Criminal Law – Quashing of Criminal Proceedings - Defamation – Builder-Buyer Protest – Peaceful Banner Display by Flat Owners – Complaint Quashed – The appellants protested against the developer by publicly displaying banners alleging non-performance and defects – The builder filed a defamation complaint – Held: The language used was temperate, grievances were genuine and publicly voiced in good faith for protection of residents' interests – Complaint and summons quashed [Paras 2–6, 14–16, 30–35].

Section 499 IPC – Ninth Exception – Good Faith Imputation in Public Interest – Applicable – Court held that peaceful expression of consumer grievances with no abusive or foul language fell under the ninth exception to Section 499 IPC – The protest aimed at safeguarding collective interests of homeowners and was thus protected [Paras 17–21].

Freedom of Speech – Peaceful Protest and Consumer Rights – Protest Upheld – Supreme Court reaffirmed right to protest under Article 19(1)(a), (b), and (c) – Noted that expressing dissatisfaction in a non-abusive, legitimate way is a protected form of dissent in a democratic setup – Attempt to criminalize such expression is misuse of process [Paras 26–30].

Scope of Magistrate’s Duty – Consideration of Exceptions at Summons Stage – Clarified – Referring to Iveco Magirus ruling, Court held that magistrates are not barred from considering applicability of exceptions to defamation at the time of issuing process – If a complete defense is evident, summons should not be issued [Paras 10, 13].

Decision – Criminal Complaint and Summons Quashed – High Court’s refusal to quash proceedings reversed – Appeal allowed – Complaint in CC No. 2042/SS/2016 and order issuing summons set aside [Paras 30–35].

Civil Law - Limitation – Suit Filed to Set Aside Decree after 17 Years – Bar under Article 59 of the Limitation Act – Suit Held Time-Barred – Respondents filed suit in 1982 to set aside a 1965 decree and claim partition – Trial Court and First Appellate Court dismissed the suit as barred by limitation – High Court remanded the matter for retrial on limitation issue – Held: Respondents were aware of earlier proceedings and were party to execution – Limitation is a question of law in this case, and Courts below rightly dismissed the suit as barred by law [Paras 13-16, 23-24].

Second Appeal – Jurisdiction under Section 100 CPC – Remand by High Court Without Deciding Substantial Questions of Law – Set Aside – High Court failed to decide substantial question of law framed at admission and remanded for retrial on limitation – Held: High Court's remand unsustainable as Section 100 empowers it to adjudicate substantial legal issues directly – Framing and non-framing of issues immaterial where parties had full opportunity to contest limitation [Paras 11-12, 18-22].

Procedural Law – Limitation and Framing of Issues – Courts’ Duty under Section 3 of Limitation Act – Even in Absence of Plea or Issue, Court Must Examine Limitation – Trial and Appellate Courts rightly adjudicated limitation based on pleadings, evidence, and statutory mandate – Procedural lapses do not override substantive justice where parties have had fair trial and no prejudice is caused [Paras 19-22].

Final Decision – Appeal Allowed – High Court’s judgment remanding case for fresh trial set aside – Judgments of Trial Court and First Appellate Court dismissing the suit restored – Respondents' claim barred by limitation and no relief warranted – Each party to bear own costs [Paras 23-24].

Bail – Anticipatory Bail in Economic Offences – Orders Set Aside – SFIO challenged anticipatory bail granted to several accused by the High Court despite earlier non-bailable warrants and proclamation orders issued by the Special Court – Held: High Court erred in granting anticipatory bail ignoring mandatory provisions under Section 212(6) of the Companies Act and repeated defiance of court summons – Anticipatory bail granted to absconding accused is impermissible unless under exceptional circumstances [Paras 3-9, 23-27].

Economic Offences – Serious Fraud – Cognizable and Non-Bailable Nature – Twin Conditions for Bail Under Section 212(6) – Charges involved fraud of ₹4,120 crores through shell companies – Accused siphoned funds via forged documentation – Held: Section 447 offences are cognizable and attract twin bail conditions – High Court failed to consider these restrictions while granting anticipatory bail [Paras 1, 3, 24-26].

Legal Principles – When Anticipatory Bail Should Not Be Granted – Judicial Discretion Must Account for Abscondence and Public Interest – Court reiterated that anticipatory bail is an extraordinary remedy and should not be granted to accused who obstruct legal process – Cited P. Chidambaram, Jagan Mohan Reddy, Srikant Upadhyay and others to affirm that economic offences require stricter scrutiny and denial of anticipatory bail in normal circumstances [Paras 18-21, 23].

Final Decision – Appeals Allowed in 14 Cases – High Court's anticipatory bail orders quashed – Accused directed to surrender within one week – Appeals against three respondents dismissed where no NBW or proclamation was issued or where bail was granted by Special Court – No opinion expressed on merits of individual cases [Paras 6, 30-31].
 

Taxation Law – Input Tax Credit – Exemption under Section 7(c) – Prohibition under Section 13(7) – Credit Denied – Dealer claimed entitlement to input tax credit for purchases sold to manufacturer-exporters under Form-E as per exemption notification – Authorities rejected the claim citing Section 13(7) which bars credit where sales are exempt under Section 7(c) – Held: Section 13(7) imposes a clear statutory bar; no input tax credit is allowed for exempt sales to manufacturer-exporters, and interpreting the provision by legislative intent or policy cannot override express legislative language [Paras 2-3, 6-10].

Notifications and Circulars – Interpretation of Notifications dated 24.02.2010 and 25.03.2010 – No Input Tax Credit Benefit to Seller – Appellant’s reliance on these notifications and state policy to justify input tax credit claim was misplaced – Notifications were intended to facilitate manufacturer-exporters and not seller-dealers – The clear wording of Section 13(7) overrides any inferred policy advantage [Paras 3, 9-10].

Statutory Interpretation – Tax Statutes – Plain Meaning Rule – No Role of Legislative Intent – Court held that in the context of taxing statutes, legislative intent or policy is not a valid ground if language is clear – Section 13(7) unambiguously denies input tax credit for transactions exempt under Section 7(c), making dealer’s claim unsustainable in law [Para 9].

Final Decision – Civil Appeal Dismissed – Supreme Court upheld decisions of Assessing Authority, Appellate Authority, Tribunal, and High Court – No entitlement to input tax credit for dealer due to express statutory bar under Section 13(7) of UP VAT Act – Appeal dismissed with no order as to costs [Para 10].

Service Law – Reservation for Women – Horizontal Reservation under Punjab Civil Services Rules, 2020 – Post Validly Reserved for Women – The appellant challenged the Division Bench's order remanding the matter regarding the validity of reservation of a DSP post under the 'SC Sports (Women)' category – Held: The advertisement reserving the post was validly issued under the 2020 Rules and could not be altered retrospectively based on later-issued roster points – Once selection process began, rules of the game could not be changed midstream [Paras 15-17, 21-24].

Rosters and Amendments – Roster Points Issued Post Advertisement – No Retrospective Application – The private respondent sought quashing of the women's reservation based on the roster introduced after the advertisement’s closing date – Held: Roster system introduced post-deadline cannot affect a concluded process – Amendments to the Rules could not apply retrospectively unless explicitly stated [Paras 13, 16, 24].

Recruitment Process – Changing Eligibility Midway – Prohibited – Once Advertisement No. 14 dated 11.12.2020 was issued with clear eligibility and reservation criteria, no post-facto amendment could alter its terms – Supreme Court reaffirmed the principle that recruitment rules cannot be changed after the process begins, relying on Constitution Bench decision in Tej Prakash Pathak v. High Court of Rajasthan, (2025) 2 SCC 1 [Paras 21-22].

Final Decision – Appeal Allowed – Supreme Court upheld the learned Single Judge's order confirming the validity of the DSP (SC Sports – Women) reservation – Set aside Division Bench’s remand order – Directed compliance within three weeks [Paras 25].

PIL - Food Labelling – Front-of-Pack Nutrition Labelling (FOPNL) – Mandamus Sought – Direction Issued - The petitioner sought implementation of Front-of-Package Warning Labels on packaged foods to enhance consumer awareness of high sugar, salt, and fat content – The Union of India submitted that the Food Safety and Standards Authority of India (FSSAI) had already notified a draft regulation in 2022 proposing the Indian Nutrition Rating (INR), a star-based FOPNL system, and received over 14,000 public comments – An Expert Committee was constituted to analyze the feedback and recommend changes – The Court acknowledged the steps taken and directed the Expert Committee to finalize and submit its report within three months to enable further regulatory action – Held: Petition disposed with directions for timely compliance and monitoring [Paras 1, 4–8].

Motor Accident Claim – Enhancement of Compensation – Delay in Filing Appeal – Appeal Allowed - The Supreme Court set aside the High Court’s judgment which had enhanced the compensation awarded by the Tribunal – Held: The MAC appeal filed by the minors (after attaining majority) was grossly delayed by nearly 8 years and not maintainable under law – Exemption under Section 6 of the Limitation Act applies only to suits and applications for execution of decrees, not appeals [Paras 4, 8-9, 13-14].

Limitation Act – Section 6 – Legal Disability and Appeals – No Relief for Minors Filing Late Appeal - The Court clarified that provisions granting extension of limitation on account of minority (Section 6) do not apply to appeals – Held: There can be no inferred or extended disability when the guardian actively chose not to appeal; delay not condonable under Section 5 either [Paras 9-12].

Doctrine of Procedural Autonomy – Guardian’s Strategic Decision Binding – Finality of Award Upheld - The father, who was natural guardian and party in earlier proceedings, chose not to appeal against the Tribunal’s award – The Supreme Court held that this conscious decision bound the minors – No ground to reopen the case after years of delay [Paras 13-14].

Decision – High Court Judgment Set Aside – Appeal by Insurance Company Allowed - The Supreme Court allowed the insurer’s appeal and held the MAC appeal filed by the children was not maintainable – High Court’s enhanced compensation award was set aside [Paras 13-14].

Anticipatory Bail – Theft of Judicial File – Disclosure Statement by Co-Accused – Bail Granted - FIR was filed alleging theft of a judicial file involving multiple co-accused – Appellant was not named in FIR but implicated through co-accused's disclosure – High Court denied anticipatory bail – Supreme Court noted appellant had joined investigation and that the probe remained incomplete for over two years – Held: Custodial interrogation not required – Interim protection from arrest made absolute and anticipatory bail granted [Paras 2, 5–11].

Closure Report – Magistrate's Rejection – No Interference – Investigative Continuity Maintained - Closure report filed by police was rejected by Magistrate with directions for continued investigation – Supreme Court refused to interfere, allowing investigation to proceed – Appellant's prayer to quash Magistrate's order declined [Paras 8–9, 20].

Proclaimed Offender Declaration – Order Quashed – Due to Bail Grant - Magistrate’s order declaring appellant a proclaimed person under Section 174A IPC set aside as Supreme Court granted anticipatory bail – Held: Appellant no longer required to be declared absconding – Related appeal allowed [Para 20].

Bar Council Proceedings – Misuse Warning – Conditional Liberty - Court noted potential misuse of position by appellant (a lawyer) – Directed that in case of future interference with justice, Bar Council may suspend his license after due procedure [Para 14].

Employment Law - Reservation in Public Employment – Requirement of Valid Certificate by 
Cut-Off Date – Rejection Upheld – Appellants were excluded from interview round for Civil Judge Cadre due to OBC-NCL/MBC-NCL/EWS certificates not being valid as on application cut-off date (31.08.2021) – Held: Advertisement required valid certificate as per rules— Relevant circulars and judicial precedents mandate certificate to be issued within one year or supported by affidavit for older documents—None of the appellants fulfilled these conditions [Paras 3–6, 33–36, 40]. 
 
Eligibility Cut-Off – Last Date of Application is Decisive – No Arbitrary Action – Court affirmed principle from Bhupinderpal Singh and Rekha Chaturvedi that eligibility for reservation must be determined by last date of application if rules are silent—Subsequent Notice of 04.08.2022 clarified cutoff and was not arbitrary but in line with state policy and prior case law [Paras 27–30, 36]. 
 
Validity of Certificates – OBC-NCL Valid for One Year – Extendable to Three Years with Affidavit – Circulars Enforced – Government circulars required OBC/MBC-NCL certificates to be renewed annually or supported by affidavit up to 3 years—Appellants failed to produce either within stipulated time—Held: Failure to comply with known policy rules disentitles candidates to reservation benefit [Paras 20–22, 33–35, 37]. 
 
Precedents Distinguished – Ram Kumar Gijroya Not Applicable – No Delay by Authorities – Court clarified that Ram Kumar Gijroya involved delay in issuance by competent authority despite timely application—In this case, appellants had neither applied in time nor held valid certificates—Hence, no parity [Para 38]. 
 
Decision – Appeals Dismissed – High Court Judgment Affirmed – No Discretionary Relaxation Permitted in Absence of Rule-Based Authority – No Costs – Pending Applications Also Disposed [Paras 39–42].