Arbitration – Scope of Judicial Interference – Sections 34 and 37 of the Arbitration Act – Arbitral award granting idle time compensation for Backhoe Dredger (BHD) was upheld under Section 34 by Single Judge – Division Bench under Section 37 reversed award interpreting contract differently – Supreme Court held that appellate jurisdiction under Section 37 is narrower and cannot extend beyond Section 34 – Reversal of award unsustainable [Paras 20–22, 30–32, 36–38, 50–52].

Arbitration – Contract Interpretation – Tribunal’s view prevails – Tribunal interpreted Clauses 38, 41.1, 41.2, and 51.1 of License Agreement to uphold idle time claim for BHD – Court reiterated that tribunal's interpretation, when reasonable and accepted under Section 34, cannot be revisited under Section 37 – Deployment of BHD not contrary to contract terms – Award is a speaking award without patent illegality [Paras 29, 39–49].

Arbitration Law – Public Policy and Patent Illegality – No violation of public policy or fundamental principles of justice found – Arbitral award not suffering from patent illegality – Respondent’s reliance on Ssangyong Engineering misplaced – Award based on valid reasoning and evidence [Paras 28, 41–44].

Arbitration – Contractual Compensation – Clause 38 not exhaustive – Tribunal rightly found that BHD, even if not classified as major dredger, was entitled to idle time compensation under Clause 51.1 – Licensing terms did not bar such claims for minor equipment – Tribunal's view held as plausible and within its jurisdiction [Paras 42–48].

Decision: Appeal allowed – Division Bench judgment under Section 37 set aside – Arbitral award in favour of appellant-Dredging India restored – No order as to costs.

Criminal Law – Bail – Accused summoned under Section 319 Cr.P.C. – Parameters for grant of bail – Appellant named in FIR but not charge-sheeted – Subsequently summoned as accused on application under Section 319 Cr.P.C. based on deposition of eyewitnesses – Appellant arrested pursuant to non-bailable warrant and bail rejected by High Court – Held: While considering bail of a person added as an accused under Section 319 Cr.P.C., Court must assess existence of strong and cogent evidence of complicity – Standard higher than prima facie case for framing charge but short of proof beyond reasonable doubt – Nature of offence, quality of evidence and likelihood of absconding or tampering to be considered – Appellant entitled to bail [Paras 14, 17].

Criminal Trial – Section 319 Cr.P.C. – Summoning of additional accused – FIR against nine accused – Charge-sheet against three accused – Six dropped by police – Trial court partly allowing Section 319 application and summoning three accused including appellant – Order under Section 319 Cr.P.C. not challenged and attained finality – Trial against newly added accused to proceed afresh after framing of charges [Paras 6–9, 11].

Bail – Parity – Co-accused granted anticipatory bail – Two co-accused summoned under Section 319 Cr.P.C. granted anticipatory bail by High Court – State’s appeal seeking cancellation of anticipatory bail – Held: No case made out for cancellation as co-accused have complied with conditions and appeared before trial court regularly – Appeal by State dismissed [Paras 15, 18–19].

Criminal Appeal – Scope of observations in bail proceedings – Clarification – Observations confined only to consideration of bail and anticipatory bail – Trial court to decide the case independently and uninfluenced by observations made by Supreme Court [Paras 20–21].

Decision: Appeal filed by MD Imran @ D.C. Guddu allowed – Appellant directed to be released on bail on terms and conditions to be imposed by trial court – Appeal filed by the State of Jharkhand dismissed – Pending applications disposed of.

Arbitration Law – Commencement of Arbitral Proceedings – Interim Protection – Appellant obtained ad-interim injunction under Section 9 of the Act on 17.02.2024 – High Court vacated injunction holding arbitration not “initiated” within 90 days under Section 9(2) read with Rule 9(4) of the 2001 Rules – Supreme Court held “commencement” under Section 21 refers to the date the arbitration notice is received by respondent – Held: Respondent No. 2’s reply dated 23.04.2024 to notice dated 11.04.2024 evidences receipt and therefore arbitration was commenced within 90 days – Interim relief could not be vacated [Paras 16(A), 23–24, 29–31].

Interpretation – Rule 9(4) vs. Section 21 – High Court erroneously treated filing of Section 11 petition as commencement – Supreme Court clarified that “initiation” in Rule 9(4) must be read harmoniously with “commencement” in Section 21 – Legislative intent and UNCITRAL Model Law support receipt of arbitration notice as sole determinant of commencement – Court harmonised procedural rule with statutory provision [Paras 25–27].

Contract and Consent – Franchise Agreement Validity – Respondent No. 2’s objection to being non-signatory rejected – Franchise Agreement dated 23.03.2019 held valid and acted upon – Finding of High Court on validity of Franchise Agreement attained finality as unchallenged by Respondents [Paras 12, 16].

Decision: Appeal allowed – High Court’s judgment and Trial Court’s order vacating interim relief set aside – Interim injunction order dated 17.02.2024 restored – Contempt petition disposed of without further proceedings [Paras 32–35].

Criminal Law – Bail – Section 319 CrPC – Appellant summoned as additional accused based on eyewitness testimony after being dropped during investigation – Arrested pursuant to non-bailable warrant – High Court denied regular bail – Supreme Court held that stronger threshold of “cogent evidence” must be satisfied to deny bail under Section 319 – Bail granted subject to conditions [Paras 4–14, 17].

Criminal Procedure – Anticipatory Bail – Parity – Co-accused summoned under Section 319 and granted anticipatory bail by High Court – State sought cancellation – Supreme Court declined to interfere, noting compliance with bail conditions and regular court appearance – No case made out for cancellation [Paras 9, 15, 18–19].

Section 319 CrPC – Summoning Additional Accused – Charges framed against newly summoned accused – Trial to proceed afresh – Court clarified that evidence at this stage must be stronger than prima facie case for framing charges but need not reach conviction standard – Observations not to influence trial [Paras 11, 14, 21].

Decision: Appeal filed by Md. Imran @ D.C. Guddu allowed – Bail granted – Appeal by State against anticipatory bail to Md. Samsher and Md. Arshad dismissed – All three accused to cooperate with trial [Paras 17–20].

Company Law – Condonation of Delay – Section 58(3), Companies Act, 2013 – Appeal Allowed – The Company Law Board (CLB), a quasi-judicial body operating between 12.09.2013 and 01.06.2016, lacked the power to condone delay in filing an appeal under Section 58(3) of the Companies Act, 2013 – Section 10E(4C) of the Erstwhile Companies Act, 1956, restricted the CLB's powers to those of a court only for specific matters, not including the application of the Limitation Act, 1963 – The legislature consciously timed the coming into force of Section 433 of the Companies Act, 2013 (empowering NCLT/NCLAT to apply Limitation Act) with the creation of NCLT/NCLAT, indicating no intent to confer such power on the CLB – The High Court erred in affirming the CLB's order condoning delay – The appeal is allowed, and the impugned judgment is set aside [Paras 37, 38, 41, 52, 131, 132, 160(i), 160(ii), 161, 162].

Limitation Act, 1963 – Applicability to Quasi-Judicial Bodies – Section 5, Limitation Act, 1963 – Principles not applicable – The provisions of the Limitation Act, 1963, including Sections 4 to 24, apply only to suits, applications, or appeals made before 'courts' and not to quasi-judicial bodies or tribunals, unless expressly empowered by statute – There is no inherent power for statutory authorities or quasi-judicial bodies to condone delay under Section 5 of the Limitation Act, 1963, unless specifically indicated by law – The CLB was not expressly empowered to apply Section 5 of the Limitation Act, 1963 – The absence of express exclusion of the Limitation Act, 1963, does not, by itself, confer power to condone delay on a quasi-judicial body – The principles underlying Section 5 of the Limitation Act, 1963, cannot be analogously applied to quasi-judicial bodies due to the discretionary nature of the power and the requirement of 'sufficient cause' – The use of "may" in a statutory provision does not automatically render a prescribed period merely directory – The simpliciter limitation period under Section 58(3) of the Companies Act, 2013, is mandatory – The High Court's reliance on Nupur Mitra (supra) and Mackintosh (supra) was misplaced as those cases either dealt with different statutory provisions or did not conclusively affirm the CLB's power to condone delay under Section 5 of the Limitation Act, 1963 [Paras 42, 48, 51, 53, 55, 58, 65, 66, 68, 69, 75, 78, 81, 82, 84, 85, 86, 90, 101, 107, 119, 120, 123, 124, 125, 128, 147, 150, 153, 154, 156, 160(iii), 160(iv), 160(vi), 160(vii), 160(viii), 160(ix), 160(xv)].

Limitation Act, 1963 – Exclusion vs. Extension of Time – Section 5 vs. Section 14, Limitation Act, 1963 – Distinction – Section 5 of the Limitation Act, 1963, deals with the 'extension' of the prescribed period, involving judicial discretion based on 'sufficient cause', effectively adjusting the limitation period – Section 14 of the Limitation Act, 1963, deals with the 'exclusion' of time spent prosecuting a bona fide proceeding in a court without jurisdiction, which is mandatory upon fulfilling specific conditions, and does not alter the original limitation period but rather deems the time spent as not having occurred for limitation purposes – This distinction is crucial in determining the applicability of these provisions to quasi-judicial bodies – The principles underlying Section 6 (legal disability) are more akin to Section 14 (exclusion) than Section 5 (extension) due to their mandatory nature and focus on exclusion of time [Paras 62, 67, 70, 71, 72, 73, 74, 75, 76, 77, 79, 80, 81, 82, 83, 84, 85, 86, 88, 89, 160(vi), 160(vii), 160(viii)].

Retrospective Application of Law – Section 433, Companies Act, 2013 – Not Retrospective – Section 433 of the Companies Act, 2013, which empowers NCLT/NCLAT to apply the Limitation Act, 1963, came into force on 01.06.2016, coinciding with the constitution of these tribunals – This provision cannot be applied retrospectively to the CLB, which was a different body with distinct powers – The respondent's remedy was already time-barred under the Erstwhile Companies Act, 1956, before Section 58(3) of the Companies Act, 2013, or Section 433 came into force – Retrospective application of a procedural law like limitation is generally permissible, but not if it revives a dead remedy or extinguishes a vested right – In this case, applying Section 433 retrospectively would revive a dead remedy and affect vested rights of the appellant – Therefore, the change in law cannot benefit the respondent [Paras 130, 132, 138, 139, 140, 141, 144, 145, 146, 160(xvi)].

Company Law Board Regulations – Inherent Powers – Regulation 44, Company Law Board Regulations, 1991 – No power to condone delay – Regulation 44, saving the inherent powers of the CLB, does not empower it to circumvent mandatory time limits or condone delay in filing appeals under Section 58(3) of the Companies Act, 2013 – Inherent powers are complementary to specific statutory powers and cannot conflict with express legislative intent or provisions – Regulations 25 and 43 of the CLB Regulations deal with granting time for adjournments or enlargement of time for procedural acts within the regulations, not for extending statutory limitation periods for filing petitions or appeals [Paras 99, 100, 101, 103, 105, 106, 160(xi)].

Decision: Appeal allowed – The impugned judgment and order of the High Court are set-aside – [Paras 162].

Specific Performance – Validity of Power of Attorney – Ratification – Appellant entered agreement for purchase of co-owned land through unregistered POA holder of co-owner – Respondent executed later registered POA in favour of her son – However, she later executed an affidavit (Exh. A5) ratifying earlier POA and consenting to transfer – Held: Affidavit constituted binding ratification, and respondent is estopped from denying authority of previous POA holder – Registered POA does not automatically revoke earlier unregistered POA if ratified later [Paras 17–18, 35–38].

Contract Law – Limitation – Agreement to sell executed in 2007, extended thrice – Suit filed in 2013 – Trial Court and High Court held suit barred under Article 54 – Supreme Court held limitation runs from date of final refusal, i.e., affidavit ratifying POA dated 30.04.2013 – Suit held within limitation [Paras 13, 36–37].

Readiness and Willingness – Plaintiff paid full sale consideration and obtained sale deed from other co-owners – Respondent failed to execute her part despite ratification – Supreme Court found plaintiff demonstrated continuous willingness – Trial Court and High Court erred in denying decree [Paras 34, 38–39].

Equity – Respondent declined reasonable offer of Rs.75 lakhs for 1/11th share and attempted to leverage school’s land requirement – Court invoked equitable jurisdiction under Article 136 to avoid unjust enrichment and ensure school’s continued functioning [Paras 30–31, 39].

Education Law – Kerala Education Rules – Minimum land requirement of 3 acres for higher secondary school – Withholding of 1/11th share by respondent could jeopardize school recognition – With decree of specific performance granted, school’s land compliance now secured [Paras 29, 51–52].

Interim Management – Kerala DEO appointed to manage school during pendency of writ – After decree granted, no justification for interim DEO management – Interim order of High Court set aside [Paras 49–54].

Decision: Appeals allowed – High Court and Trial Court judgments set aside – Decree for specific performance granted – Trial Court to compute balance consideration with 9% simple interest – Registered sale deed to be executed – Interim management arrangement revoked.

Criminal Law – Cheating and Criminal Conspiracy – Multiple Victims – Same Transaction – Allegations of inducement and cheating of 1,852 investors pursuant to a single conspiracy to dupe public by false representation of divine powers to multiply money – One FIR registered and remaining complaints treated as statements under Section 161 CrPC – Held, where allegations disclose a single conspiracy with unity of purpose and design, multiple acts of cheating may form part of the same transaction – Registration of a single FIR in such circumstances is legally permissible [Paras 9–11, 18–21].

Criminal Procedure – FIRs – Multiplicity vs Consolidation – High Court held that each deposit constitutes a separate transaction requiring separate FIRs – Supreme Court disagreed – Law does not mandate registration of separate FIRs where subsequent information relates to same cognizable offence or same transaction – Subsequent complaints can be treated as statements under Section 161 CrPC – Multiple FIRs in such cases would lead to unnecessary multiplicity of proceedings [Paras 13–16, 21].

Criminal Procedure – Premature Reference under Section 395(2) CrPC – Reference made by Additional Sessions Judge during pendency of investigation – Held, reference was premature as it was not possible at that stage to determine whether offences formed part of same transaction – Question of consolidation of FIRs or charges arises only after investigation, at the stage of framing of charges [Paras 8, 20–21].

Same Transaction – Tests – Reaffirmation of settled principles – Unity of purpose or design, proximity of time and place, and continuity of action are relevant tests – Tests not required to be cumulatively satisfied – Determination depends on facts of each case – Magistrate to apply these tests on basis of material collected during investigation [Paras 11, 19–20].

Charges and Trial – Sections 218 to 223 CrPC – General rule under Section 218 CrPC mandates separate trial for distinct offences – Sections 219 to 223 CrPC are exceptions permitting joint trial – Where offences form part of same transaction, joint charges and trial permissible under Sections 220(1) and 223(a) & (d) CrPC – If not, separate trials required, subject to statutory limits on joinder of offences [Paras 19–20].

Sentencing – Multiple Offences – Sentencing to be governed by Section 71 IPC read with Sections 31 and 325 CrPC – If offences tried together as part of same transaction, punishment to follow accordingly – Issue of proportionality and concurrency of sentences to be considered by Trial Court on established facts [Paras 3, 22].

Rights of Complainants – Protest Petitions – Even where multiple complainants are treated as witnesses in a single FIR, their right to file protest petitions is preserved – Magistrate duty-bound to consider such protest petitions if closure report is filed or discharge is contemplated [Paras 13, 22].

High Court Judgment – Interference Warranted – Answers given by Delhi High Court to Questions (a) and (b) holding that separate FIRs and charge sheets were mandatory held erroneous – Set aside – Matter left to Magistrate to decide applicability of “same transaction” doctrine at appropriate stage [Paras 21–23].

Decision: Appeal allowed – Judgment dated 08.07.2019 of the Delhi High Court in Criminal Reference No. 1 of 2014 set aside insofar as it answered Questions (a) and (b) – Registration of single FIR upheld – Issue of consolidation of charges/trial to be decided by Magistrate in accordance with law.

Criminal Law – Quashing - Multiple FIRs – Civil Dispute Given Criminal Colour – Petitioners accused of misappropriation of refund amount – Three separate proceedings initiated on identical facts – Two proceedings either stayed or withdrawn – Final report in FIR No. 396/2025 concluded no evidence against petitioners – Held: Initiation of multiple criminal cases on same cause of action impermissible – Proceedings except Tajganj FIR closed [Paras 1-7].

Quashing of FIR – Final Report Filed – No Arrest – Chargesheet in Agra case (FIR 396/2025) concluded allegations not substantiated – Petitioners not to be arrested – Directed to appear before jurisdictional court and be granted bail on same day – Recognized that continuation of prosecution cannot result in custodial harassment in absence of incriminating material [Paras 5-8].

Corporate Insolvency – Complainant Representation – Complainant company undergoing insolvency – Interim Resolution Professional impleaded – IRP permitted to represent complainant and summon former officials for trial if required [Paras 4, 9].

Judicial Comity – Proceedings in Different Jurisdictions – Parallel complaints in Delhi and Agra – Delhi proceedings stayed or treated as not pressed – Court directed closure of Karkardooma proceedings and disposal of pending criminal revision as not pressed – Upheld principle that litigants should not harass opponents through multiple jurisdictions [Paras 6-7].

Decision: Special Leave Petition disposed of – Petitioners granted protection from arrest – Directed to appear before jurisdictional court and be granted bail – All other criminal proceedings on same facts closed – IRP allowed to participate in proceedings [Paras 7-10].

Motor Accident Claim – Compensation – Assessment under Section 166 MV Act – Appellant injured in a motor accident originally claimed under Section 163A – Tribunal and High Court awarded Rs.2,12,800 and Rs.2,23,000 respectively – Supreme Court held that despite reference to Section 163A, pleadings and claim amount established the claim was under Section 166 – Hence, just compensation principles to apply [Paras 2, 5].

Income Computation – Minimum Income – Appellant claimed Rs.8,000/month as a salesman but failed to produce proof – Court relied on Ramachandrappa v. Royal Sundaram to fix income at Rs.5,000/month for 2005 accident, considering inflation and self-employment – Future prospects at 40% and multiplier of 17 (age 27) applied – Total loss of income recomputed accordingly [Paras 3, 6, 8].

Disability Assessment – Improper Reduction by High Court – Disability assessed at 60% by medical expert and accepted at 50% by Tribunal – High Court reduced to 40% without appeal by Corporation – Supreme Court held reduction unjustified and restored 50% disability as assessed by Tribunal [Para 7].

Decision: Appeal allowed – Compensation recomputed to ₹7,14,000 for loss of income – Additional conventional heads as per Tribunal/High Court upheld – Interest at 7.5% p.a. – Respondent to pay within 3 months [Paras 8–10].