Civil Procedure – First Appeal – Scope and Duty of First Appellate Court – Section 96 CPC provides for filing an appeal from a decree passed by a court of original jurisdiction – Order 41 Rule 31 mandates that the judgment of the appellate court must state points for determination, decisions thereon, and reasons for decisions – Appellate court’s failure to comply with these requirements leads to infirmity in the judgment – High Court erred by not considering evidence and reasoning provided by the Trial Court, and by failing to form points for determination [Paras 26-30]​​.

Property Law – Ancestral and Self-Acquired Property – Appellant and respondent, as children of deceased Puttanna, were entitled to shares in the property acquired by their father – Property cultivated by Puttanna and granted occupancy rights posthumously is heritable – Appellant entitled to 1/2 share, not 1/4 share as modified by the High Court – High Court's judgment set aside, Trial Court’s decree restored [Paras 9-25, 31]​​.

Decision – Appeal Allowed – High Court’s judgment set aside – Trial Court’s decree restored, affirming appellant’s 1/2 share in property described at item no. 3 of Schedule 'A' – Final decree proceedings to be conducted accordingly – No order as to costs [Paras 31-32]​​.

NEET-PG Counselling – Conduct of Special Stray Round – Petitioners sought a Special Stray Round of counselling for the remaining 1456 vacant seats after NEET-PG-2021 counselling rounds – Supreme Court held that the admission process must have an endpoint and must adhere to a strict schedule – Emphasized that any deviation could compromise medical education standards and public health – Found that non-clinical seats typically remain vacant annually and re-affirmed no scope for mid-session admissions [Paras 1-12].

Procedural Adherence – Adherence to Time Schedule – Court noted the existing nine rounds of counselling already conducted, fulfilling the mandated procedure – Further round was deemed unnecessary and impractical, as it could interfere with NEET-PG-2022 admissions – Affirmed previous decisions highlighting the importance of maintaining the time schedule for medical admissions to ensure academic and professional integrity [Paras 10.1-10.7].

Public Interest and Education Quality – Balancing Seats and Quality – Court recognized the need to balance seat occupancy with quality education – Determined that endless counselling rounds would disrupt educational timelines and lower the standard of medical education – Emphasized that maintaining a strict schedule is crucial for the credibility and functionality of medical education systems [Paras 10.4-10.6].

Decision – Petitions Dismissed – Held – Petitions for conducting a Special Stray Round of counselling for NEET-PG-2021 dismissed – No order as to costs – Reiterated that adherence to established counselling schedules is essential for maintaining order and standards in medical education [Paras 11-12].

Custody of Child – Welfare of Minor – The paternal grandparents sought custody of their minor grandson, whose parents passed away during the Covid-19 pandemic – High Court had handed over custody to the maternal aunt – Supreme Court reversed this decision, emphasizing the emotional and loving care provided by paternal grandparents – Grandparents' ability to provide a stable environment and the minor's expressed preference to stay with them were significant factors – Court directed that custody remain with the paternal grandparents while granting visitation rights to the maternal aunt [Paras 1-12].

Guardianship – Emotional Bond and Stability – The Court highlighted that grandparents often provide deep emotional support and stability to grandchildren – Rejected the notion that age and financial independence alone could determine the best interest of the child – Court acknowledged that the minor showed a willingness to stay with grandparents during the interim custody period [Paras 7.1-7.2].

Decision – Appeal Allowed – Held – High Court's order to give custody to the maternal aunt was set aside – Custody granted to paternal grandparents with visitation rights to the maternal aunt – Directed both families to act jointly and cordially for the child's welfare – Emphasized the need to consider the minor's emotional and educational well-being, ensuring regular contact with both families [Paras 8-12].

Insolvency Law – Withdrawal of CIRP – The appellant sought to withdraw the Corporate Insolvency Resolution Process (CIRP) of Siva Industries under Section 12A of the IBC after the Committee of Creditors (CoC) approved a settlement plan with a 94.23% majority – NCLT and NCLAT rejected the withdrawal application and directed liquidation – Supreme Court emphasized the paramount importance of the commercial wisdom of the CoC in such decisions, stating that adjudicating and appellate authorities should not interfere unless the decision is capricious or irrational [Paras 1-28].

Commercial Wisdom of CoC – Paramount Status – The Court reiterated that the commercial decisions of the CoC should not be subject to judicial review unless found to be arbitrary, capricious, or de hors the law – The Court upheld the decision of the CoC to approve the settlement plan and allowed the withdrawal of CIRP, aligning with the principles of minimizing judicial intervention in commercial decisions under the IBC framework [Paras 21-28].

Decision – Appeals Allowed – Held – Orders of NCLT and NCLAT set aside – Application for withdrawal of CIRP allowed – Emphasized the importance of adhering to the commercial wisdom of CoC and reducing judicial intervention in insolvency proceedings [Paras 28-29].

Environmental Protection – Ecologically Sensitive Zones (ESZ) – Supreme Court directed a minimum ESZ of 1 kilometer around all protected forests, national parks, and wildlife sanctuaries, with existing activities allowed to continue subject to guidelines – Emphasized the importance of a buffer zone to protect wildlife and forest ecosystems – For Jamua Ramgarh sanctuary, subsisting activities allowed within 500 meters, but new activities require adherence to the 1-kilometer ESZ norm [Paras 1-20].

Prohibited and Regulated Activities – Guidelines Adherence – The Court mandated strict compliance with the Guidelines of 9th February 2011 for activities within the ESZ – Prohibited activities include commercial mining, setting up of industries causing pollution, and major hydro-electric projects – Certain activities like tree felling, commercial use of water resources, and establishment of hotels to be regulated [Paras 6-7, 9, 32].

Role of State – Public Trust Doctrine – The Court highlighted the State's role as a trustee of natural resources, emphasizing sustainable development – Reiterated the need for States to protect forests while balancing economic activities – Directed State and Union Territories' authorities to ensure compliance and report on subsisting structures within ESZs [Paras 25, 28-29].

Decision – Applications Allowed/Dismissed – Held – Directions issued for maintaining ESZ and regulating activities within these zones – Rejected claims for resuming mining activities within prohibited areas of the Jamua Ramgarh sanctuary – Allowed implementation of the Guidelines for ESZ across all protected areas – Emphasized the need for compliance with environmental protection laws and sustainable development principles [Paras 34-35, 42].

Ancient Monuments and Archaeological Sites – Permissible Construction – The construction activities undertaken by the State of Odisha within the prohibited area of Shree Jagannath Temple for providing basic amenities like toilets, cloak rooms, and electricity rooms – Supreme Court upheld these constructions, stating that they do not fall under the definition of "construction" as per Section 2(dc) of the Act and are necessary for public convenience – Court emphasized the harmony between Section 2(dc) and Sections 20C and 20D, permitting essential public facilities even within the prohibited area [Paras 30-43].

Interpretation of Statutes – Legislative Intent – The Court highlighted that legislative intent behind excluding certain constructions from the definition of "construction" under Section 2(dc) was to allow essential services for public convenience – Emphasized that statutory provisions should be read harmoniously to avoid rendering any section otiose or redundant [Paras 41-42].

Public Interest – Development of Heritage Sites – Supreme Court reiterated its previous directions from the Mrinalini Padhi case for providing modern amenities like toilets and cloak rooms in the vicinity of Shree Jagannath Temple – The Court recognized the necessity of such facilities for the welfare of devotees and aligned with the broader goal of developing Puri as a world heritage city [Paras 21-28].

Decision – Appeals Dismissed – Held – The construction activities challenged by the appellants were found to be in accordance with the statutory provisions and necessary for public welfare – Appeals dismissed with costs – The Court criticized the misuse of public interest litigations for personal or publicity interests, emphasizing the need to curb such practices [Paras 57-60].

Criminal Law – Sole Witness Testimony – The conviction of the appellants was based on the sole testimony of Amol Singh (P.W.6) – Supreme Court held that when a witness is "wholly reliable," conviction or acquittal can be based on such testimony – Conversely, if a witness is "wholly unreliable," neither conviction nor acquittal can be based on their testimony – The evidence of Amol Singh (P.W.6) was found to be "wholly unreliable" due to contradictions and the testimonies of other witnesses – The Court emphasized that corroboration is necessary when the testimony falls in the third category of being neither wholly reliable nor wholly unreliable [Paras 12-22].

Medical Evidence and Motive – The Court noted that medical evidence only established that the death was homicidal and could not corroborate the witness’s claim of having witnessed the incident – It also reiterated that establishing motive alone is insufficient for conviction if the primary evidence is unreliable [Paras 22-23].

Decision – Appeals Allowed – Held – The convictions and sentences imposed by the High Court and the Trial Court were set aside – The appellants were acquitted of all charges and ordered to be released forthwith if not required in any other case [Paras 24-25].

Criminal Law – Multiple Dying Declarations – The appellant was convicted for the murder of his wife based on her dying declarations – The Supreme Court noted that while dying declarations hold significant evidentiary value, their reliability must be scrutinized, especially when there are inconsistencies – Court found substantial procedural lapses in recording the dying declarations, including the absence of a doctor’s certification of the deceased's mental fitness – The oral dying declarations made to interested witnesses (father and mediator) were inconsistent with the written declarations and thus unreliable [Paras 11-37].

Legal Principles – Dying Declarations – Emphasized that a dying declaration, if found reliable and voluntarily made, can form the basis of conviction even without corroboration – However, in cases of multiple dying declarations with discrepancies, the court must carefully scrutinize each declaration and rely only on those consistent with other evidence – Reiterated the need for dying declarations to be free from tutoring and made in a fit state of mind [Paras 15-24].

Decision – Appeal Allowed – Held – The High Court’s judgment upholding the trial court’s conviction was set aside – The Supreme Court acquitted the appellant, granting him the benefit of doubt due to the unreliable and contradictory dying declarations – Directed the appellant’s immediate release unless required in other cases [Paras 38-39].

Tribunals – Territorial Jurisdiction – The appellant challenged the orders of the NGT Principal Bench, New Delhi, which prohibited further construction at Rushikonda Hill and rejected the application for vacating the stay – Supreme Court held that the NGT, being a Tribunal, is subordinate to the High Court within the territorial jurisdiction of the High Court – Court emphasized that in case of conflicting orders between constitutional courts and statutory tribunals, the orders of the constitutional courts would prevail – The continuation of proceedings before the NGT was found inappropriate when the High Court was already in seisin of the matter [Paras 1-13].

Conflict of Jurisdiction – High Court vs. NGT – The Court noted that the High Court had already passed an interim order permitting construction in accordance with the permissions from the Ministry of Environment, Forest and Climate Change, and the existing master plan – The NGT’s orders were in conflict with the High Court’s directions, leading to an anomalous situation for the authorities – The proceedings before the NGT were quashed and parties directed to approach the High Court for appropriate orders [Paras 3-14].

Environmental Considerations – Balance Between Development and Environment – While acknowledging the need for economic development, the Court emphasized the importance of safeguarding the environment for future generations – Directed the High Court to consider the report of the Experts Committee constituted by the NGT and decide accordingly [Paras 15-20].

Decision – Appeals Allowed – Held – Proceedings before the NGT quashed – Parties directed to seek appropriate orders from the High Court – Interim construction permitted only on previously constructed and demolished areas until the High Court’s further decision – No opinion on merits expressed by the Supreme Court, leaving all issues to be raised before the High Court [Paras 14-21].