Land Acquisition – Fraud on Power – Section 4 Notification: The Supreme Court held that the decision of the State of Haryana to withdraw from the land acquisition after the notification under Section 4 was a fraud on power. The judgment invalidated all transfers effected from the date of publication of the notification under Section 4 to the date of the State's decision to revoke the acquisition on 29.01.2010, declaring the State's decision as mala fide and inoperative​​.

Regulatory Framework – Development Rights – Collaboration Agreements: The Court examined the nature of collaboration agreements where landowners transferred development rights to developers during the period of acquisition notification. The collaboration agreements were deemed to involve significant transfers of rights and interests in the property, effectively constituting a 'transfer' despite the nominal retention of title by the landowners​​.

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. The lands covered by the collaboration agreements were to be considered as 'transfers' within the meaning of the main judgment, necessitating compliance with the Acquisition Act and related statutory requirements​​.

Rights of Migrant Labourers – Registration and Welfare Schemes – Article 21: The Supreme Court directed the Central Government to develop a portal in consultation with the National Informatics Centre (NIC) for the registration of unorganized labourers/migrant workers. It emphasized the necessity of completing the registration process under the National Database for Unorganised Workers (NDUW Project) by 31.07.2021 and fully implementing it by 31.12.2021, ensuring all concerned States/Union Territories and contractors cooperate to register these workers so they can benefit from welfare schemes​​.

Provision of Foodgrains – Pandemic Measures: The Central Government was instructed to distribute additional foodgrains as demanded by States/Union Territories to migrant labourers. The allocation was to be based on the States' needs under the 'Open Market Sales Scheme.' The Court also mandated the States to establish a scheme for distributing dry rations to migrant labourers, operational by 31.07.2021, and to continue it throughout the pandemic​​.

One Nation One Ration Card Scheme – Implementation: States yet to implement the 'One Nation One Ration Card' scheme were ordered to do so by 31.07.2021. Additionally, the Central Government was directed to reassess the total number of persons to be covered under the National Food Security Act, 2013, to ensure coverage beyond the 2011 census figures, considering population growth and ensuring no eligible person is left out​​.

Running Community Kitchens: States/Union Territories were directed to operate community kitchens in areas with significant numbers of migrant labourers, ensuring they receive adequate meals at least until the pandemic subsides​​.

Decision: The Supreme Court directed the completion of the registration of unorganized workers within six weeks and the implementation of foodgrain distribution and community kitchen schemes. It also emphasized the need for the Central Government to update the NFSA beneficiary lists to reflect current population data, ensuring the right to food under Article 21 is upheld​​.

Civil Procedure – Substitution of Legal Representatives – Appellant's application for substitution as legal representative of his deceased mother was rejected by the Trial Court and affirmed by the High Court – Appellant contended he was entitled to be substituted based on a registered Will – Supreme Court held that the appellant's entitlement as a legal heir could not be denied, and the application for substitution should not have been dismissed [Paras 1-13].

Order XXII, Rule 5 of CPC – Procedure for Substitution – Court emphasized that the Trial Court should have conducted an inquiry as per Rule 5 of Order XXII, if required, rather than outright dismissing the application – Proper procedural approach for determining the rightful legal representative highlighted [Para 11].

Legal Heirs – Inclusion in Suit – Addressed the necessity of impleading all legal heirs in the suit – Appellant's substitution should have been considered within the framework of testamentary and non-testamentary succession laws [Paras 7-10].

Decision – Appeal Allowed – Held – Orders by the Trial Court and High Court set aside – Application for substitution restored for reconsideration by the Trial Court in accordance with the law – No order as to costs [Para 13].

Arbitration – Appointment of Arbitrator – Disputes between IOCL and NCC Ltd. – High Court appointed arbitrators under Section 11 of the Arbitration and Conciliation Act, 1996 – Supreme Court examined the scope of court’s jurisdiction under Section 11, focusing on whether certain disputes fall within “excepted matters” as per the contract – Held that courts should perform a prima facie review to determine if a dispute is arbitrable, particularly regarding "excepted matters" stipulated in the contract [Paras 1-11].

Arbitration Clause – Interpretation – Contract included specific clauses excluding certain matters from arbitration, termed as "excepted matters" – Supreme Court emphasized party autonomy in arbitration agreements and the necessity to honor the contractual provisions that exclude certain disputes from arbitration – Reviewed whether the claims were notified as per contractual requirements [Paras 10.2-10.7].

Section 11(6-A) of the Arbitration Act – Scope of Review – Limited judicial intervention at the stage of appointment of arbitrators – Court’s role is confined to the existence of an arbitration agreement and prima facie review of arbitrability – Full and final settlement of claims by NCC Ltd. discussed, impacting the arbitrability of the claims – Court underscored the importance of adhering to statutory and contractual frameworks in arbitration [Paras 10.8-10.11].

Decision – Appeals allowed – Held – Orders of the High Court appointing arbitrators set aside – Determined that the disputes raised by NCC Ltd. were not arbitrable as they fell within the "excepted matters" under the contract – Highlighted the significance of proper procedural adherence in contractual and arbitration matters [Para 13].

Hindu Law – Suit for Partition – Succession opened in 1948 before the Hindu Succession Act, 1956 – Daughter born posthumously has no right to the joint family property as per prevailing law prior to 1956 – Adoption of a son by the widow relates back to the time of the death of the adoptive father, rendering the adopted son as the sole heir, divesting the daughter's rights [Paras 1-18].

Doctrine of Relation Back – Adoption by Widow – Adoption relates back to the date of the adoptive father’s death – Adopted son considered as being in existence from the date of the father's death, excluding other heirs such as daughters – Discussed in context of decisions by the Supreme Court in Govind Hanumantha Rao Desai v. Nagappa alias Narahari Laxman Rao Deshpande and Shripad Gajanan Suthankar v. Dattaram Kashinath Suthankar [Paras 5-11].

Rights of Daughter – Daughter’s claim for partition dismissed – High Court correctly applied the doctrine of relation back – Daughter not recognized as an heir due to the presence of an adopted son, who is considered as a natural son by legal fiction [Paras 12-15].

Remarriage of Widow – Impact on Inheritance – Remarriage of the mother does not confer any additional rights to the daughter in the presence of an adopted son, who remains the sole heir [Paras 16-18].

Decision – Appeal dismissed – Held – Orders of the High Court upheld – Plaintiff's claim for partition rejected, as adopted son deemed sole heir from the date of the father's death – No order as to costs [Para 18].

Criminal Law – Bail Conditions – Proportionality – Bail conditions must have a nexus to the purpose they serve and be proportional – Court emphasized that conditions leading to the deprivation of rights and liberties must be avoided – Blanket prohibition on social media activity deemed disproportionate and violating freedom of speech [Paras 29-30].

Criminal Procedure – Consolidation of FIRs – Multiple FIRs arising from the same set of tweets – Supreme Court directed the transfer of all FIRs to the Special Cell of Delhi Police for a consolidated investigation – Disbandment of the Special Investigation Team (SIT) by Uttar Pradesh Police [Paras 22-23].

Personal Liberty – Protection Against Harassment – Highlighted the misuse of criminal law for harassment – Emphasized the necessity for police officers to justify arrests and the need to avoid arbitrary detention – Cited principles from Arnesh Kumar v. State of Bihar [Paras 20, 27-28].

Decision – Writ Petition Partly Allowed – Held – Interim bail granted to the petitioner in all FIRs upon filing a personal release bond – All existing and future FIRs related to the tweets to be transferred to the Special Cell of Delhi Police – Petitioner's liberty to seek quashing of FIRs in High Court of Delhi preserved – Protective order against future arrests based on the same tweets extended [Paras 31-32].

Army Law – Disability Pension – Administrative Discharge – Respondent discharged on administrative grounds under Rule 13(3) III(v) of Army Rules, 1954, not on medical grounds – Claim for disability pension filed 20 years after discharge not entertained – Tribunal erred in ordering Review Medical Board to assess disability [Paras 1-27].

Entitlement Rules – Conditions for Disability Pension – Rule 14(c) – For a disease to warrant disability pension, it must be shown that military service determined or contributed to the onset of the disease – Tribunal failed to establish that the respondent’s disability was attributable to or aggravated by military service – Resurvey Medical Board’s findings 20 years post-discharge not adequate for determining entitlement [Paras 11-24].

Presumption and Burden of Proof – Disability arising in service presumed under certain conditions but rebuttable – No presumption applicable where discharge is not due to medical reasons – Burden on claimant to establish service connection of disability [Paras 19-23].

Decision – Appeal Allowed – Held – Judgment and order of Tribunal set aside – Respondent’s claim for disability pension dismissed as not justified under the rules and conditions governing such entitlements – No order as to costs [Paras 26-27].

NDPS Act – Post-Arrest Bail – Commercial Quantity – Respondent accused of trafficking 50,000 Tramadol tablets (20 kg) – High Court granted bail, ignoring the application of Section 37 of the NDPS Act – Supreme Court quashed the bail order, highlighting the importance of "reasonable grounds" for believing the accused is not guilty and is unlikely to commit an offence while on bail [Paras 1-19].

Section 37 of NDPS Act – Restrictions on Bail – Court must consider Public Prosecutor's opposition and establish reasonable grounds for non-guilt – “Reasonable grounds” require credible and plausible evidence beyond prima facie grounds – High Court's order failed to consider other circumstantial evidence beyond inadmissible confessional statements under Section 67 NDPS Act [Paras 10-18].

Decision – Appeal Allowed – Held – High Court's order granting bail to the respondent set aside – Bail bonds cancelled – Respondent directed to be taken into custody [Paras 19].

Civil Procedure – Transfer Petition – Matrimonial Matters – Appellant sought transfer of F.C.O.P. No. 125 of 2020 from Family Court Vellore to Family Court Chennai due to her inability to travel and her dependency on aged parents – Supreme Court emphasized the principle of convenience of the wife and ordered the transfer to avoid multiplicity and conflict of decisions – High Court’s rejection of transfer petition set aside [Paras 1-12].

Section 24 CPC – Transfer of Proceedings – Convenience of Wife – Economic and social factors considered – Generally, the wife's convenience should be prioritized in matrimonial disputes – Need to consolidate related cases for uniformity in decision-making [Paras 9-11].

Decision – Appeal Allowed – Held – High Court’s order set aside – F.C.O.P. No. 125 of 2020 transferred to Family Court Chennai – Cases to be clubbed for a common order – No order as to costs [Paras 12-13].