Jurisdiction of Civil Courts – Retrospective Application of Rent Control Act – Applicability to Pending Suits – Appellants contested a decree for possession passed by a civil court after the Rajasthan Rent Control Act, 2001 became applicable – Supreme Court held that the Act does not bar the execution of a decree passed by a civil court if the suit was filed before the Act's applicability – The Act only restricts the jurisdiction of civil courts from the date it became applicable to the area – The rights of parties are determined based on the law at the time of filing the suit [Paras 8-10, 28-30].

Execution of Decrees – Civil Court's Authority – Decrees Passed Prior to Rent Control Act – Civil courts retain authority to pass decrees in suits initiated before the Rent Control Act became applicable to the area – Decrees passed by civil courts in such circumstances remain valid and executable – Supreme Court emphasized the principle that rights crystallize at the time of filing the suit, not based on subsequent changes in law [Paras 18-20, 29-30].

Decision: Appeals dismissed – High Court's decision upholding the decree for possession passed by the civil court affirmed – Decree valid and executable despite the subsequent applicability of the Rajasthan Rent Control Act, 2001 to the area in question [Paras 30].

Specific Performance – Execution and Consideration – Admission by Vendor – Once the execution of the agreement to sell and receipt of substantial advance sale consideration were admitted by the vendor, no further proof was required by the plaintiff-vendee – The Trial Court correctly decreed the suit for specific performance – High Court's interference in the decree based on the necessity of cancellation of subsequent sale deeds was misplaced [Paras 2.5, 5.2-5.4].

Fraudulent Sale Deeds – Necessity of Specific Relief – In a suit for specific performance, it is sufficient to implead subsequent purchasers and seek a direction for them to join in the execution of the sale deed – No need to seek cancellation of the sale deeds – The High Court erred in quashing the decree based on the absence of a specific prayer for cancellation [Paras 3.3, 5.6-5.7].

Discretionary Relief – Section 20 Specific Relief Act – High Court’s Reversal – Despite the discretionary nature of relief under Section 20, the Trial Court's findings of admitted execution and receipt of consideration, and the fraudulent nature of subsequent sale deeds, justified the decree for specific performance – The High Court's interference was unwarranted [Paras 5.8, 6].

Decision: Appeal allowed – High Court’s judgment set aside – Trial Court’s decree for specific performance restored – No order as to costs [Paras 6].

Bail Under UAPA – Section 43D(5) – Stringency and Prolonged Incarceration – Appellant denied bail under Section 439 CrPC – Held, UAPA’s Section 43D(5) conditions less stringent than NDPS Act – Appellant in custody for nearly 8 years – Trial progress slow with only 6 of 109 witnesses examined – Prolonged incarceration considered significant – Bail granted with conditions set by the trial court – Observations limited to bail application purposes [Paras 1-11].

Decision: Appeal allowed – High Court’s order denying bail set aside – Appellant to be released on bail subject to conditions set by the trial court [Para 11].

Suspension of Sentence – Pendency of Appeal – Sections 354, 363 IPC and Section 8 of POCSO Act – Appellant convicted for kidnapping and outraging the modesty of a 9-year-old – Trial Court awarded concurrent sentences under IPC and POCSO Act – High Court denied suspension of sentence – Supreme Court allowed appeal noting maximum sentence of three years and delay in hearing appeal – Recognized that prolonged incarceration during appeal pendency without consideration for sentence length and hearing delay can cause irreparable injury [Paras 1-18].

Decision: Appeal allowed – Execution of remaining part of the sentence suspended – Appellant to be released on bail on terms set by Trial Court [Paras 18].

Permission for Medical Courses – Requirements Under Central Council Act – Regulatory Compliance – CCIM denied permission to respondent medical colleges for postgraduate admissions for 2018-19 due to lack of Central Research Laboratory and Animal House – Karnataka High Court allowed admissions relying on subsequent permission for 2019-20 – Supreme Court held that each academic year requires independent compliance – Deficiencies for 2018-19 cannot be overlooked due to compliance in subsequent years – High Court’s decision flawed as it did not consider legislative scheme of Section 13A of the Act [Paras 1-41].

Non-Recognition of Qualifications – Section 13B – Medical qualifications granted without proper permissions not recognized – Ensures adherence to standards prescribed by the Act – Essential for maintaining educational standards [Paras 28-30].

Decision: Appeals allowed – High Court’s judgments set aside – Writ petitions by Karnataka Ayurveda Medical College and others dismissed – No order as to costs [Paras 40-41].

Tax Exemption Withdrawal – Sick Industrial Companies Act – Section 19(3) – Exemption Withdrawal – Appellant revived a sick unit and received tax exemption as per the Kerala Government's 2004 order – Supreme Court held that the exemption granted under Section 19(3) is binding on the State – Government's withdrawal of exemption through the 2006 order was improper – Exemptions granted under BIFR schemes are binding and cannot be unilaterally withdrawn by the State – Emphasis on fairness and adherence to statutory provisions [Paras 1-21].

Promissory Estoppel – State's Obligation – Promissory estoppel cannot compel the State to act against statutory provisions – Exemption provided to a single unit under Section 19(3) was binding and could not be withdrawn arbitrarily [Paras 22-31].

Legislative Interpretation – Strict Compliance – Exemption Provisions – Exemptions must be interpreted strictly as per legislative intent – Withdrawal of exemption without a clear statutory basis is invalid – Supreme Court reiterated the need for legislative adherence and non-arbitrariness in tax exemptions [Paras 14-20, 32-44].

Decision: Appeal allowed – High Court’s judgment set aside – Withdrawal of tax exemption declared invalid – State directed to comply with the original exemption granted under the 2004 order as per BIFR scheme [Paras 40-44].

Dam Safety – Mullaperiyar Dam – Interim Supervisory Committee – Court orders the continuation and strengthening of the Supervisory Committee constituted under the 2014 judgment until the National Dam Safety Authority (NDSA) is fully operational – The Supervisory Committee to function as the NDSA and be accountable for all matters relating to the dam's safety, including functions specified in Section 9 of the 2021 Act – States directed to nominate technical experts to the Committee and provide necessary support [Paras 1-22].

Supervisory Committee – Functions and Powers – Until the NDSA is established, the reconstituted Supervisory Committee to discharge all functions and powers of the NDSA under the 2021 Act – The Supervisory Committee to review the safety of the Mullaperiyar Dam and frame terms of reference as per the 2021 Act – All concerned authorities to comply with directions issued by the Supervisory Committee, and any failure to do so may invite legal consequences [Paras 6-20].

State Cooperation – Responsibilities of States – The States of Tamil Nadu and Kerala to nominate technical experts to the Supervisory Committee and ensure all directions for the dam's maintenance and safety are executed promptly – Ministry of Jal Shakti, Government of India, to provide logistical support to the Supervisory Committee [Paras 9, 13, 15, 16].

Decision – Interim Arrangement – Supervisory Committee to continue as per the 2014 judgment with additional responsibilities under the 2021 Act until NDSA is functional – Regular NDSA to be established at the earliest to ensure the dam's safety [Paras 20-22].

Criminal Law – Sentencing – Appeal against the High Court's reduction of the sentence of Banwari Lal, convicted under Section 307 IPC, from three years' rigorous imprisonment to the period already undergone (44 days) – High Court's order reducing sentence held unsustainable due to lack of consideration of the gravity of the offense and the nature of injuries – Supreme Court restored the trial court's sentence of three years' rigorous imprisonment [Paras 1-88].

Section 307 IPC – Attempt to murder – High Court's reduction of sentence based on the long duration of the trial and the accused's age at the time of the offense – Supreme Court emphasized that merely the passage of time cannot justify a disproportionate and inadequate sentence – Importance of considering the seriousness of the offense and the injuries caused [Paras 6-10].

Probation – Benefit granted to co-accused Mohan Lal under Section 360 Cr.P.C. – High Court's decision not challenged by the State at that level – Supreme Court dismissed the appeal against the order granting probation, as it was not contested earlier by the State [Paras 11-12].

Decision – Appeal partly allowed – Sentence of Banwari Lal restored to three years' rigorous imprisonment – Banwari Lal directed to surrender within four weeks to serve the remaining sentence – Appeal against Mohan Lal dismissed [Paras 12].

Payment of Gratuity – Meaning of "Wages" – Ad hoc payments made to workers pursuant to interim orders of the Supreme Court – Held, such ad hoc payments do not form part of "wages" under Section 2(s) of the Payment of Gratuity Act, 1972, as they were not earned by the employee in accordance with the terms and conditions of employment – Interim benefits cease upon final adverse judgment – Supreme Court clarifies that "wages" includes only basic wages and Dearness Allowance [Paras 1-22].

Decision – Appeals allowed – Orders of High Court, Controlling Authority, and Appellate Authority under the Act set aside – Management directed not to recover amounts already paid to employees or their families due to passage of time and circumstances [Paras 21-22].