Criminal Law – Quashing – Set Aside - Section 143, Railways Act, 1989 – Unauthorised Ticket Procurement and Supply – Section 143 prohibits unauthorized procurement and supply of railway tickets to ensure system integrity – Penal provisions aim to regulate ticket procurement and eliminate touting – The provision remains valid and applicable irrespective of physical or online ticketing modes, considering the legislative objective [Paras 14, 27-28].

Statutory Interpretation – Development of Technology – Provisions Broadly Construed - Statutory provisions must accommodate technological advancements if their language permits – Section 143 encompasses illegal online ticketing, contrary to the Kerala High Court’s interpretation – The provision applies to the e-ticketing system as it regulates the business of procuring tickets irrespective of the method used [Paras 20-22].

Quashing of Criminal Proceedings – Section 482 CrPC – Differential Outcomes - Quashing is permissible if FIR reveals no cognizable offence or continuance would result in injustice – Mathew, an unauthorized agent, must face trial under Section 143 – Ramesh, being an authorized agent, cannot be criminally prosecuted for contractual breaches, which require civil remedies [Paras 32-37].

Online Ticketing Rules – Use of Multiple User IDs – Unauthorized Practice Penalized - Use of multiple personal user IDs for profit by unauthorized agents violates IRCTC rules and attracts penalties under Section 143 – However, the provision does not criminalize such actions when committed by authorized agents [Paras 19, 36].

Decision  – Differential Relief Granted - Criminal proceedings against Mathew restored for trial under Section 143, while proceedings against Ramesh quashed due to lack of statutory violation – Appeals allowed partially [Paras 37-40].

Civil Law - Jurisdiction of Civil Courts – Bar under Section 34 SARFAESI Act – Interpretation of Tribunal Powers – Civil Court jurisdiction is not barred by Section 34 of the SARFAESI Act for matters beyond the scope of the Debt Recovery Tribunal (DRT)’s powers under Section 17 – Reliefs seeking declaration of sale and mortgage deeds as nullity, and possession of property are within the domain of civil courts as such issues involve title disputes and precede the measures taken under Section 13(4) SARFAESI Act [Paras 12-18, 23, 25].

Scope of DRT’s Powers – Section 17 SARFAESI Act – Limitations – The DRT’s authority under Section 17(3) SARFAESI Act is confined to addressing whether measures taken by secured creditors under Section 13(4) are in compliance with the Act – DRT lacks jurisdiction to adjudicate upon disputes regarding ownership, validity of sale deeds, or claims by third parties with adverse title. Use of the term "restore possession" in Section 17(3) confirms that possession can only be returned to a borrower or aggrieved person previously in possession, not to an independent claimant [Paras 17, 23, 39].

Rejection of Plaint – Order VII Rule 11 CPC – Partial Rejection Prohibited – A plaint cannot be partially rejected under Order VII Rule 11 CPC – If any relief survives and is not barred by law, the entire plaint must be allowed to proceed to trial – Even if certain reliefs are arguably barred by Section 34 SARFAESI Act, as long as others survive, the plaint cannot be dismissed in part [Paras 24-25, 34].

Judicial Precedents – SARFAESI Act – Validity of Civil Court Jurisdiction – Reaffirmed principles from Mardia Chemicals Ltd. v. Union of India (2004) 4 SCC 311 regarding limited ouster of civil court jurisdiction under Section 34 SARFAESI Act – Highlighted that title disputes, allegations of fraud, and reliefs outside the DRT's scope remain adjudicable by civil courts [Paras 26-36].

Standard for Bar of Jurisdiction – Interpretation of Statutes – Bar of civil court jurisdiction under special statutes is not to be readily inferred – Statutory provisions ousting jurisdiction must be interpreted strictly, with civil court jurisdiction upheld unless explicitly or implicitly excluded by the statute [Paras 22, 43].

Final Decision – Civil Court jurisdiction upheld for the reliefs sought in the present case – The High Court's restoration of the plaint was affirmed, and all connected appeals dismissed – Observed that proper due diligence in loan transactions, including title clearance, is critical to avoid such disputes [Paras 45-46].

Civil Law - Arbitration Agreement – Requirement of Validity – Mandatory Precondition - Arbitration relies on the existence of a valid arbitration agreement as per Section 7 of the Arbitration and Conciliation Act, 1996 – In this case, no such agreement was evidenced between the parties, rendering the awards invalid – Held: Awards declared null and void [Paras 20-21, 24].

Fraudulent Arbitration Proceedings – Lack of Party Consent – Violation of Party Autonomy - Respondent No. 1 unilaterally appointed arbitrators, violating the core principle of mutual consent – Proceedings found fraudulent under Section 18 of the Act, which requires fairness and impartiality – Such awards are unenforceable [Paras 21-24].

Execution Proceedings – Jurisdiction and Limitation – Fraud Can Be Raised at Execution Stage - Although objections under Section 34 were dismissed as time-barred, fraud and lack of subject matter jurisdiction were validly raised at the execution stage under Section 47 of the CPC – Held: Awards unenforceable for lack of jurisdiction [Paras 18, 24].

Unilateral Arbitrator Appointments – Judicial Scrutiny – Invalidity and Standards of Impartiality - Referring to Central Organisation of Railway Electrification v. ECI PIC SMO MCPL, unilateral appointments breach standards of independence – Arbitrators must maintain impartiality akin to judicial officers – Held: Proceedings lacked legal sanctity [Paras 23-24].

Judgment Outcome – Appeals Allowed - The ex-parte awards dated 15.02.2008 and 25.06.2008 were declared null and void – Execution proceedings dismissed – Costs awarded to the appellants [Paras 25].

Juvenile Justice – Plea of Juvenility – Retrospective Application – Procedural Mandate – Benefit under Juvenile Justice Act, 2015 – Appellant raised a plea of juvenility at every stage of proceedings, claiming to be 14 years old at the time of the offence – Trial Court, High Court, and Supreme Court dismissed the plea relying on irrelevant factors such as a bank account – Birth certificates and ossification test confirmed juvenility – Mercy Petition partially allowed, commuting death penalty to life imprisonment with conditions – High Court dismissed Writ Petition challenging Presidential Order and seeking determination of juvenility under Section 9(2) of the 2015 Act – Supreme Court held that procedural mandates under the Juvenile Justice Acts were not followed and the plea of juvenility, being a constitutional mandate, can be raised at any stage – Appeal allowed – Appellant’s sentence reduced in line with the Juvenile Justice Act, 2015 – Directions issued for the Appellant’s rehabilitation and reintegration into society [Paras 33–54].

Judicial Duty – Determination of Truth in Juvenile Justice Cases – Courts are obligated to proactively determine the age of an accused, especially when the accused is illiterate and submits credible evidence – Procedural lapses in earlier adjudications cannot deny rightful relief under social welfare legislations like the Juvenile Justice Act [Paras 47-49].

Rehabilitation and Reintegration – Right to Livelihood under Article 21 – Appellant’s release directed with State Legal Services Authority tasked to ensure rehabilitation and reintegration into society – Emphasis placed on welfare schemes for livelihood, shelter, and sustenance [Para 53].

Decision – Conviction maintained, sentence reduced to align with the Juvenile Justice Act – Appellant directed to be released forthwith if not required in any other case [Para 54].

Limitation Law – Filing of Subsequent Suit for Specific Performance – Article 113 and Order VII Rule 13 of the Code – Suit Barred – The second suit filed in 2007 for specific performance was barred under Article 113 of the Limitation Act – Held: The second suit must be filed within three years from the rejection of the earlier plaint in 1998; filing the suit beyond 2001 made it time-barred under Order VII Rule 11(d) [Paras 9.8-9.12].

Pleadings – Misuse of Extension Letter – Letter dated 15.07.1991 used in second suit not mentioned in first suit filed in 1993 – Attempt to misuse it for continuity of cause of action – Held: Such reliance was mischievous and inadmissible [Paras 9.9-9.11].

Law of Limitation – Nature and Scope – Doctrine of Continuous Running of Time – Once time starts running under limitation, it continues unless interrupted by statutory provisions – Held: Extension based on pending litigation irrelevant for computing limitation under Article 113 [Para 9.11].

Decision – Second Suit for Specific Performance Rejected – Application under Order VII Rule 11(d) allowed – Appeal allowed, setting aside trial court and High Court orders [Paras 9.12, 10].

Arbitration – Delay Attributable to Claimant – Section 14 of the Limitation Act – Interest Granted from Specific Date – Arbitral Tribunal directed interest @ 12% per annum for the delay, which was upheld by the High Court – Held: In peculiar facts, interest allowed only from 06/03/2010, the date on which the Arbitral Tribunal condoned the delay and deemed claims within limitation [Paras 2-3].

Contractual Obligation – Insurance Claim and Delayed Payment – Liability for Interest – Respondent approached legal remedies due to appellant’s refusal to pay – Held: Appellant liable to pay interest for outstanding dues; justice requires modifications to interest start date [Paras 3-4].

Decision – Modification of Interest Period – Arbitral Award modified to calculate interest @ 12% per annum from 06/03/2010 – Appellant directed to pay the balance within four weeks [Para 4].

Land Acquisition – Compensation Under 2013 Act – Supreme Court’s Powers Under Article 142 – The respondents, landowners, sought compensation for acquired lands – The Supreme Court, following K.L. Rathi Steels Ltd. (2024) 7 SCC 315, directed that compensation be paid under the 2013 Act – The time for fresh acquisition proceedings under Section 24(2) of the 2013 Act was extended by one year, from 01/08/2024 – Held: Respondents entitled to compensation under the 2013 Act, subject to procedural compliance as outlined in K.L. Rathi (2024) [Para 3].

Article 142 – Exercise of Inherent Powers – Balancing Public and Private Interests – The Court exercised Article 142 powers to ensure uniformity in compensation awards and to balance public interest with private rights – Provisions of Chapters II and III of the 2013 Act (Social Impact Assessment) were dispensed with, given the urban/semi-urban nature of the land – Held: Directions issued to expedite fresh acquisition proceedings, while waiving procedural requirements to ensure fairness and efficiency [Paras 3-4].

Land Acquisition – Procedural Directions – Expedited Compensation Payment – The Court issued specific directions:

a) Time limit for acquisition extended by one year (from 01/08/2024).

b) Status quo to be maintained on possession and land use.

c) Social Impact Assessment waived due to urban nature of land.

d) Pre-2014 notifications deemed preliminary notifications under Section 11 of the 2013 Act.

e) Compensation to be assessed as of 01/01/2014, with all monetary benefits except rehabilitation.

f) Collector to determine compensation as per Section 28, award solatium under Section 30 – Landowners may seek enhancement under Chapter VIII of the 2013 Act.

Held: Orders passed to ensure fair compensation while streamlining procedural requirements [Para 3].

Decision: Miscellaneous Applications Disposed of – Supreme Court extended the time for fresh acquisition proceedings and ordered compensation to be paid under the 2013 Act, with procedural waivers to ensure expeditious resolution – Pending interlocutory applications also disposed of [Paras 5-6].

Accident Claim - Golden Hour – Definition and Significance – Section 162 of Motor Vehicles Act, 1988 – Golden hour defined under Section 2(12-A) as the one hour following a traumatic injury – Critical for saving lives through prompt medical treatment – Held: Cashless treatment during the golden hour is a statutory obligation to uphold the right to life under Article 21 of the Constitution [Paras 1-3].

Motor Vehicle Accident Fund – Establishment and Utilization – Section 164-B of the Motor Vehicles Act – Fund established to finance the treatment of accident victims – Central Motor Vehicles (Motor Vehicle Accident Fund) Rules, 2022 specify utilization, but cashless treatment scheme under Section 162 yet to be implemented – Held: Central Government directed to frame and implement the scheme by 14/03/2025 [Paras 4-8].

Pending Claims – Hit and Run Scheme – Data on claims reveals significant delays due to deficiencies in documentation – Directions issued to GIC to process claims with specified minimal documents and coordinate with claimants to resolve deficiencies – Portal development for claim processing expedited to avoid delays [Paras 10-12].

Decision – Central Government directed to finalize the cashless treatment scheme for golden hour victims by 14/03/2025 and report compliance – Directions issued to General Insurance Council (GIC) to process pending claims and expedite portal development [Paras 8, 12].

Criminal Law – Rape and POCSO Act – Acquittal – Respondent accused of abducting and raping a 16-year-old prosecutrix under threat of a knife – FIR filed after two days of delay, with initial report by father alleging assault by three boys unrelated to the accused – Medical examination showed no injuries; contradictions in prosecutrix’s testimony regarding assault – Trial Court and High Court acquitted the accused for lack of credible evidence – Supreme Court upheld acquittal – Held: Sole testimony of prosecutrix must inspire confidence to convict; prosecutrix’s testimony contradictory and lacked corroboration – Appeal dismissed [Paras 4–12].

Delay in FIR – Unexplained Delay – Incident allegedly occurred on 16.09.2014; FIR lodged on 18.09.2014 – Trial Court found delay unexplained and raised doubts about the veracity of allegations – High Court and Supreme Court concurred that delay undermined prosecution’s case in the absence of corroborative evidence [Paras 5, 7, 12].

Testimony of Prosecutrix – Contradictions and Credibility – Prosecutrix’s testimony contradicted her earlier statements under Section 164 CrPC and her examination-in-chief – Allegations of hitting the accused with a danda varied in description, with no injuries found on the accused during surrender – Supreme Court emphasized that conviction based on sole testimony of prosecutrix requires absolute confidence in its reliability, which was absent in this case [Paras 9–10].

Absence of Resistance or Alarm – Credibility Questioned – Prosecutrix stated that accused, known to her, threatened her with a knife but raised no alarm while being taken through a public bazaar and into a shop – Supreme Court noted that prosecutrix’s explanation failed to inspire confidence, as circumstances contradicted normal behavior in such situations [Paras 11–12].

Medical Evidence – Lack of Injuries – Medical examination revealed torn hymen but no external injuries on prosecutrix – Supreme Court noted absence of corroborative medical evidence to support allegations of force or assault, further weakening prosecution’s case [Paras 9, 12].

Decision: Appeal dismissed – Orders of Trial Court and High Court acquitting the respondent upheld – Supreme Court reiterated caution in convicting based on sole testimony without corroboration in rape cases [Paras 12–13].