Environmental Law - Reserved Forest Land – Status upheld since 1879 – Fabricated Gazette Notification exposed – Land in Survey No. 20 originally notified as Reserved Forest in 1879 remained so despite partial de-reservation in 1934 – RRCHS relied on a 1944 notification found to be forged – Held: The land retained its Reserved Forest character, and any contrary claim based on forged records is invalid [Paras 12-21].

Forest (Conservation) Act – Prior approval mandatory – Allotment without Central clearance illegal – The 1980 FC Act prohibits State authorities from de-reserving or allotting forest land without Central Government approval – High officials bypassed this requirement citing an outdated precedent – Held: Such actions were contrary to statutory mandate and Supreme Court's binding orders, rendering the allotment void ab initio [Paras 22-38].

Doctrine of Desuetude – Inapplicable to Forest Law – Forest protection laws not rendered obsolete – RRCHS argued land lost forest status due to non-use – Held: Doctrine of desuetude applies only where statutes fall into complete disuse and contrary practices prevail—Neither condition satisfied here—Forest entries actively maintained and enforced [Paras 39-47].

Bonafide Purchaser – RRCHS complicit – Deals predating allotment invalidate claim – RRCHS entered development agreements and took possession before land was even officially allotted – Held: RRCHS was not a bonafide purchaser; the Chavan Family acted as a front—All transactions violated allotment conditions and were legally impermissible [Paras 48-64].

Alternate Land Claim – Not Entitled – Distinction drawn from precedent – RRCHS sought alternate land relying on prior Supreme Court order – Held: Unlike earlier case where State illegally took over private land, here RRCHS acted illegally with full knowledge of violations—No relief can be granted for self-inflicted illegality [Paras 65-74].

Doctrine of Public Trust – Breached by State Officials – Forest land handed over for private profit – State authorities including Minister and Divisional Commissioner colluded to transfer forest land to builders under the guise of resettlement – Held: This was a grave violation of the public trust doctrine and environmental norms—Such conduct undermines constitutional duties of the State [Paras 75-91].

Nationwide Directions – Forest lands under Revenue control to be handed over – Orders issued to all States/UTs – Supreme Court mandated that all forest lands under Revenue Departments be transferred to Forest Departments – Directed recovery or restoration where lands have been illegally allotted for non-forest use [Paras 92-94].

Decision – Allotment cancelled – Environmental clearance quashed – Forest land to be restored – Appeal disposed – Held: The 11.89 ha land allotted in 1998 and later sold to RRCHS was illegally transferred—Environmental clearance issued to RRCHS is quashed—Land to be restored to Forest Department and nationwide steps for forest protection initiated [Paras 95-96].

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].

Electricity Act – Connection Agreement and Liability – Sole Responsibility of Applicant – Appeal Allowed - The Supreme Court held that under the Connection Agreement dated 02.07.2021, BHP Ltd., as the sole applicant, bore full liability to HPPTC Ltd. for Bay construction and O&M charges – Respondents No. 2 and 3, not being parties to the agreement, could not be held contractually liable by HPPTC Ltd. – Any recovery from these parties was BHP Ltd.'s internal matter governed by a separate Internal Tripartite Agreement – The Appellate Tribunal for Electricity erred in holding otherwise [Paras 21–24, 28–30].

Doctrine of Privity – Applicability to Electricity Transmission Contracts – Third Parties Not Liable – Appeal Allowed - The Court reaffirmed that under the doctrine of privity, parties not signatory to a contract (Respondents 2 and 3) could not be held liable by a party (HPPTC Ltd.) for obligations under said contract (Connection Agreement), even if they benefitted from its execution – Tribunal’s reasoning failed to consider this foundational contractual principle [Paras 26–29].

Decision – APTEL Order Set Aside – State Commission Order Restored - The Supreme Court set aside the judgment of the Appellate Tribunal for Electricity dated 17.03.2023 – Restored the Himachal Pradesh State Electricity Regulatory Commission’s Order dated 27.12.2022 – Appeal by HPPTC Ltd. allowed with no order as to costs [Paras 30–31].

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].

Army Law – Adverse ACRs – Bias and Concealed Downgrading – Appeal Allowed - The appellant, a highly decorated officer, was denied promotion due to two ACRs with allegedly biased and intentionally concealed lower ratings by the Initiating Officer (IO) – The Tribunal expunged only one ACR (07/18–06/19), but not the earlier one (12/17–06/18) despite identical circumstances and reporting pattern – The Supreme Court held that both ACRs suffered from the same mala fide intent and required equal treatment – Directed expunction of ratings in both ACRs and reconsideration of promotion [Paras 13–16].

Confidential Reports – Discrepancy in Disclosed vs. Undisclosed Parts – Intent to Mask Lower Ratings – Appeal Allowed - It was found that the IO had given consistent positive ratings in the disclosed portions of the ACRs but gave relatively low grades in the confidential (undisclosed) sections to deliberately impact the appellant’s promotion prospects – The Court held such action as mala fide and unjustified – Tribunal’s partial relief was extended to include both contested ACRs [Para 15].

Promotion – Reconsideration Direction – Notional Benefits on Superannuation – Appeal Allowed - The Court modified the Armed Forces Tribunal’s order by extending relief to both contested ACRs and directed reconsideration for promotion to Major General, even if the appellant had already superannuated – Monetary benefits to be granted within three months [Para 16].

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].

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].