Land Acquisition – Urgency Clause – Section 17(4) of the Land Acquisition Act – Challenge to the invocation of urgency clause and dispensing with the hearing under Section 5A – Supreme Court holds that bare assertions by the State are insufficient – Existence of exceptional circumstances justifying urgency must be proven – High Court’s dismissal of writ petition set aside – Case remanded for reconsideration of urgency and adherence to procedural safeguards [Paras 22-24, 37-38].

Evidence – Burden of Proof – Section 106 of the Evidence Act – Facts specifically within the knowledge of the State must be laid before the court – State must provide relevant material justifying invocation of Section 17(4) [Para 23].

Constitutional Law – Right to Property – Compulsory acquisition requires compliance with statutory safeguards – Section 5A of the Land Acquisition Act guarantees a right to be heard – Dispensation with this right requires strict scrutiny and adherence to statutory requirements [Para 22].

Decision – Appeal allowed – High Court's judgment set aside – Case remanded to reconsider the validity of invoking Section 17(4) and adherence to Section 5A – Costs imposed on respondents [Para 38].

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].

Criminal Procedure – Recalling Judgment – Section 362 CrPC – High Court lacks jurisdiction to recall its own order after it is passed – Only correction of clerical or arithmetical errors allowed under Section 362 – High Court's suo moto recall of the order quashing the FIR was without jurisdiction – Original order quashing FIR restored [Paras 2-5].

Jurisdiction – Suo Moto Recall – Court's power limited to corrections – Recall of detailed reasoned order not permissible under Section 362 – High Court's recall order set aside [Paras 4-5].

Decision – Appeal allowed – High Court's order dated 28.04.2021 recalling its earlier order quashing the FIR is set aside – Original order dated 20.04.2021 quashing the FIR is restored – No costs ordered [Para 5].

Succession – Interpretation of Will – The First Appellate Court found that the will's recitals clearly conveyed full ownership to the testator's wife, which the High Court erroneously reversed by incorrectly applying Section 14 of the Hindu Succession Act, 1956 – The Supreme Court held that the High Court should not have interfered as the First Appellate Court's findings were not perverse and were final on matters of fact and law [Paras 1-13].

Judicial Interference – High Court's Role – The High Court exceeded its jurisdiction under Section 100 of the CPC by reevaluating factual findings without identifying any substantial question of law – The First Appellate Court’s judgment was based on a correct interpretation of the will, granting full ownership, which the High Court wrongly assessed under Section 14 of the Hindu Succession Act [Paras 10-12].

Decision – Appeal allowed – High Court's judgment and decree set aside – The suit filed by the appellant along with Smt. Shevantabai decreed as prayed for as per the First Appellate Court's judgment dated 22.01.1992 – No order as to costs [Para 13].

Land Ceiling – Jurisdiction of Civil Courts – Urban Land (Ceiling and Regulation) Act, 1976 is a self-contained code providing for appeal and revision before designated authorities – Civil courts lack jurisdiction to try suits related to land under ceiling proceedings – Orders by competent authorities under ULC Act are final and cannot be declared illegal or non est by civil courts – High Court erred in affirming the lower courts’ judgments granting relief to the respondent [Paras 1-15].

Possession and Utilization – ULC Act Compliance – Competent authority's orders declaring surplus land became final – Possession taken by conducting panchnama, respondent signatory as a witness – Land utilized for public purpose, construction of houses for slum dwellers – Civil court's decree declaring possession not taken is erroneous [Paras 12-14].

Decision – Appeal allowed – Judgments and decrees of the lower courts and High Court set aside – Suit filed by respondent dismissed – No order as to costs [Para 17].

Promotion – Relaxation in Qualifying Service – High Court directed the competent authority to grant relaxation in qualifying service for promotion, permissible under Rule 4 of the 2006 Rules – Supreme Court held that relaxation under Rule 4 is discretionary, not a right – The term "MAY" in Rule 4 indicates the authority's discretion – High Court erred in issuing writ of mandamus to compel the grant of relaxation – Eligibility lists prepared in accordance with Rule 5(iii) and Rule 8(iii) of the Rules, 1990 were correct – Appeal allowed [Paras 1-8].

Discretionary Power – Mandamus – The court emphasized that relaxation in qualifying service cannot be claimed as a right – Authorities' discretion cannot be overridden by mandamus unless there is a failure to exercise discretion lawfully – High Court's command to grant relaxation was inappropriate [Paras 7-8].

Decision – Appeal allowed – Judgments of the Single Judge and Division Bench of the High Court set aside – Eligibility lists excluding respondents were valid – Writ petition by original writ petitioners dismissed – No order as to costs [Para 8].

Penal Code – Private Defence – Sections 96 to 102 – A plea of private defence need not be set up in a particular manner and can be applied to others if the evidence shows a preponderance of probabilities – The concept of acting in excess must be assessed based on the continuous apprehension of danger – Use of weapons significant in context – Courts must be cautious and apply the principle of sifting the chaff from the grain when evidence is inseparable and impacts credibility [Paras 46-47, 48-49].

Penal Code – Common Object – Section 149 – Mere presence in an assembly does not constitute an offense unless it becomes unlawful with a common object – Prosecution must prove the assembly had a common unlawful object and the offense was committed in prosecution of that object – Courts should be cautious due to the deeming fiction under Section 149 IPC requiring higher onus on prosecution [Paras 50-51].

Evidence – Falsus in Uno, Falsus in Omnibus – The principle of rejecting entire testimony due to falsehood does not strictly apply – Courts should sift credible evidence unless discrepancies are inseparable and material – Discrepancies impacting witness credibility can lead to rejecting their testimony [Paras 48-49].

Evidence – Motive – While motive may lose significance with adequate eyewitness evidence, it is crucial when the plea of private defence is raised – Avoidance of unimpeachable evidence regarding motive can seriously impact the prosecution's case [Paras 51-52].

Decision – Appeals allowed – High Court’s judgment set aside – Case remanded for fresh consideration on possession and maintainability – Appellants entitled to benefit of doubt – Plea of private defence accepted as possible and plausible – Appeals by de facto complainant dismissed – No costs ordered [Paras 60-61].