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].

Service Law – Leave Encashment – Salary Component – Leave encashment forms part of salary under the Rajasthan Non-Government Educational Institutions Act, 1989 – State responsible for 70% of leave encashment, with the management establishment covering 30% – Arbitrary Rule 5(viii) of the 2010 Rules invalidated as unconscionable and unenforceable [Paras 18-21].

Gratuity – Employer's Liability – Rule 82 of the 1993 Rules mandates gratuity payments by aided institution's management – Rajasthan Welfare Society case reaffirmed management's liability for gratuity – High Court's rejection of appellants' claim for gratuity and leave encashment overturned [Paras 22-23].

Decision: Appeal allowed – State to calculate and pay 70% of leave encashment, management establishment to cover remaining 30% – Management establishment to pay gratuity from date of employment to absorption in State service – Interest at 10% per annum on due amounts until payment [Paras 23-24].

Service Law – Termination of Services – Suppression of Information – Employee terminated for suppressing material information and making false statements in the verification form regarding criminal antecedents – Court held that suppression of such information impacts the character, conduct, and antecedents of the employee – Employer has the right to consider antecedents and suitability for the post, and acquittal in a criminal case does not automatically entitle the candidate to appointment – Employer justified in terminating services based on the suppression of information and false statements​​.

Judicial Review – Limited Scope – Suitability for Public Employment – Courts cannot second-guess the suitability of a candidate for public office – Review limited to checking malice, mindlessness, or gross illegality – Employer's decision on suitability is final unless tainted by extraneous considerations – Employer's discretion upheld in cases of false information or suppression regarding criminal antecedents​​.

Decision: Appeals dismissed – High Court’s orders affirming termination of services upheld – Employers entitled to terminate services for suppression of material information and making false statements regarding criminal antecedents​​

Constitutional Law – Right to Life and Personal Liberty – Article 21 – Extension of Investigation Period – It is mandatory to produce the accused either physically or virtually when the Court considers an application for extension of the investigation period under Section 167(2) CrPC and Section 20(2) of the GCTOC Act – Failure to do so is not a mere procedural irregularity but a violation of Article 21 rights [Paras 1-18, 22-23, 28-33].

Criminal Procedure – Section 167(2) CrPC – Extension of Time for Investigation – The Public Prosecutor's report must set out the investigation's progress and specific reasons for continued detention – The Court must ensure these requirements are met before granting an extension – Failure to inform the accused of the Public Prosecutor's application and failing to produce the accused before the Court invalidates the extension order [Paras 15-23, 29].

Default Bail – Right to Bail – Failure to Produce Accused – The accused is entitled to default bail if the mandatory requirements of producing the accused and informing him of the extension application are not met – The extension order's illegality entitles the accused to default bail [Paras 30-38].

Decision: Appeals allowed – Orders extending the investigation period quashed – Appellants granted default bail on conditions including furnishing a bail bond, surrendering passports, and cooperating with the investigation and trial process [Paras 38-39].

Criminal Procedure – Quashing of FIRs – FIRs/complaints arising from the Newshour Debate telecasted on Times Now on 26.05.2022 were transferred to the IFSO unit of Delhi Police – Supreme Court holds that there cannot be two investigating agencies for the same incident involving different co-accused – Petitioner permitted to approach the High Court under Article 226 of the Constitution or Section 482 of CrPC for further relief [Paras 1-9].

Transfer of Investigation – Investigative Parity – Considering parity with a co-accused whose investigation was transferred to the IFSO unit of Delhi Police – All similar FIRs/complaints against the petitioner also transferred to IFSO unit – Emphasizes the necessity for a single investigating agency to maintain consistency and efficiency in the investigation process [Paras 5-7].

Interim Relief – No Coercive Steps – Supreme Court directs that no coercive action shall be taken against the petitioner for a period of eight weeks – Allows the petitioner to seek appropriate relief from the Delhi High Court during this period [Para 7(iv)].

Decision: Writ Petition disposed of – Investigation of all FIRs/complaints transferred to the IFSO unit of Delhi Police – Liberty granted to petitioner to approach the High Court for further relief – Clarification that no opinion expressed on the merits of the allegations [Paras 7-9].

Civil Law – Permanent Injunction – Appeal against High Court's decision affirming the first appellate court's decree for permanent injunction – Based on an unregistered agreement to sell on ten rupees stamp paper – Supreme Court holds that such an unregistered document is inadmissible in evidence for substantive relief – Plaintiff cannot obtain relief indirectly which is otherwise not permissible directly [Paras 1-8].

Unregistered Documents – Admissibility and Collateral Use – Unregistered agreement to sell can only be used for collateral purposes – However, relief for permanent injunction cannot be granted when specific performance is not achievable due to the document's unregistered status – Trial court's dismissal of suit for permanent injunction and allowance of defendant's counter-claim for possession restored [Paras 5-7].

Procedural Impropriety – Clever Drafting – Plaintiff's attempt to circumvent the inadmissibility of the unregistered document by seeking permanent injunction without specific performance – Supreme Court emphasizes that clever drafting cannot be used to achieve what is otherwise legally untenable [Paras 6-7].

Decision: Appeal allowed – High Court's judgment and decree set aside – Trial court's judgment dismissing the suit for permanent injunction and allowing the counter-claim for possession restored – No order as to costs [Paras 7-8].

Criminal Law – Bail Cancellation – High Court granted bail to the respondent based on parity with co-accused – Supreme Court finds that bail granted to co-accused was previously disapproved – Bail order found to suffer from illegality and impropriety – High Court failed to consider the gravity of the offense and relevant factors – Impugned order set aside [Paras 1-18].

Parity in Bail – Relevance and Limitations – Bail cannot be granted solely on the ground of parity without independent consideration of the individual case's facts – Supreme Court emphasizes that each bail application must be assessed on its own merits, considering the nature of the crime and the role of the accused [Paras 12-17].

Seriousness of Crime – Consideration of Facts – Daylight murder with multiple grievous injuries – Respondent named in the FIR as one of the assailants – Supreme Court underscores the need to consider the crime's seriousness and potential impact on public interest and justice administration [Paras 16-17].

Decision: Appeal allowed – High Court's order granting bail set aside – Respondent directed to surrender forthwith – Liberty granted to respondent to apply for bail afresh after surrendering – Application to be considered on its own merits at an appropriate stage [Paras 18-20].