Criminal Law - Sections 420, 406, 467, 468, 473, 474, and 120B of the Indian Penal Code, 1860 - Quashing of FIR – Forged Lease Deed Used – FIR Restored – Allegation that accused used a forged lease deed to sell land and obtained ₹10 lakh as advance – Held: High Court erred in quashing FIR by relying on defence plea that accused were unaware of forgery or were willing to return money – Such issues are matters for trial – FIR restored for continuation of investigation and trial [Paras 2–10].

Plea of Defence – Not a Ground for Quashing – Accused Claimed to Be Victims Themselves – Rejected – Supreme Court reiterated that defence pleas cannot be considered at FIR stage – Even willingness to refund money does not negate commission of cognizable offence – Quashing order set aside [Paras 8–10].

Multiple FIRs – Distinct Transactions – Not Barred – Separate Victims, Separate Offences – Held: Presence of other FIRs relating to similar modus operandi does not make the current FIR a second FIR for the same offence – Each transaction with separate victim constitutes a distinct offence [Para 10].

Final Relief – FIR Quashing Set Aside – Criminal Proceedings to Continue – Supreme Court held that allegations made out a prima facie case – Investigation having culminated in a charge sheet, FIR and proceedings restored for trial – Appeal allowed [Paras 10–11].

Criminal Law - Criminal Complaint – Bar of Limitation – Section 468 CrPC – Cognizance Set Aside – Magistrate took cognizance only under Section 323 IPC (maximum punishment: one year) after three years of the alleged incident – Held: Section 468 CrPC applies; the complaint is barred by limitation – The Magistrate's and High Court’s orders set aside; complaint quashed [Paras 3–11].

Interpretation – Section 468(3) CrPC – Scope Limited to Joint Trial – Not Applicable When Cognizance Taken for Single Offence – Though the complaint alleged multiple offences including one under Section 452 IPC (punishable with up to seven years), cognizance was taken only under Section 323 IPC – Thus, the benefit of extended limitation under Section 468(3) CrPC not available – High Court misread the provision [Paras 6–9].

Legal Principle – Act of Court Cannot Prejudice – Limitation Relates to Date of Offence – Where delay in cognizance is due to court’s process and not complainant’s fault, bar may not apply – However, no justification or extension under Section 473 CrPC invoked in this case – Hence, bar under Section 468 CrPC attracted [Para 8].

Final Relief – Complaint Quashed – Cognizance Beyond Limitation Invalid – Appeal Allowed – The Supreme Court quashed Complaint Case No.13176 of 2018 – Cognizance taken on 27 September 2019 was beyond limitation for an offence under Section 323 IPC, alleged to have occurred on 5 September 2015 [Paras 10–11].

Criminal Writ – PIL – Allegation of Fraudulent Cost Escalation – Prima Facie Rejected – Petitioner, a former MLA and PAC Chairman, alleged wrongful revision of estimates in PRRLIS causing Rs. 2,426.07 crores loss to public exchequer – Supreme Court upheld the High Court’s dismissal of the writ petition – Held: Allegations required factual adjudication not suitable for exercise of writ jurisdiction under Article 226 – Summary dismissal by High Court justified [Paras 1, 4, 10, 18].

CBI Investigation – Scope of Judicial Discretion – Writ Court’s Non-Interference Upheld – Petitioner sought CBI investigation into the alleged irregularities – Supreme Court held that the High Court was justified in refusing to refer the matter to CBI – Mere allegations unsupported by prima facie evidence or substantiated material do not mandate such referral – Discretion exercised by the High Court cannot be faulted in SLP proceedings [Paras 9, 19].

Res Judicata – Constructive Res Judicata – Repetitive Petitions by Same Petitioner – Earlier PILs by the same petitioner on related issues (Nos. 28/2016, 179/2016, 338/2017) were already disposed of – Present SLP found to be barred by principle of constructive res judicata – Also noted suppression of material facts by the petitioner – Held: Maintainability of repeated PILs on same subject matter is seriously questionable [Paras 13, 21].

Vigilance Report – CVC Finding Complaint Unsubstantiated – Evidentiary Value – Central Vigilance Commission had closed the complaint regarding PRRLIS packages 5 and 8 as unsubstantiated by order dated 12.09.2017 – Supreme Court noted this finding while rejecting prayer for further inquiry – Held: Findings of competent statutory body carry persuasive value in assessing prima facie case in PILs [Paras 14, 21].

Final Decision – No Interference Warranted – Supreme Court found no illegality in High Court’s decision – Held: No justification to reopen the matter or interfere with impugned judgment – Special Leave Petition dismissed [Paras 20, 22].

Consumer Law - Challenge To Constitutionality And Validity Of Specific Provisions Of The Consumer Protection Rules, 2020 - Consumerism and Constitutional Philosophy – Broad Interpretation of Consumer Rights – Socio-Economic Relevance Affirmed – The Court held that the concept of consumerism is constitutionally embedded within principles of equality, dignity, justice and participatory democracy – Consumer forums are instruments of social justice promoting public accountability and participative governance – Consumer rights cannot be narrowly construed but must be seen in the context of constitutional values under Articles 38 and 51-A(h) [Paras 2–20].

Selection Committee Composition – Rule 6(1) of 2020 Rules Struck Down – Executive Dominance Held Unconstitutional – The Court held that Rule 6(1), which allowed excessive control of executive in appointment process, violated doctrine of separation of powers – Held: Only one nominee from executive branch can be permitted – Impugned rule declared ultra vires and struck down [Paras 55–58, 83].

Tenure of Appointees – Rule 10(2) Held Invalid – Minimum Five-Year Tenure Mandated – The 4-year term under Rule 10(2) was found contrary to precedent and judicially established principles – A minimum five-year tenure is essential to ensure institutional independence and stability of consumer fora – Rule 10(2) struck down [Paras 84, 99].

Written Examination Requirement – Directions in Limaye–I Clarified – No Written Exam for Judicial Members or Presidents – Held: Requirement of written test introduced in Limaye–I applies only to non-judicial members – Judicial Members and Presidents are exempted – Review Petitions allowed to clarify this misinterpretation – Appointments made without written tests for judicial roles upheld [Paras 78–81, 100].

Appointments Made Under 2023 Advertisements – Appointments of 112 Candidates Valid – Non-Impleadment of Appointees Rendered HC Decision Invalid – Held: High Court’s failure to implead selected candidates violates natural justice – Also, written examination was substantially complied with – Hence, appointments made via notification dated 05.10.2023 upheld [Paras 86–89].

Reappointments – Not a Vested Right – Must Be Made Under New Rules – The Court held that repealed 2019 Rules cannot govern reappointments – Held: Any reappointment must comply with fresh set of rules to be framed – Rule 8(18) of 2019 Rules cannot be revived or relied upon – No automatic reappointment possible [Paras 90–98].

Appointments in Telangana – Prospective Application of Limaye–I – No Retrospective Invalidation – The Court set aside High Court's decision cancelling Telangana appointments made prior to Limaye–I – Held: Directions in Limaye–I do not operate retrospectively – Appointees to be reinstated [Para 101].

Final Relief and Constitutional Directions – Mandate to Frame New Rules – SC exercised powers under Article 142 to direct Union of India to frame fresh Rules governing appointment, tenure and conditions of service – Emphasis on permanent consumer fora with clear recruitment framework – Court underscored need for transparency and institutional efficiency [Paras 102–104].

Decision – Civil Appeals Partly Allowed, Review Petitions Allowed in Part – Appointments upheld in certain states and quashed in others depending on compliance with legal and constitutional standards – Rules 6(1) and 10(2) declared unconstitutional – Directions issued for new regulatory framework and future appointments [Paras 99–104].

Civil Writ – Service Law - Performance Appraisal – Role of IAS Officers in IFS PAR – Government Order Quashed – Government of Madhya Pradesh issued a G.O. on 29th June 2024 allowing IAS officers to participate in the appraisal of IFS officers – Held: Such appraisal structure is contrary to Supreme Court’s binding rulings in Santosh Bharti and P.C. Wadhwa cases – Only officers from the IFS cadre can serve as reporting/reviewing authorities up to the level of Additional PCCF, with exceptions for PCCF level – Government Order quashed for violating binding judicial orders [Paras 1-3, 34-39].

Constitutional Governance – Contemptuous Nature of Administrative Orders – Judicial Orders Must Be Followed – The impugned G.O. was issued despite existing Supreme Court directions and without seeking clarification or modification – Held: The G.O. is contemptuous and demonstrates administrative disregard for the rule of law – Court refrains from initiating contempt proceedings but warns against future violations [Paras 36-39].

Service Jurisprudence – Reporting Authority Hierarchy – IFS Confidential Reports – Reporting and reviewing officers must be immediate superiors within the same department – Past judicial interpretations and DoPT/MoEF circulars reiterated this – Evaluation by non-IFS officers is impermissible unless officer works outside the department – Observed: Superior officers must be in higher rank and grade than the one being appraised [Paras 11-20, 24-26, 30-33].

Judgment – Government Order Struck Down – Relief Granted – The impugned G.O. dated 29th June 2024 is quashed and set aside – State directed to reframe rules within one month in compliance with the directions issued by the Court in Santosh Bharti and clarified by MoEF and DoPT [Paras 41-42].

Road Safety – Public Interest Litigation (PIL) – National Highways – Implementation of Control of National Highways Act, 2002 – Directions issued to remove unauthorised occupation from National Highways and establish enforcement mechanisms – Court found the absence of dedicated inspection teams and grievance redressal portals violated statutory mandates – Held: Centre and Highway Administrations must constitute inspection squads, grievance portals, and public reporting mechanisms to ensure road safety [Paras 1-3, 5, 10, 13-14].

Highway Administration – Failure in Statutory Duties – Rule 3 of Highway Administration Rules, 2004 (as amended in 2019) – Highway Administrations failed to enforce mandatory duties such as SOP formulation, enforcement monitoring, and grievance resolution – No concrete data or compliance with SOPs submitted – Held: Detailed affidavits with implementation timelines to be filed; strict enforcement of Rule 3 required [Paras 8-9, 13].

Encroachments – Section 24 and 26 of 2002 Act – Lack of Survey and Eviction Mechanisms – Court found that despite legal powers to detect and remove encroachments, Highway Administrations lacked proactive enforcement – No regular surveys, no public complaint channels, and negligible action taken despite notices – Held: Mandatory regular inspections, citizen complaint portal, and toll-free reporting system to be established [Paras 2-7, 11-12, 14].

Public Accountability – Digital Tools and Surveillance – Rajmargyatra App – Incomplete Implementation – App intended for highway users’ complaints lacked redressal transparency and citizen feedback – Court directed upgrade of app with tracking features, status updates, and appeal mechanisms – Also ordered creation of portal with full complaint and response visibility [Paras 12-13].

Judicial Monitoring – Continuing Mandamus – Enforcement Timeline – Recognizing persistent failure of executive bodies, Court retained writ petition on file to ensure periodic judicial review and enforcement of compliance – Directed Union of India and MoRTH to file action-taken affidavits within three months – Surveillance teams with police coordination to be constituted for highway patrolling [Paras 14, 16].

Decision – Interim directions issued – Highway Administration and Union of India to implement SOPs, launch public portal, upgrade mobile app, establish patrolling teams, and file compliance reports within three months – Case to remain pending as continuing mandamus – Next compliance hearing on 15 September 2025 [Paras 16(i)-(viii)].

Criminal Law - Juvenile Justice Act – Determination of Age – School Certificate and Birth Certificate Take Precedence – The JJB had wrongly rejected documentary evidence and ordered medical examination despite availability of school and municipal birth records – Held: Section 94(2) of JJ Act mandates preference for documentary proof – Medical opinion can only be considered in their absence – Order of JJB declaring respondent an adult was invalid – Reversal by Appellate Court and High Court upheld [Paras 26-28].

Juvenility – Review of Previous JJB Decision – Not Permissible – JJB had previously accepted the respondent’s date of birth as 08.09.2003 – In subsequent proceedings, JJB took contrary view – Held: JJB lacks statutory power to review earlier declaration of age – Its contrary action was legally untenable – High Court rightly affirmed appellate reversal [Paras 29-30, 34].

Juvenility – Preliminary Assessment Under Section 15 – Respondent Aged Above 16 Years – JJB Conducted Assessment – Found Respondent Fit to Undergo Trial as Adult – As per JJ Act, in heinous offences involving minors aged 16–18, a preliminary assessment is mandatory – Respondent was assessed as mentally and physically capable and trial ordered before POCSO Court – Valid exercise of jurisdiction [Paras 35-39].

Bail – Juvenile in Conflict with Law – Grant of Bail Upheld – Though bail was initially denied by JJB and Sessions Court, High Court granted bail after finding no risk of moral or physical danger or criminal association – No evidence of misuse of liberty during three years of bail – Held: No interference warranted – Appellant or State free to seek cancellation if liberty is misused [Paras 41-42].

Decision – Appeals Dismissed – Declaration of Juvenility and Grant of Bail Upheld – Supreme Court found no legal error in impugned orders – Dismissed both criminal appeals with liberty to apply for bail cancellation if needed – No costs imposed [Para 43].

Civil Law – Partition Suit – Rejection of Plaint – Plaintiffs (mother and son) filed a suit for partition, possession, declaration, injunction, and accounting in respect of properties allegedly purchased from joint family funds – Defendant No.2 (Shaifali Gupta) and Defendant No.5 (subsequent purchaser) filed applications under Order VII Rule 11 CPC for rejection of plaint alleging bar under Benami Transactions (Prohibition) Act, 1988 – Trial Court and High Court rejected the applications – Supreme Court upheld the decision, holding that the issues were mixed questions of fact and law requiring trial [Paras 1–14, 19, 29].

Benami Transactions – Bar under Section 4 of Benami Act – Defendants argued that suit properties stood in names of individuals, hence benami and suit barred – Plaint averred properties were Joint Hindu Family properties purchased from joint family business income – Court held plaint did not disclose properties as benami ex facie – Whether properties were benami is a factual issue requiring evidence – Suit not barred under Section 4 [Paras 23–28].

Civil Procedure – Order VII Rule 11 CPC – Application for rejection of plaint must show suit is barred by law based solely on plaint averments – Defendants failed to establish bar under Benami Act based on plaint alone – Application rightly dismissed – Reliance placed on precedent from Pawan Kumar v. Babu Lal, (2019) 4 SCC 367 [Paras 13, 28–29].

Plea of Female Hindu Ownership – Section 14 Hindu Succession Act – Defendant raised argument of absolute ownership by female Hindu under Section 14 for the first time before Supreme Court – Court declined to entertain as not pleaded or argued before courts below – Also held Section 14 does not bar such a suit [Paras 30–31].

Decision: Special Leave Petitions dismissed – Applications under Order VII Rule 11 CPC rightly rejected – Suit to proceed on merits – No interference warranted under Article 136 of the Constitution [Paras 32–33].

Taxation Law - Income Tax Act – Deductions under Chapter VI-A – Interpretation of Section 80-IA(9) – Clarified Scope of Restriction – Section 80-IA(9) restricts allowance of deduction under other provisions to the extent profits are already claimed under Section 80-IA – Held: The Section does not bar computation of deductions under other sections; rather, it limits the aggregate deduction allowed, preventing duplication – Deduction under each section may be computed separately, but the total cannot exceed profits from eligible business [Paras 19-21, 23-24].

Legislative Interpretation – Meaning of “Allowed” vs “Computed” – Different Stages of Deduction – The Court distinguished between ‘computation’ and ‘allowance’ of deduction – Held: Section 80-IA(9) affects the stage of allowing deductions, not their computation – As long as aggregate deductions do not exceed profits of the business, computation under multiple sections is permissible – Bombay High Court’s view upheld [Paras 22-24].

Judicial Consensus – Approval of Bombay High Court View – Rejection of Contrary Interpretations – Supreme Court endorsed reasoning of Bombay High Court in Associated Capsules Pvt. Ltd. case – Declined to follow Delhi and Kerala High Court decisions that interpreted Section 80-IA(9) restrictively – Harmonious construction preferred to avoid anomalous results [Paras 22-24].

Decision – Reference Answered – Interpretation Settled – Held: Deduction under Section 80-HHC should not be reduced by the amount allowed under Section 80-IA – Both deductions to be computed independently – However, aggregate deduction under heading ‘C’ of Chapter VI-A must not exceed profits and gains of eligible business – Reference concluded accordingly [Paras 23-25].