Sales Tax Exemption – Applicability Post Policy Amendment – The appellant challenged the eligibility of the respondent for a sales tax exemption on investments made after the inclusion of solvent extraction plants in the negative list on 16.12.1996. The Supreme Court held that the exemption could only apply to investments made before the amendment, affirming that the State had the prerogative to withdraw the exemption in public interest and that the promissory estoppel doctrine did not apply as the amendment was notified prior to substantial investments by the respondent [Paras 1-33].

Doctrine of Promissory Estoppel – Limitation in Fiscal Policy – The Court reiterated that the promissory estoppel doctrine cannot prevent the State from exercising its policy-making powers in public interest. The State had given clear notice of the impending amendment, and the investments made by the respondent post-notification did not warrant the application of promissory estoppel [Paras 23-27].

Decision: Appeal allowed – The Supreme Court set aside the High Court's decision, confirming the appellant’s stance that the sales tax exemption could not extend beyond the amendment date of 16.12.1996. The quantification made by the Lower Level Screening Committee was upheld as it aligned with the principles laid out in previous judgments [Paras 32-33].

Excise Duty – Exemption Notification – Conditionality on MODVAT Credit – The appellant contested the denial of the benefit of the exemption notification, asserting compliance with conditions stipulated in both Notification No. 1/93 dated 28.02.1993 and the amended Notification No. 135/94-CE. The Supreme Court upheld the concurrent findings of the lower authorities and the Tribunal that the appellant availed of MODVAT credit on inputs used in manufacturing aluminum circles, thus failing to meet the exemption criteria [Paras 1-11].

Strict Interpretation of Exemption Notifications – The Court reiterated the principle that exemption notifications must be construed strictly and literally. The appellant's failure to meet the specific conditions of the exemption notifications justified the denial of benefits. The requirement that no MODVAT credit be taken on inputs was a critical precondition for the exemption, which the appellant did not fulfill [Paras 9-10].

Decision: Appeals dismissed – The Supreme Court upheld the findings of the Tribunal and lower authorities, concluding that the appellant was not entitled to the exemption under the cited notifications due to the availment of MODVAT credit on the inputs. The appeals were dismissed with parties bearing their own costs [Paras 10-11].

CENVAT Credit – Interest Liability – Date of Availment vs. Utilization – The Supreme Court addressed whether interest on wrongly availed CENVAT credit should be calculated from the date of wrongful availment or from the date of utilization. The Court held that interest is payable from the date the CENVAT credit is wrongly availed, aligning with Rule 14 of the CENVAT Credit Rules, which specifies recovery along with interest from the date of wrongful availment or erroneous refund [Paras 1-23].

Statutory Interpretation – Reading Down Provisions – The Court emphasized that statutory provisions, particularly in fiscal statutes, must be interpreted strictly and literally. The High Court's reading down of Rule 14 to replace "or" with "and" was found to be erroneous. The rule clearly indicates that liability for interest arises from the date of wrongful availment, not utilization [Paras 17-19].

Decision: Appeal allowed – The Supreme Court set aside the High Court's judgment and restored the Settlement Commission's order, confirming that interest on CENVAT credit is payable from the date of wrongful availment. The parties were directed to bear their own costs [Paras 21-23].

Military Law – Scale of Punishment – Authority of Confirming Authority – The appellant, a Corporal in the Indian Air Force, was initially sentenced to three months' detention for misconduct. The Confirming Authority commuted this sentence to dismissal from service. The Supreme Court upheld this decision, affirming that the Confirming Authority acted within its powers under the Air Force Act, and the commuted punishment of dismissal was not more severe than detention, as per the scale of punishment outlined in Section 73 of the Act [Paras 1-18].

Punishment – Severity and Disciplinary Standards – The Court noted the serious nature of the charges against the appellant, including committing unnatural carnal intercourse and misconduct on duty. Given the disciplined nature of the Air Force, the punishment of dismissal was deemed appropriate and not excessive [Paras 16-18].

Decision: Appeal dismissed – The Supreme Court upheld the decision of the Confirming Authority and the lower courts, confirming that the punishment of dismissal from service was in accordance with the provisions of the Air Force Act, 1950, and appropriate for the offenses committed. The appeal was dismissed without costs [Paras 17-18].

Customs Law – Jurisdiction of Proper Officer – Appeals challenging the validity of show cause notices issued by the Commissioner of Customs (Preventive) under Section 28 – Tribunal had conflicting decisions on the jurisdiction of the Commissioner of Customs (Preventive) – Supreme Court clarified that only officers specifically assigned functions under Section 2(34) are "proper officers" to issue such notices [Paras 1-16].

Definition and Assignment – Proper Officer – Section 2(34) requires specific assignment of functions by the Board or Commissioner of Customs – Commissioner of Customs (Preventive) was not shown to be assigned functions under Section 28, hence lacked jurisdiction to issue the notices [Paras 12-14].

Procedural Clarification – Assessment and Re-Assessment – The Court explained the assessment and clearance process involving different customs officers and highlighted the roles of the Customs House and Preventive Collectorate – Emphasized the need for specific designation to perform certain functions under the Act [Paras 11-14].

Decision: Appeals involving improper issuance of notices (C.A. Nos. 4294-4295 of 2002) dismissed – Appeals challenging such improper issuance upheld (C.A. Nos. 4603-4604 of 2005) – Revenue not precluded from initiating appropriate proceedings if permissible under the Act [Paras 17-18].

Public Interest Litigation – Continuation after Petitioner’s Death – Examined the procedural validity of continuing a PIL after the death of the sole petitioner – Court emphasized that laws of procedure should not obstruct substantial justice – Suggested practical steps for continuing PILs, including allowing applications from public-spirited individuals or suo moto cognizance by the court [Paras 10-24].

Land Allotment – Change of Use – Addressed the legality of a land allotment to the appellant, initially intended for a school but used for a women’s hostel – Emphasized that the use for a hostel for working women and students served a public or semi-public purpose, aligning with the charitable objectives of the trust – Highlighted the financial transparency and social utility of the appellant’s activities [Paras 26-37].

Judgment: Appeal allowed – High Court’s order quashing the allotment set aside – Recognized the appellant’s use of the land for a women’s hostel as serving a legitimate public purpose – Directed parties to bear their own costs [Paras 37].

Motor Vehicles Act – Compensation Calculation – Appellants challenged the reduction of compensation by the High Court – High Court had applied a split multiplier and did not account for future prospects – Supreme Court held that future prospects must be considered based on concrete evidence and rejected the High Court’s method of applying a split multiplier [Paras 3-15].

Future Prospects – Addition to Income – The Supreme Court emphasized the need to consider future prospects where there is clear evidence of expected salary increments – Referred to the Sarla Verma judgment to standardize addition to income for future prospects but recognized exceptions in cases with concrete evidence of future increments [Paras 8-10].

Calculation Methodology – Correct Multiplier – Rejected the split multiplier method adopted by the High Court – Confirmed the Tribunal’s use of a multiplier of 11, appropriate for the age of the deceased as per the II Schedule of the Motor Vehicles Act [Paras 14-15].

Decision: Appeals allowed – High Court’s judgment set aside – Compensation re-calculated considering future prospects and correct multiplier – Total compensation awarded: Rs. 18,00,000/- with interest as granted by the Tribunal [Paras 16-18].

Higher Education – Eligibility Criteria – State vs. AICTE Standards

The Supreme Court examined whether the eligibility criteria for engineering admissions set by the State Government/University could be more stringent than those prescribed by the AICTE. It was held that states and universities are entitled to set higher standards to maintain educational excellence, provided they do not adversely affect the standards set by the central body, AICTE [Paras 1-10].

Unfilled Seats – Not a Basis for Lowering Standards

The court clarified that unfilled seats in engineering courses do not justify lowering the eligibility criteria to meet AICTE's minimum standards. The focus should be on maintaining educational quality rather than merely filling seats. The existing state/university regulations on eligibility criteria continue to apply unless revised by the concerned authorities [Paras 11-13].

Judicial Review – Academic Standards

Determining academic standards is primarily within the domain of educational authorities and is beyond judicial review unless such standards are arbitrary or adversely affect those set by the central body. The court upheld the validity of higher eligibility criteria set by the state/university for maintaining educational excellence [Para 13].

Decision- Appeals Allowed- The orders of the Division Bench, which allowed admissions based on AICTE norms despite non-compliance with state/university standards, were set aside. However, considering the advanced stage of the respondents' education, the court regularized their admissions for the sake of justice, allowing them to complete their courses and take the examinations [Paras 14].

Medical Education – Eligibility Criteria – MCI vs. State Rules- The Supreme Court examined the conflict between the eligibility criteria for MBBS admissions prescribed by the MCI Regulations and the State Rules 2008. It held that the MCI Regulations prevail over the State Rules, and admissions made under the latter cannot be upheld if they do not conform to the former [Paras 9-11].

Discharge of Students – Fault of Rule-Making Authority- While upholding the MCI's statutory regulations, the court recognized that the admissions of the appellants were due to the fault of the rule-making authority (State Government) rather than the students themselves. Consequently, the court exercised its powers under Article 142 to do complete justice by not disturbing the appellants' admissions [Paras 12-14].

Power under Article 142- The court emphasized its constitutional power under Article 142 to pass orders necessary for doing complete justice, considering the facts and circumstances of each case. This power can override statutory provisions if needed to ensure fairness and justice [Paras 12-13].

Decision: Appeal Disposed- The court allowed the appeals, directed that the admissions of the appellants to the MBBS course for the academic year 2008-2009 would not be disturbed, and clarified that this decision should not be treated as a precedent. The appeal was disposed of with no order as to costs [Para 14].