Legitimate Expectation – Doctrine – Abuse of Power – The Court discussed the doctrine of legitimate expectation, emphasizing that if a government induces a substantive expectation, departing from it without compelling public interest constitutes abuse of power. The respondents' expectation of merger into the BES was based on government actions and assurances, and its denial was deemed unfair and an abuse of power [Paras 1-38].

Merger of Cadres – Historical Context – The Court reviewed the historical context of the Bihar Education Service and the subordinate education service, noting various government decisions and judicial pronouncements that impacted the status and merger of +2 lecturers into the BES [Paras 4-9, 20-21].

Encadrement and Discrimination – The encadrement of +2 lecturers with nationalized school teachers through the 2009 Rules was found to be arbitrary and discriminatory. The Court held that +2 lecturers were entitled to the benefits of the BES cadre, and the artificial distinction created by the government was unjustified [Paras 14-29].

Previous Judicial Findings – Binding Nature – The Court highlighted that previous judicial findings in favor of the respondents, establishing their entitlement to the BES cadre, could not be ignored. The government's fluctuating stands and subsequent actions contravened these findings, reinforcing the respondents' legitimate expectations [Paras 19, 24, 37].

Decision: Appeals Dismissed – The Supreme Court dismissed the appeals, upholding the High Court's judgment that declared +2 lecturers as part of the BES cadre. The State of Bihar was directed to comply with this decision within six months, ensuring that all service benefits of the BES cadre were extended to the +2 lecturers [Paras 37-38].

Income Tax – Reassessment Notices – Transition to New Provisions – High Courts quashed reassessment notices issued under unamended Section 148 after 01.04.2021 – Supreme Court converted such notices into those issued under Section 148A (new provisions) – Directed Revenue to comply with new procedural requirements – Notices deemed to be issued under amended Act to protect public exchequer and reduce litigation [Paras 1-11].

Statutory Interpretation – Finance Act, 2021 – Amendments to Sections 147 to 151 of the Income Tax Act – New provisions remedial and benevolent – Ensure compliance and reduce litigation – New provisions apply to notices issued after 01.04.2021 [Paras 6-7].

Judicial Review – Article 142 of the Constitution – Supreme Court exercised power to provide relief to Revenue and assessees – Avoid multiplicity of proceedings – PAN INDIA application to similar judgments and orders of High Courts [Paras 9-12].

Decision: Appeals allowed in part – Held – Reassessment notices issued under unamended Section 148 deemed to have been issued under Section 148A (new provisions) – Assessing Officers to follow new procedure within stipulated time – High Court orders modified to this extent – Present order applicable PAN INDIA to similar cases and pending writ petitions [Paras 10-12].

Registration of Documents – Duties of Registering Officer – Role of Registering Officer is not merely mechanical – Required to independently verify statutory compliance – Failure to verify powers of attorney and other statutory requirements can invalidate registration [Paras 1-9, 58].

Judicial Review – High Court's Jurisdiction – Under Article 226 – High Court can review actions of Registering Authority to ensure statutory duties are performed – Review is permissible even if other civil remedies are available [Paras 10-54].

Powers of Attorney – Authentication vs. Registration – Distinction clarified – PoA must be authenticated, not necessarily registered – Registering Officer must ensure PoA's compliance with statutory requirements [Paras 13-24, 46].

Civil vs. Writ Jurisdiction – Scope of Challenge – Execution of document to be challenged in civil court – Procedural lapses by Registering Authority can be challenged via writ petition [Paras 53-55].

Decision: Appeals allowed – Held – Registration of sale deed by the Registering Authority set aside due to failure to adhere to statutory duties – Order of the Division Bench reversed – Order of the Single Judge restored [Paras 59].

Criminal Law – Circumstantial Evidence – Conviction based solely on circumstantial evidence requires a conclusive chain of circumstances – The last seen theory, arrest of the accused, recovery of material objects, and call details do not conclusively establish guilt – Conviction based on probabilities and inferences drawn from call records inadmissible without proper certification [Paras 1-23].

Motive and Last Seen Theory – Inconsistent Testimonies – High Court's reliance on call records to establish motive and last seen theory rejected due to inconsistencies and lack of certification under Section 65B of the Indian Evidence Act [Paras 10-22].

Admissibility of Electronic Evidence – Certification Requirement – Call records produced without the mandatory certification under Section 65B(4) of the Indian Evidence Act held inadmissible – Oral evidence in place of certification insufficient [Para 20-21].

Decision: Appeal allowed – Held – Conviction of Ravinder Singh @ Kaku under Sections 302 and 364 IPC set aside due to inconclusive circumstantial evidence and inadmissible electronic evidence – Acquittal of co-accused upheld – Ravinder Singh @ Kaku to be released immediately unless required in any other case – Appeals filed by the State dismissed [Paras 22-23].

Constitutional Law – Legislative Competence – Concurrent List – Subject of Arbitration falls under Entry 13 of List III – State Legislature can enact law on arbitration subject to President's assent – State Act reserved for and received President's assent prevails over Central law – State Act within legislative competence of State Legislature [Paras 1-9].

Arbitration – Revocation and Reopening of Awards – State Act – State Act cancelling arbitration clauses and revoking arbitrator’s authority – Provides for suit filing and appeal by State Government against awards – Enactment not arbitrary or discriminatory – Law impacts only specific project agreements [Paras 10-40].

Separation of Powers – Judicial Encroachment – State Act alleged to interfere with judicial power by revoking arbitration clauses – Supreme Court held no encroachment on judicial function – State Act provides for judicial determination of disputes post-revocation [Paras 41-49].

Decision: Appeal dismissed – Held – Kerala Revocation of Arbitration Clauses and Reopening of Awards Act, 1998 upheld as constitutional – Legislative competence affirmed – No violation of separation of powers doctrine – Awards under the Act subject to judicial scrutiny [Paras 50-57].

Foreign Medical Graduates – Licentiate and Internship Regulations – Constitutionality – Regulations 4(a)(i), 4(a)(ii), 4(b), and 4(c) of the Licentiate Regulations and Schedule II, 2(a), and 2(c)(i) of the CRMI Regulations challenged – High Court upheld regulations ensuring minimum standards for foreign medical graduates [Paras 1-10].

Judicial Review – Standard of Education – Role of Courts – Courts should not interfere with educational policies ensuring quality and standards – Regulations based on expert recommendations and past experiences – Aim to prevent commercialisation and maintain quality of medical education [Paras 10-38].

Internship Requirements – Duration and Location – Requirement for 12-month internship in foreign institution and 12-month supervised internship in India upheld – Ensures foreign medical graduates meet Indian standards [Paras 50-58].

Extraterrestrial Legislation – Applicability to Foreign Graduates – Regulations do not impose on foreign countries but set standards for practice in India – Reasonable restrictions under Article 19(6) for public interest [Paras 56-57].

Decision: Appeals dismissed – Held – Licentiate and CRMI Regulations are valid and constitutional – Necessary to maintain minimum standards and quality of medical education – High Court's dismissal upheld – Costs imposed by High Court waived off considering appellant's status as a student [Paras 60-61].

Medical Education – NEET PG Admission – Reduction in Percentile – Central Government reduced minimum marks by 15 percentile for all categories – Petitioners sought further reduction by 5 percentile to fill remaining vacancies – Government opposed additional reduction citing academic interests [Paras 2-7].

Judicial Review – Policy Decisions – Courts should not interfere with educational policies ensuring quality and standards – Decision based on data and expert consultation upheld – No manifest arbitrariness in not reducing percentile further [Paras 8-9].

Decision: Miscellaneous Application dismissed – Held – Government's decision to not reduce minimum marks further upheld – Balance between public interest in filling vacancies and maintaining standards in medical education – No arbitrariness found in decision-making process [Paras 9-10].

Insurance Law – Overlapping Policies – Marine and Domestic Coverage – Clause 47 of the STP Policy and Condition No. 4 of the SFSP Policy – Marine policy issued by Allianz covered global risks, including those insured under domestic policies – Domestic policy excluded liability where another policy covered the same risk – Marine policy interpreted as including warehouse risks [Paras 1-34].

Consumer Protection – Repudiation of Insurance Claims – Exclusion Clauses – Clause 4 of SFSP Policy excluded liability for risks covered by marine policy – Clause 47 of STP Policy intended to cover differences in conditions and limits when local policies are mandated – Insurer's liability under domestic policy excluded due to comprehensive marine coverage [Paras 35-50].

Judicial Review – Interpretation of Insurance Contracts – Double Insurance – Interpretation to avoid unjust enrichment – Claims under overlapping policies to be reconciled based on express terms and conditions – Insured cannot claim more than indemnified loss [Paras 45-51].

Decision: Appeal allowed – Held – NCDRC order set aside – Levi's complaint dismissed – Marine policy issued by Allianz considered primary for claimed losses – Domestic insurer not liable under SFSP Policy due to valid exclusion under Condition No. 4 – Ensured consistent interpretation of insurance contracts to avoid unjust enrichment [Paras 52].

Insurance Law – Terrorism Exclusion Clause – Policy Definitions Govern – Insurance claims cannot be rejected based on the definition of terrorism in penal laws – Exclusion Clause in insurance policy defines terrorism – Rights and liabilities of parties governed by terms of policy – Definitions from penal statutes irrelevant [Paras 1-14].

Consumer Protection – Repudiation of Insurance Claims – Burden of Proof – Insurer must prove exclusion clause applicability – Ambiguities in exclusion clauses construed in favor of insured – Insurer failed to prove act of terrorism as defined in policy [Paras 8-13].

Riot and Violent Means – Policy Coverage – Insurance policy explicitly covers damage caused by riots or violent means – Exclusion Clause improperly applied – Insurer's decision to repudiate policy unsustainable [Paras 14-15].

Decision: Appeal allowed – Held – Impugned judgment and order set aside – Complaint restored to file – Commission directed to decide complaint afresh within four months – Respondent to deposit Rs. 8,900,000/- with Commission within one month – Liberty to appellant to apply for withdrawal of amount pending complaint [Paras 16-18].