Service Law – Discharge for Suppression of Information – RPF Recruitment – Appellant discharged for not disclosing past criminal case in attestation form – Case was trivial, appellant acquitted honorably – Competent authority failed to consider the nature of post, duties, and triviality of case [Paras 1-16].

Judicial Precedents – Avtar Singh v. Union of India – Summarized principles for suppression of material information – Trivial cases and clean acquittals should be considered objectively [Paras 12-18].

Nature of Post and Duties – Importance of Context – Suitability for the post must consider the nature of the role and duties – Blanket discharge for all types of suppression deemed arbitrary [Paras 17-18].

Decision: Appeal allowed – Held – Discharge order dated 24th April 2015 and review order dated 23rd December 2021 quashed – Appellant to be reinstated as Constable with notional benefits including pay, seniority, and other consequential benefits – No arrears of salary for the period not served – Orders to be executed within one month [Paras 19-20].

Criminal Law – Furlough – Appellant serving life imprisonment for the remainder of his natural life without remission or parole sought furlough – Rejection based on the presidential order restricting remission and parole – Supreme Court held that the right to seek furlough is independent of the restrictions on remission and parole – Directed authorities to reconsider furlough application [Paras 1-19].

Good Conduct – Incentive – Furlough granted as an incentive for good conduct – Eligibility based on maintaining good conduct and fulfilling criteria under Delhi Prison Rules, 2018 – Presidential order did not prohibit furlough, only remission and parole – Good conduct and reformative approach emphasized [Paras 12-17].

Reformative Approach – Prisoners' Rights – Reformative justice underlined – Furlough serves as a motivation for maintaining discipline and good conduct in prison – Denying furlough counterproductive to reformation [Paras 15-17].

Decision: Appeal allowed – Impugned orders set aside – Appellant's furlough application to be reconsidered by authorities in accordance with law – Director General of Prisons to expedite decision within two months [Paras 18-19].

Service Law – Forest Guard Training – Appellants, forest guards who stood first in training, sought ranger training – Respondent challenged such training based on administrative orders – Supreme Court evaluated the validity and revocation of orders under the M.P. Class III (Non-Ministerial) Forest Service Recruitment Rules, 1967 [Paras 3-15].

Administrative Orders – Revocation – Court examined whether the 1977 order allowing top-performing forest guards to undergo ranger training was effectively revoked by subsequent orders – Concluded revocation only valid with proper government order in name of Governor, issued on 11.06.2012 [Paras 8-15].

Reorganisation Act – Continuity of Orders – Evaluated the continuation of undivided Madhya Pradesh orders post reorganisation – Orders continued to hold field till validly revoked – Court upheld that 1977 order remained effective until 2012 revocation [Paras 14-15].

Decision: Appeals allowed – Division Bench judgment set aside – 1977 order deemed valid until 2012 revocation – No costs awarded [Para 15].

Medical Education – Provisional Registration – Students completed clinical training online due to the pandemic – Appellant argued that clinical training must be completed in physical form – High Court's decision permitting two months of clinical training instead of three deemed insufficient – Appellant directed to frame a scheme for students to complete clinical training in India [Paras 1-25].

Clinical Training – Online Mode – Students argued completion of clinical training online due to COVID-19 – Appellant contended clinical training requires physical presence – Supreme Court upheld necessity for actual clinical training to ensure competence [Paras 10-19].

Pandemic Impact – Student Relief – Court acknowledged pandemic's impact on education – Directed appellant to frame a one-time scheme for clinical training in India – Emphasized balance between student career prospects and maintaining medical education standards [Paras 22-25].

Decision: Appeals disposed of – Appellant to create a scheme for clinical training in India within two months – Students to complete clinical training and undergo testing before provisional registration [Paras 25-26].

Waqf – Definition and Dedication – Appellant claimed a dilapidated structure as a mosque – No evidence at any point of time that the structure was being used as a mosque – No allegation or proof of dedication, user, or grant qualifying the structure as a waqf within the meaning of Section 3(r) of the Waqf Act – In absence of any proof of dedication or user, a dilapidated wall or platform cannot be conferred the status of a religious place for offering prayers/Namaaz [Paras 1-19].

Principles of Natural Justice – Compliance by State – It is always open to the State as lessor to exercise the powers conferred by the lease deed after complying with principles of natural justice and on good and sufficient grounds – Action of removal of structure upheld – Appeals dismissed [Paras 16-20].

Decision: Appeals dismissed – Structure removal upheld – The claim of the appellant regarding the structure being a mosque not substantiated – No merit found in the present appeals.

Service Law – Departmental Examination – Grace Marks – Respondent, an ST candidate, secured 43 marks in "Other Taxes" subject, below 45% required for general category – Respondent sought grace marks to qualify as a general category candidate – Tribunal dismissed application, upheld by High Court – Supreme Court held grace marks policy intended to help marginally failing candidates pass, not to switch categories – High Court decision set aside, Tribunal decision restored [Paras 2-8].

Grace Marks Policy – Interpretation – Policy aimed at enabling marginally failing candidates to pass exams, not to allow reserved category candidates to switch to general category – High Court misinterpreted policy's objective – Case of Rajesh Kumar Daria v. Rajasthan Public Service Commission not applicable [Paras 6-7].

Decision: Appeal allowed – High Court judgment quashed and set aside – Tribunal's dismissal of original application restored – No order as to costs [Para 8].

Service Law – Appointment in General Category – Two reserved category candidates having more marks than the general category candidates appointed were entitled to the appointment in the general category – Seats reserved for OBC category were required to be filled from and amongst the remaining candidates belonging to the OBC category – Exercise of powers under Article 142 of the Constitution of India observed and directed that on reshuffling, two candidates belonging to the general category shall not be removed from service as they are working since long [Paras 7-11].

Reservation Policy – Vertical and Horizontal Reservations – Distinction between vertical (social) and horizontal (special) reservations – Reserved category candidates securing higher marks than the last of the general category candidates are entitled to get seats/posts in unreserved categories – If candidates belong to reserved categories and have secured higher marks or are more meritorious, they must be considered against seats meant for unreserved candidates [Paras 8.1-8.6].

Judicial Review – Balance and Equity – Ensuring no disruption in the service of existing general category employees while accommodating eligible reserved category candidates – Adjusting seniority and service benefits accordingly [Para 9].

Decision: Appeal dismissed – High Court judgment upheld – Directed that reserved category candidates having more marks than the general category candidates appointed are entitled to the appointment in the general category – Observed that on reshuffling, two candidates from the general category already appointed shall not be removed from service – Respondent No.1 entitled to seniority from the date the general category candidates having lesser marks than the aforesaid two reserved category candidates were appointed [Paras 11-12].

Municipal Corporation Act – Land Acquisition – Appellant challenged notices for land acquisition under Section 299 for road widening – Claimed previous compensation not paid, lack of Central Government sanction, and procedural non-compliance under Section 297 – High Court upheld notices, confirmed regular line fixed in 1988 – Supreme Court dismissed appeal, upheld High Court's decision, directed compensation processing if not already paid [Paras 1-15].

Section 299 – Sanction Requirement – Appellant, a public limited company, not entitled to Central Government sanction – Distinction between corporations established by law and incorporated under the Companies Act emphasized – Appellant not covered under Section 299(2) for requiring sanction [Paras 10-11].

Section 297 – Regular Line of Street – High Court found regular line fixed in 1988 after following procedure – Appellant's earlier land surrender consistent with established line – Argument on procedural lapse not supported [Paras 12-13].

Public Interest – Traffic Management – Importance of maintaining regular street line for public interest and traffic management in congested areas highlighted – No interference warranted in municipal body's action [Paras 13-14].

Decision: Appeal dismissed – High Court judgment upheld – Appellant's claim for unpaid compensation to be processed if application filed within one month – No order as to costs [Para 15].

Arbitration – Group of Companies Doctrine – Non-signatory company within a group of companies bound by arbitration agreement – Factors considered: mutual intent of the parties, relationship of non-signatory to signatory, commonality of subject matter, composite nature of transaction, and performance of contract – Non-signatories may be bound on consensual theory (agency, assignment) or non-consensual basis (estoppel, alter ego) [Paras 1-33].

Arbitration Agreement – Binding Non-signatories – Sections 7, 8, 16 of Arbitration and Conciliation Act, 1996 – Group of companies doctrine applied – Interim award of Arbitral Tribunal dismissed for not considering discovery and inspection application essential to establish group of companies doctrine [Paras 27-32].

Judicial Review – Standard – Review of interim arbitral award under Section 37(2)(a) – Importance of evidentiary foundation to justify jurisdictional claims and application of doctrines binding non-signatories [Paras 34-35].

Decision: Appeal allowed – High Court judgment and Arbitral Tribunal's interim award set aside – Matter remanded to Arbitral Tribunal for reconsideration with directions to allow discovery and inspection application [Para 36].