Judicial Discipline – Directions to High Court Judge – Modification on Request of CJI – Supreme Court had earlier set aside an Allahabad High Court order and remanded matter for fresh hearing, while issuing directions restraining the concerned judge from handling criminal matters till demitting office – On written request from CJI, SC deleted paras 25 and 26 of earlier order, leaving matter to the Chief Justice of the High Court – Court reiterated that directions were issued to protect institutional dignity and public faith in judiciary, not to cast aspersions on the judge [Paras 1-8].

Institutional Integrity – Role of Supreme Court and High Courts – SC clarified it does not intend to interfere with administrative powers of High Court CJ as ‘master of the roster’ – However, in cases raising institutional concerns affecting rule of law, SC may intervene – Emphasised that High Courts must uphold rule of law, avoid perverse/unjust orders, and maintain credibility – Judges expected to discharge duties diligently and honour constitutional oath [Paras 4, 6, 9, 11-12].

Reference to Precedent – Rikhab Birani v. State of Uttar Pradesh, 2025 INSC 512 – Noted past concern over misuse of criminal proceedings for civil disputes – Stressed the need to avoid recurrence of such cases [Para 10].

Decision – Special Leave Petition disposed – Paras 25 and 26 of order dated 04/08/2025 deleted – Registry to forward copy of present order to Chief Justice of Allahabad High Court [Paras 7, 13-14].

Motor Accident Liability – Insurer’s Obligation – Appeal Allowed – Appellant, ostensible owner/driver, challenged High Court’s absolution of insurer from liability for compensation in three claim petitions—Supreme Court held that deceased/injured were owners of goods accompanying their goods in a goods vehicle, hence covered as third parties under Section 147(1)(b)(i) MV Act—Finding of gratuitous passengers by High Court set aside—Ownership remained with registered owner at accident time; insurer bound to indemnify [Paras 7-11].

Gratuitous Passengers – Evidence – Tribunal’s factual finding that victims were accompanying goods for security, hence not gratuitous passengers, upheld—Insurer’s assertion lacked substantiation; no seizure mahazar or criminal case records produced—High Court erred in reversing finding without material [Paras 7-8].

Transfer of Ownership – Possession vs. Ownership – Agreement showed only possession with balance consideration unpaid; registration not transferred as per Section 50 MV Act—Registered owner continued to be ‘owner’ for liability purposes—Naveen Kumar applied; liability falls on registered owner and indemnifiable by insurer [Paras 9-10].

Selective Appeals by Insurer – High Court failed to address claimants’ contention that insurer challenged only three of eleven awards—No rebuttal by insurer—Irrelevant in light of insurer’s liability being upheld [Para 11].

Decision – C.A. Nos. 6338-6339/2024 and 6340/2024 allowed; C.A. Nos. 6341/2024 and 6342/2024 dismissed as settled in Lok Adalat—Awards to be satisfied by insurer with interest as per Tribunal/High Court directions [Paras 6, 12].

Motor Accident Claim – Death of Minor – Tribunal’s award restored – Appeal by parents against High Court’s reduction of compensation from Rs.8,55,000/- to Rs.5,80,000/- – Supreme Court held that Tribunal’s assessment of Rs.5,000/- monthly income for a 10-year-old child under Section 166 MV Act was proper, no deduction for personal expenses applicable, multiplier of 15 justified, and certain heads of compensation wrongly deleted by the High Court – Order of Tribunal reinstated [Paras 5-7].

Quantum of Income – Schedule II in Section 163A vs. Section 166 – High Court erred in applying Schedule II (Rs.30,000/- p.a.) meant for ‘no-fault’ claims under Section 163A – Tribunal’s reliance on Division Bench precedent adopting Rs.5,000/- monthly income for minor upheld – No deduction for personal expenses in case of minor’s death – Multiplier of 15 correct considering mother’s age [Paras 5-6].

Non-Pecuniary Damages – Filial Consortium and Funeral Expenses – As per Pranay Sethi, Rs.40,000/- each for both parents allowed – Funeral expenses Rs.15,000/- maintained – High Court’s deletion of transportation expenses and loss of dress/ornaments/cycle set aside – Loss of estate Rs.15,000/- upheld – Recomputed total Rs.8,70,000/- [Paras 6-7].

Decision – Appeal Allowed – High Court judgment set aside – Tribunal’s award of Rs.8,55,000/- restored – Amount to be paid within one month after deducting sums already deposited, with interest as directed by Tribunal/High Court [Para 7].

Motor Accident Compensation – Cancelled Insurance Policy – Pay and Recovery – Appeal Disposed – Offending vehicle’s insurance policy cancelled over three months before accident due to dishonoured premium cheque; insurer intimated owner and RTO—Tribunal and High Court still directed insurer to pay claimants and recover from owner—Supreme Court applied Deddappa and United India Insurance principles: insurer absolved in law upon cancellation before accident with intimation, yet, in exercise of Article 142 powers, pay-and-recover direction sustained in part—No recovery from claimants for 50% already paid; insurer may recover that amount from owner—Remaining 50% recoverable by claimants from owner [Paras 3.1-6].

Cancellation of Policy – Effect on Third Party Claims – While cancellation before accident generally negates liability, Court balanced equities by protecting amounts already disbursed to claimants—Avoided reopening settled part-payments to prevent hardship [Paras 5.3-5.7].

Decision – Appeal partly allowed; insurer permitted to recover 50% already paid from vehicle owner; claimants to recover remaining 50% from owner—No recovery from claimants for amounts withdrawn [Para 6].

Criminal Law - Murder  – Benefit of Doubt – Appeal Allowed – Acquittal -  Appellant convicted with husband under Section 302 IPC for beating victim with sticks following land dispute—Supreme Court noted contradictions between medical evidence and prosecution’s timeline, unexplained injuries on victim’s parents, admitted family enmity over partition, and improbabilities in alleged dying declaration—Body found at victim’s house despite alleged assault at temple—Only PW-7, victim’s father with strained relations, claimed to witness attack; other witnesses only saw accused fleeing—Held: Reasonable doubt exists; conviction set aside; appellant acquitted [Paras 1-11].

Medical Evidence vs. Eyewitness Testimony – Doctor opined death occurred between 10-12 p.m., inconsistent with claim that victim died before 9 p.m.—Weapon (danda) allegedly recovered from appellant not chemically examined nor linked to fatal injury—Lack of clarity on cause and time of death undermined prosecution case [Paras 2-7].

Unexplained Injuries on Witnesses – PW-7 and victim’s mother had incised wounds possibly self-inflicted; prosecution failed to explain—Supports defence of intra-family dispute and alternative narrative [Paras 8-9].

Decision – Conviction and sentence under Section 302 IPC set aside—Appellant acquitted; to be released forthwith if not wanted in any other case; bail bonds cancelled [Paras 11-13].

Criminal Law - Dowry Demand – Quashing of FIR – Sections 3 & 4 Dowry Prohibition Act – High Court’s Finding of “Vague and Omnibus” Allegations Set Aside – The appellants lodged FIR alleging specific dowry demands by the in-laws of the prospective bridegroom, including Rs. 10 lakh, a vehicle, and cash with articles on tilak ceremony—Marriage negotiations were later called off after refusal to meet further demands—High Court quashed FIR against the father, mother, and brother of the bridegroom holding allegations vague—Held: FIR contained specific details with dates and amounts; prima facie ingredients of offences made out—High Court erred in exercising Section 482 powers to quash—Whether allegations are true is matter for trial—Order quashing proceedings set aside; trial to proceed against all accused [Paras 8-14].

Civil Suit – Adverse Possession – Necessity of Pleadings – First Appellate Court’s Finding Set Aside – Plaintiffs sought declaration that sale deed was bogus and for injunction—Trial court dismissed suit; first appellate court decreed suit partly by accepting plea of adverse possession, holding title matured during pendency of suit—High Court found no such plea in plaint or written statement; held appellate court erred in framing additional issue absent foundational pleading—Supreme Court reaffirmed that adverse possession must be specifically pleaded, put in issue, and proved; cannot be raised for first time in appeal as a surprise to defendant—Petition dismissed; trial court’s dismissal of suit restored [Paras 19-31].

Civil Law - Port Tariff Revision – Arbitration Award and Appellate Orders Set Aside – Dispute between Paradip Port Authority and Paradeep Phosphates Ltd. regarding revision of tariff for exclusive use of “fertilizer berth” under agreement dated 03.08.1985 – Arbitrator (2002) quashed unilateral tariff enhancement from October 1993 to 31.03.1999 and directed parties to approach TAMP for period from 01.04.1999 onwards – Appellate Authority (2009) and High Court (2023) upheld award – Supreme Court held Arbitrator erred by reading Clause 1 of agreement in isolation and ignoring Clause 19 subjecting respondent to port laws – Appellate Authority’s order cryptic and High Court wrongly held agreement overrides 1963 Act – Found revision of tariff from 1985 to 1999 should have been assessed by expert body (TAMP) considering cost escalations and statutory framework – Matter remitted to TAMP for determination for 1993–1999 period [Paras 19–34]

Tariff Revision for 1999–2010 – Challenge to TAMP order (22.11.2011) rejecting increase – TAMP failed to grant oral hearing despite complex factual issues and wrongly examined basis of 1985 tariff instead of considering cost escalation – Supreme Court noted principles of natural justice violated and approach misdirected – Since tariff for 1993–1999 remitted to TAMP, subsequent period (1999–2010) also remitted for fresh decision to ensure continuity of base rates [Paras 40–47]

Constitution of Appellate Authority – Court observed tariff fixation is technical and factual requiring expert appraisal – Present direct appeals from TAMP/adjudicatory board to Supreme Court under 2021 Act may not be ideal – Recommended constitution of a specialised expert appellate body before Supreme Court stage, in line with regulatory regimes under SEBI Act, TRAI Act, Competition Act, Electricity Act – Registry directed to send order to Legislative Department, Ministry of Law & Justice for consideration [Paras 48–60]

Decision – (i) Award of Arbitrator, orders of Appellate Authority and High Court for 1993–1999 period set aside – matter remitted to TAMP [Para 61.1] – (ii) TAMP and High Court orders for 1999–2010 set aside – matter remitted to TAMP [Para 61.2] – (iii) Recommendation to constitute expert appellate body for TAMP/adjudicatory board orders [Para 61.3] – Registry to forward judgment to Legislative Department [Para 62].

Civil Law - Challenge Ordinance - Temple Management – Constitutionality of Ordinance – Prior Judicial Directions Modified – Interim Committee Constituted – Status Quo Restored – The Supreme Court dealt with a batch of writ petitions challenging the Uttar Pradesh Shri Bankey Bihari Ji Temple Trust Ordinance, 2025, and seeking modification of earlier directions allowing use of Temple funds for land acquisition – The Court found that critical stakeholders (Shebait Goswamis) were not heard before passing directions in Ishwar Chanda Sharma allowing the use of Temple funds, despite the High Court's earlier contrary order having attained finality – Held: Directions in Ishwar Chanda Sharma modifying the High Court’s order dated 08.11.2023 are set aside; petitioners relegated to High Court to challenge the Ordinance – In the interim, operation of the Trust-creating provisions of the Ordinance stayed – To avoid management vacuum, a High-Powered Committee is constituted to supervise the Temple’s day-to-day functioning and public amenities [Paras 1–5, 16–20, 21–23, 28–30, 33–36].

Temple Fund Utilisation – Modification of Prior SC Directions – High Court Order Restored – Directions in Ishwar Chanda Sharma permitting use of Temple funds for acquiring 5 acres of land were passed without hearing affected stakeholders – Held: Such directions cannot override the High Court’s judgment dated 08.11.2023 that barred use of Temple funds – Supreme Court restored status quo ante and directed that redevelopment expenses must be borne by the State, not the Temple trust [Paras 16–20].

Writ Jurisdiction – Constitutional Challenge to Ordinance – Petitioners Relegated to High Court – Petitioners invoked Article 32 to challenge the 2025 Ordinance – Court held that more appropriate remedy lies under Article 226 – Given past and ongoing proceedings in High Court over Temple management, writ petitions under Article 32 not entertained – Petitioners directed to approach High Court [Paras 21–23].

Procedural Fairness – Stakeholders Not Heard – Earlier Directions Invalidated – Court noted that Shebait Goswamis were not heard before authorising Temple fund usage – Directions in Ishwar Chanda Sharma were passed in collateral proceedings unrelated to Bankey Bihari Temple – Held: Judicial fairness and best practices require affording hearing to affected parties – Directions passed in breach thereof were unsustainable [Paras 16–17].

Interim Relief – Trust Formation Stayed – Committee Constituted to Avoid Management Vacuum – Till the High Court adjudicates the constitutional validity of the Ordinance, provisions enabling formation of Trust under Section 3 and 5 of the Ordinance stayed – To prevent a vacuum in temple administration, a High-Powered Temple Management Committee constituted to oversee operations and ensure amenities for devotees – Goswami participation limited to religious rituals [Paras 28–30, 33–36].

Committee Functioning – Roles, Powers and Honorariums Defined – Final Authority with Chairperson – Chairperson (Retd. Justice Ashok Kumar) and Member (Retd. Judge Mukesh Mishra) to be paid monthly honorarium from Temple funds – Committee to operate from Mathura; Chairperson to be final authority on procedures – Petitioners and public permitted to submit suggestions to the Committee for consideration [Paras 35–36].

Decision – Supreme Court allowed modification applications – Portions of Ishwar Chanda Sharma judgment authorising use of Temple funds expunged – High Court’s order dated 08.11.2023 restored – Petitioners relegated to High Court for challenging the Ordinance – Interim stay on formation of Trust – High-Powered Committee constituted to administer Temple operations pending final adjudication [Paras 19–20, 23, 28–30, 35].