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].

Constitutional Law – Maintainability of Writ Petition – Determination of whether the Army Welfare Education Society qualifies as a “State” under Article 12 of the Constitution – Supreme Court analyzes the nature of the society and its functions, concluding that it does not meet the criteria for a “State” – Writ petition under Article 226 is not maintainable against purely private educational institutions not receiving government funds [Paras 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22].

Service Law – Doctrine of Legitimate Expectation – Staff members had a legitimate expectation that their service conditions would not be altered to their detriment upon transition to new management – Supreme Court highlights that while the doctrine of legitimate expectation is applicable, it cannot override the lack of statutory backing for enforcing the same against a private body [Paras 27, 28].

Public Law – Nature of Public Duty – Discussion on whether the imparting of education by the appellant society constitutes a public duty – Supreme Court reiterates that purely private educational institutions performing public functions do not automatically become subject to writ jurisdiction under Article 226 [Paras 29, 30, 31, 32, 33, 34, 35, 36, 37].

Decision: Appeals allowed – High Court judgment set aside – Writ petitions dismissed – Supreme Court rules that the appellant society does not qualify as a “State” under Article 12 and is not amenable to writ jurisdiction under Article 226 [Paras 38, 39, 40].

Civil Law – Revocation of Power of Attorney – Implied Revocation – Appellant and respondent No. 1 (sisters) purchased property together; appellant later executed a power of attorney (PoA) in favor of respondent No. 1. Appellant retired and returned to India, participating in a sale deed with respondent No. 1. Supreme Court held that this participation amounted to an implied revocation of the PoA, invalidating a subsequent sale deed executed by respondent No. 1 alone in favor of her husband, respondent No. 2 [Paras 1-25].

Property Law – Validity of Sale Deed – Non-Receipt of Consideration – The sale deed executed by respondent No. 1 in favor of respondent No. 2 lacked consideration. The Supreme Court confirmed the trial court's finding that the sale deed was void ab initio due to non-receipt of consideration, affirming the appellant’s half-share in the property [Paras 23-24].

Limitation – Suit for Declaration – The appellant filed the suit within the limitation period, as the right to sue first accrued when she gained knowledge of the impugned sale deed. The Supreme Court rejected the respondent’s plea that the suit was time-barred [Paras 15-15.1].

Decision: Appeal allowed – Judgment and decree of the trial court confirmed – Trial court directed to explore the possibility of determining the market value of the appellant's half share in the property and proceed accordingly. If consensus on market value is not reached, the trial court to proceed with final decree proceedings and execution in accordance with the law [Paras 25-26].

Consumer Law – Definition of Consumer – Appeals centered on whether vehicles purchased by a company for the use of its directors fall within the definition of "commercial purpose" under Section 2(1)(d) of the Consumer Protection Act – National Commission held that purchases for the personal use of directors did not amount to "commercial purpose" – Supreme Court upheld this interpretation, confirming that such purchases are not for profit-generating activities and hence do not exclude the buyer from being a consumer [Paras 1-17, 26-29].

Commercial Purpose – Dominant Purpose Test – The Court reiterated that the determination of "commercial purpose" depends on the facts and circumstances of each case – Emphasized that the dominant purpose of the purchase must be examined – Purchases for personal use of directors not linked to profit generation are not considered "commercial purpose" [Paras 11-16, 29].

Defects in Goods – Deficiency in Service – Respondents-complainants reported defects in vehicles, particularly overheating issues – National Commission found the appellants liable for deficiencies in service – Supreme Court upheld the finding, directing compensation to the complainants [Paras 18-25, 30-37].

Unfair Trade Practice – Misrepresentation – National Commission found that appellants misrepresented the safety features of the vehicles, constituting an unfair trade practice under Section 2(1)(r) of the Consumer Protection Act – Supreme Court agreed, awarding compensation for unfair trade practice [Paras 31, 34, 39].

Decision – Appeals Partly Allowed and Dismissed – Supreme Court modified the National Commission's order to permit the respondent to retain the vehicle and directed the appellant to refund a reduced amount considering the long usage of the vehicle – Other appeals dismissed, confirming the National Commission's orders on deficiencies and unfair trade practices [Paras 40-40(II)].

Civil Procedure – Inherent Powers of Court – Admission of Insufficiently Stamped Document – Trial court admitted a General Power of Attorney (GPA) as evidence without objection, which was later challenged for being insufficiently stamped. Supreme Court held that the trial court can recall the admission of such a document using inherent powers under Section 151 of the CPC, even if initially admitted without judicial determination. The court must ensure documents comply with the stamp duty requirements to prevent fiscal loss to the state [Paras 1-22].

Stamp Duty – Examination and Impounding of Instruments – GPA insufficiently stamped; trial court admitted it without judicial determination. Supreme Court emphasized the mandatory nature of Sections 33 and 34 of the Karnataka Stamp Act, 1957, requiring judicial scrutiny of stamp duty compliance, regardless of objections from parties. Absence of such scrutiny permits the court to revisit the admission of the document to enforce stamp duty obligations [Paras 10-14, 18-22].

Admissibility of Document – Judicial Determination Requirement – Admission of a document in evidence without judicial consideration of its stamp duty sufficiency is void. Supreme Court clarifies that without judicial determination at the time of admission, Section 35 of the Karnataka Stamp Act, 1957, barring further questions on stamp duty sufficiency, does not apply [Paras 12-16, 19].

Decision: Appeal allowed – High Court order set aside – Trial court's order restored, directing the respondent to pay deficit stamp duty and penalty. Trial court to proceed expeditiously with the civil suit [Paras 22-23].

Custodial Death – Conviction and Sentencing – Appellant (A1) and co-accused (A2) were convicted by the trial court under Section 302 read with Section 114 IPC for causing the death of the deceased, Jeeva, through physical violence in police custody – High Court altered the conviction to Section 304 Part I IPC, sentencing A1 to eight years rigorous imprisonment and a fine – Supreme Court examines the evidentiary inconsistencies and the medical evidence presented, concluding that the prosecution failed to prove the guilt of the accused beyond reasonable doubt [Paras 1-52].

Evidence – Witness Reliability – Testimonies of eyewitnesses Selvin Prabhakar (PW-1) and Dhanlakshmi Vaiyapuri (PW-2), sisters of the deceased, found inconsistent and unreliable – Witnesses’ conduct deemed unnatural and contrary to expected human behavior – Their delayed complaint and failure to inform their advocate about the custodial torture immediately raised doubts about their credibility [Paras 20-31].

Medical Evidence – Age of Injuries – Medical Jurist (PW-9) conducted postmortem and testified that injuries were fresh and occurred within six to eight hours of death, contradicting the prosecution's timeline of custodial torture – Expert witness (PW-10) failed to conclusively support the prosecution's case – The medical evidence suggested the possibility of injuries being inflicted while the deceased was in Sabarmati Central Jail rather than police custody [Paras 32-39, 46].

Motive and Circumstantial Evidence – Prosecution's theory of motive found implausible – Absence of evidence showing specific intent or reason for singling out the deceased for torture – Court noted that the co-accused Anna Dorai, who was also in custody, suffered no injuries, further weakening the prosecution's case [Paras 49-50].

Decision: Appeal allowed – Conviction and sentence set aside – Both accused acquitted of charges under Sections 302, 304 Part I read with Section 114 IPC – Supreme Court directs the acquittal of A1 and A2, noting the prosecution's failure to provide convincing and reliable evidence [Paras 50-53].