Electricity Act - Power Purchase Agreement – Delay in Transmission Infrastructure – No Automatic Relief – Appeal Allowed - Appellant invoked bank guarantee for delay in project commissioning by Respondent Developer due to non-readiness of transmission lines by KPTCL – Held: Contractual provisions require formal extension request under Article 5.7 or Force Majeure notice under Article 14.5 – No such compliance by Developer – Hence, invocation of bank guarantee by CESC valid and lawful – Delay attributable to KPTCL does not qualify as Force Majeure under the PPA [Paras 36-40].

Force Majeure Clause – Notice Mandatory – Delay Not Covered – Finding Reversed - Supreme Court held that Article 14.5 of the PPA mandates a Force Majeure notice within 7 days – No such notice was issued – Delay in transmission readiness does not fall within defined Force Majeure events – Developer’s plea rejected – APTEL and State Commission erred in granting relief despite non-compliance [Paras 39-40].

Jurisdiction of State Commission and APTEL – No Power to Rewrite Contract – Appeal Allowed - Held: Regulatory authorities cannot alter risk allocation, renegotiate tariffs, or order refund of performance guarantees outside contract – Interpretation must follow express terms of the PPA concluded through competitive bidding – Equity or fairness cannot override commercial contract [Paras 42-43].

Contingent Contract – Completion of Transmission Work Not Condition Precedent – Developer Obligated – Developer’s failure to commission project due to KPTCL’s delay does not convert PPA into a contingent contract – Relief lies only through mechanisms provided in PPA – Not availed – No exemption from obligation [Paras 41-42].

Judgment – Relief – APTEL and State Commission Orders Set Aside - Supreme Court set aside orders granting extension, restoring bank guarantee and allowing tariff renegotiation – Held: Invocation of performance guarantee by CESC was in line with Article 4.4 of PPA – Appeal allowed [Paras 44-45].

Motor Accident Claim – Compensation Reduction – 100% Disability – Quantum Enhanced - The appellant, a 21-year-old student, suffered 100% permanent disability in a bus accident and was initially awarded ₹67,83,866 by the Claims Tribunal – The Madras High Court reduced the compensation by ₹19 lakhs holding certain heads excessive – Held: The Supreme Court restored and enhanced compensation under various heads including future medical expenses, attendant charges, and loss of amenities – Reduction by High Court unjustified [Paras 1-4, 8].

Future Medical Expenses – Reasonable Estimation – Life Expectancy Considered – Quantum Enhanced - The High Court reduced ₹9 lakhs awarded by the Tribunal to ₹2 lakhs for future medical expenses without proper justification – Held: Considering claimant’s young age and permanent vegetative state, enhancement to ₹15 lakhs warranted – Investment of part amount would suffice to meet recurring medical needs [Paras 8-9].

Attendant Charges – Life-long Support – Permanent Disability – Enhanced Award - The High Court reduced ₹6 lakhs granted by the Tribunal to ₹3 lakhs without assigning valid reasoning – Held: Considering evidence of severe disability and need for lifelong support, compensation enhanced to ₹10 lakhs towards attendant charges [Paras 11].

Loss of Enjoyment and Amenities – Arbitrary Deduction – Compensation Restored - ₹3 lakhs awarded by the Tribunal for loss of enjoyment of life and amenities was wrongly set aside by the High Court without reasons – Held: Award restored in view of total loss of normal life and permanent incapacitation [Para 10].

Family Pain and Suffering – Valid Head – Reinstated - The Tribunal awarded ₹3 lakhs for pain and suffering of family members based on a coordinate Bench precedent – Held: High Court erred in ignoring settled precedent – Award restored [Para 12].

Permanent Disability – Distinct from Loss of Income – Compensation Justified - The High Court wrongly set aside ₹3 lakhs awarded for permanent disability on the ground of loss of income compensation – Held: Both are distinct heads – Quantum enhanced to ₹5 lakhs [Para 13].

Decision – Compensation Enhanced – Appeal Allowed – Supreme Court held that the claimant is entitled to ₹82,83,866 with 7.5% interest – Directions issued for payment within four weeks – High Court judgment set aside [Paras 14-15].

Civil Law – Consumer Protection – Execution of Orders – Appellant society challenged the order of the National Commission holding execution revision petitions to be not maintainable – Core issue related to whether Section 25 of the Consumer Protection Act, 1986 (post 2002 Amendment) permitted enforcement of final orders – Court found that substitution of “every order” with “interim order” in Section 25(1) of the 1986 Act created an anomalous situation from 15.03.2003 to 20.07.2020 – Held: provision suffered from a drafting error – Applying purposive interpretation, Section 25(1) must be read as permitting enforcement of “any order” as if it were a civil court decree – This interpretation applies to all pending execution petitions during the said period [Paras 18–27, 38].

Consumer Protection Act – Nature of Code – The 1986 Act and 2019 Act are self-contained codes – Both provide remedies for adjudication, enforcement, penalties, and appeals – Even if not explicitly stated, Fora under the Act must be deemed to possess powers necessary to implement their orders – Substitution in 2002 created inconsistency, but legislative intent was always to ensure enforceability of all orders [Paras 11, 12, 13, 14, 15].

Interpretation of Statutes – Drafting Error – Use of the term “interim order” in Section 25(1) of the 1986 Act was erroneous – Court applied purposive construction and casus omissus principles to correct the error – Held that “any order” must be read in place of “interim order” – Sub-section (1) must also be read as incorporating CPC Order XXI provisions for enforcement, in line with pre-2002 and post-2019 schemes [Paras 19–24, 25–27].

Execution Proceedings – Remedy – Against order of District Forum in execution, appeal lies to State Commission under Section 15 – Against order of State Commission in execution, no further appeal/revision lies to National Commission – Similarly, no appeal lies to Supreme Court against execution orders of National Commission – Aggrieved parties may avail extraordinary constitutional remedies before High Court – Revision jurisdiction cannot be invoked in execution matters [Paras 28, 31–37, 38.1–38.2].

Directions – Court directed NCDRC to take steps for expeditious disposal of thousands of execution petitions pending since 1992 – Observed that justice must be meaningful and not merely a paper decree [Paras 29–30].

Decision – Civil appeals disposed of – Section 25(1) of the 1986 Act shall be read as permitting enforcement of “any order” for the period 15.03.2003 to 20.07.2020 – Appeals against execution orders limited only from District Forum to State Commission – No further appeal/revision lies thereafter [Paras 38–39].

Service Law – Recruitment Process – Cancellation of Earlier Notification – Fresh Notification Valid – The erstwhile AP-Transco had initiated a recruitment process in 2011-12 which could not be completed due to litigation over weightage marks – Upon bifurcation of the State, TS-Transco issued a fresh notification in 2017 for Sub-Engineer (Electrical) posts and cancelled the earlier one – High Court held such cancellation illegal – Supreme Court held: Decision to cancel earlier selection was valid in view of (i) unresolved litigation, (ii) bifurcation of the State, and (iii) liberty granted by the High Court in 2017 order to take an independent decision – Impugned High Court judgment set aside [Paras 2–3, 12–13, 21–23, 33–34].

Recruitment Zones – Change in Structure and Reservation Policy – No Continuity with Earlier Process – Earlier zones in united Andhra Pradesh were different from the North-South bifurcation in Telangana under new notification – Number of posts and reservation ratios were also revised – Held: Selection in Telangana cannot be treated as continuation of earlier process – No obligation to recruit from old select list [Paras 24–26].

Vested Right – No Right to Appointment from Select List – Doctrine of Legitimate Expectation – Mere selection in a process does not confer a vested right to appointment – TS-Transco considered legitimate expectations by extending age relaxation in new notification – Held: Adequate accommodation provided, no interference warranted – Judicial review cannot dictate extent of policy leniency [Paras 27–29].

Judicial Review – Scope – Policy Decisions Post Bifurcation – Courts Should Not Interfere – Cancellation of recruitment based on administrative and legal necessity cannot be interfered with unless mala fide – TS-Transco acted in accordance with law and considered all stakeholders – Held: High Court’s interference unjustified and contrary to settled principles [Paras 20–23, 30–32].

Distinction with Other Posts – Section 79, AP Reorganisation Act – Protection to Appointees Only – Appointments made to other posts (Junior Assistant, Junior Lineman) were upheld because appointments were already made – Section 79 protects vested rights, not expectations – Writ petitioners in present case were not appointed – Held: Section 79 does not apply to mere selectees [Paras 31–32].

Decision – Appeals Allowed – High Court Judgment Set Aside – Validity of Notification dated 28.12.2017 upheld – Fresh selection by TS-Transco to proceed – Appeal by unqualified candidates (SLP(C) No.12599/2020) dismissed – Pending applications disposed of [Paras 33–36].

Forest Service Law – Promotion to IFoS – Interpretation of Rule 2(g), IFS Recruitment Rules, 1966 – FROs as State Forest Service – The appellant, a Forest Range Officer (later promoted as Assistant Conservator of Forests), claimed that FRO service constituted part of “State Forest Service” and thus entitled to consideration for promotion to IFoS – Held: Approval under Rule 2(g) relates to the service as a whole and not individual posts – Andhra Pradesh Forest Service Class A, including FROs and ACFs, being a gazetted cadre connected with forestry, qualifies as “State Forest Service” subject to approval – Members eligible for consideration if substantive and with 8 years’ service [Paras 6-13].

Delay and Laches – Relief Denied for Past Exercises – The appellant completed 8 years of service in 2014 but made representation only in 2021 – Held: Though legal position clarified in his favour, he cannot claim retrospective consideration for earlier recruitment years – Relief confined to future selection exercises – Reliance placed on P.S. Sadasivaswamy v. State of T.N., (1975) 1 SCC 152 [Paras 18-20].

Promotion – Zone of Consideration – Seniority to be Respected – Though declaration obtained, appellant not entitled to bypass senior officers in zone of consideration – Claim restricted to participation in future selection processes as per rules [Paras 16-20].

Decision – High Court Judgment Set Aside – Tribunal’s View Restored in Principle – Appeal allowed partly – Held: Andhra Pradesh Forest Service (Class A, including FROs) constitutes “State Forest Service” – FROs eligible for promotion to IFoS if otherwise qualified – However, appellant’s claim for earlier years rejected – Authorities directed to treat FROs as State Forest Service in future IFoS selection exercises [Paras 21-23].

Suo Moto - Stray Dog Menace – Suo Moto Action by Supreme Court – Direction to Relocate and Shelter Dogs – Reconsidered – Taking suo moto cognizance of media reports on fatal dog attacks in Delhi-NCR, the Court initially directed municipal authorities to capture and permanently shelter all stray dogs without release – Subsequently, upon challenge by animal welfare organizations citing Rule 11(19) of ABC Rules, the Court partially modified the earlier order, holding that sterilised and immunised dogs (except those with rabies or aggressive behavior) must be released back to their original localities – Direction to prohibit their release was kept in abeyance [Paras 1-33].

Balancing Fundamental Rights – Article 21 vs. Article 19 – Public Safety Prevails – The Court held that interim restrictions on stray dogs' release and regulation of public feeding did not infringe Article 19 rights of animal lovers – Emphasised that protecting the Right to Life under Article 21 of citizens, particularly children and elderly, must be paramount – Directed strict compliance with modified orders and warned of legal action against obstruction by individuals or NGOs [Paras 13, 17, 33(f)].

Animal Birth Control Rules – Rule 11(19) Clarified – Immunised Dogs to be Released Unless Rabid – The Court upheld the essence of Rule 11(19) providing for release of treated dogs to original areas – But carved out exception that dogs displaying rabid symptoms or aggression should be isolated in separate pounds post-treatment – Rejected blanket ban on street return for all dogs [Paras 24-28, 33(b)].

Feeding Stray Dogs – Designated Zones Introduced – Street Feeding Banned – Directed creation of official dog feeding zones in every municipal ward with proper signage – Banned feeding in open streets to prevent public nuisance and danger – Violators to be prosecuted under relevant laws – Dedicated helpline numbers to report violations to be created by all municipal bodies [Paras 33(d)-(e)].

Nationwide Implementation – Scope Expanded Beyond NCR – Recognizing the pan-India nature of stray dog issues, all States and UTs were impleaded through Animal Husbandry and local body Secretaries – Directed Registrar Generals of High Courts to inform about similar pending cases to consider their transfer for uniform handling by Supreme Court [Paras 34-36].

Final Directions – Previous Ban Modified – Partial Lifting of Shelter-only Condition – Aggressive dogs not to be released – Municipal authorities directed to submit compliance reports including availability of personnel, infrastructure, vehicles, and medical professionals – Monetary cost imposed on NGOs and individuals seeking intervention to ensure accountability [Paras 33(g)-(i), 37].

Election Petition – Defect in Form 25 Affidavit – Maintainability Challenged – Curable Defect – The appellant objected to the maintainability of the election petition on grounds of a defective or absent affidavit in Form 25 supporting allegations of corrupt practices – High Court allowed the respondent to cure the defect post-filing – Supreme Court held that while substantial compliance is sufficient, the High Court failed to analyse whether such compliance existed or whether defect could be cured beyond limitation – Held: Matter remanded to High Court to decide afresh after examining nature and curability of defect [Paras 12–24].

Substantial Compliance – Filing of Affidavit – Proviso to Section 83(1)(c), RP Act – Not Mandatory in Rigid Sense – The affidavit accompanying allegations of corrupt practices must substantially conform to Form 25 – Absence of precise format is not fatal if substantial requirements are met – Court clarified that even if defective, opportunity must be granted to cure defects before trial – Held: Strict compliance not mandatory – Liberal interpretation preferred as per evolving jurisprudence [Paras 15–18].

Scope of Rejection – Order VII Rule 11 CPC – Rejection at Threshold Not Justified – Where the affidavit, though not in strict format, indicates intention and substance of compliance, rejection of petition under Order VII Rule 11 CPC is unwarranted – Allegations of corrupt practices and electoral irregularities must be tried if they disclose triable issues – Held: High Court was justified in not rejecting the petition outright, but must apply proper scrutiny [Paras 6–8, 22–24].

Procedure and Scrutiny – High Court Rules and Affidavit Examination – Rules 7 and 21, Chapter XXXIII – Affidavit and petition to be scrutinised by designated officer before admission – Court noted that it was unclear whether proper scrutiny and defect-notification took place at time of filing – Held: High Court must consider if initial scrutiny was conducted and if curative opportunity was rightly given before limitation expired [Paras 20–21].

Direction for Remand – High Court to Determine Preliminary Issues – Supreme Court remitted matter to High Court with specific directions to (i) identify defects in the affidavit, (ii) decide whether they were curable, and (iii) assess whether curative action beyond limitation is permissible – Held: High Court to also strike out pleadings agreed by parties and proceed on merits thereafter [Para 24].

Decision – Appeal Disposed – Matter Remitted to High Court – Parties allowed to amend pleadings post deletion – All pending applications also disposed of – Directions issued for efficient disposal of election dispute [Paras 24–26].

Civil Law -  – Additional Evidence – Order XLI Rule 27(1) CPC – Mandatory Pleading Requirement – High Court’s Error – High Court reversed the Trial Court’s decree for specific performance by accepting additional evidence submitted by the defendant – However, the Supreme Court held that before allowing additional evidence, the Appellate Court must examine whether such evidence is supported by pleadings in the written statement – Held: Failure to undertake this threshold scrutiny invalidates the appellate judgment – High Court erred in admitting evidence not grounded in defendant’s pleadings [Paras 5.5, 6, 8, 9].

Contract Law – Specific Performance – Agreement of Sale – Pleading and Proof of Readiness and Willingness – Trial Court rightly decreed specific performance based on plaintiffs’ evidence and performance under the contract – The High Court wrongly reversed this without properly assessing the defendant’s pleadings and the legality of admitting new evidence – Held: Matter remanded for fresh consideration [Paras 2.5, 2.6, 5.3, 10].

Evidence – Signature Dispute – Section 73, Indian Evidence Act – Improper Use by High Court – The High Court erred in comparing signatures under Section 73 without proper foundation and contrary to the Trial Court's factual findings – Held: Comparison of signatures was not permissible in the manner adopted – Judgment vitiated [Para 4].

Decision – Judgment Set Aside – Matter Remanded – Supreme Court set aside the judgment of the High Court dated 30.12.2008 and remanded the matter for fresh consideration – Clarified that it had expressed no opinion on merits – Requested High Court to decide the matter expeditiously considering the long pendency since 1997 [Paras 10-12].

Environmental Law - Environmental Clearance – Sand Mining – District Survey Report – Supreme Court reiterated that replenishment studies are mandatory for valid DSRs and therefore essential for granting Environmental Clearance (EC) – Following Deepak Kumar v. State of Haryana (2012) 4 SCC 629, and reaffirming Satendra Pandey v. MoEFCC, 2018 SCC OnLine NGT 2388, the Court held that no mining activity can be permitted without prior scientific appraisal – The Court also relied on State of UP v. Gaurav Kumar, 2025 SCC OnLine SC 1069, to stress strict adherence to environmental safeguards – Appeals filed by UT of J&K, NHAI and Project Proponent dismissed – NGT’s order setting aside the EC upheld – Held: A DSR without replenishment study is untenable in law – All parties directed to bear own costs [Paras 15-16, 29-33, 35-39, 44].

Role of Appraisal Committees – Regulatory Failure – J&K Expert Appraisal Committee and SEIAA erred in proceeding with environmental clearance despite recording absence of replenishment data – Restriction of mining depth to one metre in absence of replenishment study is no substitute for mandatory scientific assessment – Such conditional ECs amount to abdication of statutory responsibility [Paras 35-37].

Breach of EC Conditions – Use of Heavy Machinery – Project Proponent violated Condition 53 of the Environmental Clearance prohibiting JCBs and heavy excavators – Tribunal rightly directed J&K Pollution Control Board to take action – Direction upheld [Paras 41-42].

Decision – Appeals dismissed – NGT order sustained – Mandatory requirement of replenishment study reinforced as integral to lawful grant of environmental clearance – Supreme Court emphasised that effective environmental protection cannot be compromised by administrative convenience [Paras 39, 44].