Succession Law – Right of Survivorship – Applicability to Scheduled Tribes – Section 2(2) of the Hindu Succession Act – The Supreme Court held that under Section 2(2) of the Hindu Succession Act, the Act is not applicable to members of Scheduled Tribes – Consequently, the female member of a Scheduled Tribe is excluded from claiming a right of survivorship under the provisions of the Act – The Court recognized the need for legislative amendment to ensure gender equality in inheritance rights for Scheduled Tribe women [Paras 6-7].

Judicial Interpretation – Role of the Legislature – The Court noted that while equity would support granting succession rights to female members of Scheduled Tribes, it is within the legislature's purview to amend the law – The Court urged the Central Government to consider amending the Hindu Succession Act to provide equal inheritance rights to female members of Scheduled Tribes [Para 6.1-7.2].

Previous Precedents – The Court discussed the minority view in Madhu Kishwar & Ors. v. State of Bihar & Ors. (1996) which suggested applying the general principles of the Hindu Succession Act to Scheduled Tribes – However, the majority view did not support this interpretation, reinforcing the exclusion under Section 2(2) [Para 6.4].

Decision: Appeal dismissed – High Court judgment upheld – Central Government directed to consider amending the Hindu Succession Act to ensure gender equality for Scheduled Tribe women in inheritance rights [Paras 7-7.2].

Land Acquisition – Lapse of Acquisition Proceedings – Section 24(2) of the 2013 Act – The Supreme Court held that the High Court's decision declaring the acquisition proceedings lapsed solely on the ground that compensation was not actually paid is unsustainable – The Constitution Bench decision in Indore Development Authority v. Manoharlal clarified that non-deposit of compensation in court does not result in the lapse of proceedings if possession has been taken – The High Court’s view was contrary to this decision [Paras 2-3].

Judicial Precedent – Indore Development Authority Case – The Supreme Court reaffirmed that both possession and payment conditions must fail for proceedings to lapse – If possession has been taken, compensation must be determined under the 2013 Act without causing lapse [Para 3].

Decision: High Court judgment quashed – Appeal allowed – Original writ petition dismissed – No costs [Paras 4].

Execution of Decree – Interest on Decretal Amount – Appellant deposited the decretal amount in court without giving notice to the decree holder – High Court held decree holder entitled to interest on the amount deposited until the appeal's decision – Supreme Court found that interest ceases when the deposited amount is credited in the decree holder's account, regardless of notice – Appeal allowed, modifying interest obligations [Paras 1-28].

Order XXI Rule 1 CPC – Modes of Payment – Legislative intent that interest ceases on principal amount once deposited and credited to decree holder's account – Notice facilitates withdrawal by decree holder, but lack of notice does not affect cessation of interest if withdrawal occurs [Paras 14-21].

Arbitration Award – Post-deposit Interest – Appellant’s obligation to pay interest on net principal amount after partial payments and set-offs – Court clarified interest payable on remaining principal after set-off against earlier payments [Paras 9-10, 22-25].

Decision – Appeal Allowed – Judgment of High Court set aside – Held – Appellant liable to pay interest at 18% per annum on net principal amount post set-off until payment – Matter remanded to executing court for exact computation [Paras 25-28].

Criminal Law – Murder and Common Intention – Acquittal of first respondent under Section 302 IPC set aside – Evidence established common intention among co-perpetrators – Gurbachan Singh inflicted injuries with a 'lathi', participated in the attack leading to the death of Teja Singh – Supreme Court convicted Gurbachan Singh under Section 302 read with Section 34 IPC [Paras 1-16].

Section 34 IPC – Joint Liability – Requirement of common intention among co-perpetrators – Common intention can form spontaneously during the occurrence – Inferred from conduct and circumstances – Gurbachan Singh shared common intention with co-accused to cause death [Paras 11-12].

Evidence – Testimonies of Eye Witnesses – Consistent accounts from Harbhajan Singh (PW-1) and Jasveer Kaur (PW-2) – Medical evidence corroborated injuries inflicted by co-accused with various weapons [Paras 9-10].

Decision – Appeal Allowed – High Court’s judgment acquitting Gurbachan Singh under Section 302 IPC set aside – Conviction under Section 302 read with Section 34 IPC restored – Life imprisonment and fine imposed as per trial court’s order – Conviction under Section 324 IPC for injuries to Harbhajan Singh (PW-1) maintained [Paras 13-16].

Service Law – Reinstatement and Consequential Benefits – Respondent appointed as untrained teacher in 1971, relieved in 1973 to undergo training, and not permitted to resume duties in 1974 due to lack of BTC certificate – Made representations over decades without approaching judicial forum until 2009 via RTI – High Court ordered reinstatement with benefits after Tribunal dismissed claims as time-barred – Supreme Court found the claim stale, time-barred, and that undue sympathy by judicial forums can lead to adverse consequences [Paras 1-24].

Principles of Delay and Laches – Repeated representations do not revive a stale claim – Respondent waived rights by not seeking timely judicial remedy – Tribunal’s dismissal of claim for being time-barred was legally correct – High Court's order set aside for overlooking principles of limitation and laches [Paras 10-21].

Judicial Conduct – Courts must avoid undue sympathy that can create illegitimate expectations and burden public exchequer – Respondent's minimal service duration did not justify High Court's grant of substantial arrears and benefits [Paras 21-22].

Decision – Appeal Allowed – High Court’s judgment set aside – Claim for reinstatement, retiral benefits, and arrears rejected – Appellants directed to pay lump-sum compensation of Rs. 5,00,000 to respondent within two months [Paras 23-24].

Motor Vehicles Act – Enhancement of Compensation – Deceased’s income was based on Income Tax Return, fixed at Rs. 118,261 annually (approx. Rs. 9,855 per month) – High Court’s enhancement of income to Rs. 5,000 per month without considering ITR was erroneous – Deduction for personal expenses set at 1/5th for seven dependents – Future prospects added at 40% – Total compensation enhanced to Rs. 2,591,388 with 9% interest from application date till payment [Paras 1-19].

Just Compensation – Concept of ‘just compensation’ under Section 168 MV Act aims for fairness, reasonableness, and equitability – Determination can never be exact but should strive for fairness irrespective of amount claimed – Court awarded enhanced compensation based on statutory documents and established principles [Paras 10-12].

Future Prospects and Conventional Heads – High Court added 40% for future prospects correctly – Tribunal and High Court erred by not awarding proper amounts under conventional heads – Supreme Court increased conventional head amounts as per Pranay Sethi and applied 10% increment every three years [Paras 13-17].

Decision – Appeal Allowed – Compensation enhanced to Rs. 2,591,388 with 9% interest per annum from filing date to payment date [Para 19].

Senior Citizens Act – Section 23 – Void Transfers – Sub-section (1) of Section 23 covers all transfers "by way of gift or otherwise" – Conditions: transfer must be subject to condition of providing basic amenities to transferor, and transferee must refuse or fail to provide such amenities – Both conditions must be fulfilled for the transfer to be voidable – Transfer often made out of love and affection without expectations – Conditions must be established before the Tribunal [Paras 1-14].

Legal Requirements – Pleading and Evidence – Petition did not plead transfer was subject to the condition of providing basic amenities – No such finding by Tribunal – Oral evidence not adduced – Order of Maintenance Tribunal unsustainable as conditions of Section 23(1) not satisfied – High Court failed to consider merits [Paras 14-15].

Decision – Appeal Allowed – Orders of the Maintenance Tribunal and High Court set aside – Petition under Section 23 of the 2007 Act dismissed – Rights of intervenor (developer) left open for appropriate proceedings [Paras 16-17].

Criminal Law – Additional Evidence in Appeal – High Court allowed the accused to present additional evidence regarding his mental condition at the time of the incident – Supreme Court set aside the High Court's order – Mental condition and capacity to face trial were already examined and affirmed by this Court – Additional evidence not warranted without a hearing on merits of the appeal [Paras 1-20].

Section 391 CrPC – Appellate Court’s Power to Take Additional Evidence – Should be exercised after hearing on merits of the appeal – High Court must record reasons and may take evidence itself or direct it to be taken by a subordinate court – High Court's approach in this case found procedurally improper [Paras 13-14].

Section 84 IPC – General Exception for Acts of Unsound Mind – Plea of insanity covered under Section 84 IPC was previously considered and rejected by Trial Court and affirmed by Supreme Court – High Court's order allowing further evidence on the same issue without examining existing records was improper [Paras 11-12].

Decision – Appeal Allowed – High Court’s order dated 29.03.2022 set aside – Criminal Appeal No. 453 of 2019 restored for reconsideration on merits – Application for additional evidence to be considered at an appropriate stage by High Court [Paras 15-20].

Constitutional Law – Article 226 – Public Project and Land Allotment – High Court erred in holding the possession by Nagpur Metro Rail Corporation as illegal – Allotment for public project by the Collector was not challenged – Public project cannot be stalled due to pending civil suit on lease termination – Appeal allowed, High Court’s order set aside [Paras 1-7].

Section 39 Metro Railways (Construction of Works) Act – Jurisdiction of Civil Court – Bar applies only where adequate remedy is provided under the Act – Civil suit for title declaration not barred – High Court misinterpreted the provision [Para 3].

Disputed Facts – Writ Petition Not Maintainable – Presence of disputed facts regarding possession and lease termination – High Court should not have entertained the writ petition under Article 226 – Civil suit pending to resolve the lease termination dispute [Paras 6.1-6.2].

Public Interest – Land Allotment for Nagpur Metro Rail Project – Public interest and necessity for the project justified the land allotment – Public project cannot be halted pending resolution of civil rights in a suit [Para 6].

Decision – Appeal Allowed – High Court’s order quashed – Writ petition dismissed – Pending civil suit to be decided on merits [Paras 7-8].