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].

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].

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].

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]. 
 

Criminal Law – Appeal against Quashing of FIR Preliminary Enquiry – Not Mandatory Before Registering FIR – Source Report Sufficient – The High Court quashed the FIR for lack of preliminary enquiry – Held: Under Section 17 of the PC Act, preliminary enquiry is not mandatory where detailed source information is already available and considered by a Superintendent of Police – Source report in this case disclosed prima facie material warranting registration of FIR [Paras 7-12, 15].

Section 17 PC Act – Compliance with Second Proviso – Order of SP Valid – Respondent challenged FIR on the ground of non-compliance with Section 17 proviso – Held: SP's order dated 04.12.2023 was based on detailed source report and satisfied the legal requirement of application of mind under the second proviso to Section 17 [Paras 6-7, 10, 15].

Right to Be Heard – No Right to Explanation Before FIR – Procedural Challenge Rejected – Respondent argued he was not given opportunity to explain disproportionate assets before FIR – Held: As per settled law in CBI v. T.H. Vijayalakshmi, no right of hearing accrues to a public servant prior to registration of FIR – Process followed was legally valid [Paras 13-14].

Interpretation of Lalita Kumari and T.N. Sudhakar Reddy – Preliminary Enquiry Discretionary – Court reaffirmed that preliminary enquiry in corruption cases is desirable but not compulsory – SP may order FIR without enquiry if material is sufficient – Held: High Court misapplied Lalita Kumari by treating preliminary enquiry as mandatory [Paras 8, 11-12].

Final Decision – Appeal Allowed – FIR Restored – Supreme Court set aside the High Court’s order dated 25.04.2024 and restored the FIR registered under PC Act against respondent – Held: Investigation to proceed in accordance with law [Paras 16-17].

Tenancy Law - Deemed Tenancy – Section 15A Bombay Rent Act – Conducting Agreement Does Not Confer Tenancy Rights – Plaintiff claimed tenancy rights under Section 15A on the basis of a 1967 agreement titled as an agreement for conducting a hotel business – Held: The agreement clearly indicated an arrangement to conduct the owner's hotel business and did not confer possession or leasehold rights over the premises – No deemed tenancy created [Paras 1-7, 16-24].

Construction of Written Agreements – Literal Interpretation Preferred – Sections 91 & 92 Evidence Act Apply – Oral Evidence Barred – The agreement's language clearly established it was a business conducting arrangement – Held: The bar under Sections 91 and 92 applies; oral evidence to contradict or vary written terms not admissible, no applicable exception made out [Paras 8, 18-19].

Nomenclature Not Determinative – Substance over Form – Despite being styled as a ‘conducting agreement’, its contents and context established business conductorship and not a license to occupy – Held: Mere nomenclature cannot confer rights absent in the substantive clauses of the agreement [Paras 16-17, 21-22].

Exclusive Possession – Not Transferred – Plaintiff Entrusted Only with Business, Not Premises – The agreement lacked any clause evidencing transfer of possession; plaintiff’s responsibilities were limited to running the hotel with owner’s supervision rights – Held: This omission is fatal to claim of tenancy or license [Paras 22-23].

Sales Tax Registration and Royalty Payments – Irrelevant to Tenancy – Business registration and monthly royalty do not establish lease/licence of premises – Held: Plaintiff's sales tax registration and business-related payments were consistent with a conducting agreement, not with tenancy [Paras 6.8, 23].

Final Decision – Appeal Dismissed – Trial court’s finding in favour of plaintiff reversed by appellate court and affirmed by High Court and Supreme Court – Held: Plaintiff had no possessory or tenancy rights; agreement was for conduct of business alone – Appeal dismissed with costs of ₹1,00,000 payable to Defendant No. 1 [Para 24].

Service Law - Exclusive Jurisdiction Clauses – Validity in Employment Contracts – Enforceable – The Court held that jurisdiction clauses conferring exclusive jurisdiction to courts in Mumbai in private employment contracts are valid and enforceable – A party who has agreed to such a clause cannot later file a suit in a different jurisdiction merely for convenience – Held: The clause was valid as per Section 28 of the Contract Act and applicable legal precedents [Paras 7-24, 27-31].

Contractual Autonomy – Private Employment – Binding Terms – Employee Bound by Terms – Employees who willingly accept and act upon appointment letters containing exclusive jurisdiction clauses cannot subsequently challenge such clauses – Difference between public and private sector employment highlighted – Held: Contractual terms govern private employment unless contrary to statute [Paras 21-24].

Jurisdiction of Court – Order VII Rule 11 CPC – Error by High Court – Pleadings Should Have Been Returned, Not Rejected – Although the Patna High Court correctly held lack of jurisdiction, it erred by rejecting the plaint under Order VII Rule 11 instead of returning it under Order VII Rule 10 CPC – Held: Plaint must be returned for presentation before competent court in Mumbai [Paras 33-34].

Cause of Action and Forum Selection – Courts in Mumbai Have Jurisdiction – The place of appointment, issuance of termination letter, and other critical actions were all in Mumbai – Held: Mumbai courts had jurisdiction under Explanation to Section 20 of CPC [Para 30].

Employment Contracts and Unequal Bargaining – No Special Treatment for Employees – Court declined to create exceptions to general principles of contract enforcement based on perceived inequality of bargaining power – Held: Law treats all contracts equally regardless of parties’ relative strengths [Paras 24-26].

Final Decision – Patna HC Judgment Upheld in Part, Delhi HC Judgment Set Aside – Rakesh’s appeal dismissed with direction to file suit in Mumbai; Deepti’s appeal allowed, plaint to be filed in competent court in Mumbai – Liberty granted for amendment and limitation pleadings if fresh suits are filed [Paras 32-38].

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].