Criminal Procedure – Anticipatory Bail – Scope and Limitations – Section 438 CrPC: The Supreme Court emphasized that when dealing with an application under Section 438 CrPC, the court must confine itself to determining whether the applicant has made out a case for anticipatory bail. Any conditions imposed must be appropriate, apposite, reasonable, and relevant to the scope of the matter before the court. The High Court erred by issuing a peremptory direction affecting a third party (the appellant) without providing notice or an opportunity to be heard, which was not justified​​.

Due Process – Impact on Livelihood – Necessity of Notice: The Court held that any order affecting an individual's livelihood must be passed with due process, including providing notice and an opportunity to be heard. In this case, the High Court’s direction to cancel the appellant's authorization as a post office agent without such process was deemed unjustified, impacting her civil rights and livelihood adversely​​.

Judicial Overreach – Scope of Orders in Bail Applications: The Court underscored that orders in bail applications should not extend to matters beyond the immediate issues of the bail application itself. The High Court's direction in this case constituted judicial overreach, as it ventured beyond the confines of the bail application to impose a penalty on a non-party without due process​​.

Decision: The Supreme Court allowed the appeal, setting aside the direction of the High Court that ordered the cancellation of the appellant's license/authorization as a post office agent. The impugned order was modified to vacate the said direction​​.

Arbitration Agreement – Absence – Section 11(6) of the Arbitration and Conciliation Act, 1996: The Supreme Court held that there was no valid arbitration agreement between the parties. Clause 15 of the Contract Agreement, titled "Settlement of Disputes/Arbitration," did not constitute an arbitration agreement as it lacked the essential attributes of such an agreement as outlined in Section 7 of the 1996 Act. The invocation of the jurisdiction of the High Court under Section 11(6) was therefore not valid​​.

Contractual Terms – Interpretation – Clause 15: Clause 15 of the Contract Agreement was interpreted as a dispute resolution mechanism at the company level rather than an arbitration agreement. It directed disputes to be settled initially at the company level and, if differences persisted, disputes involving government agencies were to be dealt with as per government guidelines, while disputes with other parties were to be resolved in a court of law. This clause did not reflect an intention to refer disputes to arbitration​​.

Policy Documents – CIL Communication Dated 7 April 2017: The communication from Coal India Limited (CIL) suggested a desire for disputes related to work contracts to be settled through arbitration, but required a further agreement between the parties to proceed with arbitration. This communication could not be construed as an arbitration agreement under Section 7 of the 1996 Act​​.

Decision: The Supreme Court allowed the appeal, setting aside the order of the High Court which had appointed a sole arbitrator. It was held that there was no arbitration agreement between the parties, and thus, no reference to arbitration could be made. The respondent was granted the liberty to seek recourse to other legal remedies available for the redressal of its grievances​​.

Consumer Protection – Insurance Claim – IMT 47 – Exclusion Clause: The Supreme Court held that the exclusion clause under IMT 47 of the insurance policy did not apply as the loss was due to a landslide causing the vehicle to fall into a deep ditch, and not due to the overturning of the vehicle while being used as a tool. The insurer was directed to pay the compensation as the landslide was covered under the policy terms​​.

Concurrent Findings – Revisional Jurisdiction – Section 21(b) of the Consumer Protection Act, 1986: The NCDRC overstepped its revisional jurisdiction by reappreciating facts and reversing concurrent findings of the District Forum and SCDRC. The Supreme Court reiterated that revisional jurisdiction is limited and should not interfere with concurrent findings of fact unless there is a failure of justice or misapplication of law​​.

Insurance Policy – Coverage of Loss – Interpretation of Terms: The policy covered loss due to landslides under Section I, which lists perils covered including landslides/rockslides. The Supreme Court emphasized that the damage was due to the collapsing of the road, not overturning while in operation as a tool, thus IMT 47's exclusion was inapplicable​​.

Decision: The Supreme Court allowed the appeal, setting aside the NCDRC's judgment and restoring the SCDRC's order, which directed the insurer to pay Rs. 13.50 lakhs to the appellant along with interest. The insurer was found liable for the loss due to landslide as covered under the insurance policy​​.

Service Law – Rejection of Candidature – Use of Different Languages in Application and OMR Sheet: The Supreme Court upheld the rejection of the respondent’s candidature for using different languages in the application form (English) and the OMR answer sheet (Hindi), which violated the advertisement instructions. This was deemed a significant procedural requirement intended to verify the identity of the candidate and maintain probity in the recruitment process​​.

Procedural Compliance – Importance of Following Prescribed Procedures: The Court reiterated the principle that when a procedure is prescribed by law, it must be followed as specified. Deviations from such procedures, even if seemingly minor, can result in the invalidation of the process. In this case, the respondent's failure to follow the prescribed language requirement led to the rejection of his candidature​​.

Judicial Review – Limits in Interfering with Administrative Decisions: The judgment emphasized that courts should not interfere with administrative decisions unless there is a clear violation of law or procedural fairness. The High Court’s decision to set aside the rejection of candidature was found unjustified, as the respondent’s non-compliance with application instructions was evident​​.

Decision: The Supreme Court allowed the appeal, setting aside the High Court's decision and dismissing the writ petition. The respondent's candidature was rightly rejected due to the violation of the advertisement’s instructions regarding the language to be used in the application form and the OMR answer sheet​​.

Arbitration Law – Appointment of Arbitrator – Territorial Jurisdiction – Section 11(6) of the Arbitration and Conciliation Act, 1996: The Supreme Court held that the High Court of Orissa at Cuttack lacked jurisdiction to entertain the application under Section 11(6) of the Arbitration and Conciliation Act, 1996, for the appointment of an arbitrator since the respondent-claimant had earlier initiated arbitration proceedings under Section 9 of the Arbitration Act in the Court at Visakhapatnam. Consequently, only the High Court of Andhra Pradesh at Amaravati had jurisdiction over subsequent applications arising out of the same agreement​​.

Section 42 of the Arbitration and Conciliation Act, 1996 – Jurisdiction: The Supreme Court emphasized the relevance of Section 42, which stipulates that once a court is approached for any application under the Arbitration Act, only that court shall have jurisdiction over all subsequent applications related to the arbitration agreement. Since the respondent had first filed an application under Section 9 in Visakhapatnam, the jurisdiction remained with the High Court of Andhra Pradesh at Amaravati​​.

Procedural Law – Importance of Jurisdiction – Ensuring Proper Legal Processes:

The Supreme Court underscored the significance of adhering to jurisdictional mandates as specified under statutory provisions. The High Court of Orissa at Cuttack's decision to appoint an arbitrator was invalidated due to lack of jurisdiction, reinforcing the principle that statutory directives regarding jurisdiction must be strictly followed to ensure orderly legal processes​​.

Decision: The Supreme Court allowed the appeal, setting aside the order of the High Court of Orissa at Cuttack which appointed an arbitrator under Section 11(6) of the Arbitration and Conciliation Act, 1996. The respondent-claimant was granted liberty to move an application under Section 11(6) before the High Court of Andhra Pradesh at Amaravati within four weeks, to be considered on its own merits and in accordance with law​​.

Service Law – Post Graduate Medical Courses – In-Service Quota – Eligibility: The Supreme Court held that there is a clear distinction between junior resident doctors who completed their undergraduate medical courses at ESIC institutions and regularly recruited Insurance Medical Officers (IMO-II). The in-service quota for postgraduate medical courses is justifiably reserved for regularly recruited IMO-II doctors and not for junior resident doctors serving under a bond​​.

Institutional Preference – Postgraduate Medical Education – Legal Validity: The Court reiterated that institutional preference in postgraduate medical admissions is permissible and constitutional as upheld in previous judgments (Pradeep Jain v. Union of India and Saurabh Chaudri v. Union of India). However, the decision to provide such institutional preference lies within the policy realm of the respondent-authority and cannot be mandated by the Court​​.

Difference in Recruitment and Employment Nature: Junior resident doctors are appointed on a contractual basis to fulfill bond conditions after completing their undergraduate courses, whereas IMO-II doctors are recruited through a formal selection process and serve as permanent employees. This fundamental difference justifies the reservation of the in-service quota for the latter category​​.

Decision: The Supreme Court dismissed the petition, holding that junior resident doctors cannot claim parity with regularly recruited Insurance Medical Officers (IMO-II) for the benefit of the in-service quota for postgraduate medical courses. The in-service quota is reserved for IMO-II doctors due to their permanent employment status and continued service in ESIC institutions post their postgraduate studies​​.

Public Trusts – Misappropriation of Government Properties – Inquiry through Economic Offences Wing: The Supreme Court held that there was no warrant to direct an inquiry through the Economic Offences Wing of the State Government as there was no finding of mens rea on the part of the trustees. The High Court did not record any finding based on material that the alienation made by the trustees resulted in causing loss to the trust or that the entire sale consideration was diverted for personal use. The entire consideration received from the purchasers was credited to the account of the trust. Allegations of misappropriation should be examined by authorities under the Public Trusts Act, not through the Economic Offences Wing. The High Court's direction was based on an erroneous assumption of misappropriation of government properties without any registered offence against the trustees​​.

Public Trusts – Applicability of Public Trusts Act – Khasgi Trust Properties-The Court emphasized that the Khasgi Trust is governed by the Madhya Pradesh Public Trusts Act, 1951. The trustees’ authority to alienate trust properties without permission was limited by Section 14 of the Act, which requires prior sanction from the Registrar for any sale, mortgage, exchange, or gift of immovable property. The Trust, being a public trust, is subject to the regulatory framework of the Act​​.

Trust Deed – Interpretation and Legal Implications: The Trust Deed executed in 1962 and the supplementary deed of 1972, which included a clause allowing the trustees to alienate trust properties, did not exempt the Trust from compliance with Section 14 of the Public Trusts Act. The Court held that such powers are subject to the constraints imposed by Section 14 and cannot override statutory requirements​​.

Decision: The Supreme Court set aside the High Court’s direction for an inquiry by the Economic Offences Wing, holding it to be non-est in law. The Registrar was directed to initiate necessary proceedings under the Public Trusts Act and carry them to a logical conclusion​​.

Forest (Conservation) Act, 1980 – Definition of Forest Land – Section 2: The Supreme Court held that land covered by a special order issued under Section 4 of the PLPA can be classified as forest land within the meaning of the Forest (Conservation) Act, 1980. The object of the Forest Act is to provide for the conservation of forests and matters connected therewith. The Act applies to all forests, irrespective of the nature of ownership or classification, including lands notified under the PLPA​​.

PLPA Notifications – Restrictions and Sustainable Development: The Court emphasized that the restriction on non-forest use of forest land without the prior approval of the Central Government aims to regulate the use of such land to ensure sustainable development and prevent ecological imbalance. Even private forest land cannot be used for non-forest purposes without such approval. This is crucial to maintain the ecological balance and protect the environment from degradation​​.

State Government’s Role – Regulatory Framework: The judgment highlighted that the State Government cannot permit the use of forest land for non-forest activities without obtaining prior approval from the Central Government. This regulatory framework is intended to prevent the depletion of green cover and ensure that any permissible non-forest use adheres to principles of sustainable development. The decision reaffirmed the necessity of adhering to statutory requirements for forest conservation​​.

Decision: The appeals were allowed, and the High Court’s order was set aside. The Supreme Court directed that the lands covered under the special orders issued by the Government of Haryana under Section 4 of the PLPA should be treated as forest land within the meaning of the Forest (Conservation) Act, 1980. The State Government was instructed to comply with the requirements of the Act and seek the necessary approvals from the Central Government for any non-forest use of such lands​​.

Medical Termination of Pregnancy – Unmarried Women – Legal Interpretation – Section 3(2)(b) of the MTP Act: The Supreme Court held that the exclusion of unmarried women from the ambit of Rule 3B of the MTP Rules is violative of Article 14 of the Constitution. The Court emphasized a purposive interpretation of the term "change of marital status" under Rule 3B to include unmarried women whose relationships have failed. The Court observed that Parliament, through the MTP Amendment Act, 2021, intended to extend the benefit of safe abortion to all women irrespective of their marital status by replacing "husband" with "partner" in Explanation I to Section 3(2) of the Act​​.

Reproductive Choice – Right to Privacy and Bodily Autonomy – Article 21 of the Constitution: The judgment underscored that a woman's right to reproductive choice is an inseparable part of her personal liberty under Article 21. This includes the right to make decisions regarding abortion. Denying an unmarried woman the right to a safe abortion infringes upon her personal autonomy and bodily integrity​​.

Delay in Judicial Process – Impact on Rights – Interim Relief: Given the delay in judicial processes, the Court held that such delays should not prejudice the petitioner. It directed the immediate constitution of a Medical Board to ascertain the safety of terminating the pregnancy and to proceed with the abortion if it posed no risk to the petitioner’s life​​.

Decision: The Supreme Court allowed the petition, modifying the High Court's order and directing the AIIMS Medical Board to evaluate and, if safe, perform the abortion. The petitioner should not be denied the benefit of the statute due to her unmarried status, and the judicial delay should not work to her prejudice​​.