Criminal Writ - Challenging Continued Imprisonment Of Foreign Nationals - Illegal Detention – Post-Sentence Confinement – Unlawful Continuation of Custody – Court held that once a foreign national completes their sentence, they cannot be kept in prison merely due to pending deportation – Detention beyond sentence period is impermissible in absence of designated correctional homes – State of West Bengal directed to address infrastructure gap [Paras 11–14].

Detention Conditions – Absence of Dedicated Centres – Urgent Rectification Ordered – Court noted that West Bengal lacks correctional homes/detention centres for illegal immigrants – Despite sentence completion, immigrants remain confined in prisons – State directed to expedite construction of such centres and update progress [Paras 13–15].

Release Guidelines – Bail for Prolonged Post-Sentence Detention – Structured Conditional Release – Court ordered bail for immigrants detained for more than 3 years post-sentence, subject to bond, verifiable address, biometric data, weekly reporting and police supervision – Directions modeled on previous Supreme Court guidelines in similar cases [Paras 17–20].

Judicial Propriety – Matter Transferred to Larger Bench – Case Tagged – Court held the core issue is under consideration in pending petitions before a larger bench (W.P. (C) No. 859/2013) – This matter to be tagged for final resolution with connected cases – Interim relief provided without adjudicating constitutional validity of impugned clauses [Paras 6–10, 23].

Decision: Interim Bail Granted – All illegal immigrants detained in West Bengal prisons for over 3 years post-sentence to be released on bail with strict conditions – State directed to complete identification within 4 weeks – Case tagged with W.P. (C) No. 859/2013 for comprehensive adjudication [Paras 17–23].

Illegal Immigrants – Post-Sentence Detention – Continued Imprisonment Held Illegal – Petitioners challenged the detention of foreign nationals post-completion of sentence under the Foreigners Act—Court held: Any person, whether citizen or not, cannot be imprisoned beyond their sentence—Illegal immigrants must instead be housed in correctional homes/detention centres pending deportation [Paras 11–13].

Infrastructure Deficiency – Absence of Detention Centres in West Bengal – Directions Issued – Court noted West Bengal lacked dedicated correctional homes for illegal immigrants—Held: Detention in prisons after serving sentence violates Article 21—Directed State to identify such detainees and ensure their release on bail if detained for over 3 years post-sentence [Paras 14–20].

Bail Conditions for Detained Foreigners – Released Pending Deportation – Directed release of illegal immigrants detained over 3 years post-sentence under specified conditions: bond of ₹1 lakh with two Indian sureties, verifiable address, biometric capture, weekly police reporting, and quarterly police supervision reports—Violations to be dealt with by Foreigners Tribunal [Para 17].

Judicial Restraint – Matter Tagged with Larger Bench – As identical issues regarding deportation, repatriation, and detention of illegal immigrants (including Rohingyas and Bangladeshis) are pending before Three-Judge Bench in Jaffar Ullah v. Union of India and Rajubala Das v. UoI, Court ordered tagging to avoid conflicting judgments—Pending decision in main matters [Paras 6–10, 23].

Constitutional Validity – Challenge to Government Circulars Reserved – Petitioners also challenged specific clauses in 2007 and 2009 deportation circulars as unconstitutional—Court did not adjudicate on this but noted the issue as part of broader challenge in connected cases [Paras 3, 4, 23].

Decision – Petition tagged with W.P. (C) No. 859/2013 and allied matters – Directed conditional release of illegal immigrants detained beyond 3 years after sentence – Directed State to complete identification within four weeks – Await further orders from larger Bench [Paras 19–23].

Civil Writ – PIL - Deepfake Regulation – Judicial Mandate Sought – Parallel Proceedings Not Entertained – Petitioner sought framing of rules under the IT Act for watermarking AI-generated content, algorithmic audits, takedown procedures, and creation of a national AI regulatory authority – Court declined to entertain the petition due to similar issues being sub judice before the Delhi High Court – Petitioner given liberty to assist the High Court proceedings [Paras 1–3].

Judicial Restraint – Matter Pending Before Coordinate Forum – PIL Dismissed Without Prejudice – Noting active consideration of identical legal issues in Chaitanya Rohilla vs. Union of India (W.P.(C) No. 15596/2023) before the Delhi High Court, the Supreme Court exercised restraint – Directed petitioner to seek impleadment before the High Court and contribute his inputs there [Paras 2–4].

Electoral Integrity and Privacy – Issues Raised but Deferred – Though the petition raised concerns on electoral misinformation, voter deception via deepfakes, and privacy violations, the Court refrained from adjudicating and instead emphasized judicial economy by consolidating proceedings [Paras 1, 4].

Decision: Petition Disposed – Supreme Court declined to entertain parallel PIL on deepfake regulation – Petitioner directed to approach Delhi High Court in ongoing related matters – Liberty granted to seek impleadment and assist with submissions [Paras 3–5].

Motor Accident Claim – Liability of Insurer – Duty limited to monetary compensation – High Court’s directive for lifetime support set aside – The High Court directed the insurer to provide prosthetic limbs, motorized wheelchair, travel expenses, and ensure ongoing support – Held: Insurer’s statutory role is limited to indemnifying loss in monetary terms, and not to maintain lifelong support infrastructure – Directions contrary to statutory framework and unsustainable [Paras 2-4, 6].

Compensation – Disability and Future Needs – Additional Rs.12 lakhs awarded – Expenses quantified for future wellbeing – The victim suffered 100% functional disability due to loss and impairment of both lower limbs at age 22 – Held: A prosthetic limb costing approx. Rs.2 lakhs, replaced every 5 years, and wheelchair costing Rs.40,000 require long-term provision – Court awarded Rs.12 lakhs with 6% simple interest to cover future expenses and mobility needs [Paras 5, 7-8].

Appeal by Insurer – No bar on grant of just compensation – High Court’s enhancement restructured – Though the appeal was filed by the insurer and not the claimant, the Supreme Court upheld the right to restructure compensation in monetary terms, in lieu of specific services previously directed – Held: The Court is merely converting non-monetary directions into quantified award and not increasing compensation beyond High Court’s intent [Paras 8-9].

Final Directions – High Court Order Set Aside – Award modified and appeal disposed – The Supreme Court set aside the High Court’s directions and substituted them with quantified compensation payable within two months – Directions given to respondent to furnish account details for online transfer – Pending applications also disposed [Paras 9-12].

Accident Claim - Motor Accident Compensation – Assessment of Monthly Income – Claim of Rs.10,000 accepted – High Court’s reduction reversed – The Tribunal awarded compensation based on the deceased driver’s claimed income of Rs.10,000 per month – High Court reduced it to Rs.4,076 applying minimum wages – Held: Based on precedent in Ramachandrappa v. Royal Sundaram, even unskilled labourers earned around Rs.4,500 in 2004, making Rs.10,000 reasonable for a skilled driver in 2014 – Tribunal’s assessment restored [Paras 3-4].

Future Prospects – 40% Addition – Compensation Properly Calculated – No Interference – The Tribunal rightly added 40% of monthly income towards future prospects – High Court erred in excluding it while calculating reduced compensation – Held: The calculation by the Tribunal aligns with prevailing law and requires no interference [Paras 2-4].

Loss of Consortium – Entitlement of Family Members – Retained Despite No Cross Appeal – Tribunal granted consortium to wife, children, and parents – Held: As per New India Assurance Co. v. Somwati, all dependents are entitled to consortium – Supreme Court retained the same though no appeal was filed by the claimants seeking enhancement [Paras 4-5].

Restoration of Tribunal’s Award – High Court Order Set Aside – Tribunal’s compensation confirmed – Appeal Allowed – Held: There was no justification for the High Court’s downward revision of compensation – Tribunal’s award reinstated in full, to be disbursed within two months and apportioned equally among legal heirs – In case of minors, amount to be held in fixed deposit [Paras 5-6].

Decision – Tribunal’s Compensation Restored – Appeal Allowed – The Supreme Court restored the full compensation awarded by the Motor Accident Claims Tribunal, setting aside the reduced award passed by the High Court – Compensation to be distributed as per Tribunal’s direction [Paras 5-6].

Criminal Law - Probation of Offenders Act – Inapplicability under PoFA Act – Section 20AA prohibits probation – Probation benefit denied - Section 20AA clearly excludes the application of the Probation of Offenders Act and Section 360 of the CrPC to those convicted under the PoFA Act unless the offender is under 18 years of age – The Court held that the provision is explicit, unambiguous, and constitutionally valid – Hence, probation not applicable [Paras 40-42].

Mollification of Sentence – FSS Act Repeal and Savings Clause – Reduced punishment not permitted – Benefit denied - Despite lesser punishment under the FSS Act, the repeal and savings clause under Section 97 preserves penalties under the repealed PoFA Act – The Court held that the presence of such a clause prevents application of lighter sentence from new law – Hence, no reduction in sentence permissible under FSS Act [Paras 43-44].

Adulteration Evidence – Discrepancy in Reports – Sentence converted to fine – Lead appeal partly allowed - In the case of Nagarajan and Selvaraj, the two lab reports on curd adulteration had significant differences—one showing deficiency in fat content, the other meeting the required standard – Applying precedent in C. Mohammed, the Court converted the 6-month imprisonment to a fine of Rs. 30,000 each [Paras 45-46].

Judicial Comity – Reliance on Coordinate Bench despite disagreement – Connected appeal partly allowed - Although the Bench disagreed with the reasoning in A.K. Sarkar & Co., it followed the decision to prevent further litigation, converting Naresh Chandra’s sentence to a fine of Rs. 20,000 in the interest of equity and justice [Paras 47-48].

Decision – Convictions upheld, Sentences modified – Probation relief and sentence reduction under FSS Act denied – However, due to specific factual circumstances and prior rulings, sentences were converted to fines – Appeals partly allowed [Paras 48-51].

Suo Motu - POCSO Cases – Setting Up of Exclusive Courts – Implementation of Judicial Directives – Compliance Directed - The Court directed that each district with more than 100 POCSO cases must establish exclusive courts under a Central scheme with appropriate staffing and child-friendly infrastructure – Majority of States complied but high-pendency States (UP, WB, Bihar, TN, Orissa, Maharashtra) were found lacking – Held: Union and State governments must prioritise timely establishment of such courts [Paras 1, 3, 5-6].

Forensic Delay – Effective Functioning of FSLs – Expedited Processing Ordered – Court acknowledged forensic delays as key bottleneck in trial completion – Directed State Forensic Labs to ensure swift analysis and reporting in POCSO cases – Mandated Chief Secretaries to ensure compliance [Para 1].

Child Sensitisation and Support – Appointment of Trained Support Persons and Prosecutors – Awareness Measures – Directions were issued to appoint child-sensitive support persons and prosecutors, and to run public awareness campaigns in cinemas and media with helpline information prominently displayed – Responsibility assigned to Ministry of Women and Child Development [Paras 1, 4].

Timely Trial – Adherence to Statutory Deadlines – States Reminded of Duty – Despite POCSO Act’s time-bound process for investigation and trial, delay persists due to inadequate infrastructure – States instructed to strictly follow the law and ensure completion of investigations and trials within statutory periods [Paras 2, 6].

Closure of Proceedings – Compliance Noted – Matter Concluded – Noting significant implementation of earlier directions and pending areas requiring attention, the Court closed the suo motu proceedings with appreciation for the amicus curiae and counsel – Held: Further monitoring not required at this stage [Paras 7-8].

Civil Law - Commercial Suit – Section 12A of Commercial Courts Act – Mandatory Nature – Rejection of plaint not justified – The suit was filed in 2019 without pre-institution mediation as mandated by Section 12A of the Commercial Courts Act – Relying on the prospective applicability of the Patil Automation decision, the Court held that suits filed prior to 20.08.2022 are not liable for rejection under Order VII Rule 11 CPC – Held: Rejection of plaint was unjustified; the High Court rightly directed the matter for mediation [Paras 5-13, 34-38, 46-48].

Doctrine of Prospective Overruling – Application to Section 12A Compliance – Relief sustained – The Court affirmed that the mandate laid down in Patil Automation applies prospectively – It ruled that suits instituted prior to 20.08.2022 without pre-institution mediation cannot be dismissed solely on that ground – The rejection would otherwise result in hardship and procedural prejudice [Paras 47-48, 54].

Urgent Interim Relief – Interpretation under Section 12A Proviso – Non-Applicability in Facts – The Court clarified that the proviso to Section 12A permitting bypass of mediation only applies where urgent interim relief is sought – In the instant case, no such relief was prayed – However, since the suit was instituted before the enforcement of the mandate, rejection was not warranted [Paras 35, 42-45].

Infrastructure Deficiency – Principle of Lex Non Cogit Ad Impossibilia – Applied in Favour of Appellant – The Court acknowledged that mediation infrastructure was lacking at the time of suit filing – Applied equitable maxim that law does not compel a man to do the impossible – Held: Procedural lapse excused in view of institutional shortcoming [Paras 15, 18-19, 49-53].

Decision – Appeal Dismissed – High Court Order Affirmed – The Supreme Court upheld the High Court’s direction to keep the suit pending and refer the matter for pre-institution mediation – Held: The approach of the High Court was proper and the appeal warranted no interference [Paras 4, 26, 55].

Employment Law - Public Employment – Format of Caste Certificate – Format compliance mandatory – Rejection of candidature upheld – Petitioners submitted OBC-NCL certificates in Central Government format rather than in the format required by the State of Uttar Pradesh – Clause 5.4(4) of recruitment advertisement clearly specified the required format and the consequence of non-compliance – Held: Non-submission in the prescribed State format rendered petitioners ineligible for OBC reservation – Authority acted within jurisdiction by excluding petitioners from consideration under OBC category [Paras 14–17].

Recruitment Rules – Non-discretionary application – Procedural fairness does not override explicit requirements – Plea that the Board should have granted a chance to correct the certificate format rejected – Held: Opportunity already existed at the time of application – Procedural fairness does not mean condoning clear procedural defaults – Equal treatment requires adherence to rules by all [Paras 19–21].

Judicial Review – Limited role of Courts – No interference when recruitment norms are unambiguous – Held: Recruitment authority is entitled to frame and implement rules unless proven to be arbitrary or violative of constitutional rights – Courts will not dilute terms of advertisement by equitable considerations unless warranted by exceptional circumstances [Paras 19–20].

Article 141 – Precedent – Summary dismissal of SLPs does not constitute binding law – Reference to previous reliefs granted to similarly situated candidates not helpful – Held: Dismissal of Special Leave Petitions in limine without reasons does not have precedential value – Does not create binding precedent under Article 141 of the Constitution [Para 23].

Decision of the Court – Appeals decided accordingly – Civil Appeal No. 5233 of 2025 (Mohit Kumar) dismissed – Civil Appeal No. 5234 of 2025 (State of U.P.) allowed – Held: Requirement of caste certificate in prescribed State format is justified and non-arbitrary – Rejection of candidature sustained [Paras 24–25].