Negotiable Instruments Act – Dishonor of Cheque – Complaint under Section 138 of the NI Act for dishonor of cheque – Respondent issued cheque for Rs. 1,50,000 as part repayment of advance – Cheque dishonored due to insufficient funds – Magistrate convicted respondent, sentencing to six months imprisonment and fine – Sessions Court upheld conviction – High Court set aside conviction – Supreme Court restored conviction – Presumption under Sections 118 and 139 in favor of holder of cheque – Respondent failed to rebut presumption – Sentence modified to enhanced fine of Rs. 2,50,000 with default imprisonment [Paras 1-22].

Judicial Review – Scope of Revision – High Court exceeded its jurisdiction in re-evaluating evidence and setting aside concurrent findings of lower courts – Limited scope in revision to interfere only if findings are perverse or incorrect [Paras 16-18].

Presumption of Debt or Liability – Sections 118 and 139 NI Act – Presumption in favor of holder – Burden on accused to rebut presumption by preponderance of probabilities – Respondent failed to provide satisfactory rebuttal evidence [Paras 11-20].

Decision – Appeals allowed in part – High Court's order set aside – Conviction restored with modified sentence of fine Rs. 2,50,000 – Fine to be paid as compensation to appellant – Default sentence of six months simple imprisonment [Paras 21-22].

Arbitration – MSMED Act – Jurisdiction and Procedure – Dispute regarding payment for supply of TMT bars – Facilitation Council dismissed proceedings citing lack of jurisdiction – High Court dismissed writ petition suggesting remedy under Section 34 of Arbitration Act – Supreme Court held Facilitation Council did not follow proper procedure under Section 18 of MSMED Act – Remanded case for proper arbitration proceedings [Paras 1-12].

Special Statute – MSMED Act Overriding Arbitration Act – MSMED Act being special statute, its provisions have overriding effect – Dispute resolution to follow Section 18 of MSMED Act – Facilitation Council first acts as conciliator, failing which arbitration proceedings commence – Arbitration Act provisions apply post-conciliation [Paras 9-10].

Decision – Appeal allowed – High Court's judgment and Facilitation Council's order set aside – Matter remitted to Facilitation Council for fresh proceedings in accordance with Section 18 of MSMED Act – Council to complete proceedings within six months [Paras 12].

Non-Release of Prisoners – Delay in Release after Bail – Suo moto proceedings initiated due to reports of non-release of prisoners post bail grant – Adoption of FASTER (Fast and Secured Transmission of Electronic Records) system proposed – Supreme Court directed ensuring internet facility in jails for electronic transmission of orders – Interim communication through State Nodal Officers until full implementation – Amendments to rules and procedures to recognize e-authenticated orders – Directions issued for smooth implementation of FASTER system by coordinating with NIC and State authorities [Paras 1-13].

Judicial Administration – ICT Utilization – Need for efficient transmission of court orders highlighted – FASTER system to transmit e-authenticated copies of orders for compliance – Steps for ensuring internet connectivity and necessary administrative amendments outlined [Paras 7-12].

Decision – Directions issued to Chief Secretaries and other relevant authorities to ensure implementation of FASTER system – Matter listed for further review after two weeks [Para 13].

Civil Procedure – Res Judicata – Section 92 CPC – Representative suit – Suit filed under Section 92 CPC for settling a scheme of administration for a mosque – Ownership of the suit property was an issue – Judgment in the representative suit is binding on all interested parties – Issue of title to the suit property determined in the representative suit bars subsequent suit for declaration of title – Appeal dismissed [Paras 1-47].

Section 92 CPC – Scope – In suits filed under Section 92 CPC, the court may decide on the title to the property if it is necessary for settling the scheme of administration – The judgment in a representative suit binds all interested parties [Paras 32-35].

Determination of Res Judicata – Mixed questions of law and fact – Res judicata can be decided as a preliminary issue if it involves only questions of law – In cases involving mixed questions of law and fact, it may be necessary to conduct a full trial [Paras 19-23].

Previous Suits – Analysis – The earlier suits involved determination of the title to the suit property – The issue of title was directly and substantially in issue and was necessary for the decision – Subsequent suit barred by res judicata [Paras 24-43].

Decision – Appeals dismissed – Suit barred by res judicata – Judgment of High Court affirmed [Paras 46-47].

Financial Crisis – COVID-19 Impact – Sree Padmanabha Swamy Temple faced financial crisis due to lockdown and lack of income – Routine rituals and salaries continued despite closure – Administrative Committee reported financial constraints and sought aid from Trust and Government [Paras 1A].

Special Audit – Compliance with Supreme Court Order – Special audit for 25 years directed by Supreme Court commenced – Issues with audit cooperation from related Trusts – Court emphasized necessity of audit to ensure transparency and proper fund utilization [Paras 1B, 1B.3, 5-6].

Trust's Independence – Miscellaneous Application by SPSTT – SPSTT claimed independence from Temple administration – Argued audit beyond Court's directive – Supreme Court rejected claim, citing interlinkages and necessity for comprehensive audit as per previous orders and directions [Paras 2-3, 6-7].

Decision – Application Partly Allowed – Held – Reiterated necessity of special audit of Sree Padmanabha Swamy Temple and SPSTT – Directed completion within three months – Ensured cooperation from SPSTT – Addressed financial crisis and audit compliance [Paras 6-10].

Industrial Disputes – Dismissal of Workmen – Disciplinary proceedings during conciliation – Supreme Court held Section 33(2)(b) ID Act applicable where misconduct not connected with the dispute – Misconduct related to vandalism of employer's property – Rejected Assistant Commissioner's finding requiring prior approval under Section 33(1)(b) – Appeal allowed, approval granted for dismissal under Section 33(2)(b) [Paras 10-14].

ection 33 Distinction – Connected vs. Unconnected Misconduct – Explained distinction between Section 33(1) requiring prior approval for misconduct connected with dispute and Section 33(2) permitting dismissal for misconduct not connected with the dispute – Emphasized factual determination of connection with the dispute – Supreme Court reiterated legislative history supporting balanced approach [Paras 9-11].

Compliance with Section 33(2)(b) – Confirmed compliance with Section 33(2)(b) requirements – Found no contrary evidence or findings – Reversed lower courts' misapplication of Section 33(1)(b) [Paras 13-14].

Decision – Appeal Allowed – Held – High Court judgment set aside – Approval granted for dismissal under Section 33(2)(b) – Clarified no impact on entitlements of deceased workmen's legal representatives [Paras 14-15].

Arbitration – Appointment of Arbitrator – Parties agreed on existence of arbitration agreements – Disputes arose under Construction Management Agreements – Respondents denied arbitrable dispute under said agreements, claimed it arose under Share Purchase Agreements – Supreme Court held disputes fell under CMAs' arbitration clauses – Narrow scope of review under Section 11(6) – Appointment of Justice (Retd.) R.V. Raveendran as sole arbitrator allowed [Paras 18-32].

Arbitration Clauses – Distinction and Application – Share Purchase Agreements contained SIAC arbitration clause with seat at Singapore – Construction Management Agreements contained Indian arbitration clause with seat at New Delhi – Supreme Court emphasized interpreting agreements harmoniously – Disputes related to construction obligations and fee payment fall under CMAs – Held Rajapura SPA/Southern Homes SPA arbitration clauses do not override CMAs' clauses [Paras 24-31].

Consolidation of Proceedings – Connected Agreements – RCMA and SCMA interlinked regarding fee computation and construction obligations – Supreme Court left consolidation decision to sole arbitrator – Emphasized avoiding conflicting awards and efficient resolution [Paras 34-35].

Decision – Petitions Allowed – Held – Appointment of sole arbitrator Justice (Retd.) R.V. Raveendran – Disputes to be resolved under arbitration clauses of CMAs – Arbitrator to decide on consolidation of proceedings – Fees as per Fourth Schedule of the Arbitration and Conciliation Act, 1996 [Paras 36-37].

NDPS Act – Bail Conditions – High Court granted bail based on absence of contraband possession and error in statement translation – Supreme Court held High Court failed to adhere to Section 37(1)(b) NDPS Act requirements – Emphasized need for "reasonable grounds" to believe accused not guilty and not likely to commit offences on bail – Set aside High Court order [Paras 17-21, 30-34].

Conscious Possession – Defined and Distinguished – Highlighted principles from previous cases on conscious possession and its relevance in drug-related offences – Supreme Court noted respondent's continuous travel with co-accused and involvement in communication supporting conscious possession [Paras 12, 22-24].

Procedural Compliance – Section 42 NDPS Act – Addressed respondent's argument on non-compliance with Section 42 – Held compliance was prima facie met, as information was recorded and communicated timely – Clarified that such procedural issues should be examined during trial [Paras 27-29].

Decision – Appeal Allowed – Held – High Court's bail order set aside – Respondent's bail application dismissed – Directed respondent to surrender forthwith – Emphasized strict adherence to statutory provisions for bail in NDPS cases to prevent misuse [Para 34-35].

Coal Mines (Special Provisions) Act – Section 11 Interpretation – Successful allottee's discretion – Supreme Court held successful bidder has complete freedom to adopt or reject existing contracts related to coal mining operations – No obligation to continue with prior contracts unless elected – Statutory provision prevails over any conflicting contractual clause [Paras 20-22].

Judicial Review – Administrative Actions – Scope and Limitations – Reiterated principles from Tata Cellular v. Union of India (1994) on judicial review focusing on decision-making process rather than merits – Emphasized legality, rationality, and procedural propriety as grounds for intervention – Rejected High Court's rationale of legitimate expectation [Paras 30-33].

Legitimate Expectation – Not Applicable Against Statute – Supreme Court clarified legitimate expectation cannot override statutory provisions – Policy decisions favoring competitive bidding justified as rational and non-arbitrary [Paras 26-27, 33].

Decision – Appeals Allowed – Held – High Court judgment set aside – Upheld PSPCL’s decision to reject EMTA’s claims based on competitive bidding policy – Directed adherence to statutory provisions of the Coal Mines (Special Provisions) Act, 2015 [Paras 35].