Property Law – Declaration of Ownership – High Court erred in denying declaration of ownership solely because plaintiffs failed to establish possession – Proviso to Section 34 Specific Relief Act not a bar if consequential relief sought but not granted on merit – Plaintiffs entitled to declaratory decree of ownership even if injunctive relief denied [Paras 15-19].

Possession – Requirement for Injunction – Plaintiffs failed to establish possession of suit property – Injunctive relief rightly denied – Earlier suit dismissed for lack of possession evidence does not bar subsequent suit for declaration with new cause of action [Paras 11, 19].

Suit Maintainability – Proviso to Section 34 Specific Relief Act – Proviso bars declaration suits without further relief only if plaintiff omits necessary relief – No bar if consequential relief sought but not established on merit – Suit maintainable despite failure on possession claim [Paras 15-16].

Doctrine of Res Judicata – Earlier suit dismissal does not bar present suit under Order II Rule 2 CPC – New incidents of interference provided fresh cause of action for declaratory relief [Paras 17-18].

Decision – Appeal partly allowed – High Court’s denial of injunctive relief and refusal to amend plaint for possession upheld – High Court’s denial of declaration of ownership set aside – Plaintiffs granted declaratory decree of ownership of suit property [Paras 20-21].

Consumer Protection – Allegations of Coercion – Allegations by the complainant of being coerced and threatened to sign blank papers for settlement – National Commission’s orders requiring personal appearance and issuing bailable warrants against Director of appellant company found premature and unwarranted without detailed examination of allegations [Paras 1-5].

Judicial Procedure – Issuance of Bailable Warrants – Bailable warrants to be issued as a last resort – Inappropriate when parties are represented and participating in proceedings – Orders set aside, but National Commission retains authority to require appearance if necessary in the future [Paras 5.1, 6].

Free Access to Justice – Importance of Unfettered Access – Court emphasizes the need for unobstructed access to justice and condemns any attempt to impede or coerce parties – Allegations to be thoroughly examined by National Commission [Para 5.1].

Decision – Appeals allowed – Orders of National Commission requiring personal appearance and issuing bailable warrants quashed – National Commission to examine allegations in detail and decide review application without being influenced by present order [Para 6].

Recovery of Debts – Limitation – Section 30 of the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 – Whether Section 5 of the Limitation Act, 1963 is applicable – Supreme Court holds that Section 5 of the Limitation Act does not apply to appeals against the order of the Recovery Officer under Section 30 of the Act – The prescribed period of 30 days for preferring an appeal cannot be extended – High Court’s order quashing DRAT’s decision is reversed [Paras 3-10].

Limitation – Appeal – Condonation of Delay – Section 5 of the Limitation Act is excluded for appeals under Section 30 of the Recovery of Debts Due to Banks and Financial Institutions Act – Appeals must be filed within the prescribed 30-day period without extension – Previous reliance on the overruled decision in A.R. Venugopal v. Jotheeswaran and Ors. was incorrect [Paras 4, 7-9].

Decision – Appeal allowed – High Court’s order set aside – DRAT’s order reinstated – Delay in preferring the appeal under Section 30 is not condoned [Paras 9-10].

Service Law – Appointment – Arts and Crafts Teachers – Dispute over equivalence – Whether the diploma in Art and Craft by Kurukshetra University through distance education is recognized as equivalent to the diploma by the Haryana Industrial Training Department – The eligibility criteria specified a "two-year Diploma in Art and Craft examination conducted by the Haryana Industrial Training Department or an equivalent qualification recognized by the Haryana Education Department" – Held, the diploma from Kurukshetra University is not equivalent as it is a distance education course and lacks the practical components required for the position – High Court’s judgment equating the two diplomas is set aside [Paras 13-20].

Educational Qualifications – Equivalence – Determination of equivalence of educational qualifications is a technical matter – Decision of equivalence must be made by the appropriate authorities based on expert recommendations – Courts should not interfere unless decisions are irrational, perverse, or based on extraneous considerations [Paras 21-25].

Decision – Appeal allowed – High Court's decision reversed – The diploma in Art and Craft from Kurukshetra University through distance education is not equivalent to the two-year diploma in Art and Craft from the Haryana Industrial Training Department – Writ petitions dismissed [Paras 26-27].

Criminal Law – Appeal against acquittal – The High Court acquitted 11 accused persons based on the reasoning that the eyewitnesses had not named the accused specifically or assigned specific roles – Supreme Court finds the High Court’s approach contrary to settled legal principles – Single witness testimony found reliable can be the basis of conviction – High Court's acquittal order reversed – Conviction and sentence by the Trial Court against 6 accused restored [Paras 1-25].

Witness Testimony – Reliability – Eyewitness accounts provided by PW1, PW2, PW24, PW25, and PW27 found consistent and credible – Presence and participation of accused confirmed – Supreme Court stresses that even a single reliable witness can be sufficient for conviction – Testimony of PW6 not considered due to inconsistency with other eyewitness accounts [Paras 10-12, 17, 23].

Section 149 IPC – Common Object – Analysis of whether the accused shared a common object – Supreme Court applies the principle from Masalti v. State of U.P. for determining liability of accused who did not commit overt acts but were part of unlawful assembly – Accused with specific allegations and overt acts convicted – Acquittal of others confirmed due to lack of specific evidence against them [Paras 18-24].

Decision – Appeals partly allowed – Conviction and sentence restored against original accused A1, A6, A7, A8, A10, and A13 – Acquittal of other accused confirmed due to benefit of doubt – Accused to surrender within four weeks or be taken into custody to serve sentence [Paras 24-25].

Disciplinary Proceedings – Recovery Order – High Court set aside the punishment order due to non-compliance with principles of natural justice – Charge of causing loss of Rs. 246,922.56 proved by Enquiry Officer – Supreme Court holds High Court should have maintained recovery order as the charge was proven – Punishment for recovery maintained – Respondent’s retirement benefits to be adjusted after recovery of the amount [Paras 4-6].

Principles of Natural Justice – Disciplinary Authority’s disagreement with Enquiry Officer’s findings without issuing notice – Procedural lapse found – High Court’s decision to set aside order correct on procedural grounds but recovery order for proven charge should be maintained [Para 4].

Decision – Appeal partly allowed – High Court’s judgment modified to maintain order of recovery for Rs. 246,922.56 – Remaining retirement benefits to be paid after deducting the recovery amount – No order as to costs [Paras 5-6].

Land Acquisition – Market Value – Compensation – High Court determined compensation at Rs. 7100 per acre based on a sale deed from 1980 – Appellants sought compensation of Rs. 15,402 per acre as per a Reference Court’s judgment in a similar case for land in the same village – Supreme Court holds that compensation should be consistent with the Reference Court’s earlier determination – Time gap between notifications (May and December 1981) deemed insignificant – Compensation of Rs. 15,402 per acre awarded [Paras 2-8].

Previous Judgments – Consistency in Compensation – Reference Court’s determination of Rs. 15,402 per acre in another case attained finality and was accepted by the State – Supreme Court finds no significant changes between the two notifications – High Court’s lower determination inconsistent with established compensation [Paras 7-8].

Decision – Appeal allowed – High Court’s judgment modified – Compensation of Rs. 15,402 per acre awarded to appellants with all statutory benefits – Subject to payment of deficient court fees, if any – No order as to costs [Para 8].

Insolvency and Bankruptcy – Residuary Jurisdiction – Section 60(5)(c) of IBC – NCLT's jurisdiction does not extend to disputes arising dehors the insolvency of the Corporate Debtor – Contractual disputes unrelated to insolvency cannot be adjudicated under Section 60(5)(c) – Termination of contract by TCS based on material breaches, not insolvency – NCLT and NCLAT orders set aside [Paras 22-27, 29-31].

Contractual Termination – Grounds – Termination notice by TCS citing multiple breaches of contract by SK Wheels – No direct relation to insolvency process – NCLT's interim stay on termination notice reversed as it exceeded jurisdiction [Paras 25-27, 30-31].

Specific Relief Act – Section 14 – Determinable contracts – Intervention by NCLT cannot convert determinable contracts into non-terminable ones – Valid termination of contract must be respected unless it leads to the corporate death of the debtor [Para 23].

Decision – Appeal allowed – NCLAT judgment set aside – NCLT's interim stay order quashed – Contract termination upheld – Proceedings against TCS dismissed for lack of jurisdiction – No costs [Paras 30-32].

Rights of Persons with Disabilities – Compensatory Time – Appellant diagnosed with Dysgraphia entitled to compensatory time under Guidelines for Written Examinations – Examination center failed to provide additional hour – Supreme Court holds National Testing Agency (NTA) responsible for ensuring compliance with guidelines – High Court’s judgment set aside – Case remanded for reconsideration of appropriate remedy to rectify the injustice caused [Paras 1-20, 22-31, 33-44, 57-60].

Examination Guidelines – Compliance – NTA must ensure examination centers are aware and comply with guidelines for persons with disabilities – Lack of awareness and training at examination centers led to wrongful denial of compensatory time – NTA directed to issue clear and unambiguous guidelines for future examinations [Paras 31-32, 57(iii)-(vi)].

Reasonable Accommodation – Inclusive Education – RPwD Act mandates reasonable accommodations for persons with disabilities – Right to inclusive education includes necessary adjustments in examination conditions – Denial of compensatory time violates the appellant’s right to inclusive education and reasonable accommodation [Paras 34-44].

Decision – Appeal allowed – High Court’s judgment set aside – NTA directed to reconsider appropriate remedy for appellant within one week – NTA to issue clear guidelines and ensure training for examination centers – No costs ordered [Paras 57-60].