - Temple Receivership – Widespread Judicial Appointments – Chronic Litigation – Reformed - Supreme Court found long-standing misuse of receivership across 197 temples in Mathura where most receivers were advocates – Held: Such appointments led to indefinite litigation, stalling temple administration and violating public trust – Courts must avoid routine receivership and expedite dispute resolution to restore autonomy to temple trusts [Paras 4.10, 6, 22–26, 31–33].

Receiver Appointment – Advocates Not Absolutely Barred – Statutory Discretion Retained - Court acknowledged that Order XL CPC does not prohibit advocate appointment as receivers – However, courts must exercise discretion judiciously – Held: Only persons with religious knowledge, devotion, and administrative capacity, especially from the Vaishnav Sampradaya, should be considered for receiver roles in sacred temples – Blanket appointment of advocates deprecated [Paras 9.3, 21–22, 29, 31, 33].

Article 14 Challenge – Advocates’ Exclusion Not Discriminatory – Petition Dismissed - Appellant’s argument that excluding advocates violated Article 14 was rejected – Held: Classification was reasonable given spiritual, cultural, and practical requirements of temple administration – Religious competence is a valid criterion under the Constitution’s secular structure [Paras 9.4, 22–24].

Braj Region Temple Crisis – Structural Reforms Mandated – Systemic Clean-Up Ordered - Found that litigation over temple control dated back to 1923, and no final adjudication occurred in hundreds of cases – Directed trial courts to cease using receivers as a substitute for adjudication – Held: Courts must now consider spiritual competence and local customs before appointing receivers [Paras 4.10, 23–24, 28–29, 31–33].

Banke Bihari Temple Corridor – State’s Development Scheme Approved – Fund Use Permitted - Supreme Court allowed State of Uttar Pradesh to use temple funds to purchase 5 acres of land around Banke Bihari Temple for crowd management – Directed that acquired land must remain in the name of the Deity – High Court order modified under Article 142 – Upheld need for collaborative public-private development model in Braj region [Paras 11.6–11.9, 20, 24].

Decision – Appeal Dismissed – High Court Order Upheld – Future Receiver Appointments Regulated - Held: The order setting aside the Seven Member Receiver Committee was correct – Trial Court must now appoint a receiver with spiritual and administrative alignment, preferably from Vaishnav Sampradaya – Temple reform directions binding on lower courts – Appeal and all IAs disposed [Paras 24–25].

Family Law - Child Custody – Repetitive IA Requirement – Procedural Burden Criticized – Modified - The Family Court required the father to file fresh interlocutory applications for custody every time he visited India – Held: Such repetitive litigation imposes undue burden on non-custodial parent and child, disrupts planning, and hinders bonding – Supreme Court substituted a structured interim visitation schedule to ensure predictability and preserve parental relationship [Paras 2, 6, 15–17].

Child Welfare – Shared Parenting Principles – Interim Custody Balanced - The Court recognized the importance of regular meaningful contact with both parents – Held: Even while trial is pending, structured parenting time is essential for the child’s emotional well-being – Interim custody split during vacations and alternate weekends, with structured video interaction during the appellant’s overseas postings [Paras 16–20].

Family Court Jurisdiction – Interim Access Orders – Judicial Discretion Guided - High Court’s refusal to grant structured schedule was reversed – Held: Interim arrangements must account for practicalities of international employment and avoid repetitive litigation – Family Court may vary logistics only upon material change, but not reduce access granted [Paras 17–20].

Decision – Appeal Allowed in Part – Permanent Interim Visitation Framework Issued - Supreme Court replaced piecemeal interim custody system with a standing schedule – Directed equal division of vacation time (if appellant present), alternate weekends, routine video contact, and streamlined coordination procedures – Directed Family Court to adjudicate main custody case expeditiously [Paras 19–21].

Arbitration Law - Arbitral Award – Division of Interest Periods – Legality of Granting Separate Interest for Pre-reference and Pendente Lite Periods – Arbitral Discretion Upheld - Arbitral Tribunal’s bifurcation of interest into pre-reference, pendente lite, and post-award periods is not contrary to Section 31(7)(a) – Held: Tribunal is empowered to award varying interest rates over subdivided segments within the larger period from cause of action to award, consistent with statutory scheme and judicial precedents [Paras 30-35].

Compound Interest – Interpretation of 'Sum' in Section 31(7)(b) – Inclusion of Past Interest in Principal for Future Interest Computation – Permissible - Held: Tribunal did not err in treating awarded interest as part of the “sum” under Section 31(7)(b) – Supreme Court affirms legality of awarding post-award interest on a total comprising principal and interest components – Overrules High Court's reliance on SL Arora and upholds Hyder Consulting and UHL Power judgments [Paras 40-44].

Interest Award – Judicial Review Scope – High Court’s Interference with Arbitral Award Unjustified - Division Bench erred in interfering with a well-reasoned arbitral award in absence of manifest illegality – Tribunal had discretion under Section 31(7) and exercised it judiciously – Supreme Court restores award in full [Paras 36, 45-46].

Motor Accident Claim – Liability of Insurer – Duty limited to monetary compensation – High Court’s directive for lifetime support set aside – The High Court directed the insurer to provide prosthetic limbs, motorized wheelchair, travel expenses, and ensure ongoing support – Held: Insurer’s statutory role is limited to indemnifying loss in monetary terms, and not to maintain lifelong support infrastructure – Directions contrary to statutory framework and unsustainable [Paras 2-4, 6].

Compensation – Disability and Future Needs – Additional Rs.12 lakhs awarded – Expenses quantified for future wellbeing – The victim suffered 100% functional disability due to loss and impairment of both lower limbs at age 22 – Held: A prosthetic limb costing approx. Rs.2 lakhs, replaced every 5 years, and wheelchair costing Rs.40,000 require long-term provision – Court awarded Rs.12 lakhs with 6% simple interest to cover future expenses and mobility needs [Paras 5, 7-8].

Appeal by Insurer – No bar on grant of just compensation – High Court’s enhancement restructured – Though the appeal was filed by the insurer and not the claimant, the Supreme Court upheld the right to restructure compensation in monetary terms, in lieu of specific services previously directed – Held: The Court is merely converting non-monetary directions into quantified award and not increasing compensation beyond High Court’s intent [Paras 8-9].

Final Directions – High Court Order Set Aside – Award modified and appeal disposed – The Supreme Court set aside the High Court’s directions and substituted them with quantified compensation payable within two months – Directions given to respondent to furnish account details for online transfer – Pending applications also disposed [Paras 9-12].

Suo Motu - POCSO Cases – Setting Up of Exclusive Courts – Implementation of Judicial Directives – Compliance Directed - The Court directed that each district with more than 100 POCSO cases must establish exclusive courts under a Central scheme with appropriate staffing and child-friendly infrastructure – Majority of States complied but high-pendency States (UP, WB, Bihar, TN, Orissa, Maharashtra) were found lacking – Held: Union and State governments must prioritise timely establishment of such courts [Paras 1, 3, 5-6].

Forensic Delay – Effective Functioning of FSLs – Expedited Processing Ordered – Court acknowledged forensic delays as key bottleneck in trial completion – Directed State Forensic Labs to ensure swift analysis and reporting in POCSO cases – Mandated Chief Secretaries to ensure compliance [Para 1].

Child Sensitisation and Support – Appointment of Trained Support Persons and Prosecutors – Awareness Measures – Directions were issued to appoint child-sensitive support persons and prosecutors, and to run public awareness campaigns in cinemas and media with helpline information prominently displayed – Responsibility assigned to Ministry of Women and Child Development [Paras 1, 4].

Timely Trial – Adherence to Statutory Deadlines – States Reminded of Duty – Despite POCSO Act’s time-bound process for investigation and trial, delay persists due to inadequate infrastructure – States instructed to strictly follow the law and ensure completion of investigations and trials within statutory periods [Paras 2, 6].

Closure of Proceedings – Compliance Noted – Matter Concluded – Noting significant implementation of earlier directions and pending areas requiring attention, the Court closed the suo motu proceedings with appreciation for the amicus curiae and counsel – Held: Further monitoring not required at this stage [Paras 7-8].

Criminal Law - Probation of Offenders Act – Inapplicability under PoFA Act – Section 20AA prohibits probation – Probation benefit denied - Section 20AA clearly excludes the application of the Probation of Offenders Act and Section 360 of the CrPC to those convicted under the PoFA Act unless the offender is under 18 years of age – The Court held that the provision is explicit, unambiguous, and constitutionally valid – Hence, probation not applicable [Paras 40-42].

Mollification of Sentence – FSS Act Repeal and Savings Clause – Reduced punishment not permitted – Benefit denied - Despite lesser punishment under the FSS Act, the repeal and savings clause under Section 97 preserves penalties under the repealed PoFA Act – The Court held that the presence of such a clause prevents application of lighter sentence from new law – Hence, no reduction in sentence permissible under FSS Act [Paras 43-44].

Adulteration Evidence – Discrepancy in Reports – Sentence converted to fine – Lead appeal partly allowed - In the case of Nagarajan and Selvaraj, the two lab reports on curd adulteration had significant differences—one showing deficiency in fat content, the other meeting the required standard – Applying precedent in C. Mohammed, the Court converted the 6-month imprisonment to a fine of Rs. 30,000 each [Paras 45-46].

Judicial Comity – Reliance on Coordinate Bench despite disagreement – Connected appeal partly allowed - Although the Bench disagreed with the reasoning in A.K. Sarkar & Co., it followed the decision to prevent further litigation, converting Naresh Chandra’s sentence to a fine of Rs. 20,000 in the interest of equity and justice [Paras 47-48].

Decision – Convictions upheld, Sentences modified – Probation relief and sentence reduction under FSS Act denied – However, due to specific factual circumstances and prior rulings, sentences were converted to fines – Appeals partly allowed [Paras 48-51].

Accident Claim - Motor Accident Compensation – Assessment of Monthly Income – Claim of Rs.10,000 accepted – High Court’s reduction reversed – The Tribunal awarded compensation based on the deceased driver’s claimed income of Rs.10,000 per month – High Court reduced it to Rs.4,076 applying minimum wages – Held: Based on precedent in Ramachandrappa v. Royal Sundaram, even unskilled labourers earned around Rs.4,500 in 2004, making Rs.10,000 reasonable for a skilled driver in 2014 – Tribunal’s assessment restored [Paras 3-4].

Future Prospects – 40% Addition – Compensation Properly Calculated – No Interference – The Tribunal rightly added 40% of monthly income towards future prospects – High Court erred in excluding it while calculating reduced compensation – Held: The calculation by the Tribunal aligns with prevailing law and requires no interference [Paras 2-4].

Loss of Consortium – Entitlement of Family Members – Retained Despite No Cross Appeal – Tribunal granted consortium to wife, children, and parents – Held: As per New India Assurance Co. v. Somwati, all dependents are entitled to consortium – Supreme Court retained the same though no appeal was filed by the claimants seeking enhancement [Paras 4-5].

Restoration of Tribunal’s Award – High Court Order Set Aside – Tribunal’s compensation confirmed – Appeal Allowed – Held: There was no justification for the High Court’s downward revision of compensation – Tribunal’s award reinstated in full, to be disbursed within two months and apportioned equally among legal heirs – In case of minors, amount to be held in fixed deposit [Paras 5-6].

Decision – Tribunal’s Compensation Restored – Appeal Allowed – The Supreme Court restored the full compensation awarded by the Motor Accident Claims Tribunal, setting aside the reduced award passed by the High Court – Compensation to be distributed as per Tribunal’s direction [Paras 5-6].