Bail – Seriousness and Gravity of Offense – Appellant challenged the High Court’s order granting bail to respondent No. 2 – Supreme Court noted that the High Court did not consider the seriousness and gravity of the offense alleged against the respondent, who is facing trial for offenses under Sections 302 and 120B IPC – Held, High Court failed to consider relevant material and gave no cogent reasons for granting bail [Paras 2, 2.1].

Non-Bailable Warrant – Prior Proceedings and Arrest – High Court overlooked that respondent No. 2 initiated proceedings to quash the criminal case, which were dismissed, and that a non-bailable warrant was issued leading to his arrest in 2021 – Supreme Court emphasized these aspects are material while considering bail [Para 2.1].

Parole – Parity with Co-Accused – High Court granted bail based on parity with co-accused without considering the distinct roles and allegations against respondent No. 2 – Supreme Court held this approach inadequate [Para 2.2].

Judicial Review – Consideration of Relevant Facts – Supreme Court reiterated that courts must consider the seriousness of the offense, relevant materials, and provide cogent reasons when granting bail in serious cases [Paras 2, 3].

Decision: Appeals allowed – High Court’s order granting bail to respondent No. 2 set aside – Respondent No. 2 directed to surrender within two weeks, failing which a non-bailable warrant to be issued – Trial Court to conduct trial on merits without being influenced by the Supreme Court’s observations [Para 3].

Industrial Dispute – Termination Approval – Appellant challenged the High Court’s order which confirmed the Labour Court’s judgment setting aside the termination of the workman – Supreme Court held that once the order of termination was approved by the Industrial Tribunal, the findings recorded by the Tribunal were binding between the parties – Held, no contrary view could be taken by the Labour Court contrary to the findings recorded by the Industrial Tribunal [Paras 5.1-5.2, 6].

Jurisdiction – Role of Industrial Tribunal and Labour Court – Supreme Court noted that the Industrial Tribunal had permitted the employer to prove the charges and misconduct before it and had approved the termination – High Court failed to consider this finality and binding nature of the Industrial Tribunal’s decision – Held, the Labour Court’s subsequent interference was not permissible [Paras 5.1, 5.2].

Precedent – Distinction from Previous Cases – Supreme Court distinguished the case from John D'Souza vs. Karnataka State Road Transport Corporation (2019) 14 Scale 57 – Held, the specific facts of this case, where the Industrial Tribunal had permitted evidence and approved the termination, made the Labour Court’s contrary view unsustainable [Para 5.2].

Decision: Appeals allowed – High Court’s order confirming the Labour Court’s judgment set aside – Labour Court’s judgment setting aside the termination quashed – No order as to costs [Paras 6-7].

Motor Vehicle Accident – Determination of Just Compensation – Appellant challenged the High Court’s decision reducing compensation – Supreme Court held that compensation under Section 168 of the Motor Vehicles Act must be fair, reasonable, and equitable, emphasizing a comprehensive approach to pecuniary relief [Paras 11-12].

Income from Business Ventures and Investments – Treatment of Income – Supreme Court held that the entire amount from the deceased's business ventures and investments should be treated as income, as the deceased was actively involved in day-to-day management – Income derived from capital assets not sufficient to negate compensation for loss of managerial skills [Paras 16-18].

Income from House Property and Agricultural Land – Management and Dependency – Supreme Court partially deducted income from house property and agricultural land, attributing a portion to the deceased’s managerial skills – Awarded Rs 250,000 for managerial skills, including agricultural land management [Paras 19-23].

Just Compensation – Calculation and Awards – Supreme Court recalculated the compensation based on income and future prospects, applying relevant deductions and multipliers – Awarded additional compensation for funeral expenses, loss of estate, and consortium [Paras 24-25].

Decision: Appeals allowed – High Court’s order reducing compensation set aside – Appellants entitled to enhanced compensation with interest at 7.5% per annum from the claim petition date until realization – Enhanced amount to be paid within three months, adjusted by any amount already paid or deposited [Paras 26-28].

Animal Welfare – Custody of Seized Cattle – Appellant challenged the High Court’s order granting interim custody of seized cattle to private respondents – Supreme Court held that prima facie evidence indicated cruelty in transportation conditions – Held, under the proviso to Section 8(3) of the Maharashtra Animal Preservation Act, 1976, pending trial, seized cattle should be handed to an animal welfare organization [Paras 19-21].

Judicial Discretion – Relevance of Prima Facie Evidence – High Court noted the prima facie case of cruelty but did not ensure the seized cattle would be properly preserved – Supreme Court emphasized the need for careful judicial consideration of circumstances surrounding animal welfare and transportation [Paras 19-21].

Provisions of Law – Interpretation and Application – Supreme Court interpreted the amended provisions of the Maharashtra Animal Preservation Act, aligning with the legislative intent to ensure the welfare of animals pending trial – Held, High Court's direction contrary to the proviso of Section 8(3) of the Act, restoring JMFC's order [Paras 20-21].

Expeditious Trial – Welfare of Animals – Supreme Court directed that trials for offences under the Maharashtra Animal Preservation Act must be conducted expeditiously to avoid indefinite custody of animals, ensuring timely justice and welfare [Paras 22-23].

Decision: Appeals allowed – High Court’s order set aside – JMFC’s order granting custody to the appellant restored – Trial to be concluded within six months – Appellant waived claim for maintenance compensation pending trial [Paras 24-25].

Arbitration – Preliminary Inquiry – Appellant challenged the High Court’s order appointing arbitrators without determining if the dispute was arbitrable – Supreme Court held that the High Court was required to conduct a primary inquiry to ascertain if the dispute fell under Clause 36 (specific performance through court) or Clause 37 (arbitration clause) of the addendum agreement – Held, appointment of arbitrators without such inquiry was unsustainable [Paras 6, 7].

Contract Interpretation – Arbitration Clause – Supreme Court emphasized the necessity to interpret contract clauses strictly, particularly arbitration clauses – Held, disputes explicitly falling under excepted matters (Clause 36) should not be arbitrated – High Court failed to appreciate this distinction [Paras 6.1-6.4].

Judicial Review – Scope and Limits – Supreme Court reiterated principles from Vidya Drolia and others v. Durga Trading Corporation, emphasizing limited judicial review at the Section 11 stage to check and protect parties from non-arbitrable disputes – Held, prima facie review needed to determine arbitrability before referring to arbitration [Paras 6.5-6.7].

Decision: Appeals allowed – High Court’s order appointing arbitrators set aside – Matter remitted to the High Court to decide afresh, conducting a preliminary inquiry on arbitrability under Clauses 36 and 37 of the addendum agreement [Paras 7-8].

Right to Information vs. Right to Privacy – Balance of Rights – Petitioners (Banks) challenged the RBI’s directive to disclose information under RTI – Supreme Court acknowledged the conflict between the fundamental right to information and the fundamental right to privacy – Held, courts must balance these rights carefully, ensuring neither is disproportionately compromised [Paras 39-42].

Judicial Precedent – Reconsideration of Earlier Judgments – Supreme Court found the RBI directive based on the judgment in Reserve Bank of India vs. Jayantilal N. Mistry (2016) 3 SCC 525, which did not adequately consider the right to privacy – Held, it is permissible for the Court to reconsider and possibly refer such matters to a larger bench if earlier judgments did not lay down correct positions of law [Paras 39-42].

Disclosure of Information – Statutory Exemptions and Privacy – Petitioners argued that the RBI’s directive violated provisions under the RBI Act, Banking Regulation Act, and RTI Act – Supreme Court noted the necessity of protecting confidential information and the fundamental right to privacy of individuals against unwarranted disclosure [Paras 13, 14, 18-21].

Ex Debito Justitiae – Correction of Judicial Mistakes – Supreme Court cited principles of inherent judicial duty to correct mistakes to prevent gross miscarriage of justice – Emphasized no man should suffer due to court errors, reinforcing the principle of ex debito justitiae [Paras 30-32].

Decision: Writ petitions entertained – Preliminary objections rejected – Matter referred for reconsideration to ensure balanced protection of rights to information and privacy – Observations in Jayantilal N. Mistry’s case to be re-evaluated for alignment with the right to privacy as a fundamental right [Paras 43].

Rejection of Plaint – Limitation – Appellant challenged the High Court’s dismissal of revision petitions confirming trial court’s refusal to reject plaints under Order VII Rule 11(d) CPC – Supreme Court held that the respective suits were barred by limitation as they were filed 10 years after the execution of sale deeds – Held, vague allegations and clever drafting to invoke Section 17 of the Limitation Act do not suffice to bring suits within limitation period [Paras 7, 7.9].

Cause of Action – Allegations of Fraud – Supreme Court noted that mere allegations of fraud without specific details are insufficient to establish a valid cause of action – Plaintiffs' claim of discovering fraud in 2015 was deemed too vague to delay the start of the limitation period [Paras 7.7, 7.8].

Judicial Review – Exercise of Powers under Order VII Rule 11 – Supreme Court emphasized that courts must consider the averments in the plaint and determine if the suit is manifestly vexatious and meritless – Held, both trial court and High Court erred in not rejecting the plaints as barred by limitation [Paras 7.9, 8].

Decision: Appeals allowed – High Court’s judgment and trial court's orders set aside – Applications for rejection of plaints allowed – Plaintiffs' suits rejected as barred by limitation [Para 8].

Criminal Law – Conviction Based on Circumstantial Evidence – Appeal against conviction under Section 302 read with Section 34 IPC – High Court upheld trial court's decision – Supreme Court set aside the conviction – Held, reliance on voluntary statements made to police inadmissible under Section 161 Cr.P.C. and Article 20(3) of the Constitution – Lack of direct or scientific evidence linking appellants to crime – Recovery of weapon and stolen items deemed unreliable [Paras 1-88].

Evidence – Admissibility of Voluntary Statements – Statements made to police inadmissible under Section 25 of the Indian Evidence Act – Trial court's reliance on video-recorded confessions improper – High Court erred in affirming reliance on such statements – Confessional statements must be recorded before a magistrate under Section 164 Cr.P.C. to be admissible [Paras 13-24].

Recovery of Evidence – Doubtful Nature of Recovered Items – Recovery of weapon and stolen items occurred months after arrest – Independent witness to recovery turned hostile – Recovered items not conclusively linked to the crime – Court emphasized rigorous scrutiny in cases based on circumstantial evidence [Paras 8-12].

Decision: Appeals allowed – Convictions and sentences set aside – Appellants to be released unless required in connection with another case [Paras 17].

Medical Termination of Pregnancy – Scope of Rule 3B – Unmarried women are entitled to safe and legal abortion under Section 3(2)(b) of the MTP Act read with Rule 3B – The rule includes all women who face a change in material circumstances, irrespective of marital status – The exclusion of unmarried women is discriminatory and violative of Article 14 of the Constitution – Interpretation of Rule 3B must be broad and inclusive to uphold constitutional values of equality and reproductive autonomy [Paras 121-137].

Reproductive Rights – Constitutional Protection – Right to reproductive autonomy, dignity, and privacy under Article 21 extends to unmarried women – Legal interpretation should support these rights equally for married and unmarried women – Law must not be guided by patriarchal principles regarding permissible sex and family structures [Paras 100-103, 121-137].

Decision: Appeal allowed – The exclusion of unmarried women from Rule 3B of the Medical Termination of Pregnancy Rules, 2003, is set aside – Directions issued for inclusive interpretation of Rule 3B to encompass all women facing changes in material circumstances [Paras 136-137].