Electricity Law – Grant of Licence – Minimum Area of Supply – Appeal against the cancellation of distribution licence – Interpretation of Section 14 of the Electricity Act, 2003, and Explanation to Rule 3 of the Distribution of Electricity Rules, 2005 – Held, 'minimum area of supply' within a municipal council or corporation does not imply the entire area but must fall within the defined boundaries – The licence granted to JSPL for an industrial park and two villages within a revenue district is valid – Interpretation should support distribution in specified areas to promote efficient electricity supply and competition [Paras 26-46].

Regulatory Compliance – Statutory Interpretation – The 'area of supply' as defined under Section 2(3) of the Act does not necessitate the entire municipal or revenue district but should be within it – Emphasis on practical application and historical permissions granted under previous laws [Paras 31-45].

Decision: Appeals allowed – The cancellation of JSPL's distribution licence is set aside – The licence granted by CSERC is reinstated with specified conditions on supply obligations [Paras 44-46].

Civil Procedure – Preliminary Issue – Limitation – Determination of Limitation as a Preliminary Issue – Issue of limitation can be framed and determined as a preliminary issue under Order XIV Rule 2(2)(b) CPC when it can be decided on admitted facts – Though limitation is a mixed question of law and facts, it becomes a question of law when foundational facts determining the starting point of limitation are clearly stated in the plaint – The Court can frame and decide the preliminary issue on limitation if it warrants postponement of settlement of other issues [Paras 1-18].

Civil Procedure – Concurrent Findings – Scope of Appeal – Concurrent findings by three courts are binding unless infected with perversity – Interference in appeal under Article 136 of the Constitution is limited to cases where the judgment is absolutely perverse [Paras 3-4].

Decision: Appeal dismissed – No perversity or illegality in the concurrent findings of the Trial Court, First Appellate Court, and High Court – Preliminary issue of limitation correctly determined based on admitted facts in the plaint [Paras 27-28].

Maintenance – Section 125 CrPC – Husband's Duty to Provide – Husband is required to earn money even by physical labor if he is able-bodied and cannot avoid his obligation except on legally permissible grounds – The Court directed the husband to pay a maintenance amount of Rs. 10,000 per month to the wife [Paras 9-13].

Social Justice – Section 125 CrPC as Social Legislation – Proceedings under Section 125 CrPC are meant to achieve social justice and prevent destitution and vagrancy – The object is to provide speedy remedy for food, clothing, and shelter to deserted wives and children [Paras 9-10].

Decision: Appeal allowed – Respondent directed to pay Rs. 10,000 per month as maintenance to appellant-wife from the date of filing the Maintenance Petition – Respondent to deposit arrears within eight weeks, adjusting any amount already paid or deposited [Paras 13-15].

Criminal Law – Conviction Based on Circumstantial Evidence – Appeal against conviction and death sentence for rape and murder – Prosecution relied solely on circumstantial evidence without medical examination of the accused – Failure to obtain Forensic Sciences Laboratory report on blood/semen stains – Prosecution’s failure to provide medical evidence critical when victim is deceased – Serious doubts raised on prosecution’s case due to lack of trustworthy ocular evidence and delay in FIR transmission [Paras 9-13, 58-68, 69-81].

Judicial Responsibility – Higher Scrutiny in Heinous Crimes – Courts must carefully assess evidence quality, especially in heinous crimes – Sessions Court and High Court failed to scrutinize contradictions and procedural lapses adequately – Injustice to the appellant due to improper investigation and judicial oversight [Paras 83-84].

Decision: Appeals allowed – Conviction and death penalty set aside – Appellant to be released forthwith if not required in connection with any other case [Para 85].

Appeal against the High Court’s decision allowing the writ petition and setting aside the cancellation of the fair price shop licence of respondent No.9.

Specific Performance – Agreement of Sale – Condition Precedent – Agreement of sale stipulated obtaining permission from ULC Authorities within 75 days, failing which the purchaser could reclaim advance payment within 90 days – Defendant terminated agreement when permission was not obtained in time – Plaintiff's delay in taking action until after permission was granted – Courts denied specific performance due to plaintiff’s inaction and stipulation in agreement [Paras 10-14].

Discretion in Granting Specific Performance – Courts’ Discretion – Time stipulations in agreements must be given significance – Rising property prices and delay by plaintiff considered – Specific performance denied but compensation awarded due to long-held advance payment [Paras 12, 15-16].

Decision: Appeal partly allowed – Specific performance denied – Respondents directed to pay Rs. 15,00,000 to appellants within 3 months [Para 16].

Necessary Party – Tests for Determination – Two tests for determining a necessary party: (1) there must be a right to some relief against such party concerning the controversies involved in the proceedings; (2) no effective decree can be passed in the absence of such a party – Plaintiff admitted the suit property was jointly owned by defendant, his wife, and three sons – Effective decree could not be passed without impleading all co-owners – Suit for specific performance dismissed due to non-joinder of necessary parties [Paras 19-21].

Specific Performance – Joint Ownership – Agreement to sell property jointly owned by defendant, his wife, and three sons – Plaintiff failed to implead all necessary parties – Courts below erred in granting specific performance without all co-owners – High Court's judgment upheld with modification for refund [Paras 19-22].

Decision: Appeals dismissed – High Court's order for refund of Rs. 30,000 with 9% interest per annum affirmed – No order as to costs [Paras 22-24].

Civil Procedure – Rejection of Plaint – Delay in Reasoning – High Court orally pronounced order rejecting plaint under Order VII Rule 11 CPC but delayed providing reasoned order – Supreme Court held this delay unacceptable, violating principles of justice – Order set aside for lack of timely reasoning – Case restored for reconsideration by the High Court [Paras 15-23].

Judicial Process – Need for Reasoned Orders – Courts must provide reasoned judgments promptly – Supreme Court referenced "Anil Rai v. State of Bihar" and "State of Punjab v. Jagdev Singh Talwandi" emphasizing timely reasoned orders to prevent prejudicing parties – Lack of reasons impedes parties' right to appeal and understand the judicial decision [Paras 9-10, 16-17].

Decision: Appeal allowed – Impugned High Court order set aside – Matter restored for reconsideration by the High Court – Chief Justice of High Court to assign case for fresh consideration – Parties to appear before Chief Justice on October 10, 2022 [Paras 24-27].

SARFAESI Act – Powers of District Magistrate – Ministerial Role – Powers exercisable by District Magistrate (DM) under Section 14 of the SARFAESI Act are ministerial – DM is not required to adjudicate disputes between the borrower and the secured creditor or any third party – High Court rightly set aside DM’s order delaying possession until tenant eviction proceedings were completed [Paras 5-8].

SARFAESI Act – Scope of Section 14 – Section 14 empowers DM to assist secured creditors in taking possession of secured assets without adjudicating rights – DM must act on a secured creditor's application for possession after verifying compliance with statutory requirements – Delay in action contradicts the Act's objective [Paras 5.1-5.2].

Decision: Special Leave Petition dismissed – High Court's order directing DM to dispose of the application under Section 14 of the SARFAESI Act upheld [Paras 6-8].