Land Acquisition – Lapse of Acquisition Proceedings – Section 24(2) of the 2013 Act – The Supreme Court held that a subsequent purchaser is not entitled to claim lapsing of acquisition proceedings under the 2013 Act – The High Court's decision declaring the acquisition proceedings lapsed due to non-payment of compensation was found unsustainable in light of the Constitution Bench decision in Indore Development Authority v. Manoharlal, which required both non-possession and non-payment of compensation for lapsing to occur [Paras 3-3.3].

Judicial Precedent – Indore Development Authority Case – The Supreme Court reaffirmed that for lapsing of acquisition under Section 24(2) of the 2013 Act, both conditions of not taking possession and not paying/tendering compensation must be satisfied – If possession is taken, the proceedings do not lapse even if compensation is not deposited in court [Para 3.3].

Subsequent Purchasers – No Locus to Claim Lapse – The Court ruled that subsequent purchasers do not have the locus to file writ petitions for claiming lapsing of acquisition proceedings under Section 24(2) of the 2013 Act – This view was consistent with previous judgments in Godfrey Philips (I) Ltd. & Ors. and Delhi Administration Thr. Secretary Land and Building Department & Ors. v. Pawan Kumar & Ors. [Para 3.1].

Decision: High Court judgment quashed – Appeal allowed – Original writ petition dismissed – Directions for compensation payment to recorded owner if claimed in accordance with law – No costs [Paras 4].

Succession Law – Right of Survivorship – Applicability to Scheduled Tribes – Section 2(2) of the Hindu Succession Act – The Supreme Court held that under Section 2(2) of the Hindu Succession Act, the Act is not applicable to members of Scheduled Tribes – Consequently, the female member of a Scheduled Tribe is excluded from claiming a right of survivorship under the provisions of the Act – The Court recognized the need for legislative amendment to ensure gender equality in inheritance rights for Scheduled Tribe women [Paras 6-7].

Judicial Interpretation – Role of the Legislature – The Court noted that while equity would support granting succession rights to female members of Scheduled Tribes, it is within the legislature's purview to amend the law – The Court urged the Central Government to consider amending the Hindu Succession Act to provide equal inheritance rights to female members of Scheduled Tribes [Para 6.1-7.2].

Previous Precedents – The Court discussed the minority view in Madhu Kishwar & Ors. v. State of Bihar & Ors. (1996) which suggested applying the general principles of the Hindu Succession Act to Scheduled Tribes – However, the majority view did not support this interpretation, reinforcing the exclusion under Section 2(2) [Para 6.4].

Decision: Appeal dismissed – High Court judgment upheld – Central Government directed to consider amending the Hindu Succession Act to ensure gender equality for Scheduled Tribe women in inheritance rights [Paras 7-7.2].

Motor Vehicles – Compensation for Death – Determination of Income – In motor accident claims, the standard of proof is based on the preponderance of probability, not the strict criminal standard – The Supreme Court held that the High Court erred in rejecting the deceased's salary certificate and pay slip – The documents were corroborated by the testimony of the deceased's wife and co-workers – The total compensation payable under various heads based on the deceased's income should be recalculated [Paras 19-20, 23].

Loss of Dependency – Calculation – The deceased's monthly income was affirmed at Rs. 11,225 – Future prospects assessed at 30% – After deductions, the loss of dependency was calculated using a multiplier of 14, resulting in Rs. 1,838,655 [Paras 20-21].

Loss of Consortium and Other Heads – Compensation Increased – The Court awarded Rs. 44,000 to each dependent for loss of consortium, totaling Rs. 220,000 – Compensation for funeral expenses and loss of estate was increased to Rs. 20,000 each [Paras 22, 32].

Interest on Compensation – The rate of interest on the total compensation was set at 9% per annum from the date of the claim petition until realization [Para 24].

Decision: High Court judgments quashed – Appeals allowed – Total compensation recalculated and increased – No costs [Paras 34-35].

Land Acquisition – Lapse of Acquisition Proceedings – Section 24(2) of the 2013 Act – The Supreme Court held that the High Court's decision declaring the acquisition proceedings lapsed based on the non-payment of compensation is unsustainable – The decision in Pune Municipal Corporation v. Harakchand Misirimal Solanki, relied upon by the High Court, was overruled by the Constitution Bench in Indore Development Authority v. Manoharlal, which clarified that non-deposit of compensation does not result in lapse if possession has been taken – The High Court's judgment was contrary to this precedent [Paras 2-3].

Judicial Precedent – Indore Development Authority Case – The Supreme Court reaffirmed that both conditions, possession and payment, must fail for proceedings to lapse – If possession has been taken, the proceedings do not lapse even if compensation was not deposited in court [Para 3].

Decision: High Court judgment quashed – Appeal allowed – Original writ petition dismissed – No costs [Para 3].

Employees Compensation – Enhancement of Compensation – 100% Functional Disability – The Supreme Court held that the appellant, who suffered severe injuries resulting in permanent disability, is entitled to compensation calculated based on 100% functional disability – The Commissioner for Workmen's Compensation erred in assessing the disability at 20% – Considering the appellant's incapacity to continue her work as a laborer, the disability qualifies as total disablement under the Act [Paras 19-23].

Judicial Interpretation – Calculation of Compensation – The functional disability of the appellant, being 100%, her age 40 years, and income Rs. 8000, was recalculated – Applying the multiplier of 184.17, the compensation amounted to Rs. 884,016, with an additional Rs. 42,200 for medical expenses, totaling Rs. 930,000 [Para 23].

Interest on Compensation – The appellant is entitled to 9% interest per annum from the date of the application until the actual payment [Para 24].

Decision: High Court order modified – Enhanced compensation awarded – Respondents directed to pay Rs. 930,000 with 9% interest – Appeal allowed [Paras 24-25].

Land Acquisition – Lapse of Acquisition Proceedings – Section 24(2) of the 2013 Act – The Supreme Court held that the High Court's decision declaring the acquisition proceedings lapsed solely on the ground that compensation was not actually paid is unsustainable – The Constitution Bench decision in Indore Development Authority v. Manoharlal clarified that non-deposit of compensation in court does not result in the lapse of proceedings if possession has been taken – The High Court’s view was contrary to this decision [Paras 2-3].

Judicial Precedent – Indore Development Authority Case – The Supreme Court reaffirmed that both possession and payment conditions must fail for proceedings to lapse – If possession has been taken, compensation must be determined under the 2013 Act without causing lapse [Para 3].

Decision: High Court judgment quashed – Appeal allowed – Original writ petition dismissed – No costs [Paras 4].

Execution of Decree – Interest on Decretal Amount – Appellant deposited the decretal amount in court without giving notice to the decree holder – High Court held decree holder entitled to interest on the amount deposited until the appeal's decision – Supreme Court found that interest ceases when the deposited amount is credited in the decree holder's account, regardless of notice – Appeal allowed, modifying interest obligations [Paras 1-28].

Order XXI Rule 1 CPC – Modes of Payment – Legislative intent that interest ceases on principal amount once deposited and credited to decree holder's account – Notice facilitates withdrawal by decree holder, but lack of notice does not affect cessation of interest if withdrawal occurs [Paras 14-21].

Arbitration Award – Post-deposit Interest – Appellant’s obligation to pay interest on net principal amount after partial payments and set-offs – Court clarified interest payable on remaining principal after set-off against earlier payments [Paras 9-10, 22-25].

Decision – Appeal Allowed – Judgment of High Court set aside – Held – Appellant liable to pay interest at 18% per annum on net principal amount post set-off until payment – Matter remanded to executing court for exact computation [Paras 25-28].

Criminal Law – Murder and Common Intention – Acquittal of first respondent under Section 302 IPC set aside – Evidence established common intention among co-perpetrators – Gurbachan Singh inflicted injuries with a 'lathi', participated in the attack leading to the death of Teja Singh – Supreme Court convicted Gurbachan Singh under Section 302 read with Section 34 IPC [Paras 1-16].

Section 34 IPC – Joint Liability – Requirement of common intention among co-perpetrators – Common intention can form spontaneously during the occurrence – Inferred from conduct and circumstances – Gurbachan Singh shared common intention with co-accused to cause death [Paras 11-12].

Evidence – Testimonies of Eye Witnesses – Consistent accounts from Harbhajan Singh (PW-1) and Jasveer Kaur (PW-2) – Medical evidence corroborated injuries inflicted by co-accused with various weapons [Paras 9-10].

Decision – Appeal Allowed – High Court’s judgment acquitting Gurbachan Singh under Section 302 IPC set aside – Conviction under Section 302 read with Section 34 IPC restored – Life imprisonment and fine imposed as per trial court’s order – Conviction under Section 324 IPC for injuries to Harbhajan Singh (PW-1) maintained [Paras 13-16].

Service Law – Reinstatement and Consequential Benefits – Respondent appointed as untrained teacher in 1971, relieved in 1973 to undergo training, and not permitted to resume duties in 1974 due to lack of BTC certificate – Made representations over decades without approaching judicial forum until 2009 via RTI – High Court ordered reinstatement with benefits after Tribunal dismissed claims as time-barred – Supreme Court found the claim stale, time-barred, and that undue sympathy by judicial forums can lead to adverse consequences [Paras 1-24].

Principles of Delay and Laches – Repeated representations do not revive a stale claim – Respondent waived rights by not seeking timely judicial remedy – Tribunal’s dismissal of claim for being time-barred was legally correct – High Court's order set aside for overlooking principles of limitation and laches [Paras 10-21].

Judicial Conduct – Courts must avoid undue sympathy that can create illegitimate expectations and burden public exchequer – Respondent's minimal service duration did not justify High Court's grant of substantial arrears and benefits [Paras 21-22].

Decision – Appeal Allowed – High Court’s judgment set aside – Claim for reinstatement, retiral benefits, and arrears rejected – Appellants directed to pay lump-sum compensation of Rs. 5,00,000 to respondent within two months [Paras 23-24].