Limitation Law – Condonation of Delay – Liberal Approach for State – Delay Condoned with Costs – The appellant challenged the High Court’s order condoning a 1537-day delay in filing a Second Appeal by the respondent-State – The Court acknowledged that though the law of limitation applies equally to the Government, in the peculiar facts involving valuable Government land and absence of mala fides, delay deserved to be condoned – COVID-19 and prior filing of a Review Petition were also considered as contributing factors to delay – Held: The delay is condoned subject to cost of Rs. 50,000 payable by the State to the appellant – Second Appeal to be heard on merits [Paras 12, 15, 18-22]. 
 
Discretionary Power – Section 5 of Limitation Act – Not Mandatory to Condone Delay 
Even if Cause Shown – Exercise of Discretion Must Consider Negligence and Due Diligence – The appellant argued that the State was negligent and failed to show sufficient cause; Court emphasized that discretion to condone delay under Section 5 is not automatic and must be exercised judicially – However, due to the nature of the land and interest of substantial justice, discretion was exercised in favor of State [Paras 7-9, 12, 15]. 
 
Possession of Government Land – Dispute Involving State and Private Party – Necessity of Adjudication on Merits – The Court observed that the land in question was recorded as Government land and remained in the State's possession, reinforcing the need for a decision on merits rather than on limitation grounds alone – Suit originally dismissed, reversed in appeal, warranting further judicial scrutiny [Paras 1112]. 
 
Delay in Filing Review and Appeal – Two-Step Delay Considered Collectively – The Court accepted that a substantial portion of the delay was due to prior attempt to file a Review Petition, followed by Second Appeal filing delay due to pandemic – The delay from 2015 to 2020 was thus analyzed holistically [Paras 10, 12, 15]. 
 
Judgment – Appeal Dismissed – High Court Order Condoning Delay Upheld – Costs Imposed – The Supreme Court upheld the High Court’s order condoning the delay in filing Second Appeal – However, imposed costs of Rs. 50,000 to be paid by the State within one month, failing which the Second Appeal would be dismissed – Liberty granted to both parties to contest on all grounds before the High Court [Paras 19-23]. 
 

Land Acquisition – Sovereign Power of Eminent Domain – Private Settlement Impermissible – The appellant, a statutory board, challenged an arbitral award enforcing a private agreement that returned part of the acquired land to the original owner – The Supreme Court held that once land is acquired under the Land Acquisition Act, 1894, it vests absolutely in the Government and cannot be returned through a private settlement – Held: A statutory beneficiary of land acquisition cannot override the sovereign power of eminent domain by entering into a private contract to reverse the acquisition process [Paras 16-18].

Arbitral Award Against Public Policy – Contravention of Fundamental Principles of Law – The Court found that the arbitral award, which upheld the private settlement, was in clear violation of statutory provisions governing public acquisitions – Under Section 34(2)(b) of the Arbitration and Conciliation Act, an arbitral award that contradicts the fundamental policy of Indian law can be set aside – Held: The award, which sought to nullify a lawful public acquisition through an illegal private agreement, was contrary to public policy and had to be set aside [Paras 15-17].

Land Vested in Government – No Right to Reverse Acquisition – The land was acquired in 1963 and possession was taken in 1986 – The Delhi Agricultural Marketing Board, as the beneficiary, attempted to return part of the land to the original owner through an agreement in 1988 – The Court held that once possession is taken, the land vests in the Government absolutely under Section 16 of the Land Acquisition Act, 1894 – Held: Even the Government itself could not withdraw from the acquisition after possession was taken, making the Board’s agreement legally untenable [Paras 13-14].

Fraudulent Transaction – Lack of Authority in Chairman’s Actions – The agreement was executed one day before the Chairman’s tenure ended, without proper approval from higher authorities – The Court noted that the preparation of the agreement, including the purchase of stamp papers, took place before the Board even discussed the matter – Held: The transaction was conducted in undue haste, raising serious doubts about its legality and propriety [Paras 17-18].

Judicial Oversight in Arbitration – Failure to Apply Public Policy Test – The Court found that neither the Delhi High Court’s single judge (under Section 34 of the Arbitration Act) nor the Division Bench (under Section 37) properly examined whether the arbitral award violated public policy – Held: Courts must scrutinize arbitral awards to ensure they do not contravene statutory provisions or the fundamental legal framework of the country [Paras 18-19].

Decision: Appeal allowed. The judgment of the Division Bench of the Delhi High Court in FAO (OS) No. 436 of 2013, the judgment of the Single Judge in OMP No. 561 of 2007, and the arbitral award dated 10.07.2007 were set aside. Pending applications were disposed of, and parties were directed to bear their own costs.

Service Law - Pensionary Benefits – Parity with Regular Government Employees – The respondents, appointed under a temporary scheme, sought pension benefits equivalent to permanent government employees – The State contended that they were governed by the Contributory Provident Fund (CPF) Scheme and were not eligible for pensions – Held: The employees were entitled to pension since their service conditions were aligned with those of regular employees, and the government had made a conscious decision to grant retiral benefits [Paras 14-16].

Government Policy Decisions – No Discrimination Among Similarly Placed Employees – The respondents relied on government communications from 1997 and 1998, which stated that their service conditions were to be governed by rules applicable to the Cane Development Department – The Supreme Court upheld the High Court’s view that once a policy decision had been taken to extend benefits, selective denial was impermissible – Held: Employees cannot be denied pension when similarly placed employees have already been granted the benefit [Paras 12-14].

Limitation on Arrears – Doctrine of Continuing Wrong – The State argued that the claim was delayed, and employees had already withdrawn their CPF dues – The Supreme Court applied the principle of a continuing wrong, holding that pension rights do not lapse due to delay, but limited arrears to three years before the filing of the writ petition – Held: Pension granted, but arrears restricted to three years prior to the petition date [Para 19].

Contributory Provident Fund Withdrawal – Deduction from Pension Arrears – The respondents had withdrawn CPF amounts upon retirement, leading the State to argue that they were estopped from claiming pension – The Court ruled that CPF withdrawals must be deducted from pension arrears but did not bar pension entitlement – Held: The amount received under CPF to be adjusted against arrears before pension payments commence [Paras 20-21].

Decision: Appeal dismissed, except for restricting pension arrears to three years before the writ petition filing date and permitting deduction of CPF withdrawals from arrears. Pension benefits to be implemented within one month.

Criminal Law - Appeal against acquittal - Confessional Statements under TADA – Voluntariness and Procedural Safeguards – Rejection Upheld – The Supreme Court reaffirmed that strict compliance with Section 15 of TADA and Rule 15 of TADA Rules is essential to admit confessions – The confessional statements of three accused recorded by a single officer were held inadmissible due to failure to give reflection time, lack of questions and answers, absence of production details, and recording in custodial military settings – Held: Procedural violations rendered confessions inadmissible [Paras 22–26].

Issue Estoppel – Prior Acquittal in Separate Case – Confession Already Rejected – Confessional statement of Mohd. Salim Zargar had been previously rejected in an earlier trial and became final – The Court held that the principle of issue estoppel barred the prosecution from relying on the same confession in a fresh trial – Held: Statement rightly rejected by Special Court; its admission would disturb final finding of fact [Paras 22.3–24].

Evidence – Lack of Corroboration – Eyewitnesses Non-Identifying – Weapon Not Recovered – The eyewitnesses failed to identify the accused and the AK-47 rifle used in the murders was not recovered – Confessions being inadmissible, no independent evidence remained to support conviction – Held: Acquittal justified as prosecution failed to prove guilt beyond reasonable doubt [Paras 9–11, 28].

Decision – Appeals Dismissed – Acquittal Upheld – The Supreme Court upheld the Special Court's decision acquitting the accused – It held that confessions were improperly recorded and inadmissible, and prosecution failed to establish guilt through independent evidence – No case made out to reverse the order of acquittal – Held: Criminal Appeals 1681 and 1770 of 2009 dismissed [Paras 27–33].
 

Criminal Law - Penal Code – Section 302 vs. 304 Part II – Medical Evidence Inconclusive – Conviction Altered – The Supreme Court upheld the High Court’s reduction of conviction from Section 302 read with 149 IPC to Section 304 Part II – Held: Post-mortem report and doctor’s deposition failed to conclusively establish death resulted from injuries caused by the accused – Death occurred 15 days after assault; no poison detected; cause of death noted as asphyxia but reason unknown [Paras 12–14].

Sentencing Policy – Age and Delay Considered – Sentence Reduced to Time Undergone – The High Court sentenced respondents to time already served (76 days) due to incident being over 28 years old at the time of judgment and advanced age of accused (70–80 years) – Fine of ₹16,000 each imposed, part of which directed as compensation – Held: In view of the long lapse of time and mitigating circumstances, no interference warranted [Paras 10, 14].

Criminal Appeals Management – Need for Prioritisation – Pendency and Accused on Bail – Court issued observations stressing need to prioritise old criminal appeals where accused are on bail – Held: Delayed disposal may result in impractical consequences of re-incarceration after decades – Appeals involving elderly or long-pending cases should also be heard expeditiously [Paras 15–16].

Decision – Appeal Dismissed – Conviction under Section 304 Part II IPC Sustained – Supreme Court found no error in High Court's reasoning or evaluation of medical evidence – Held: No justification to interfere with sentence or findings of fact; appeal stands dismissed [Para 16].
 

Taxation Law - Corporate Insolvency – Resolution Plan and Tax Demands – Binding Effect under Section 31 of IB Code – Tax Demands Set Aside - The Supreme Court held that once a resolution plan is approved by the Adjudicating Authority (NCLT), all claims not part of the plan stand extinguished – Income tax demands for AYs 2012-13 and 2013-14, which were not submitted prior to approval and were not part of the resolution plan, were thus invalid – Held: Demands raised by the Income Tax Department post-approval are extinguished and unenforceable under Section 31(1) of the IB Code as interpreted in Ghanashyam Mishra [Paras 5-9].

Binding Nature of Resolution Plan – Extinguishment of Undisclosed Claims – Fresh Start Doctrine – Tax Claims Invalid - Court reinforced that successful resolution applicants are entitled to a “fresh slate” – The inclusion of belated or undisclosed claims would undermine certainty and business revival under the IB Code – Held: All statutory dues not claimed before CIRP and not part of the approved plan are extinguished [Paras 7-13].

Failure of NCLT and NCLAT – Ignorance of Binding Precedent – Orders Set Aside - The NCLAT erroneously refused to consider binding precedent from the Supreme Court merely because it was not cited before the NCLT – Supreme Court rebuked this approach as perverse and unjustified – Held: Orders of both NCLT and NCLAT set aside; costs imposed by NCLT also quashed [Paras 9-10, 14].
 

Service Law – Eligibility Criteria – Interpretation of 'Degree' under FSS Act and UGC Act – Postgraduate Degree Acceptable – The term ‘degree’ used in Rule 2.1.3 of the FSS 2011 Rules includes Bachelor’s, Master’s, or Doctorate degrees – Held: A candidate possessing a Master’s degree in the specified subjects (except Chemistry, which specifically requires a Master’s) is eligible – Exclusion of Master's degree holders was arbitrary and contrary to statutory provisions [Paras 22-34].

Recruitment Process – State Government’s Limited Role – Qualifications Governed by Central Rules – The Court clarified that only the Central Government has the authority to prescribe qualifications for Food Safety Officers under Sections 37 and 91 of the FSS Act – Held: The State Government cannot restrict eligibility contrary to centrally prescribed rules [Paras 23-27].

Statutory Interpretation – Literal and Harmonious Construction – Rule 2.1.3 of FSS 2011 Rules – Interpreted to Include Master’s and Doctorate Degrees – The Court applied the golden rule of interpretation to conclude that excluding higher degrees from eligibility was unconstitutional and illogical – Held: Master’s degree in specified subjects is sufficient [Paras 29-32].

Relief – Supernumerary Appointments – No Back Wages – Seniority Below Original Appointees – The Court set aside High Court rulings and allowed appellants to rejoin the 2016 recruitment process from the interview stage – Directed creation of supernumerary posts if necessary – Appointments to be without back wages but with notional seniority below existing appointees [Paras 35(i)-(iv)].

Decision – Appeal Allowed – High Court Judgments Set Aside – The Supreme Court held that the appellants, possessing Master’s degrees in eligible subjects, were fully qualified under the applicable rules – It quashed the orders of the learned Single Judge and Division Bench of the Jharkhand High Court – Directed that appellants be allowed to participate in the selection process from the interview stage with notional benefits and no back wages [Paras 34-35].

Administrative Law – Nature of Control – Deep and Pervasive Control Not Established – Court held that ICSSR’s control over CRRID is limited to funding and regulatory oversight under Grant-in-Aid Rules – Presence of nominees on CRRID's Governing Body does not amount to deep and pervasive control – Held: CRRID is an autonomous private society, not a ‘State’ under Article 12; High Court erred in holding otherwise [Paras 13–17].

Grant-in-Aid – Withholding of Grants for Rule Violations – ICSSR Action Justified – Following audit findings of irregular appointments, fake degrees, and misuse of funds, ICSSR withheld grants as per Rule 6 of Grant-in-Aid Rules – Court held ICSSR was justified in its decision to suspend disbursement from April 2021 to March 2023 – Held: Grant-in-aid is discretionary and cannot be claimed as a right; institutions must comply with prescribed conditions [Paras 18–22].

Employment Law – No Master-Servant Relationship Between ICSSR and CRRID Employees – Court ruled that respondents were employees of CRRID, not ICSSR – There was no privity of contract between them and ICSSR – Held: Employees cannot claim salaries directly from ICSSR; responsibility lies with CRRID [Paras 24–26].

Judicial Review – Compassionate View vs. Legal Liability – High Court Orders Set Aside – Court observed that although the High Court took a compassionate view, legal responsibility for paying salaries lies with CRRID – Held: Orders of Single Judge and Division Bench directing ICSSR to release funds are unsustainable in law [Paras 13, 26–28].

Decision – Appeals Allowed – High Court Orders Set Aside – Supreme Court directed CRRID to pay salaries from its own resources for April 2021 to March 2023 – ICSSR permitted to withhold future grants if compliance is not shown – Amount deposited by ICSSR in court to be returned – Held: ICSSR not liable to fund CRRID salaries under law [Paras 28–30].

Consumer Law – Definition of ‘Consumer’ – No Privity of Contract – Complaint Not Maintainable – The Court held that the respondent had no direct contractual relationship with the appellant – Held: The complainant, not being a party to the home loan agreement, and with no established privity of contract, does not qualify as a ‘consumer’ under the Consumer Protection Act, 1986 – High Court erred in assuming existence of a Tripartite Agreement unsupported by evidence [Paras 12, 16–17, 21].

Consumer Forum Jurisdiction – Deficiency of Service – Lack of Evidence and Improper Inference – No Deficiency Proved – NCDRC’s reliance on a partly blank, unsigned, and unstamped document as a Tripartite Agreement was unjustified – Burden of proving its existence was wrongly placed on the appellant – Held: Adverse inference should have been drawn against the complainant for non-production of valid agreement [Paras 11, 16].

Limitation – Delay of Over 10 Years – No Reasoned Order of Condonation – Complaint Barred – The complaint was filed in 2018 for cause of action arising in 2008 – Held: NCDRC failed to record any reason for condoning delay as mandated under Section 24A of the Act – Complaint was time-barred and not maintainable [Paras 21–22].

Necessary Party – Non-joinder of Borrower – Complaint Incomplete – The borrower, being central to the transaction and the only party linked to both the complainant and appellant, was not made a party – Held: Borrower was a necessary party and failure to implead him rendered adjudication incomplete [Paras 23].

Arbitration Clause – No Bar for Consumer Forum – Subject to Choice of Consumer – The Court reiterated that in consumer matters, the option to invoke arbitration must rest solely with the consumer – However, as respondent was held not to be a consumer, this principle was inapplicable in the present case [Paras 24–25].

Decision – Appeal Allowed – NCDRC Order Set Aside – The Supreme Court found that the respondent was not a consumer, the claim was time-barred, and the borrower was not made a party – Held: Complaint not maintainable; appellant not liable to pay disputed amount – Appeal allowed, parties to bear their own costs [Paras 26–27].