Constitutional Law – Article 131 Jurisdiction – State of West Bengal challenges the authority of the CBI to register cases post-withdrawal of consent under Section 6 of the DSPE Act – Issue involves interpretation of Article 131 and its limitations – Supreme Court's original jurisdiction exclusive and includes disputes involving the existence or extent of a legal right [Paras 1-3, 30-31, 44-51, 84].

Legal Framework – Supreme Court Rules, 2013 – Order XXVI Rule 6 applicable for rejecting plaints that do not disclose a cause of action or are barred by law – Provisions analogous to Order VII Rule 11 of the CPC – Duty of court to examine averments in plaint as a whole and reject plaints even without defendant's intervention [Paras 22-29].

Maintainability of Suit – Preliminary Objections – Union of India contends suit is barred due to ongoing appeals under Article 136 – Argument that Article 131 suits should not involve private parties or duplicate issues pending elsewhere – Supreme Court rejects these contentions, affirming maintainability of suit for adjudication on merits [Paras 4-14, 32-43, 67, 78-79, 85].

Federalism – Consent Withdrawal and CBI Jurisdiction – West Bengal's consent under Section 6 of DSPE Act withdrawn – CBI's authority to register cases post-withdrawal questioned – Legal implications on federal structure and state's sovereign powers emphasized – Supreme Court examines constitutional framework and legislative intent behind Sections 5 and 6 of the DSPE Act – Reiterates need for central agencies to respect state jurisdiction absent explicit consent or court order [Paras 6-21, 52-66, 68-77].

Interpretation of Article 131 – Legal Rights vs. Political Disputes – Dispute must involve legal rights, not merely political disagreements – Supreme Court distinguishes between genuine federal disputes and political conflicts – Emphasizes that Article 131 intended to address substantial questions impacting legal rights of states versus central government authority [Paras 108-117].

Decision: Preliminary objections dismissed – Suit to proceed on merits – Supreme Court emphasizes necessity to address core constitutional issues regarding federalism and state immunity from central overreach [Paras 84-85].

Criminal Law – Murder Conviction – The appellant was convicted for the murder of Muthu due to an altercation over non-payment of electricity bills. The prosecution relied on eyewitness testimony to establish that the appellant attacked the deceased with a billhook, causing fatal injuries. The Supreme Court upheld the conviction under Section 302 IPC, rejecting the defense's argument that the act was not intentional and occurred in the heat of passion [Paras 1-8].

Eyewitness Testimony – Reliability – The Supreme Court found the testimonies of the eyewitnesses credible, noting that minor discrepancies in the timing did not undermine the overall reliability of their accounts. The Court emphasized the consistency of the witnesses' statements regarding the appellant's assault on the deceased [Paras 6-7].

Intention and Provocation – The Court ruled that the appellant's actions demonstrated a clear intention to cause serious harm, as evidenced by his retrieval of the weapon from his house. The appellant's defense that the incident occurred due to sudden provocation was dismissed, as the deceased had come to intervene and not to provoke [Paras 7-8].

Medical Evidence – The post-mortem report confirmed severe injuries, including brain damage, leading to the deceased's death due to shock and bleeding. This medical evidence supported the conviction under Section 302 IPC [Para 7].

Decision: Appeal dismissed – Conviction and sentence affirmed.

Land Acquisition – Compliance with Section 5A – The Supreme Court analyzed whether the procedures under Section 5A of the Land Acquisition Act, 1894, were duly followed. It emphasized that the Collector must provide an opportunity for personal hearing to the objectors and consider their objections with due application of mind. The failure to do so can vitiate the acquisition proceedings. In this case, the High Court's finding of non-compliance was based on the ineffective notice to the landowners and mechanical rejection of objections, which the Supreme Court upheld for those who filed objections but did not accept compensation [Paras 13-24, 36-43].

Locus Standi – Acceptance of Compensation – The Court held that landowners who accepted compensation without protest waived their right to challenge the acquisition process. It also ruled that subsequent purchasers of the land post-Section 4 notification do not have locus standi to challenge the acquisition, as the title acquired is encumbered and void against the government. Therefore, objections by such purchasers were not entertained [Paras 25-35].

Intimation and Personal Hearing – The Supreme Court reiterated the necessity of serving notices to objectors, ensuring their right to personal hearing. The absence of proper notice and the ensuing failure to provide a meaningful hearing render the acquisition process non-compliant with Section 5A. The Court underscored the principle of audi alteram partem and statutory presumption in favor of regular performance of official acts unless convincingly rebutted [Paras 38-43].

Decision: Appeals partly allowed – The acquisition proceedings quashed for landowners who filed objections and did not accept compensation – Appeals of landowners who accepted compensation or purchased land post-Section 4 notification dismissed.

Land Acquisition – Compensation – Appellant owned land acquired for construction of a flood protection wall – Land Acquisition Officer awarded Rs. 5,61,000 per hectare – Appellant claimed higher compensation of Rs. 500 per sq. ft. – Reference Court enhanced compensation; High Court reversed and ordered refund with interest – Supreme Court held appellant entitled to rental compensation from the date of possession (15.11.1998) to the date of the award (04.08.2000) @ 8% of the enhanced compensation [Paras 1-80] ​​.

Civil Procedure – Entitlement to Rental Compensation – Supreme Court reiterated entitlement based on Government Resolutions – High Court's order directing appellant to refund excess amount withdrawn was set aside – Appellant allowed to withdraw compensation as per enhanced award by Reference Court [Paras 75-80]​​ .

Decision: Appeals allowed in part – High Court’s order set aside – Appellant entitled to rental compensation @ 8% of the enhanced amount from 15.11.1998 to 04.08.2000 – No order as to costs [Paras 81-82] .

Land Acquisition – Quantum of Compensation – The appeals arose from a dispute regarding compensation for land acquired by NOIDA. The Supreme Court evaluated the determination of fair market value and enhancement of compensation from INR 222-233 per sq. yd. to INR 449 per sq. yd. by the High Court. The Court utilized the principle of guesstimation, emphasizing the need for a holistic view considering all relevant factors [Paras 1-22, 34-44]​​.

Guesstimation – Factors to Consider – The Court identified three primary factors for guesstimation: characteristics of the land, future potentiality, and market sentiment. It stressed that valuation is influenced by land's location, potential uses, and surrounding development [Paras 22-44]​​.

Maintainability of Miscellaneous Applications – The Court addressed the maintainability of applications seeking parity with Bir Singh (supra). Despite procedural lapses, it invoked Article 142 of the Constitution to ensure equitable relief, enhancing compensation to INR 403 per sq. yd. for all landowners [Paras 45-49]​​.

Decision: Appeals partly allowed – Compensation rate enhanced to INR 403 per sq. yd. – Appeals against enhanced compensation of INR 449 per sq. yd. allowed in part, reducing it to INR 403 per sq. yd. – Miscellaneous Applications allowed – Enhanced compensation to be deposited within eight weeks [Paras 54-56]​​.

Civil Procedure – Impleadment of Transferee Pendente Lite – The appellant purchased land during the pendency of a suit for declaration and injunction regarding the same land. The trial court dismissed his application for impleadment, a decision upheld by the High Court based on the doctrine of lis pendens under Section 52 of the Transfer of Property Act, 1882. The Supreme Court reversed this decision, holding that the doctrine of lis pendens does not render the transfer void but subservient to the rights of the parties in the litigation. The Court emphasized that impleadment is discretionary and necessary to protect the transferee's interests, especially where collusion or failure to defend by the transferor is suspected [Paras 1-22]​​.

Doctrine of Lis Pendens – The Supreme Court clarified that the doctrine does not nullify the transfer but subjects it to the outcome of the pending litigation. The impleadment of a transferee pendente lite is permissible even with notice of the pending suit, as long as it helps protect the transferee's rights and interests [Paras 16-19]​​.

Collusion and Delay – The Court found a substantial delay in the filing of the underlying suit and potential collusion among the original parties, all relatives, which warranted the inclusion of the appellant to ensure a fair trial. The appellant's interest in the property, represented by a registered sale deed, further justified his impleadment [Paras 20-21]​​.

Decision: Appeal allowed – Impugned orders set aside – Appellant to be impleaded as a party-defendant in the underlying suit [Paras 22-23]​​.

Criminal Law – Maintenance for Divorced Muslim Women – Appeal challenging reduction of interim maintenance from INR 20,000 to INR 10,000 per month – Appellant argued applicability of the Muslim Women (Protection of Rights on Divorce) Act, 1986 over CrPC – High Court upheld maintainability of maintenance under CrPC – Supreme Court affirmed, highlighting the continued existence of rights under both statutes, emphasizing the harmonious construction of the laws [Paras 1-41].

Section 125 CrPC vs. 1986 Act – Interpretation and Applicability – Court reiterated that Section 125 CrPC remains applicable to divorced Muslim women – The 1986 Act provides additional and not exclusive remedies – Clarified that rights under CrPC are independent and can be invoked simultaneously [Paras 10-37].

Doctrine of Stare Decisis – Supreme Court bound by previous decisions – Reiterated principles from Danial Latifi and Shamim Bano cases – Upheld that divorced Muslim women are entitled to maintenance under CrPC despite provisions of 1986 Act [Paras 24-37].

Decision – Appeal dismissed – High Court’s order reducing interim maintenance upheld – Appellant allowed to seek state government remission considering mitigating factors and time served [Para 40-41].

Independence of Administrative Bodies – Autonomy and non-interference are essential for the effective functioning of administrative bodies. These bodies must be free from undue interference to carry out their specialized tasks impartially and efficiently [Para 1].

Right to Information Act – Authority to Frame Regulations – Central Information Commission (CIC) has the authority under Section 12(4) to frame the Central Information Commission (Management) Regulations, 2007 – This authority is implied within the broad powers of superintendence, direction, and management of the CIC’s affairs, which includes the formation of benches for efficient case handling [Paras 9-24].

High Court’s Narrow Interpretation – The High Court’s restrictive reading of the RTI Act, focusing on the absence of explicit provisions for the formation of benches, overlooked the broad powers vested in the CIC. A purposive interpretation aligns with the objective of the RTI Act to promote transparency and accountability [Paras 16-22].

Principle of Non-Interference – Emphasized the importance of non-interference in the administrative functions of the CIC for maintaining its integrity and efficacy. The ability to form benches and allocate work among Information Commissioners is crucial for the CIC to manage its workload effectively [Paras 23-24].

Decision: Appeal allowed – Judgment of the Delhi High Court set aside – Chief Information Commissioner’s powers to frame Regulations and constitute Benches of the Commission upheld as within the ambit of Section 12(4) of the RTI Act [Para 25].

Impleadment – Transferee pendente lite – Appellant sought impleadment in an ongoing suit related to the property purchased during litigation – High Court dismissed the impleadment application citing Section 52 of the Transfer of Property Act, 1882 – Supreme Court held that Section 52 does not void such transfers but makes them subservient to the litigation outcome – Appellant’s right to defend his interest recognized [Paras 16-17].

Doctrine of Lis Pendens – Scope and application – High Court erroneously applied Section 52 of the Transfer of Property Act to nullify the appellant’s sale deed – Supreme Court clarified that lis pendens merely subordinates the purchaser’s rights to the outcome of the pending suit and does not void the transaction [Para 17].

Discretionary Impleadment – Transferees pendente lite with notice of litigation – Supreme Court emphasized the discretionary nature of impleadment to protect purchasers’ interests, especially to prevent possible collusion between the original parties – Reiterated that impleadment can be allowed even without the transferee’s prior court permission [Paras 18-19].

Bona Fide Purchaser – Not a precondition for impleadment – Supreme Court held that knowledge of pending litigation does not bar impleadment – Emphasized the necessity to protect transferees’ interests where there is a potential collusion between parties and considerable delay in the filing of the underlying suit [Paras 19-20].

Decision – Appeal allowed – Impugned order and the trial court’s order set aside – Appellant directed to be impleaded as a party-defendant in the ongoing suit – Recognized the appellant’s registered sale deed and disputed question of fact regarding consideration payment to be determined by the trial court [Para 22].