Motor Vehicles Act, 1988 – Insurance Company – Right to Contest Claim – Quantum of Compensation – Issue whether insurer, when impleaded as a party-respondent in a claim petition, can challenge the award on all available grounds including quantum without restriction to Section 149(2) – Held: Once insurer is impleaded as a party, it is entitled to contest the claim on all grounds and is not confined to defences under Section 149(2) of the Act [Paras 7–7.3].

Section 170, Motor Vehicles Act, 1988 – Permission to Contest on Merits – Rejection by Tribunal – Application filed by insurer under Section 170 rejected by Tribunal – High Court refused to consider challenge to quantum – Held: Rejection of Section 170 application does not bar insurer from contesting claim when it is already impleaded as a party – Such rejection can always be assailed along with final adjudication [Paras 7.3, 7.4].

Precedent – Binding Nature of Three-Judge Bench Decision – Reliance placed on United India Insurance Co. Ltd. v. Shila Datta – Held: Law laid down by three-Judge Bench is binding – Any contrary view of a smaller Bench has no precedential value – Shila Datta authoritatively settles that insurer impleaded as respondent can contest claim on all grounds [Paras 4, 7].

Motor Accident Claims – Assessment of Income – Quantum – Insurer alleged collusion between parties and improper proof of income of deceased seaman drawing salary in foreign currency – High Court failed to examine quantum on merits – Held: Error in law in depriving insurer of opportunity to contest assessment of compensation [Paras 4, 7.4].

Appellate Jurisdiction – Remand – Impugned judgment of High Court set aside – Matter remitted to High Court for fresh consideration on issue of quantum of compensation – Both parties to be afforded opportunity of hearing – Amount already released to claimant to remain subject to final outcome [Paras 8–9].

Delay – Expeditious Disposal – Accident occurred more than 15 years ago – High Court requested to expedite hearing of appeal on remand [Para 9].

Decision: Appeal allowed – Impugned judgment of High Court set aside – Matter remitted to High Court for fresh decision on quantum of compensation – Pending applications disposed of.

Arbitration – Section 11(6A) – Arbitrability of Disputes – Leave and License Agreement – Monetary Claims – Arbitrator Appointment – Exclusive Jurisdiction of Small Causes Court under Section 41 of 1882 Act – Valid Arbitration Clause Not Rendered Inoperative by Statutory Bar – Clause 33 of Agreement Held to Exist and Operative – High Court Rightly Appointed Arbitrator – Appeal Dismissed – Dispute arose from a Leave and License Agreement for premises in Malad, Mumbai – Appellant terminated the agreement and claimed refund of security deposit – Respondent claimed arrears of license fees for the lock-in period – Arbitrator appointed under Section 11, Arbitration Act – Appellant objected citing Section 41 of the Presidency Small Cause Courts Act, 1882, contending exclusive jurisdiction of Small Causes Court – Held: Court under Section 11(6A) to only examine the existence of arbitration agreement – Clause 33 validly provides for arbitration – Dispute on nature of claim (debt vs. license fee) to be determined by arbitral tribunal under Section 16 – Reliance on Central Warehousing judgment distinguished based on facts – Arbitration clause not rendered non-existent by Section 41 of 1882 Act – Appeal dismissed – Arbitrator to conclude proceedings in 6 months [Paras 1-28].

Environmental Law – Aravalli Hills and Ranges – Uniform Definition – Mining Activities – Ecological Protection – Court noted long-standing ecological significance of Aravallis as “green lungs” of North-Western India and impact of unchecked urbanisation and mining – Divergent definitions adopted by States led to regulatory inconsistencies – Court earlier directed constitution of an expert Committee to evolve a uniform definition – Committee’s report defining Aravalli Hills on elevation criteria of 100 metres and Aravalli Range on proximity of 500 metres accepted in judgment dated 20.11.2025 – Directions issued prohibiting new mining leases pending preparation of a Mining Plan for Sustainable Mining (MPSM) [Paras 1–6].

Environmental Governance – Expert Committee Report – Judicial Review – Post-judgment Challenges – Multiple IAs and applications filed questioning scientific basis of the adopted definition and its implications – Court observed prima facie ambiguity and lack of clarity in the Committee Report and earlier judgment, particularly regarding ecological continuity, exclusion of low-lying hills, and possible regulatory gaps enabling unregulated mining – Public concern and criticism by environmentalists taken note of by Court [Paras 7–8].

Precautionary Principle – Need for Independent Expert Assessment – Court held that before implementation of Committee recommendations and earlier directions, an independent, impartial, high-powered expert opinion is necessary – Issues framed relating to narrowing of protected areas, treatment of inter-hill gaps beyond 500 metres, accuracy of elevation-based exclusion of hills, and long-term ecological consequences – Court proposed constitution of a High-Powered Expert Committee to undertake comprehensive scientific and ecological evaluation [Paras 9–10].

Mining Ban – Interim Protection – Aravalli Region – Exercise of Powers under Articles 32 and 142 – To prevent irreversible environmental harm, Court stayed implementation of Committee Report and judgment dated 20.11.2025 – Directed that no new mining leases or renewal of old leases shall be granted in Aravalli Hills and Ranges as defined in the FSI Report dated 25.08.2010 without prior permission of the Court – Stay to continue till further orders [Paras 12–13].

Decision:

Notice issued to Union of India and States of NCT of Delhi, Rajasthan, Haryana and Gujarat – Matter directed to be listed before the Green Bench – Recommendations of Committee and earlier judgment dated 20.11.2025 kept in abeyance – Absolute interim prohibition on grant or renewal of mining permissions in Aravalli Hills and Ranges without leave of Court – Ordered accordingly [Paras 11–14].

Environmental Law – Endangered Species – Habitat Conservation – Protection of the Great Indian Bustard (GIB) – Petition under Article 32 sought urgent directions for the conservation of critically endangered GIB and LF species – Court affirmed the Expert Committee’s recommendation to designate revised priority areas in Rajasthan (14,013 sq. km) and Gujarat (740 sq. km) – Mitigation measures for conservation including habitat restoration, creation of enclosures, and predator control accepted – Ordered immediate implementation of in-situ and ex-situ conservation strategies, supported by long-term climate monitoring [Paras 1–6, 24–26, 32, 76].

Renewable Energy – Power Infrastructure – Undergrounding and Mitigation – Blanket prohibition on overhead transmission lines lifted by Court’s March 2024 order – Expert Committee formed to assess area-specific solutions – Court accepted recommendations for undergrounding or rerouting powerlines (66kV and above), creation of powerline corridors, and limited exemptions for 11kV and below – Ordered that critical 250 km lines in Rajasthan be undergrounded within 2 years [Paras 14, 24, 44, 71, 76].

Bird Flight Diverters (BFDs) – Efficacy and Scientific Scrutiny – Petitioners sought mandatory BFDs across all existing/future lines – Expert Committee concluded their efficacy for bustards is unproven and recommended pilot study by WII – Court agreed and directed Wildlife Division, MoEFCC to evaluate effectiveness through scientific studies and pilot projects before large-scale implementation [Paras 60–63, 76].

Corporate Environmental Responsibility – Expansion of CSR – Supreme Court declared that Corporate Social Responsibility (CSR) under Section 135 of the Companies Act must include "Corporate Environmental Responsibility" – Affirmed that CSR funds can and should be used for GIB conservation – Ecocentric interpretation of statutory duties emphasized – Recognized corporations as duty-bearers under Article 51A(g) of the Constitution [Paras 35–40].

Public Interest vs. Development – Balancing Sustainability and Biodiversity – Court upheld the Committee’s calibrated approach balancing India’s climate commitments with species conservation – Restrictions on new solar projects (>2MW), new wind turbines, and overhead lines in Revised Priority Areas affirmed – Site-specific case-by-case mitigation adopted in lieu of blanket bans [Paras 14–15, 65–67, 76].

Decision: Writ Petition and Civil Appeal allowed in part – Expert Committee’s revised priority area designations accepted – Committee recommendations on conservation and mitigation to be implemented – 250 km of critical lines to be undergrounded within 2 years – Petitioners’ additional requests (such as expanding area to include Rasla enclave) rejected – All authorities directed to optimize transmission line corridors, enforce restrictions, and conduct further study on BFD efficacy [Paras 76–77].

Criminal Law – Quashing of Complaint – Jurisdiction under Section 482 CrPC – High Court quashed complaint under Section 138 N.I. Act holding that the cheque was not issued for any debt or liability – Held: The High Court exceeded its jurisdiction by examining disputed facts at pre-trial stage and conducting a roving enquiry into the existence of debt/liability – Complaint disclosed all essential ingredients of Section 138 – Prima facie case made out – Quashing was impermissible [Paras 5, 8, 11-13, 18].

Negotiable Instruments – Presumption under Section 139 – High Court not justified in rebutting statutory presumption of debt at threshold stage – Presumption under Section 139 includes legally enforceable debt – Can only be rebutted during trial – Trial is the proper stage to raise such defence – Complaint could not be quashed merely on the plea that no debt existed [Paras 13-15, 18].

Precedents – Application of Legal Principles – Court reaffirmed principles laid down in Maruti Udyog Ltd. v. Narender, Rangappa v. Sri Mohan, Rajeshbhai Muljibhai Patel v. State of Gujarat, and Rathish Babu Unnikrishnan v. State (NCT of Delhi) – Interference at threshold discouraged when presumption exists and trial stage is yet to commence [Paras 14-17].

Decision: Appeal allowed – Order of High Court quashing the complaint set aside – Criminal complaint restored on file of Magistrate to be decided as per law – No opinion expressed on merits of cheque issuance [Paras 19-20].

Criminal Law – Murder – Reversal of Acquittal – High Court reversed acquittal of five accused (A-1 to A-4 and A-10) and sentenced them to life imprisonment under Section 302 read with Section 34 IPC – Conviction based on consistent eyewitness testimony, corroborated by medical and forensic evidence, and supported by circumstantial links such as weapon recovery and sniffer dog trail – FIR registered promptly and attributed overt acts to main accused – Delay in FIR reaching Magistrate held to be satisfactorily explained – Trial court’s findings found to be speculative and based on illusory contradictions [Paras 2, 4-5, 40-45, 48-51].

Eyewitness Testimony – Related Witnesses – Credibility – PWs 1 and 2 (brother-in-law and brother of the deceased) found to be natural and reliable witnesses – Their failure to intervene during the fatal attack justified due to real threat of harm – Minor inconsistencies treated as non-fatal – Court reaffirms duty to sift grain from chaff in witness testimony, especially in Indian context [Paras 34-38, 40, 46].

Medical Jurisprudence – Post-Mortem Report – Eleven incised and lacerated wounds recorded, including severed wrist and deep neck wounds – Medical evidence corroborated oral evidence of PWs 1 and 2 and FIR – Timing of post-mortem ruled out possibility of FIR manipulation – Defence’s argument regarding absence of rolling injuries found to be irrelevant embroidery [Paras 5, 43-44, 48, 50].

Circumstantial Evidence – Recovery of Weapons – Ninja chain and 9 sickles recovered pursuant to disclosure – Sniffer dog tracing to A-4’s house – Physical evidence supports premeditated attack and shared common intention – Motive proved through prior feuds and earlier FIRs [Paras 5, 27, 41, 47].

Appellate Jurisdiction – Interference with Acquittal – High Court’s approach upheld – Trial court's acquittal held to be based on erroneous appreciation of evidence – No perversity in findings of High Court – Conviction upheld by Supreme Court [Paras 6-7, 32, 51-52].

Decision: Appeals dismissed – Conviction and life sentences of A-1 to A-4 and A-10 upheld – No ground for interference found by Supreme Court.

Criminal Law – IPC and ITPA - Child Trafficking – Minor Victim – Commercial Sexual Exploitation – Appellant convicted for keeping minor girl in rented premises for prostitution – Decoy operation by NGO workers led to rescue of minor – Testimony of minor victim (PW-13) found credible, consistent, and corroborated by witnesses PW-8, PW-11, PW-12 and seizure of condom and marked currency – Defence’s denial of relationship with victim rejected – Held: Offences under IPC and ITPA proved beyond reasonable doubt [Paras 3–6, 8–13].

Victim Testimony – Appreciation of Evidence – Supreme Court lays out principles for evaluating testimony of trafficked minors – Emphasized need for latitude and sensitivity due to victim’s socio-economic vulnerability, fear, trauma, and organised nature of crime – Held: Victim is not an accomplice – Sole credible testimony of minor victim sufficient for conviction – Reliance placed on State of Punjab v. Gurmit Singh [Para 11].

Juvenile Justice – Determination of Age – Victim’s age proved as 16 years 6 months based on school certificate (Ex. P-3) issued by PW-7 (Headmaster) – Court reaffirmed that school records prevail over medical opinion – Ossification test not mandatory when documentary proof exists – Relied on Jarnail Singh v. State of Haryana [Para 14].

Procedural Law – ITPA – Validity of Search – Compliance with Section 15(2) – Objection raised regarding absence of respectable woman from locality during raid – Court held that decoy witnesses (PW-8 and PW-12) were credible, and PW-14 (owner’s wife) was approached – Her hostility does not vitiate compliance – Reiterated that non-compliance with S. 15(2) is irregularity, not illegality, unless it causes prejudice – Conviction sustained [Paras 15–18].

Decision: Appeal dismissed – Conviction and sentence under IPC and ITPA upheld – Statutory provisions substantially complied with – Testimony of victim reliable and corroborated – No interference warranted with concurrent findings of courts below [Para 19].

Criminal Law – Recalling Witness – Section 311 CrPC – High Court set aside Trial Court’s refusal and allowed examination of minor child (daughter of deceased) after 7 years of incident – Held: Discretion under Section 311 CrPC is wide but must be exercised sparingly – Evidence must be essential to just decision of case – In absence of proof of child being present during incident, her proposed testimony is speculative – Trial Court's rejection restored [Paras 3.4, 5, 10.1–10.3, 11–12]

Child Witness – Reliability – Memory and Suggestibility – At time of incident, child was under 5 years old and is now about 11 – No contemporaneous statement recorded – Court held that memory of such tender age is vulnerable to distortion – Continuous residence with maternal grandparents creates apprehension of tutoring – Testimony would be unreliable and prejudicial to defence [Paras 3.5, 7, 10.2]

Evidence Law – Section 118 Indian Evidence Act – Competency of minor witness – Though legally competent, credibility must be judicially assessed – Court emphasized evidentiary value and not mere admissibility – Permitting examination after 21 witnesses would cause delay and prejudice [Paras 5, 10.3]

Trial Management – Protraction of Trial – Late-stage introduction of speculative witness without disclosure in FIR or charge-sheet undermines fairness – Section 311 not intended for strategic supplementation of prosecution case – High Court erred in overruling considered Trial Court discretion [Paras 3.3, 9–11]

Decision: Appeals allowed – High Court’s order dated 27/11/2024 set aside – Trial Court’s order dated 30/03/2024 restored – Prosecution not permitted to examine minor child witness – Trial to proceed as per law.

Service Law – Regularization – Ad-hoc Appointments – Discrimination – Appellants appointed to Class III posts in High Court as Operator-cum-Data Entry Assistants under powers of Chief Justice – Though similarly situated persons were regularized, appellants denied such benefit citing their appointments were ad-hoc – Held: All categories of appointees were appointed through same channel under Rules 8(a)(i), 41 and 45 of 1976 Rules – Mere difference in wording of appointment orders not sufficient ground to treat them differently – Distinction drawn by administrative committee was arbitrary and violated Article 14 – Directions issued under Article 142 for reinstatement and regularization [Paras 23–28, 30–34].

Constitutional Law – Article 14 – Equal Treatment – Arbitrary Discrimination – Supreme Court held that all appointees appointed through same legal authority and performing same duties must be treated equally – Classification based on labels such as "ad-hoc" or absence of examination clause in appointment letters is irrational when nature of work and source of power are identical – Denial of regularization violated principles of non-arbitrariness [Paras 24–29].

Constitution of India – Article 142 – Complete Justice – Appellants rendered over a decade of service before discontinuation – Supreme Court invoked Article 142 to restore their services and direct regularization with consequential benefits (excluding back wages), overriding technical objections of procedural limitations or rule amendments – Relief restricted to facts of this case [Paras 33–36].

Decision: Appeals allowed – Impugned High Court orders set aside – Appellants to be reinstated and regularized with all consequential benefits (excluding salary for non-working period) – Compliance directed within 8 weeks – Relief not to be treated as precedent [Paras 34–36].