Industrial Dispute – Termination Approval – Appellant challenged the High Court’s order which confirmed the Labour Court’s judgment setting aside the termination of the workman – Supreme Court held that once the order of termination was approved by the Industrial Tribunal, the findings recorded by the Tribunal were binding between the parties – Held, no contrary view could be taken by the Labour Court contrary to the findings recorded by the Industrial Tribunal [Paras 5.1-5.2, 6].

Jurisdiction – Role of Industrial Tribunal and Labour Court – Supreme Court noted that the Industrial Tribunal had permitted the employer to prove the charges and misconduct before it and had approved the termination – High Court failed to consider this finality and binding nature of the Industrial Tribunal’s decision – Held, the Labour Court’s subsequent interference was not permissible [Paras 5.1, 5.2].

Precedent – Distinction from Previous Cases – Supreme Court distinguished the case from John D'Souza vs. Karnataka State Road Transport Corporation (2019) 14 Scale 57 – Held, the specific facts of this case, where the Industrial Tribunal had permitted evidence and approved the termination, made the Labour Court’s contrary view unsustainable [Para 5.2].

Decision: Appeals allowed – High Court’s order confirming the Labour Court’s judgment set aside – Labour Court’s judgment setting aside the termination quashed – No order as to costs [Paras 6-7].

Motor Vehicle Accident – Determination of Just Compensation – Appellant challenged the High Court’s decision reducing compensation – Supreme Court held that compensation under Section 168 of the Motor Vehicles Act must be fair, reasonable, and equitable, emphasizing a comprehensive approach to pecuniary relief [Paras 11-12].

Income from Business Ventures and Investments – Treatment of Income – Supreme Court held that the entire amount from the deceased's business ventures and investments should be treated as income, as the deceased was actively involved in day-to-day management – Income derived from capital assets not sufficient to negate compensation for loss of managerial skills [Paras 16-18].

Income from House Property and Agricultural Land – Management and Dependency – Supreme Court partially deducted income from house property and agricultural land, attributing a portion to the deceased’s managerial skills – Awarded Rs 250,000 for managerial skills, including agricultural land management [Paras 19-23].

Just Compensation – Calculation and Awards – Supreme Court recalculated the compensation based on income and future prospects, applying relevant deductions and multipliers – Awarded additional compensation for funeral expenses, loss of estate, and consortium [Paras 24-25].

Decision: Appeals allowed – High Court’s order reducing compensation set aside – Appellants entitled to enhanced compensation with interest at 7.5% per annum from the claim petition date until realization – Enhanced amount to be paid within three months, adjusted by any amount already paid or deposited [Paras 26-28].

Animal Welfare – Custody of Seized Cattle – Appellant challenged the High Court’s order granting interim custody of seized cattle to private respondents – Supreme Court held that prima facie evidence indicated cruelty in transportation conditions – Held, under the proviso to Section 8(3) of the Maharashtra Animal Preservation Act, 1976, pending trial, seized cattle should be handed to an animal welfare organization [Paras 19-21].

Judicial Discretion – Relevance of Prima Facie Evidence – High Court noted the prima facie case of cruelty but did not ensure the seized cattle would be properly preserved – Supreme Court emphasized the need for careful judicial consideration of circumstances surrounding animal welfare and transportation [Paras 19-21].

Provisions of Law – Interpretation and Application – Supreme Court interpreted the amended provisions of the Maharashtra Animal Preservation Act, aligning with the legislative intent to ensure the welfare of animals pending trial – Held, High Court's direction contrary to the proviso of Section 8(3) of the Act, restoring JMFC's order [Paras 20-21].

Expeditious Trial – Welfare of Animals – Supreme Court directed that trials for offences under the Maharashtra Animal Preservation Act must be conducted expeditiously to avoid indefinite custody of animals, ensuring timely justice and welfare [Paras 22-23].

Decision: Appeals allowed – High Court’s order set aside – JMFC’s order granting custody to the appellant restored – Trial to be concluded within six months – Appellant waived claim for maintenance compensation pending trial [Paras 24-25].

Arbitration – Preliminary Inquiry – Appellant challenged the High Court’s order appointing arbitrators without determining if the dispute was arbitrable – Supreme Court held that the High Court was required to conduct a primary inquiry to ascertain if the dispute fell under Clause 36 (specific performance through court) or Clause 37 (arbitration clause) of the addendum agreement – Held, appointment of arbitrators without such inquiry was unsustainable [Paras 6, 7].

Contract Interpretation – Arbitration Clause – Supreme Court emphasized the necessity to interpret contract clauses strictly, particularly arbitration clauses – Held, disputes explicitly falling under excepted matters (Clause 36) should not be arbitrated – High Court failed to appreciate this distinction [Paras 6.1-6.4].

Judicial Review – Scope and Limits – Supreme Court reiterated principles from Vidya Drolia and others v. Durga Trading Corporation, emphasizing limited judicial review at the Section 11 stage to check and protect parties from non-arbitrable disputes – Held, prima facie review needed to determine arbitrability before referring to arbitration [Paras 6.5-6.7].

Decision: Appeals allowed – High Court’s order appointing arbitrators set aside – Matter remitted to the High Court to decide afresh, conducting a preliminary inquiry on arbitrability under Clauses 36 and 37 of the addendum agreement [Paras 7-8].

Right to Information vs. Right to Privacy – Balance of Rights – Petitioners (Banks) challenged the RBI’s directive to disclose information under RTI – Supreme Court acknowledged the conflict between the fundamental right to information and the fundamental right to privacy – Held, courts must balance these rights carefully, ensuring neither is disproportionately compromised [Paras 39-42].

Judicial Precedent – Reconsideration of Earlier Judgments – Supreme Court found the RBI directive based on the judgment in Reserve Bank of India vs. Jayantilal N. Mistry (2016) 3 SCC 525, which did not adequately consider the right to privacy – Held, it is permissible for the Court to reconsider and possibly refer such matters to a larger bench if earlier judgments did not lay down correct positions of law [Paras 39-42].

Disclosure of Information – Statutory Exemptions and Privacy – Petitioners argued that the RBI’s directive violated provisions under the RBI Act, Banking Regulation Act, and RTI Act – Supreme Court noted the necessity of protecting confidential information and the fundamental right to privacy of individuals against unwarranted disclosure [Paras 13, 14, 18-21].

Ex Debito Justitiae – Correction of Judicial Mistakes – Supreme Court cited principles of inherent judicial duty to correct mistakes to prevent gross miscarriage of justice – Emphasized no man should suffer due to court errors, reinforcing the principle of ex debito justitiae [Paras 30-32].

Decision: Writ petitions entertained – Preliminary objections rejected – Matter referred for reconsideration to ensure balanced protection of rights to information and privacy – Observations in Jayantilal N. Mistry’s case to be re-evaluated for alignment with the right to privacy as a fundamental right [Paras 43].

Rejection of Plaint – Limitation – Appellant challenged the High Court’s dismissal of revision petitions confirming trial court’s refusal to reject plaints under Order VII Rule 11(d) CPC – Supreme Court held that the respective suits were barred by limitation as they were filed 10 years after the execution of sale deeds – Held, vague allegations and clever drafting to invoke Section 17 of the Limitation Act do not suffice to bring suits within limitation period [Paras 7, 7.9].

Cause of Action – Allegations of Fraud – Supreme Court noted that mere allegations of fraud without specific details are insufficient to establish a valid cause of action – Plaintiffs' claim of discovering fraud in 2015 was deemed too vague to delay the start of the limitation period [Paras 7.7, 7.8].

Judicial Review – Exercise of Powers under Order VII Rule 11 – Supreme Court emphasized that courts must consider the averments in the plaint and determine if the suit is manifestly vexatious and meritless – Held, both trial court and High Court erred in not rejecting the plaints as barred by limitation [Paras 7.9, 8].

Decision: Appeals allowed – High Court’s judgment and trial court's orders set aside – Applications for rejection of plaints allowed – Plaintiffs' suits rejected as barred by limitation [Para 8].

Criminal Law – Conviction Based on Circumstantial Evidence – Appeal against conviction under Section 302 read with Section 34 IPC – High Court upheld trial court's decision – Supreme Court set aside the conviction – Held, reliance on voluntary statements made to police inadmissible under Section 161 Cr.P.C. and Article 20(3) of the Constitution – Lack of direct or scientific evidence linking appellants to crime – Recovery of weapon and stolen items deemed unreliable [Paras 1-88].

Evidence – Admissibility of Voluntary Statements – Statements made to police inadmissible under Section 25 of the Indian Evidence Act – Trial court's reliance on video-recorded confessions improper – High Court erred in affirming reliance on such statements – Confessional statements must be recorded before a magistrate under Section 164 Cr.P.C. to be admissible [Paras 13-24].

Recovery of Evidence – Doubtful Nature of Recovered Items – Recovery of weapon and stolen items occurred months after arrest – Independent witness to recovery turned hostile – Recovered items not conclusively linked to the crime – Court emphasized rigorous scrutiny in cases based on circumstantial evidence [Paras 8-12].

Decision: Appeals allowed – Convictions and sentences set aside – Appellants to be released unless required in connection with another case [Paras 17].

Medical Termination of Pregnancy – Scope of Rule 3B – Unmarried women are entitled to safe and legal abortion under Section 3(2)(b) of the MTP Act read with Rule 3B – The rule includes all women who face a change in material circumstances, irrespective of marital status – The exclusion of unmarried women is discriminatory and violative of Article 14 of the Constitution – Interpretation of Rule 3B must be broad and inclusive to uphold constitutional values of equality and reproductive autonomy [Paras 121-137].

Reproductive Rights – Constitutional Protection – Right to reproductive autonomy, dignity, and privacy under Article 21 extends to unmarried women – Legal interpretation should support these rights equally for married and unmarried women – Law must not be guided by patriarchal principles regarding permissible sex and family structures [Paras 100-103, 121-137].

Decision: Appeal allowed – The exclusion of unmarried women from Rule 3B of the Medical Termination of Pregnancy Rules, 2003, is set aside – Directions issued for inclusive interpretation of Rule 3B to encompass all women facing changes in material circumstances [Paras 136-137].

Civil Procedure – Review Petition – Trial Court initially rejected plaintiff's application to file a rejoinder – Plaintiff filed review petition, presenting the rejoinder was already filed – Trial Court reviewed its decision and accepted the rejoinder – High Court disapproved, stating review powers were exceeded – Supreme Court held review was justified, allowing rejoinder and permitting defendants to file sur-rejoinder if new facts are introduced [Paras 1-16].

Civil Procedure – Article 227 Jurisdiction – High Court interfered with Trial Court's procedural order under Article 227 – Supreme Court limited High Court's interference, emphasizing necessity of expeditious trial proceedings and balance in procedural operations [Paras 11-13].

Decision: Appeal allowed – Trial Court's order accepting the rejoinder reinstated with modification – Defendants permitted to file sur-rejoinder limited to new facts in rejoinder – Directions for expeditious trial proceedings reiterated [Paras 12-16].