Civil Law - Andhra Pradesh Land Grabbing (Prohibition) Act, 1982 - Land Grabbing – Scope of 'Land Grabbing' and 'Land Grabber' – Interpretation of AP Land Grabbing Act – Criminal Intent Not Mandatory - Under the Act, both narrow and broad meanings of "grab" apply – While mens rea is not always required, unlawful and unauthorized possession or creation of third-party interests suffices – The Court affirmed that the statute covers even non-violent and non-criminal encroachments when done without lawful entitlement [Paras 5-7].

Land Ownership Dispute – Survey Number Mismatch – Registered Titles in Different Survey Numbers – Appellant's Claim Rejected - The appellant claimed title under Survey No. 10 while the land in possession was confirmed by the Commissioner’s report to fall under Survey No. 9 – Held: Possession was unauthorized; appellant failed to rebut the presumption of land grabbing after respondent established prima facie title [Paras 9-12].

Adverse Possession – Lack of Proof of Hostile Possession – Claim Denied - Appellant's claim of adverse possession failed due to absence of proof regarding the start and continuity of hostile possession – Respondent's prompt objection through cooperative society proceedings disproved the claim of adverse, uninterrupted possession [Paras 16].

Jurisdiction and Nature of Proceedings under the Land Grabbing Act – Special Court's Summary Powers Upheld – No Procedural Illegality - Special Court has both civil and criminal jurisdiction – Proceedings follow principles of natural justice and are based on CPC – Burden of proof shifts upon prima facie evidence by complainant – No prejudice caused to appellant due to this scheme [Paras 13-15].

Final Decision – Dismissal of Appeal – Special Court and High Court Findings Affirmed - The Supreme Court found no merit in the appeal – Observed that the appellant failed to rebut the evidence and presumption raised – Appeal dismissed, upholding the findings of the courts below [Paras 17-18].

Criminal Law - Custodial Death – Demand for Independent Investigation – Local Police Involved – CBI Directed to Take Over – Allegations of police brutality leading to the death of Deva Pardhi in custody prompted a plea by relatives seeking transfer of investigation from local police, who were the accused themselves – Supreme Court found that no arrests were made eight months after FIR and that doctors possibly acted under pressure – Held: Investigation transferred to CBI to ensure impartiality and credibility [Paras 3–32].

Witness Intimidation – Sole Eyewitness Threatened and Implicated – Witness Protection Ordered – Gangaram Pardhi, sole eyewitness to the custodial torture, was being implicated in multiple FIRs post-incident – Court acknowledged threats and coercion and upheld High Court's order shifting him to Central Jail – Held: State authorities directed to provide witness protection as per law [Paras 7, 12, 20, 27, 35–36].

Bail Application – Direction to Approach High Court – Liberty Granted – Supreme Court refrained from directly granting bail but noted ongoing persecution of the eyewitness – Held: Gangaram Pardhi permitted to approach High Court for bail in all implicated cases post-incident; High Court to decide considering present observations [Paras 33–34].

Decision – CBI to Investigate – Witness Protection and Bail Liberty Granted – Supreme Court allowed the appeal in part by transferring the investigation to CBI, directing protection for Gangaram Pardhi, and permitting him to seek bail from High Court with due consideration to the case circumstances [Paras 31–37].

Criminal Law - Wild Life (Protection) Act, 1972 (Wildlife Act) - Wildlife Offences – Possession of Scheduled Animal Parts – Conviction Justified – The appellants were caught red-handed with tiger skins, claws, bones and antlers in a car at a petrol pump by the CBI – Two independent witnesses supported the seizure – Held: Recovery was convincingly established and corroborated by witness testimony, justifying conviction under the Wildlife Act and IPC Section 120-B [Paras 3-8, 22].

Investigation Gaps – Failure to Trace Full Chain – No Ground for Acquittal – Investigation failed to trace source or intended buyer of the wildlife items and did not establish age of the articles – Held: These shortcomings do not dismantle the prosecution's core case, which is based on direct recovery and seizure from the accused [Paras 20-21].

Sentencing – Youth of Accused and Lack of Evidence of Poaching – Sentence Reduced – Accused were young at the time of incident and there was no direct evidence they killed the animals – Held: Sentence of six years reduced to three years' simple imprisonment with increased fine, considering mitigating factors [Paras 23-24].

Final Decision – Conviction Maintained, Sentence Modified – Supreme Court confirmed guilt of the appellants but reduced their sentence to three years’ simple imprisonment and fine of Rs.25,000 each – Failure to pay fine will result in an additional three months’ simple imprisonment [Paras 24-26].

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].

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].

Arbitration – Objection on Jurisdiction – MP Act Applicability Raised Late – Award Restored – The respondent failed to object to the jurisdiction of the arbitral tribunal during arbitration or in initial Section 34 petition – Only after the L.G. Chaudhary (II) decision was such a ground introduced – Held: In line with precedent, an award cannot be annulled solely on jurisdictional ground if no such plea was raised at the relevant stage – Award restored [Paras 6–9, 36–40].

Jurisdictional Plea – Not Raised Under Section 16 – Considered Waived – In absence of timely objection under Section 16 of the Arbitration Act, a jurisdictional plea is deemed waived – No valid reason shown to excuse delay in raising such a plea – Held: Respondent cannot be permitted to approbate and reprobate – High Court’s annulment of award erroneous [Paras 27–35, 39–41].

L.G. Chaudhary (II) vs. Lion Engineering – No Real Conflict – Limited Exception Carved – While Lion Engineering allows legal pleas on jurisdiction in Section 34, L.G. Chaudhary (II) clarified that MP Act applicability raised post-award without earlier objection will not annul the award – Held: L.G. Chaudhary (II) not per incuriam, reflects conscious carving of exception due to earlier inconsistent precedents [Paras 18–23, 36–37].

Decision – Civil Appeal Allowed – Arbitral Award Restored – High Court’s annulment set aside – Matter remanded to Commercial Court to adjudicate other Section 34 objections without disturbing the award on ground of jurisdiction – Held: MP Act objection cannot be raised post-award without prior challenge [Paras 40–41].

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 - Temple Receivership – Widespread Judicial Appointments – Chronic Litigation – Reformed - Supreme Court found long-standing misuse of receivership across 197 temples in Mathura where most receivers were advocates – Held: Such appointments led to indefinite litigation, stalling temple administration and violating public trust – Courts must avoid routine receivership and expedite dispute resolution to restore autonomy to temple trusts [Paras 4.10, 6, 22–26, 31–33].

Receiver Appointment – Advocates Not Absolutely Barred – Statutory Discretion Retained - Court acknowledged that Order XL CPC does not prohibit advocate appointment as receivers – However, courts must exercise discretion judiciously – Held: Only persons with religious knowledge, devotion, and administrative capacity, especially from the Vaishnav Sampradaya, should be considered for receiver roles in sacred temples – Blanket appointment of advocates deprecated [Paras 9.3, 21–22, 29, 31, 33].

Article 14 Challenge – Advocates’ Exclusion Not Discriminatory – Petition Dismissed - Appellant’s argument that excluding advocates violated Article 14 was rejected – Held: Classification was reasonable given spiritual, cultural, and practical requirements of temple administration – Religious competence is a valid criterion under the Constitution’s secular structure [Paras 9.4, 22–24].

Braj Region Temple Crisis – Structural Reforms Mandated – Systemic Clean-Up Ordered - Found that litigation over temple control dated back to 1923, and no final adjudication occurred in hundreds of cases – Directed trial courts to cease using receivers as a substitute for adjudication – Held: Courts must now consider spiritual competence and local customs before appointing receivers [Paras 4.10, 23–24, 28–29, 31–33].

Banke Bihari Temple Corridor – State’s Development Scheme Approved – Fund Use Permitted - Supreme Court allowed State of Uttar Pradesh to use temple funds to purchase 5 acres of land around Banke Bihari Temple for crowd management – Directed that acquired land must remain in the name of the Deity – High Court order modified under Article 142 – Upheld need for collaborative public-private development model in Braj region [Paras 11.6–11.9, 20, 24].

Decision – Appeal Dismissed – High Court Order Upheld – Future Receiver Appointments Regulated - Held: The order setting aside the Seven Member Receiver Committee was correct – Trial Court must now appoint a receiver with spiritual and administrative alignment, preferably from Vaishnav Sampradaya – Temple reform directions binding on lower courts – Appeal and all IAs disposed [Paras 24–25].