Land Acquisition – Lapse of Proceedings – High Court declared acquisition proceedings lapsed under Section 24(2) of the 2013 Act due to non-taking of possession and non-payment of compensation – Supreme Court holds High Court erred, citing Indore Development Authority case – Appeal allowed [Paras 1-7].

Litigation Impact – Acquisition proceedings subject to prolonged litigation – Authority could not take possession due to pending legal challenges – Non-taking of possession not to benefit landowners in such context [Para 6.2].

Decision – Appeal allowed – High Court’s judgment quashed – Acquisition proceedings upheld [Para 7].

Tax Law – Concessional Rate of Tax – High Court granted concessional tax rate of 2% for oxygen gas used in steel manufacturing by Tata Steel, treating it as raw material – Supreme Court held that oxygen gas is a refining agent and not a raw material – Appeal allowed [Paras 1-12].

Expert Committee Findings – Detailed inspection report by six-member expert committee found oxygen gas to be a refining agent in steel manufacturing – High Court erred in interfering with these findings under Article 226 [Paras 6-7].

Decision – Appeal allowed – High Court’s judgment quashed – Assessment order by assessing officer reinstated [Para 12].

Land Acquisition – Lapse of Proceedings – High Court's order declaring the lapse of acquisition proceedings under Section 24(2) of the 2013 Act due to non-tendering of compensation to the original writ petitioner – Supreme Court holds that the High Court erred in its reliance on the overruled Pune Municipal Corporation case – Appeal allowed [Paras 1-3].

Subsequent Purchaser – Locus Standi – High Court erred in entertaining writ petition by a subsequent purchaser challenging acquisition proceedings under the 2013 Act – Supreme Court clarifies such claims are not maintainable [Para 2.1].

Compensation and Possession – Constitution Bench judgment in Indore Development Authority case clarifies that if either possession is taken or compensation paid, there is no lapse of proceedings under Section 24(2) of the 2013 Act – High Court's reliance on the lack of compensation payment alone is incorrect [Para 2.2].

Decision – Appeal allowed – High Court’s judgment quashed – Acquisition proceedings upheld [Para 3].

Anticipatory Bail – ISRO Spy Case – High Court granted anticipatory bail to respondents without considering the allegations, roles, or recommendations by Justice D.K. Jain Committee – Supreme Court quashes High Court’s order – Cases remanded for fresh consideration [Paras 1-9].

Role and Allegations – High Court failed to assess the specific roles and positions held by the accused at the time of the original investigation and the nature of allegations – Required fresh evaluation by the High Court [Paras 4-5].

Judicial Recommendations – High Court ignored the recommendations of the Committee headed by Justice D.K. Jain – New FIR registered based on these recommendations – Necessity to consider these factors in bail decisions [Para 5].

Decision – Appeal allowed – High Court’s judgment granting anticipatory bail quashed – Matter remanded for fresh consideration in accordance with law [Para 7].

Land Acquisition – Lapse of Proceedings – High Court's order declaring the lapse of acquisition proceedings under Section 24(2) of the 2013 Act due to non-tendering of compensation to the original writ petitioner – Supreme Court holds that the High Court erred – Appeal allowed [Paras 1-4].

Judicial Precedent – Overruled Case Law – High Court relied on Pune Municipal Corporation case, which has been overruled by the Constitution Bench in Indore Development Authority case – Acquisition proceedings cannot be deemed lapsed if either possession is taken or compensation is paid [Para 3].

Decision – Appeal allowed – High Court’s judgment quashed – Acquisition proceedings upheld [Para 4].

Land Acquisition – Lapse of Proceedings – High Court's order declaring the lapse of acquisition proceedings under Section 24(2) of the 2013 Act due to non-tendering of compensation to original writ petitioner – Supreme Court holds that the High Court erred – Appeal allowed [Paras 1-3].

Subsequent Purchaser – Locus Standi – High Court erred in holding that the writ petition by a subsequent purchaser challenging the acquisition proceedings was maintainable – Referenced recent Supreme Court decisions clarifying that subsequent purchasers have no locus standi [Para 2.1].

Compensation and Possession – Constitution Bench judgment in Indore Development Authority case clarifies that if either possession has been taken or compensation paid, there is no lapse of proceedings under Section 24(2) of the 2013 Act – High Court's reliance on the lack of compensation payment alone is incorrect [Para 2.2].

Decision – Appeal allowed – High Court’s judgment quashed – Acquisition proceedings upheld [Para 3

Service Law – Appointment Denial – Candidate denied appointment on the sole ground of being tried for an offence under Section 498A IPC despite acquittal – High Court erred in denying appointment – Appeal allowed [Paras 1-9].

Acquittal and Employment – Previous trial under Section 498A IPC resulted in acquittal due to settlement – No suppression of facts by candidate – Employment denial solely on past trial deemed unjustified – High Court's reliance on Avtar Singh case misplaced as facts differ significantly [Paras 6-8].

Decision – Appeal allowed – High Court’s judgment quashed – Appellant to be appointed as Police Constable – Entitled to benefits from the date of actual appointment only [Para 9].

Land Acquisition – Lapse of Proceedings – High Court relied on Pune Municipal Corporation decision to declare land acquisition lapsed due to non-tendering of compensation – Supreme Court held reliance unsustainable as Pune Municipal Corporation overruled by Indore Development Authority – Possession of land taken in 2012 and compensation deposited due to apportionment dispute – Appeal allowed, High Court judgment quashed [Paras 1-3].

Compensation and Possession – Constitution Bench in Indore Development Authority clarified that non-deposit of compensation in court does not cause acquisition lapse – Possession taken and compensation tendered sufficient to avoid lapse – Acquisition proceedings not invalidated by non-deposit in court treasury [Paras 2-3].

Precedents Overruled – Pune Municipal Corporation and related decisions overruled by Indore Development Authority – Compensation tendering and possession taking evaluated under clarified legal standards – High Court decision based on overruled precedent set aside [Para 3].

Decision: Civil Appeal allowed – High Court judgment declaring acquisition lapse quashed – Possession and compensation actions upheld – No costs [Para 3].

Civil Procedure – Indigent Person Application – Trial Court and High Court rejected the application to sue as indigent persons, citing lack of cause of action and res judicata – Supreme Court upheld rejection under Order 33 Rule 1 CPC but granted appellants time to pay requisite court fees to proceed with the suit – Observations on res judicata and cause of action limited to indigent person application, not affecting merits of the suit [Paras 1-6].

Rejection Grounds – Cause of Action and Res Judicata – Order 33 Rule 5 CPC allows rejection of indigent person application if no cause of action or suit is barred by law – Prima facie findings of no cause of action and res judicata justify rejection – Appellants granted opportunity to pay court fees and pursue suit [Paras 6-6.5].

Procedure for Indigent Persons – On rejection of indigent person application, court may grant time for payment of court fees – Upon payment, suit deemed instituted on original application date – Defendants may file appropriate applications, including under Order 7 Rule 11 CPC, for plaint rejection [Paras 6.6-6.6].

Decision: Appeal disposed of – Appellants granted four weeks to pay court fees – Suit deemed instituted on original application date – Observations on res judicata and cause of action confined to indigent person application – Defendants may seek plaint rejection under Order 7 Rule 11 CPC [Para 6.6].