Land Reforms – Constitutional Validity – The Supreme Court upheld the constitutional validity of Section 50(a) of the Delhi Land Reforms Act, 1954, which governs the succession of agricultural land holdings. The court ruled that the Act is a special law dealing with agricultural land tenures and falls under Entry 18 of List II of the Seventh Schedule, thus not repugnant to the Hindu Succession Act, 1956 (a general law) governed by Entry 5 and 7 of List III. Consequently, Article 254 of the Constitution does not apply [Paras 15-20].

Amendments – Retrospective Effect – The court held that the repeal of Section 4(2) of the Hindu Succession Act, 1956, does not have retrospective effect. The rights to succession crystallized before the amendment remain unaffected. The 1954 Act, being a special law on agricultural land, remains unaffected by the amendment to the 1956 Act [Paras 21-26].

Gender Discrimination – Ninth Schedule – The court dismissed arguments regarding gender discrimination, emphasizing that the 1954 Act is protected under Article 31(B) by being part of the Ninth Schedule, thus immune to challenges based on fundamental rights [Para 28].

Decision – Appeal Dismissed – The court dismissed the appeal, affirming that the 1954 Act governs the succession of agricultural land in Delhi and is constitutionally valid. The appeal against the High Court's decision was found to lack merit [Para 30].

Writ Jurisdiction – Availability of Alternative Remedy – The Supreme Court held that the High Court erred in entertaining the writ petition under Article 226 of the Constitution of India against the assessment order, bypassing the statutory remedies available under the MVAT Act and CST Act. The court emphasized that judicial prudence requires the exhaustion of statutory remedies before resorting to writ jurisdiction, especially in revenue matters where the statutes provide a hierarchy of appeals [Paras 6-10].

Statutory Remedies – Disputed Facts – The court highlighted that there were serious disputed facts regarding the date of the assessment order, which necessitated recourse to the statutory appeal process rather than direct intervention by the High Court under Article 226. The proper forum for resolving such disputes is the statutory appellate authority provided under the relevant tax statutes [Paras 7-9].

Decision – Appeal Allowed – The Supreme Court set aside the impugned judgment and order of the High Court, directing the respondent-assessee to avail the statutory remedy of appeal within four weeks. The appellate authority was instructed to decide the appeal on merits, without raising any questions of limitation, subject to compliance with other statutory conditions [Para 10].

Religious Freedom – Sikh Gurdwaras – The Supreme Court upheld the validity of the Haryana Sikh Gurdwara (Management) Act, 2014, which is similar to the Sikh Gurdwaras Act, 1925. The Act allows the Haryana Committee, constituted under Section 3, to manage the affairs of Gurdwaras and their properties within the State of Haryana. The court found that the Act does not violate Articles 25 and 26 of the Constitution since the management of religious affairs is left in the hands of the Sikh community alone, preserving their religious rights [Paras 1-27].

Inter-State Corporations – Legislative Competence – The court held that the Haryana Act falls within the legislative competence of the Haryana State Legislature under Entry 32 of List II of the Seventh Schedule of the Constitution. It was not necessary for the Act to fall under Entry 44 of List I, which pertains to inter-state corporations [Paras 28-30].

Transitional Provisions – The court explained that Sections 72 of the Punjab Reorganisation Act, 1966, and Sections 3 and 4 of the Inter-State Corporation Act, 1957, were transitional provisions to facilitate the functioning of inter-state bodies after the reorganisation of States. These provisions did not preclude the State Legislature from enacting laws for the management of Gurdwaras within its territory [Paras 31-34].

Decision – Writ Petitions Dismissed – The court dismissed the writ petitions, upholding the Haryana Sikh Gurdwara (Management) Act, 2014, and affirming the legislative competence of the State of Haryana to enact such a law [Para 35].

Arbitration Law – Stay of Arbitral Award – The Supreme Court held that once an application under Section 36(2) of the Arbitration and Conciliation Act, 1996, is filed for stay of the operation of the arbitral award, the court is empowered to impose conditions as it deems fit. This may include furnishing security covering the entire amount of the award, including interest. The court is required to record reasons in writing while granting such a stay [Paras 2-3, 28-30].

Interim Relief – Section 9 vs. Section 36 – The court discussed the interplay between interim measures under Section 9 and applications for stay of awards under Section 36(2). It was clarified that there is no hard and fast rule that an application made earlier in point of time must be heard before a later application, particularly when both relate to the same arbitral award. The court emphasized the wide jurisdiction under Section 9 to grant interim measures, including securing the amount in dispute [Paras 21-24, 33-34].

Decision – Appeals Dismissed – The court dismissed the appeals, upholding the High Court’s order directing the appellant to deposit the awarded amount as a condition for stay. The court requested the High Court to expedite the disposal of the pending application under Section 34 for setting aside the award, preferably within three months [Para 37].

Insolvency Law – Limitation – The Supreme Court held that for the purpose of limitation, the relevant date is the date on which the right to sue accrues, which is the date when a default occurs. The Court emphasized that the condition precedent for condonation of delay in filing an application or appeal is the existence of sufficient cause. The existence of sufficient cause for delay would depend on the facts of each case, and there cannot be any straitjacket formula for accepting or rejecting the explanation furnished by the appellant for the delay [Paras 11-17].

Limitation Act – Exclusion of Time – The Court explained that the date of enforcement of the IBC and/or the date on which an application could have first been filed under the IBC are not relevant in the computation of limitation. It is the date on which the right to sue accrues that matters. The fact that an application for initiation of CIRP was filed within three years from the date of enforcement of the relevant provisions of the IBC is inconsequential if the right to sue had accrued much earlier [Paras 18-19, 28].

Decision – Appeal Allowed – The Supreme Court set aside the impugned order of the NCLAT, which had incorrectly interpreted the limitation period for filing applications under the IBC. The Court held that the initiation of winding-up proceedings in the Madras High Court would not save limitation for initiation of proceedings for CIRP under the IBC in the NCLT. The judgment, however, does not prevent the respondent from pursuing any other remedy in accordance with law [Paras 29-31].

Death Penalty – Mitigating Circumstances – The Supreme Court emphasized the need to frame guidelines for considering potential mitigating circumstances while imposing death sentences to ensure a uniform and fair approach. The court observed that in the current legal framework, convicts are at a disadvantage as aggravating circumstances are always on record as part of the prosecution's evidence, whereas mitigating circumstances are often not presented adequately due to the stage of their consideration being post-conviction [Paras 23-24].

Bifurcated Hearing – The court highlighted the importance of a bifurcated hearing as mandated by Section 235(2) of the CrPC, ensuring the accused has a real and meaningful opportunity to present mitigating circumstances. The court referred to various precedents emphasizing that sentencing is a crucial stage requiring due consideration of factors beyond the crime itself, including the convict's background and circumstances [Paras 2-13].

Referral to Larger Bench – Due to conflicting judgments on the application of Section 235(2) and the necessity of a bifurcated hearing for death sentence cases, the court referred the matter to a larger bench of five judges to provide clarity and ensure uniformity in the application of the law. The referral aims to address the issue of providing a fair and effective hearing to the convict before imposing a death sentence [Para 24].

Decision – Referred to Larger Bench – The court directed that the matter be placed before the Chief Justice of India for appropriate orders to constitute a larger bench to frame guidelines regarding the consideration of mitigating circumstances in death penalty cases [Para 24].

Admissions – Merit-Based Allocation – The Supreme Court reiterated the principle that merit must be the primary consideration for admissions to medical colleges. It underscored the importance of following a fair procedure and adhering to the prospectus for counseling to ensure no meritorious student is denied admission due to administrative errors or misinterpretations [Paras 15-16, 18].

Interpretation of Prospectus – The court interpreted the relevant clauses of the prospectus, holding that clause 3, which pertains to the mop-up round, must be applied first before considering clause 4, which deals with converting management quota seats to state quota. The court found the appellants erred in upgrading students from the management quota to the state quota without considering higher-ranked students like the first respondent [Paras 16-18].

Compensation for Loss of Academic Year – The court acknowledged the hardship faced by the first respondent, who lost her rightful admission due to the appellants' error. While setting aside the High Court's direction for redrawing the merit list due to practical constraints, the court directed the appellants to pay Rs. 10 lakhs as compensation to the first respondent for the loss of one academic year [Paras 24-25].

Decision – Appeal Partially Allowed – The Supreme Court upheld the High Court's interpretation of the prospectus but set aside the direction to redraw the merit list. Instead, it directed the appellants to compensate the first respondent with Rs. 10 lakhs within one month [Para 25].

Taxation – Additional Duties of Excise – The Supreme Court examined whether 'Pan Masala' containing tobacco and gutka, which are covered by an entry in the First Schedule to the ADE Act, can be subjected to sales tax by the States under their respective sales tax laws. The court observed that once goods are chargeable under the ADE Act, they are exempt from State sales tax under the relevant State enactments [Paras 7-10].

Doctrine of Precedent – Numerical Strength of Benches – The court discussed the principle that a decision by a larger Bench prevails over that of a smaller Bench, regardless of the number of judges constituting the majority. This principle ensures consistency and stability in the law [Paras 1-4, 17-19].

Conflict in Judgments – The court addressed the conflict between the judgments in Kothari Products Ltd. v. State of A.P. and CST v. Agra Belting Works regarding the taxability of goods under the ADE Act and State sales tax laws. The court found no real conflict as the two lines of cases dealt with different aspects of the law – one with the exclusion of ADE Act goods from State sales tax and the other with the interplay between exemption under one section and taxability under another section of the same State Act [Paras 17-19].

Decision – Appeals Disposed Of – The Supreme Court held that the reference to the Constitution Bench was incompetent due to the lack of conflict between the lines of cases and directed that the cases be placed before the regular Bench for a decision on the merits [Paras 17, 19-20].

Service Law – Pension – The Supreme Court upheld the High Court’s decision that the respondent’s past service with the Rajasthan Agriculture Engineering Board and the Rajasthan State Agro Industry Corporation should be counted for pension calculation. The Court emphasized that denial of pension is a continuing wrong, and financial rules capable of multiple interpretations should be interpreted in favor of the employee [Paras 16, 23, 28].

Continuing Wrong – Pension – The Court observed that pension is a lifelong benefit, and denial constitutes a continuing wrong. The Court also noted the financial difficulties faced by retired employees in approaching the Court, which should be considered while deciding such cases [Paras 27-28].

Rule 25(2) – Resignation and Past Service – The Court clarified that under Rule 25(2) of the Rajasthan Civil Services (Pension) Rules, 1996, resignation does not entail forfeiture of past service if submitted with proper permission to take up another government appointment. The Court presumed prior permission was obtained due to the respondent’s selection through the RPSC and the nature of his employment [Paras 23-26].

Decision – Special Leave Petition Dismissed – The Supreme Court found no grounds to interfere with the High Court’s judgment, which was based on a purposive interpretation of Rule 25(2) favoring the respondent. The petition was dismissed [Paras 32-33].