Review Jurisdiction – Scope under Section 114 and Order 47 CPC – Review Order Quashed – The Appellant sought amendment of a preliminary decree to claim her rightful share as a coparcener after the 2005 Amendment to the Hindu Succession Act – The Trial Court dismissed the plea; High Court initially allowed the revision, recognising her 1/3rd coparcenary right – In a subsequent review, the High Court reversed its prior order and remanded the matter for fresh trial – Held: The review order went beyond the permissible scope under Order 47 Rule 1 CPC by reassessing facts and reaching fresh conclusions – Review jurisdiction is limited to correcting apparent errors, not reappreciating evidence or substituting views – The High Court's review amounted to an appeal in disguise and was unsustainable [Paras 13–20].

Coparcenary Rights of Daughters – Retrospective Application of HSA 2005 – Right Recognised – Appellant, being a daughter of a coparcener alive at the time of commencement of HSA 2005, is entitled to equal share – The original preliminary decree was passed ex parte and without impleading her – She has a legitimate claim to 1/3rd share and additional share through a will – Her right is not barred by estoppel or limitation – Held: Daughter’s coparcenary right is birthright and enforceable even after preliminary decree, as final decree was yet to be passed [Paras 3–7, 10].

Jurisdictional Overreach – Review vs. Appeal – Error of Law – The impugned review order failed to identify any “error apparent on the face of the record” and instead conducted a re-evaluation of the entire case – Held: Such exercise falls outside the scope of review jurisdiction – Review order set aside; order in CRP dated 23.09.2022 restored [Paras 15–19].

Final Decision – Appeal allowed – High Court’s review order dated 19.10.2024 set aside – Order dated 23.09.2022 in CRP No. 1439 of 2019 restored – Trial Court directed to dispose of pending applications within three months [Para 20].

Section 125 of the Electricity Act - Change in Law – Pro rata allocation of coal – Sections 62 & 63, Electricity Act – Appeals dismissed – Challenge to APTEL order upholding CERC’s direction that coal supplied under firm and tapering linkage is for the station as a whole and costs of alternate coal (import/open market) due to shortfall be apportioned pro rata based on energy supplied – Held: Allocation under SLC-LT approvals/LOAs and FSA terms is plant-wide and not PPA-specific – Haryana Utilities and GRIDCO cannot claim exclusivity or priority – CERC’s methodology sustained – Appeals dismissed [Paras 31–34, 40, 45–46].

Section 125 Electricity Act – Scope confined to substantial question of law via Section 100 CPC – Judicial restraint over concurrent expert findings – Two expert bodies (CERC and APTEL) rendered concurrent, reasoned findings based on documents and policy – No perversity, arbitrariness, or statutory breach shown – Interference unwarranted [Paras 18–25].

Fuel Supply Agreements and SLC-LT decisions – Interpretation – FSA Clause 4.1.1 ties ACQ to percentage of generation under long-term PPAs – Clause 4.2 earmarks coal “for use at Power Plant (3x350 MW)” – SLC-LT minutes (14.02.2012) and LOAs (25.07.2008 and 08.07.2009) demonstrate station-level allocation including tapering linkage for all three beneficiaries – MCL clarifications confirm coal release against total PPA capacity, not segregated PPA-wise [Paras 31–33, 35].

Appropriation claim rejected – Haryana’s contention that its 300 MW must be met entirely from firm linkage and that tapering/imported coal costs fall on GRIDCO/Bihar rejected – Such reading is contrary to plant-wide allocation, would disadvantage Odisha/Bihar consumers, and violates parity among equals – Pro rata allocation avoids cross-subsidy and aligns with Energy Watchdog [Paras 32–34].

Necessary and proper party – GRIDCO not necessary party in Section 63 Change in Law proceedings – Its PPA is under Section 62 (cost-plus) with tariff determined separately – Proceedings under Sections 62 and 63 are distinct – Non-impleadment did not vitiate CERC orders – GRIDCO’s priority claim based on earlier PPA execution/COD untenable in face of plant-wide allocation [Paras 41–45].

Judicial deference to sectoral expertise – Court reiterates restraint where expert bodies have applied regulations/policy following stakeholder processes – Unwarranted appeals impose carrying costs ultimately borne by consumers – Need to curb such litigation emphasized [Paras 19–23].

Decision – Civil Appeal No. 1929 of 2020 (Haryana Utilities) and Civil Appeal No. 3429 of 2020 (GRIDCO) dismissed – APTEL judgment dated 20.12.2019 upholding CERC order dated 20.03.2018 affirmed – Payment of supplementary bills with late payment surcharge as per PPA sustained [Paras 40, 45–46].

Motor Accident Claim – Causal Connection Between Accident and Death – Claim Rejected - The deceased, an Excise Guard, died of pulmonary embolism five months after sustaining leg and finger fractures in a road accident – Supreme Court upheld High Court’s finding that there was no proximate or direct causal link between the accident and death – Held: Death not attributable to accident injuries; post-surgical complications with pre-existing diabetes and hypertension more likely cause [Paras 1-11].

Expert Evidence – Doctor’s Testimony Inconclusive – Medical Opinion Favoured Natural Cause - PW-1, the plastic surgeon, opined the death was due to myocardial infarction, and though stated long bed rest could trigger embolism, he admitted to no post-mortem and acknowledged cardiac risk factors – Held: Absence of conclusive medical evidence and lack of post-mortem weakens claimants’ case; expert's deposition supported natural medical cause [Paras 6-7].

Preponderance of Probability – Not Established – No Clear Nexus Between Injury and Death - Supreme Court reiterated that even in civil cases requiring lesser standard of proof, the causal connection must meet preponderance of probability – Held: Injuries were not serious; death occurred after successful skin grafting – No evidence of extended immobility or bed rest [Paras 8-11].

Final Disposition – High Court Judgment Affirmed – Claim for Death Compensation Denied - Tribunal’s finding of causality reversed by High Court based on medical evidence – Supreme Court declined to interfere, holding the reasoning sound and based on expert medical testimony – Held: No compensation payable for death; claimants still entitled to compensation for injuries [Paras 11-12].

Motor Accident Claim – Functional Disability – Medical Board Certificate – Acceptance Limited - Claimant suffered hemipelvectomy and produced 90% disability certificate – Supreme Court accepted the medical evidence but held that for compensation purposes, 50% functional disability was rightly assessed by High Court based on actual earning capacity and use of prosthetic limb – Held: Functional disability determines loss of income, not the medical percentage per se [Paras 7-8].

Loss of Income – Income Tax Returns Accepted – Estimation Based on Documentary Evidence - The Court found that income tax and sales tax returns submitted prior to the accident could not be disregarded – Held: Income of ₹1,91,000 (net of tax) for 2007-08 accepted; applying multiplier of 18 and 50% disability, total loss of income calculated at ₹17,19,000 [Paras 8-9].

Future Prospects – No Addition Permitted – Functional Earning Capacity Sufficient - The claimant, fitted with a prosthetic limb, could continue his business and did not require enhancement for future prospects – Held: 40% addition for future income prospects disallowed, as loss already compensated through disability-based income loss [Para 9].

Medical Expenses – Full Reimbursement Allowed – Lack of Reasoning by Lower Courts Cured - Tribunal awarded ₹3.39 lakh and High Court increased to ₹8 lakh without reasoning – Supreme Court allowed full ₹12.54 lakh based on vouchers submitted – Held: Entire verified medical expense payable in absence of valid rebuttal by insurer [Para 10].

Future Medical Expenses – Replacement of Prosthetic Limb – Additional Compensation Awarded - Recognizing that prosthetic limbs need periodic replacement and servicing, though no authenticated receipts were filed, the Court granted ₹10 lakh towards future medical needs – Held: Compensation must include realistic provision for ongoing disability management [Paras 12].

Compensation Recalculated – Enhancements Over High Court Award - Supreme Court restored ₹1 lakh for attendant expenses and ₹4.70 lakh for initial prosthetic limb purchase omitted by High Court – Combined total compensation recalculated and awarded at ₹48,44,790 with 6% interest from date of application, after deducting amounts already paid [Paras 11, 13-14].

Criminal Trial – Transfer of Case – Allegations Against Presiding Officer – Transfer Directed - The petitioner sought transfer of his pending trial from the current Presiding Officer alleging lack of fairness and transparency – The Delhi High Court rejected the transfer plea – On hearing the Special Leave Petition, the Supreme Court invoked its powers to direct the Principal District and Sessions Judge, Shahdara, to either retain the matter on his own file or assign it to another Court of equivalent jurisdiction – Held: To ensure impartiality and protect the fairness of trial, transfer ordered without expressing any opinion on allegations – Allegations against judicial officer to be unconditionally withdrawn by petitioner [Paras 2-5, 10].

Expeditious Trial – Directions to Trial Court – Three-Month Deadline – The Supreme Court directed the transferee Court to complete the trial within three months from the date of transfer – The parties were instructed to cooperate fully, and in case of non-cooperation, the Court concerned may take strict steps as per law – The State assured full cooperation in production of witnesses – Held: Trial Court must adhere strictly to the fixed timeline and manage its calendar accordingly [Paras 7-9].

Conduct of Litigants – Allegations Against Judicial Officers – Unconditional Withdrawal – During proceedings, the petitioner was queried about the allegations against the trial Judge – Petitioner’s counsel unconditionally withdrew the same and undertook not to make such insinuations in future – Held: Supreme Court accepted the withdrawal and cautioned parties to maintain decorum in judicial proceedings [Paras 10-11].

Decision – SLP Disposed – Transfer and Time-Bound Trial Ordered – In view of the agreement between the parties and interest of justice, the SLP was disposed with specific directions for transfer and expeditious disposal – Registry was directed to communicate the order to the District Judge concerned – Held: No opinion expressed on merits; matter disposed with procedural directions to ensure fair trial [Paras 5-6, 12-15].

Anticipatory Bail – Allegations of Rape and Sexual Assault – IPC Sections 376(1), 377, 354A – Bail Granted - The appellant, alleged to be a spiritual leader, was accused of sexually exploiting a married woman and others – The FIR was lodged after delay, and the High Court had rejected anticipatory bail – Supreme Court noted earlier grant of interim protection and found the case suitable for anticipatory bail – Held: Order of High Court set aside; anticipatory bail granted with conditions including cooperation in investigation and restraint from tampering with evidence [Paras 1-3].

False Implication – Allegations of Conspiracy and Blackmail – Delay in Filing FIR - Appellant contended that the complainant and her husband fabricated the case using videos to create false evidence for ulterior motives – Further claimed the relationship was consensual – Held: Without commenting on merits, Supreme Court found grounds sufficient for anticipatory bail as the FIR was belated and under suspicious circumstances [Paras 2-3].

Serious Allegations – Accused as Spiritual Leader – Court Balances Liberty and Investigation – The complainant alleged that the appellant misused his position as a godman to exploit women – The Court recognized the seriousness but emphasized liberty and fair process – Held: Conditional anticipatory bail appropriate; liberty not to be misused, and any breach would lead to cancellation [Paras 2-3].

Decision – Appeal Allowed – Anticipatory Bail Granted – The Supreme Court set aside the Bombay High Court’s order and granted anticipatory bail on furnishing ₹25,000 cash security with two sureties – Directions issued for cooperation and non-interference with evidence – Held: Non-compliance would lead to cancellation of bail [Para 3].

PIL - Anand Karaj marriages—Section 6, Anand Marriage Act—States/UTs directed to notify rules within 4 months—Till then, registration to be facilitated under existing marriage registration frameworks without discrimination—Union of India to coordinate and file compliance report—Petition disposed with time-bound directions [Paras 11–16].

Constitutional Duty – Registration of Marriages – Section 6 of the Anand Marriage Act imposes a positive duty on States to establish registration machinery for Anand Karaj marriages – Duty not optional or contingent on population size – Non-notification frustrates legislative intent of 2012 amendment [Paras 7–8].

Civil Consequences of Registration – Marriage certificates enable proof of status for residence, maintenance, inheritance, succession, and enforcement of monogamy – Particularly safeguard rights of women and children – Unequal access across jurisdictions violates equal treatment [Para 9].

Harmonisation with Existing Frameworks – Until rules are notified, general marriage registration frameworks must accept Anand Karaj marriages on the same footing as other marriages – Certificate to record that marriage was solemnised by Anand Karaj where parties so request [Para 10].

General Directions – (i) All States/UTs without rules to notify within 4 months; (ii) immediate registration under existing laws without discrimination; (iii) States with rules to issue clarifications within 3 months; (iv) Nodal officer to be designated within 2 months; (v) Union of India to coordinate and circulate model rules, and file consolidated status report in 6 months [Para 12].

Special Directions – Goa: Interim registration under civil registration offices; Union to extend Anand Marriage Act within 4 months; Goa to frame rules within 4 months thereafter [Para 13]. – Sikkim: Interim registration under 1963 Rules; Union to consider extension under Article 371F(n); Sikkim to notify rules within 4 months after extension [Para 14].

Decision – Writ petition disposed of with directions—Time-bound rule-making mandated—Interim facilitation under existing frameworks ordered—Compliance affidavits to be filed by States/UTs; Union to file consolidated status report in 6 months [Paras 15–16].

Anticipatory Bail – Modification During SLP Pendency – High Court's Jurisdiction Restrained – Stay Issued - The petitioners challenged the anticipatory bail granted to respondent no. 1 in 31 criminal cases related to financial fraud – Despite pendency of SLP, the High Court permitted modification of bail condition allowing travel abroad – Held: Such modification during pendency of appeal before Supreme Court is impermissible and violates judicial discipline – Orders dated 12.08.2025 and 23.08.2025 stayed [Paras 1-11].

Judicial Discipline – High Court Should Exercise Restraint During Pendency of SLP – Doctrine Clarified – Supreme Court reiterated that once an SLP is admitted and notice issued, High Courts must not pass orders that may circumvent or frustrate the proceedings before the apex court – Held: Proper administration of justice demands mutual respect between courts in a hierarchical system – Precedents from Tirupati Balaji Developers and Chhavi Mehrotra relied upon to reinforce judicial propriety [Paras 8-10].

Concealment of Material Facts – Conduct of Accused Under Scrutiny – Show Cause Issued - Respondent No. 1 failed to inform the Supreme Court of filing applications before the High Court for modification of bail terms – Affidavit filed before Supreme Court omitted this material fact – Held: Court expressed grave displeasure and issued notice to explain why anticipatory bail should not be cancelled for suppression of facts [Paras 12-13].

Passport and Travel Restriction – Interim Direction – Supreme Court Mandates Compliance - In view of pending investigation in 31 criminal cases, the Court directed respondent no. 1 to immediately surrender her passport and not to leave India without prior permission – Held: Travel restriction reinstated pending further hearing [Para 15].

Anticipatory Bail – Withdrawal of Previous Applications – Co-Accused Already Granted Bail – Relief Granted - The appellant's anticipatory bail was denied by the High Court solely on the ground that he had earlier withdrawn similar applications – The Supreme Court noted that co-accused were granted bail and had already extended interim protection to appellant – Held: Interim protection confirmed; anticipatory bail granted – Arresting authority directed to release on bail if arrested, subject to Trial Court's terms [Paras 2-4].

Subsequent FIR – Interim Protection Already Secured – No Bar to Current Bail Relief - State submitted that a fresh FIR under Bharatiya Nyaya Sanhita, 2023, was registered against appellant during pendency – The appellant clarified he had secured interim protection in that case from the Sessions Court – Held: Existing relief not affected by subsequent FIR; future applications to be decided independently on merits [Paras 5, 7].

Cooperation in Investigation – Liberty to Cancel Bail If Violated – Investigative Balance Maintained - The Court emphasized that the appellant must cooperate fully with the investigation – Held: Non-cooperation would entitle the State to seek cancellation of bail from Trial Court [Para 6].

Final Disposition – Appeal Allowed – Bail Granted – Appellate Court Clarified Scope of Order - The Court clarified that its order granting bail in this case would not influence other proceedings or applications of the appellant pending elsewhere – Held: Appeal disposed with protection to liberty and due process [Paras 7-8].