Criminal Law – Anticipatory Bail – Appellant, an expert on the Interview Board for JPSC, sought anticipatory bail against charges including conspiracy, forgery, and corruption – High Court rejected bail based on parity with other accused – Supreme Court held appellant’s position distinct due to lack of local connections and motive – Granted anticipatory bail considering his academic credentials and lack of prior criminal antecedents [Paras 1-15].

Personal Liberty – Fundamental Right – Supreme Court emphasized personal liberty as a precious fundamental right – Evaluated whether case for anticipatory bail was made considering the nature of the accusation, applicant's antecedents, risk of flight, and potential for injury or humiliation through arrest [Paras 7-12].

Decision: Appeal allowed – High Court and Special Judge's orders rejecting anticipatory bail set aside – Appellant granted anticipatory bail with conditions to cooperate with investigation, avoid inducement to witnesses, and not leave India without court permission [Paras 13-15].

Civil Procedure – Amendment of Pleadings – Plaintiff sought to amend plaint to include new plaintiffs and defendants and explain payment details – Trial court partially allowed amendment – Appellant contended amendment altered cause of action and was barred by limitation – Supreme Court held amendment did not change cause of action, but clarified facts – Amendment allowed to avoid multiplicity of litigation [Paras 1-14].

Pleadings – Material Facts and Evidence – Order 6 Rule 2 CPC requires concise statement of material facts, not evidence – Amendment permissible under Order 6 Rule 17 CPC to determine real questions in controversy – Proviso restricts amendments after trial commencement unless due diligence is shown [Paras 6-8].

Amendment of Pleadings – Principles – Amendments should be bona fide, not cause undue prejudice, and necessary for case adjudication – Amendments before trial viewed liberally to avoid multiplicity of litigation – Court should balance procedural justice and substantive rights [Paras 9-12].

Decision: Appeal dismissed – High Court’s order allowing partial amendment upheld – Amendment necessary for clarifying facts and did not alter cause of action [Paras 13-14].

Arbitration – Limitation for Application – Application under Sections 5, 11, and 12 of the Arbitration Act, 1940 to appoint a new arbitrator after original arbitrators became functus officio – High Court allowed the application beyond limitation period – Supreme Court held that application should be made within three years from the date arbitrators became functus officio – Application filed after three years was time-barred [Paras 1-21].

Limitation Act – Application of Article 137 – Article 137 of the Limitation Act prescribes three years for any application not otherwise provided for – Limitation period begins when the right to apply accrues – For arbitration, the right to apply for new arbitrator accrues when the original arbitrators become functus officio [Paras 15-17].

Decision: Appeal allowed – High Court’s order set aside – Application under Sections 5, 11, and 12 of Arbitration Act dismissed as time-barred [Paras 21-22].

Criminal Law – Probation – Appellant convicted under Section 7 of the Essential Commodities Act, 1955, and sentenced to one-year imprisonment and a fine – Sought modification for probation under Section 360 of CrPC or Section 4 of Probation of Offenders Act – High Court rejected the plea, citing it was functus officio after judgment delivery – Supreme Court upheld High Court's decision, emphasizing no scope for post-judgment modifications under Section 362 CrPC [Paras 1-12].

Judicial Process – Abuse of Court – Appellant repeatedly approached courts, abusing judicial process – Supreme Court dismissed the petition as misconceived and untenable, imposing costs for frivolous litigation – Reinforced courts' stance against misuse of judicial process [Paras 13-16].

Economic Offences – Probationary Measures – Discussed non-applicability of probationary measures for economic offences and anti-social activities under the Essential Commodities Act – Cited societal risks and improbability of rehabilitation through probation [Paras 17-19].

Decision: Appeal dismissed – High Court’s refusal to modify judgment upheld – Appellant directed to pay costs for frivolous petition [Para 19].

Land Acquisition – Lapse of Proceedings – Award under Section 11 of the Land Acquisition Act not made within the prescribed two years from the publication of the declaration under Section 6 – High Court erroneously excluded the period from the date of dismissal of interim relief to the date when certified copy of judgment was received by the authority – Supreme Court held such exclusion not permissible under Section 11A – Acquisition proceedings lapsed [Paras 1-14].

Limitation – Exclusion of Time – Section 11A mandates the award to be made within two years from declaration, excluding only the period during which action or proceeding is stayed by a court – No provision to exclude time taken to obtain certified copy of judgment – Section 12 of Limitation Act not applicable to Section 11A [Paras 8-12].

Statutory Interpretation – Legislative Intent – Provisions of Limitation Act cannot be read into special provisions of Land Acquisition Act unless explicitly provided – Section 28A incorporates exclusion of time for obtaining copy of award, unlike Section 11A, showing clear legislative intent [Para 11].

Decision: Appeal allowed – High Court's judgment set aside – Acquisition proceedings declared lapsed [Paras 13-14].

Land Lease – Renewal – Lease initially granted to Gopaldas Mohta for 30 years – Corporation passed a resolution for renewal of lease for another 30 years – Subsequent lease granted to appellant found illegal as the initial renewal was not cancelled or rescinded – Sanction of State Government required for lease renewal under Section 70(5) of City of Nagpur Corporation Act not obtained prior to decision [Paras 1-9].

Doctrine of Equality – Public Property – Corporation must follow procedures consistent with Article 14 of the Constitution – Alienation of public property should be done through auction or inviting tenders – Supreme Court held that renewal of lease without such procedure is arbitrary and violative of Article 14 [Paras 10-16].

Contract Law – Specific Performance – High Court reversed trial court’s decree for specific performance favoring appellant – Appellant’s failure to prove readiness and willingness to perform the contract resulted in dismissal of suit – Findings became final as appellant did not challenge High Court's judgment under Article 136 [Paras 8-9].

Decision: Appeals dismissed – Appellant directed to hand over possession to Corporation within three months – Corporation to alienate the property through auction or tender process – Market value of the structure to be paid to the appellant [Paras 20-22].

Taxation – Mandi Fee – Appellants contested mandi fee imposed on stock transfers by Krishi Utpadan Mandi Samiti under Section 17 of Uttar Pradesh Krishi Utpadan Mandi Adhiniyam, 1964 – High Court upheld imposition, rejecting appellants' claim for refund – Supreme Court held statutory presumption of sale within market area unrebutted due to insufficient evidence by appellants – Mandi fee deemed valid [Paras 1-22].

Judicial Review – Standard of Proof – Rebuttable presumption under Section 17(iii) of the Act – Appellants required to provide clear and convincing evidence to rebut presumption of sale – High Court’s findings not irrational or perverse – No interference warranted by Supreme Court [Paras 23-36].

Procedural Law – Machinery Provisions – Appellants argued lack of assessment and adjudicatory machinery under the Act – Supreme Court noted presence of adequate mechanisms for dispute resolution and rejected claims of procedural deficiency [Paras 37-41].

Decision: Appeals and writ petition dismissed – High Court's decision affirmed – Mandi fee imposition upheld – Appellants directed to pay costs [Paras 42-62].

Armed Forces Tribunal – Appeal to Supreme Court – Section 30 appeal subject to provisions of Section 31 – No absolute right of appeal against Tribunal’s final decisions/orders – Leave of Tribunal or Supreme Court required for appeal – Section 31 application necessary before Supreme Court’s leave – Appeals dismissed for lack of compliance with Section 31 [Paras 1-12].

Statutory Interpretation – "Subject to" Clause – Interpretation of "subject to the provisions of Section 31" – Section 30 appeals conditional upon Section 31 compliance – No redundancy of legislative words – Prior application for Tribunal’s leave mandated before Supreme Court approach [Paras 6-9].

Judicial Precedents – Consistent Legislative Intent – Comparison with other statutes providing direct Supreme Court appeals – Armed Forces Tribunal Act distinguished – Interpretation based on specific legislative wording and intent – Reference to established case law on statutory interpretation principles [Paras 12-16].

Decision: Appeals dismissed – Liberty to appellants to seek Tribunal’s leave under Section 31 – Period of limitation for leave application to start from date of Supreme Court order – No opinion on merits of the controversy expressed [Paras 17-18].

Criminal Law – Murder – High Court acquitted respondents of murder charge under Section 302/149 IPC – Respondents convicted for other offences – High Court noted injuries on deceased were simple, inflicted on non-vital parts, and not sufficient to cause death – Trial Court’s reliance on internal injuries unsupported by external evidence [Paras 1-7].

Evidence – Medical Testimony – Dr. Narendra Swarup Mathur (PW-13) testified injuries were simple and on non-vital parts – No external head injuries despite internal blood clots – Doctor did not certify injuries sufficient to cause death in ordinary course – Evidence insufficient for murder conviction [Paras 6-8].

Judicial Reasoning – High Court correctly assessed evidence – Absence of intent or knowledge to cause death – Respondents’ conviction for lesser offences affirmed – Sentence of imprisonment already undergone deemed sufficient [Paras 7-9].

Decision: Appeal dismissed – High Court's judgment affirmed – Respondents acquitted of murder charge, conviction for remaining offences upheld – Respondents to be released if not required in other cases [Paras 8-9].