Taxation Law – Disallowance under Section 14A – Appeal against High Court’s order endorsing disallowance of proportionate interest for investments in tax-free bonds and securities – Supreme Court held that proportionate disallowance under Section 14A is not warranted where the assessee has sufficient interest-free funds exceeding the investments – Reiterated that tax-exempt income investments made from mixed funds should be presumed to have come from interest-free funds if available – Emphasized clarity and non-arbitrariness in taxation [Paras 1-30]​​.

Interpretation of Section 14A – Investment from Mixed Funds – Court noted that in the absence of separate accounts for interest-free funds and borrowed funds, the presumption should favor the assessee if interest-free funds exceed investments – Highlighted that there is no statutory requirement for maintaining separate accounts for different types of funds [Paras 17-20, 22-23]​​.

Decision – Appeals allowed – Supreme Court set aside High Court’s judgment endorsing proportionate disallowance – Held that investments in tax-free securities by banks with sufficient interest-free funds should not attract disallowance under Section 14A – Directed that the disallowance is impermissible without establishing a direct nexus between expenditure and exempt income [Paras 27-30]​​.

Arbitration – Setting Aside of Award – Patent Illegality and Public Policy – The Supreme Court held that the Division Bench of the High Court erred in setting aside the arbitral award. It emphasized that the High Court's intervention was based on reappreciation of evidence, which is impermissible under Section 34 of the Arbitration and Conciliation Act, 1996. The court clarified that the grounds for setting aside an award on the basis of patent illegality must involve an error that goes to the root of the matter and not mere erroneous application of law. The High Court's categorization of the award as perverse or patently illegal was found to be incorrect as it did not appreciate the contours of these expressions appropriately [Paras 17, 24, 36]​​ .

Public Policy – Fundamental Policy of Indian Law – The Supreme Court reiterated that an award could only be set aside if it contravenes the fundamental policy of Indian law, which includes principles of natural justice or if it shocks the conscience of the court. The concept of "public policy of India" was narrowly interpreted to avoid excessive judicial interference in arbitration awards, thus preserving the object of minimal interference under the 1996 Act [Paras 14, 27, 38]​​ .

Decision- Appeal allowed – The Supreme Court set aside the judgment of the Division Bench of the High Court and restored the arbitral award. The court highlighted the importance of adhering to the principles of minimal judicial interference in arbitration matters, as envisaged under the Arbitration and Conciliation Act, 1996 [Para 39] .

Civil Law – Second Appeal – High Court's Jurisdiction – Appeals against High Court's judgment reversing first appellate court’s decree on examining disputed documents – High Court considered substantial question of law on genuineness of sale agreement – Supreme Court upheld High Court's jurisdiction to review facts under Section 103 CPC when findings of fact by lower courts are perverse or lack logic – Validated High Court’s approach in rectifying erroneous factual conclusions to prevent injustice [Paras 14-18]​​.

Power of High Court under Section 103 CPC – Limited Factual Review – High Court justified in examining evidence when lower courts overlook material evidence or reach findings defying logic – Section 103 CPC empowers High Court to determine facts if evidence on record is sufficient and findings are palpably perverse – Upheld High Court’s detailed scrutiny of sale agreement and related documents to correct erroneous appreciation of facts by first appellate court [Paras 15-18]​​.

Decision – Appeals dismissed – Supreme Court affirmed High Court’s decision and methodology in exercising factual review under Section 103 CPC – Held High Court’s intervention appropriate and necessary to correct substantial errors by first appellate court – No order as to costs [Paras 18-19]​​.

Arbitration Law – Appointment of Arbitrator – Appeal against High Court’s order appointing an arbitrator other than the Chairman as per the distributorship agreement – Supreme Court held that the High Court correctly applied Section 11 and Section 14 of the Arbitration and Conciliation Act, 1996 – Chairman deemed ineligible under Section 12(5) read with Seventh Schedule due to lack of neutrality – Upheld High Court’s decision to appoint an independent arbitrator [Paras 1-12, 9.1]​​.

Interpretation of Section 12(5) and Seventh Schedule – Neutrality of Arbitrators – Court emphasized independence and impartiality as fundamental principles of arbitration – Noted that despite prior agreement, disqualification applies to ensure neutral arbitrators – Previous contractual terms cannot override statutory provisions ensuring fairness in arbitration [Paras 6-9, 7.1]​​.

Conflict with Rajasthan Co-Operative Societies Act – Section 58 – Supreme Court held that the Arbitration and Conciliation Act, 1996 being a special Act prevails over the Rajasthan Co-Operative Societies Act, 2001 – Arbitration agreement and statutory provisions of the Arbitration Act take precedence [Para 7.1]​​.

Decision – Appeals dismissed – Supreme Court upheld the High Court's appointment of an independent arbitrator – Reiterated the importance of neutrality in arbitration and confirmed that statutory amendments ensuring impartial arbitrators supersede prior agreements [Paras 12]​​.

Consumer Protection – Execution of Orders – Insolvency Proceedings – The Supreme Court addressed the conflict between execution proceedings under the Consumer Protection Act and the moratorium imposed under Section 14 of the IBC. The court held that while the moratorium prevents actions against the corporate debtor, it does not extend to the promoters of the corporate debtor. Consequently, the petitioners (home buyers) are permitted to proceed against the promoters despite the moratorium [Paras 14-15]​​.

Insolvency and Bankruptcy Code – Moratorium – Scope and Effect – The court emphasized that the moratorium under Section 14 of the IBC only applies to the corporate debtor and not to its promoters or directors. This interpretation aligns with the decision in P. Mohanraj v. Shah Bros. Ispat (P) Ltd., where it was clarified that the moratorium does not protect individuals associated with the corporate debtor from legal proceedings [Paras 15-16]​​.

Decision - Appeal allowed – The court directed the National Company Law Tribunal (NCLT) to expedite the approval process of the Resolution Plan submitted by the Committee of Creditors (CoC) and to decide the application within six weeks. It granted liberty to the petitioners to pursue remedies against the promoters after the approval of the Resolution Plan [Para 16]​​.

Consumer Protection – Deficiency in Service – Conversion of Leasehold to Freehold – The Supreme Court held that the consumer forums do not have jurisdiction to entertain complaints regarding the conversion of leasehold property to freehold, as this does not constitute a "service" under the Consumer Protection Act, 1986. The conversion fee paid for transferring the title is part of the sale consideration and not a service charge. The actions of the Chandigarh Administration in delaying conversion were found to be arbitrary and discriminatory [Paras 24-25]​​.

Administrative Decision – Transfer of Title – Jurisdiction – The court directed the Chandigarh Administration to decide the claims for conversion based on the date when the consumer complaints were filed, emphasizing that administrative notings do not constitute final decisions unless communicated. The Administration's delay in processing conversions was noted as arbitrary, with instructions for future adherence to statutory rules [Paras 21, 25]​​.

Decision-Appeal  allowed – The Supreme Court set aside the orders of the District, State, and National Consumer Disputes Redressal Commissions. The Chandigarh Administration was directed to decide the conversion claims within three months. Additionally, the court mandated the formation of a committee to review and streamline administrative procedures related to property transactions and report back within four months [Paras 30-31]​​.

Penal Code – Sections 302, 149, 201 r/w 120B – Murder – Cancellation of Bail –The Supreme Court held that the High Court erred in releasing the accused on bail pending appeal against their conviction under Sections 302, 149, 201, r/w 120B IPC. The High Court failed to consider the accused’s repeated threats to witnesses and the gravity of the accusations. The conduct of the accused during the trial, including multiple FIRs under Sections 504 and 506 IPC for issuing threats, was not given due weight. The High Court's order lacked clarity and did not address the submissions of the Public Prosecutor, leading to the conclusion that the bail was unjustified [Paras 11, 11.2, 11.3]​​.

Judgment Writing – Clarity and Reasoning – The Supreme Court emphasized the importance of clarity in judicial opinions, outlining that a judgment should clearly differentiate between submissions, findings, and reasoning. A well-reasoned judgment must detail relevant facts, legal issues, deliberations, and conclusions, ensuring comprehensibility and justifying the verdict logically. The judgment criticized the High Court's lack of detailed reasoning and failure to consider the state's opposition to bail, underscoring the need for precision and thorough analysis in judicial decisions [Paras 9.2, 9.4]​​.

Decision- Appeal allowed – The Supreme Court quashed and set aside the High Court’s orders releasing the accused on bail pending appeal. The accused were directed to surrender forthwith to serve their sentences, with the trial court instructed to issue warrants of arrest if necessary. The High Court was instructed to decide the pending appeals on their merits, uninfluenced by the Supreme Court’s observations [Paras 12, 13, 14]​​.

Employment Law – Manipulated Appointment – Fraudulent Selection Process – The Supreme Court allowed the appeal, overturning the Division Bench’s judgment and restoring the Single Judge’s decision. The court held that the reinstatement of workmen appointed through a manipulated and fraudulent process, without being listed by the Employment Exchange, was unjustified. The workmen, aware of their non-bonafide appointment, benefitted from a process that circumvented statutory requirements. The sanctity of public employment must be protected against such fraudulent practices [Paras 1-18]​​.

Public Employment – Fraudulent Practice – Judicial Responsibility – The court emphasized that fraudulent practices to gain public employment cannot be condoned. Public employment, being a measure of social welfare and mobility, must be safeguarded from manipulation and corruption. Courts must ensure that employment schemes are not exploited by deceitful practices, thereby depriving rightful beneficiaries of their opportunities [Paras 17-18]​​.

Decision - Appeal allowed – The judgment of the Division Bench of the High Court was set aside, and the decision of the learned Single Judge was restored. The parties were directed to bear their own costs [Para 18]​​.

Temple Lands – Ownership and Management – The presiding deity of a temple is recognized as the owner of land attached to the temple. The Pujari, tasked with performing puja and managing the deity's properties, does not hold ownership but serves in a managerial capacity. The Supreme Court upheld the Madhya Pradesh Government’s circulars directing the deletion of Pujari names from revenue records to protect temple properties from unauthorized sales by Pujaris. The name of the deity should be recorded in ownership and occupancy columns, while the Pujari’s name, if recorded, should be in the remarks column [Paras 1-28].

Executive Instructions – Validity and Scope – The State Government can issue executive instructions to supplement statutes and rules, provided they do not contravene legal provisions. The instructions to delete the names of Pujaris from revenue records were deemed legal and within the authority of the State. However, the Collector's name cannot be recorded as the manager of temple properties unless the temple is vested with the State [Paras 27-29].

Rights of Pujaris – Non-Transferable and Conditional – The rights conferred on Pujaris are limited to performing puja and managing temple properties without any proprietary rights, including the right to transfer. The Pujari’s managerial role is subject to proper performance of duties, and rights can be reassumed if duties are not met. The judgment clarified that Pujaris do not hold Bhumiswami rights under the Madhya Bharat Land Revenue and Tenancy Act or the Madhya Pradesh Land Revenue Code [Paras 20-24].

Decision – Appeal allowed – High Court order set aside – Circulars dated 21.03.1994 and 07.06.2008 upheld. The Court reinforced that temple properties are owned by the deity, managed by Pujaris without ownership rights, and the executive instructions issued by the State to protect these properties are valid [Paras 30-31].