Criminal Law - Dowry Death – Applicability of Section 304-B IPC – Conviction Upheld – The deceased died an unnatural death within 1 year and 4 months of marriage due to traumatic brain injuries – Consistent testimonies from father and brothers of the deceased established dowry harassment and monetary demands by the accused-husband – Held: Essential ingredients of Section 304-B IPC were fulfilled; conviction proper [Paras 27-30, 39].

Presumption under Evidence Act – Section 113-B – Failure to Rebut – Presumption Drawn – Once prosecution proved harassment and unnatural death soon before death, burden shifted to the accused to rebut presumption – Defence of depression due to knee pain and alternate theories of suicide or accidental fall were rejected as unsubstantiated and contradictory – Held: Presumption under Section 113-B validly invoked; defence theories not credible [Paras 20-22, 28, 31, 34-36].

Medical Evidence – Post-Mortem via Affidavit – Curable Irregularity – Medical Officer's Affidavit Accepted – Though medical evidence was recorded by affidavit contrary to Section 296 CrPC, the defence cross-examined the doctor and did not object – Held: No prejudice caused; post-mortem proved cause of death as traumatic head injury due to mechanical violence [Paras 23-26].

Contradictory Defence – Inconsistencies in Accused's Explanation – Defence Rejected – The accused alternated between claiming accidental fall and suicide due to medical condition – Neither theory matched facts including the location of the body and the timing of distress calls – Held: Defence concocted; does not displace prosecution's case [Paras 28-29, 35-36].

Demand for Money for Job – Treated as Dowry – Dowry Demand Proved – Accused demanded Rs. 5 lakhs from deceased’s father to secure employment – Rs. 50,000 was paid; harassment continued thereafter – Held: Such demand, linked to marriage, qualifies as dowry under law [Paras 16-17, 22, 30].

Final Decision – Appeal Dismissed – Conviction and Sentence Affirmed – No infirmity found in reasoning of Trial or High Court – Accused-appellant directed to surrender and serve remaining sentence [Paras 40-42].

Civil Law - Electricity Act - Jurisdiction of CERC – Powers under Section 79 – Regulatory Order Valid – Held: CERC has dual functions of regulation and adjudication – Even in absence of regulations under Section 178, CERC is empowered to regulate tariff matters between parties under Section 79 – Grant of liberty to claim compensation falls within such regulatory scope [Paras 43-48, 60-63].

Maintainability of Writ Petition – Alternative Remedy Available – Writ Petition Improperly Admitted – The High Court entertained the writ despite availability of appellate remedy under Section 111 – No violation of natural justice, no constitutional question involved, and no lack of jurisdiction shown – Held: High Court erred in applying Whirlpool exception – Writ petition was not maintainable [Paras 64-66].

Compensation for Delay – Transmission Charges – Regulatory Function Not Adjudication – CERC’s direction to allow appellant to claim transmission charges for unutilized assets due to respondent’s delay addressed a regulatory gap – Such order was not an adjudication on liability, but regulation to fill a lacuna in the 2014 Tariff Regulations – Held: Ad hoc regulatory action permissible and valid [Paras 55-60].

Decision – Appeals Allowed – Writ Petitions Dismissed – Supreme Court set aside the High Court’s order admitting the writ petitions – Clarified that respondent may raise factual challenge on merits before APTEL if it chooses to appeal – No determination on actual liability was made [Paras 65-66].

Civil Law - Arbitration and Conciliation Act, 1996 - Arbitration Clause – Interpretation of Dispute Resolution Clause – Article 20 of Concession Agreement – Arbitration Denied – The Supreme Court examined whether Article 20 of the Concession Agreements executed between Municipal Corporations of Delhi and private contractors constituted a valid arbitration agreement – Held: The clause contemplated a mediation process led by the Commissioner, lacked mutual appointment of an arbitrator, did not satisfy the requirements under Section 7 of the Arbitration and Conciliation Act, 1996, and hence could not be treated as an arbitration clause – Textual references such as “final and binding” were not enough to qualify the process as arbitration in absence of intent, neutral adjudicator, and adversarial procedure [Paras 14-51].

Finality of Decision – Not Indicative of Arbitration – Language referring to decisions as “final and binding” in Article 20 was held insufficient to imply arbitration where the mechanism remained internal and non-judicial – Such decisions can be departmental or administrative in nature and do not imply submission to an arbitral tribunal under the Act [Paras 39-41].

Judicial Censure – Drafting of Arbitration Clauses – Observations on Ambiguity – The Court expressed strong concern over ambiguously drafted dispute resolution clauses that prolong litigation instead of facilitating resolution – It called upon legal practitioners to ensure clarity and warned against professional conduct that leads to unnecessary judicial burden – It emphasized the need for accountability and judicial proactivity in rejecting unclear arbitration provisions [Paras 53-59].

Decision – Appeals Disposed – Article 20 is Not an Arbitration Clause – Judgments of High Court in SMS Ltd. and CCC Ltd. cases set aside – Judgment in DSC Ltd. upheld – Parties permitted to pursue alternative legal remedies [Paras 60-61].

Custom Law - Customs Exemption – Administrative Circular Cannot Override Statutory Notification – Appeal Allowed - The Supreme Court held that Circular No. 10/2004-Cus., which expanded the scope of excluded goods under Notification No. 53/2003-Cus., was legally unsustainable – Such a circular cannot add conditions or restrict exemptions granted by a statutory notification under Section 25 of the Customs Act – Held: Circular had no legal consequence and could not deny exemption to crude degummed soyabean oil [Paras 30–36, 58(i)].

Manufacture – Crude Degummed Soyabean Oil is Distinct Product – Not Agricultural – Appeal Allowed - The Court found that the process to extract crude degummed soyabean oil from soyabean constituted ‘manufacture’ resulting in a distinct, marketable product – Rejected the High Court’s view that crude oil retained the identity of soyabean – Held: Crude degummed soyabean oil is not an agricultural product and thus not excluded from exemption under Notification No. 53/2003 [Paras 40–57, 58(ii)-(iv)].

EXIM Policy – Entitlement Under Duty-Free Scheme – Benefit Restored – Appeal Allowed - The appellant, a recognized status holder, was entitled to duty-free import benefit under the 2002–2007 EXIM policy – Import through MMTC and the classification under Chapter 15 supported their claim – Demand of duty by Customs and High Court’s order upholding it were both quashed [Paras 5–8, 58(v)–60].

Arbitration Law - MSMED Act vs. Arbitration Act – Statutory Override – Appeal Allowed - The Court held that arbitration proceedings under Section 18 of the MSMED Act override contractual arbitration clauses, including those specifying seat and venue – MSMED Act being a special legislation prevails over the Arbitration Act – Arbitral jurisdiction validly exercised by Delhi Facilitation Council and Delhi Arbitration Centre despite agreement specifying Bengaluru as the seat – Karnataka High Court’s contrary finding set aside [Paras 2, 8–10, 13].

Arbitration – Jurisdiction of Facilitation Council – MSME Location Determinative – Appeal Allowed - The Court reaffirmed that under Section 18(4) of the MSMED Act, the jurisdiction for arbitration is determined by the location of the MSME supplier – The appellant being located in Delhi conferred valid jurisdiction on the Delhi Facilitation Council – Appointment of arbitrator through Delhi Arbitration Centre upheld [Paras 10–11].

Contractual Clause – Cannot Override Statutory Mechanism – Appeal Allowed - Clauses in the agreement stipulating Bengaluru as the seat of arbitration were held ineffective once the statutory scheme of MSMED Act was invoked – The overriding effect under Section 24 and the non-obstante clauses in Section 18(1) and 18(4) made the private agreement subordinate to statutory mandate – High Court’s reliance on contractual seat rejected [Paras 6, 9].

Decision – High Court Order Set Aside – Arbitration to Proceed in Delhi - The Supreme Court set aside the order dated 22.04.2024 of the Karnataka High Court – Directed arbitration to continue under Delhi Arbitration Centre as initiated by the Delhi Facilitation Council – Merits of the dispute left open for determination by the arbitrator [Paras 12–14].

Criminal Law – Quashing of FIR – Appellants, members of a political party, sought quashing of FIR registered under Section 3(1) of the UP Gangsters & Anti-Social Activities (Prevention) Act, 1986 – FIR dated 30th April, 2023, based on a prior incident dated 10th October, 2022, wherein appellants were already booked under IPC Sections 147, 148, 149, 427, 307, 323, 504, 506 and Section 7 of Criminal Law Amendment Act – High Court dismissed the writ petition seeking quashing – Supreme Court held that invocation of UP Gangsters Act was unwarranted in absence of any subsequent criminal activity between the first FIR dated 11th October, 2022, and the gang chart prepared on 29th April, 2023 – No evidence of organized crime, habitual behavior, or intent to gain undue advantage [Paras 3, 4, 5, 9, 14, 16, 19, 20, 22, 29, 30].

Gangsters Act – Applicability – Definition of ‘Gang’ under Section 2(b) requires a group engaged in anti-social activities with objective of disturbing public order or gaining undue pecuniary, temporal or material advantage – FIR merely refers to a single protest incident triggered by an inflammatory post on religion – No evidence of hierarchical structure, systematic planning or continuity of criminal acts – Held, appellants' participation in spontaneous protest does not constitute membership of a gang under the Act – Invocation of the Gangsters Act was colorable exercise of power [Paras 11, 12, 14, 16, 17, 18, 22, 25].

Mala Fide Intention – Political Vendetta – Registration of FIR under the Gangsters Act occurred just days after appellant’s family member filed nomination for Nagar Panchayat elections – Appellants had filed a prior representation anticipating false implication – Supreme Court observed that FIR appeared politically motivated and a misuse of statutory powers [Paras 5.4, 21, 24].

Constitutional Safeguards – Personal Liberty – Court reiterated that extraordinary statutes abridging procedural safeguards must be invoked with strong evidentiary foundation – Absence of fresh criminal conduct or continuing threat rendered invocation of Gangsters Act arbitrary and violative of Article 21 of the Constitution – Procedural fairness underlined as essential [Paras 23, 24, 25].

Decision: Appeal allowed – Judgment of High Court set aside – FIR dated 30th April, 2023, and all consequential proceedings quashed – Pending proceedings in earlier FIRs CC No. 294 of 2022 and CC No. 296 of 2022 to continue unaffected – Pending applications disposed of [Paras 29, 30, 31, 32].

Criminal Law  – Murder – Appeal Against Acquittal -  Identification in Court – Failure to Prove Guilt Beyond Reasonable Doubt – Appeal Allowed - The Supreme Court held that failure by eyewitnesses to identify accused in court as perpetrators of the crime was fatal to the prosecution's case – Mere naming of individuals in deposition without proper court identification insufficient to sustain conviction – Resultant acquittal of all appellants due to lack of conclusive proof [Paras 21–23, 25].

Eyewitness Testimony – Material Omissions – Contradictions Under Section 162 CrPC – Appeal Allowed - The Court found significant and unexplained omissions in police statements versus court depositions by prosecution witnesses – These discrepancies amounted to contradictions and weakened the prosecution’s case – Cross-examination further established inconsistency in testimonies and non-corroboration by independent witnesses [Paras 9–10, 12, 14, 16, 19, 23].

Counter Case – Separate Trial – No Prejudice Established – Appeal Allowed - Though appellants raised grievance of prejudice due to separate trial of the counter-case arising from the same incident, the Court found no conclusive prejudice – Nonetheless, acquittal was ordered on merits due to evidentiary failure [Paras 4, 7].

Decision – Conviction Set Aside – All Appellants Acquitted - The impugned judgment dated 10.09.2010 of the Chhattisgarh High Court and convictions under Sections 302/149 and 307/149 IPC were set aside – All appellants acquitted – Bail bonds cancelled as appellants were already on bail for twelve years [Paras 25–26].

Civil Law - Land Allotment – Not a Sale – Statutory Scheme Governs – Appeal Allowed - The Supreme Court held that the alienation of land in favour of the respondent-charitable trust was not an outright sale but a conditional allotment under a statutory scheme governed by the Telangana Land Revenue Act and relevant rules – The District Collector’s 2001 order explicitly imposed conditions, including usage for specific purposes and completion of construction – High Court erred in treating this as a freehold sale without restrictions [Paras 15–18, 21].

Condition on Use – Validity of Restrictions – Section 10 TPA Not Attracted - The Court held that Section 10 of the Transfer of Property Act, 1882, which renders conditions restraining alienation void, does not apply to state allotments under statutory schemes – The restrictions imposed in public interest override the general rule applicable to private transfers – Respondent’s claim that conditions violated Section 10 was untenable [Paras 22–23].

Fraudulent Misrepresentation – GPA Executed without Disclosure – Mala Fide Intent Inferred - The Respondent-Trust executed a General Power of Attorney in 2011 without disclosing the conditional nature of the allotment – The Court held this as indicative of mala fides – The decision to develop and sell plots from the allotted land amounted to fraud on statute [Paras 24–25].

Decision – Impugned Judgments Set Aside – Appeal Allowed - The judgments of the Single Judge and Division Bench of the Telangana High Court dated 24.06.2014 and 05.07.2022 were set aside – The Appeal filed by the State of Telangana was allowed, upholding the conditional nature of the land allotment [Para 26].

Contract Law – Clause Requiring Minimum Service Period – Not Restraint of Trade – Appeal Allowed - The Supreme Court held that Clause 11(k) of the appointment letter, requiring an employee to serve a minimum of three years or pay ₹2 lakh as liquidated damages, was not violative of Section 27 of the Contract Act – Such negative covenants during the subsistence of an employment contract are not considered restraint of trade – Held: Clause valid and enforceable [Paras 13–16, 35].

Public Policy – Standard Form Employment Contract – No Inequality of Bargaining – Appeal Allowed - The Court rejected the argument that the clause was imposed through unequal bargaining power – Held: The clause was part of a legitimate strategy to curb attrition in a competitive environment and was not unconscionable or unfair – Not opposed to public policy under Section 23 of the Contract Act [Paras 18–21, 27].

Liquidated Damages – ₹2 Lakhs Not Disproportionate – Appeal Allowed - The clause requiring ₹2 lakh payment for premature resignation was held reasonable and not causing unjust enrichment – Recruitment process costs, administrative disruptions, and public sector constraints justified the amount – Respondent paid under protest but failed to establish excessive hardship [Paras 28–31].

Decision – High Court Order Set Aside – Restrictive Covenant Upheld - The Supreme Court allowed the appeal and restored the enforceability of Clause 11(k) – High Court’s reliance on prior decision in BEML held inapplicable due to different factual context – Civil Appeal No. 11499 of 2016 dismissed following same reasoning [Paras 32–37].