SARFAESI Act – Sale Notice Compliance – Appellants challenged the validity of the Second Sale Notice for not adhering to the statutory requirement of a 30-day notice period – Supreme Court held that the notice violated Rules 8(6) and 9(1) of the Security Interest (Enforcement) Rules, 2002, mandating a clear 30-day notice for sale of immovable property – Court emphasized compliance with statutory provisions to protect borrowers' rights and ensure fair procedure [Paras 10-21].

Continuity of Sale Notices – Clarified that once a sale does not occur as scheduled, subsequent sales must follow fresh notice procedures – Supreme Court invalidated the sale held under the Second Sale Notice, affirming that reliance on an earlier notice for subsequent sales without fresh compliance is impermissible [Paras 19-21].

Procedural Irregularity – Importance of procedural fairness highlighted – Court reiterated principles from Mathew Varghese v. M. Amritha Kumar and others (2014) regarding mandatory compliance with notice periods to protect borrowers' right of redemption and ensure transparent and fair auction processes [Paras 15-20].

Decision – Appeals Allowed – Held – Second Sale Notice and consequent sale invalidated – Directed compliance with the statutory 30-day notice requirement for any subsequent sale proceedings – Emphasized the need for adherence to procedural safeguards to ensure justice and fairness [Para 21].

Land Acquisition – Compensation Assessment – Appellants sought higher compensation based on later acquisitions – High Court upheld Reference Court's award – Supreme Court modified compensation to Rs. 28.12 per square yard – Appeals partly allowed [Paras 1-15].

Land Valuation – Comparison with Subsequent Acquisitions – Claim for higher compensation based on 1983 land acquisition rates rejected – Supreme Court held that compensation for later acquisitions not comparable due to subsequent developments and sanctioned plans – Emphasized consistency in valuation for similar time periods [Paras 13-15].

Procedural Fairness – Evidence Submission – Appellants' application to present additional documents under Order XLI Rule 27 CPC dismissed – Supreme Court upheld High Court's approach, ensuring that procedural rules were followed and factual consistency maintained [Paras 5-6].

Decision – Appeals Partly Allowed – Held – Compensation enhanced to Rs. 28.12 per square yard for land acquired in 1976 – Appellants entitled to statutory benefits under the Land Acquisition Act on the enhanced compensation – No order as to costs [Para 15].

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].

Constitutional Law – Articles 14 and 16 – Educational Qualifications – Classification – Circular issued by Kolkata Municipal Corporation prescribing separate conditions for diploma and degree holders for promotion to supernumerary Assistant Engineer posts – Supreme Court upheld the classification as reasonable and in line with past promotion practices – Distinguished between equal opportunity and reasonable classification based on educational qualifications for administrative efficiency [Paras 1-5, 16-27].

Judicial Review – Classification and Promotion – Limited Scope – Court's scrutiny extends only to examining the reasonableness and rational basis of classification – Does not interfere with administrative policy unless arbitrary – Educational qualifications as a criterion for classification upheld as valid for enhancing administrative efficiency [Paras 18-19, 28-32].

Administrative Efficiency – Valid Ground for Classification – Previous judgments supported classification based on educational qualifications to achieve efficiency in public services – Classification not arbitrary if it bears a nexus to the objective sought to be achieved [Paras 16-20, 33-36].

Decision – Appeal Dismissed – Held – Circular prescribing separate conditions for promotion to supernumerary posts upheld – Classification based on educational qualifications found reasonable and not violative of Articles 14 and 16 – High Court’s decision affirmed [Paras 43-44].

Civil Procedure Code – Rejection of Plaint – Order VII Rule 11 – Court’s Power – Power to reject a plaint is drastic and must be exercised in clear cases where the plaint fails to disclose a cause of action or is barred by law – Plaintiffs sought declaration of entitlement to firm’s assets and dissolution of firm – High Court rejected plaint for lack of cause of action and legal tenability – Supreme Court upheld High Court’s decision emphasizing stringent adherence to Order VII Rule 11 CPC to prevent sham litigation [Paras 1-5, 13-22].

Cause of Action – Meaningful Reading – Required to examine entire plaint meaningfully, not formally – If meaningful reading shows vexatious and meritless claims with no clear right to sue, rejection under Order VII Rule 11 CPC warranted – Emphasis on preventing unnecessary protraction of meritless cases to save judicial time [Paras 14-15].

Partnership Firm – Legal Provisions – Sections 40, 42, 43, 44 of Indian Partnership Act, 1932 – Dissolution of firm possible only under specified conditions – Plaintiffs, not being partners, cannot seek dissolution – Clauses of Partnership Deed indicated firm’s continuation despite partners’ deaths – Reliefs sought legally untenable [Paras 10-11, 18].

Decision – Appeals Dismissed – Held – High Court’s order upheld – Reliefs sought in plaint found legally untenable based on meaningful reading of plaint and relevant legal provisions – Rejection of plaint appropriate under Order VII Rule 11 CPC to prevent futile litigation [Paras 22].

Service Law – Misuse of Service Weapon – Departmental Proceedings – Respondent dismissed for firing service weapon causing death and injury – Acquitted in criminal trial due to lack of evidence – Reinstated but later faced departmental inquiry – Evidence from departmental witnesses confirmed misuse of official weapon – High Court’s reinstatement order overturned due to erroneous interference with disciplinary findings – Supreme Court emphasized difference in standards of proof between criminal and departmental proceedings [Paras 3-4, 15-20, 29].

Judicial Review – Scope and Limitations – High Court exceeded jurisdiction by reappreciating evidence in disciplinary proceedings – Judicial review limited to ensuring fairness, compliance with principles of natural justice, and absence of procedural irregularities – Findings based on substantial evidence and adherence to procedures should not be disturbed [Paras 22-23].

Evidence and Procedure – Adequacy of Evidence – Disciplinary findings upheld based on testimonies and circumstantial evidence – Oral testimonies corroborated misuse of service weapon – Burden of proof in departmental inquiries based on preponderance of probabilities, not beyond reasonable doubt – High Court’s reliance on absence of physical evidence misplaced given circumstances and procedural context [Paras 19-20, 28-29].

Decision – Appeal Allowed – Held – High Court’s order set aside – Original dismissal order reinstated – Emphasized importance of maintaining discipline within armed forces and respecting disciplinary authority’s findings unless procedurally flawed [Para 30].