Eviction – Mesne Profits/Compensation – Tenant liable for mesne profits or compensation from date of eviction decree – Compensation should reflect market rate at which landlord could have let out premises if tenant vacated – Landlord not bound by previous contractual rate [Paras 7.1-7.2].

Tenancy – Determination of Compensation – High Court's methodology of calculating compensation based on property's purchase price and estimated return found unsound – Supreme Court remands case for fresh determination – Compensation to be based on rate at which landlord could have let out premises [Paras 7-8].

Interim Arrangement – Pending fresh determination, tenant directed to deposit compensation at Rs. 250,000 per month from date of eviction decree – Subject to final decision by High Court on remand [Para 8].

Decision – Appeal partly allowed – High Court's determination of compensation quashed – Case remanded for fresh determination of compensation – Parties allowed to present evidence on market rent – Interim compensation set at Rs. 250,000 per month [Paras 8-8.1].

Land Acquisition – Compensation – Determination of market value – Land acquired for coal excavation by Singareni Collieries Company Limited – High Court awarded Rs. 80,000 per acre after deducting 1/3rd for developmental activities – Supreme Court held that no developmental activity was required as land was for mining – Compensation enhanced to Rs. 1,23,000 per acre plus Rs. 10,000 per acre for sub-soil coal deposits – Appeals partly allowed [Paras 2-7].

Development Charges – Deduction Unjustified – Land acquired solely for mining purposes – Supreme Court observed that deduction towards developmental activities such as roads, sewage lines, parks, etc. not applicable – High Court erred in deducting 1/3rd of the market value for such activities – Compensation recalculated without deduction [Paras 6.2-6.3].

Sub-soil Rights – Additional Compensation – High Court awarded Rs. 10,000 per acre for sub-soil coal deposits – Supreme Court upheld this award – Recognized importance of sub-soil mineral rights in determining market value of land [Paras 6-7].

Decision – Appeals allowed in part – Compensation for land acquired set at Rs. 1,23,000 per acre with statutory benefits under the Land Acquisition Act, 1894 – Additional Rs. 10,000 per acre for sub-soil coal deposits affirmed – High Court judgment modified to reflect this enhanced compensation – No order as to costs [Paras 7-7.1].

Land Acquisition – Lapse of Proceedings – Acquisition for public purpose (planned development of Delhi) – Possession taken in 2005 but compensation not paid – High Court declared acquisition lapsed under Section 24(2) of the Act, 2013 – Supreme Court overturned this decision, citing the Constitution Bench judgment in Indore Development Authority v. Manoharlal and Ors. (2020) 8 SCC 129, which overruled Pune Municipal Corporation v. Harakchand Misirimal Solanki (2014) 3 SCC 183 – Held, deemed lapse of acquisition proceedings requires both non-possession and non-compensation for five years before the commencement of the Act, 2013 – Appeal allowed, High Court decision set aside [Paras 1-88].

Subsequent Purchaser – No Right to Claim Lapse – Original writ petitioner (subsequent purchaser) acquired right through Agreement to Sell dated 09.05.2005 – Agreement to Sell does not confer title – Subsequent purchasers cannot claim lapse of acquisition – High Court erred in entertaining writ petition by subsequent purchaser – Appeal allowed, writ petition dismissed [Paras 4-4.2].

Decision – Appeal allowed – Impugned High Court judgment declaring acquisition lapsed under Section 24(2) of the Act, 2013 quashed – Writ petition dismissed – Supreme Court reiterates duty of courts to follow the Constitution Bench's interpretation of Section 24(2) and restrict claims of lapse to circumstances where both possession and compensation are lacking for five years or more [Paras 5-5.2].

Insurance Law – Repudiation of Claim – Appellant's shop insured under a policy from the respondent – Policy excluded coverage for basement locations – Shop located in basement and met with fire accident – State Commission ruled in favor of appellant citing unfair trade practice and non-disclosure by insurer – National Commission overturned decision – Supreme Court emphasized insurer's duty of good faith and full disclosure – Exclusion clause considered void due to non-disclosure and prior knowledge of insurer about shop’s location [Paras 1-88].

Adhesion Contracts – Doctrine of Blue Pencil – Standard-form insurance contracts require high degree of good faith – Exclusion clause contrary to main purpose of contract – Clause void as it undermines the contract’s primary objective – Supreme Court applied "blue pencil" doctrine to sever the exclusion clause, rendering the contract enforceable [Paras 8-22].

Duty of Disclosure – Good Faith – Insurer's duty to disclose all material facts and ensure policy terms are clear to insured – Failure to disclose material facts, especially regarding exclusion clauses, constitutes unfair trade practice – Supreme Court stressed reciprocal duty of good faith between insurer and insured [Paras 14-35].

Consumer Protection – Unfair Trade Practice – Non-compliance with IRDA regulations – Exclusion clause leading to contract repudiation without proper disclosure considered an unfair trade practice – Supreme Court held that insurance companies must strictly comply with regulatory requirements to avoid repudiation on such grounds [Paras 36-42].

Decision – Appeal Allowed in Part – Order of National Commission set aside except denial of Rs.2.5 lakhs towards harassment and mental agony – State Commission’s award reinstated except for the aforementioned amount – Insurer's non-compliance with disclosure duties highlighted – Future caution advised for insurance companies to comply with IRDA regulations [Paras 40-42].

Motor Accident – Permanent Disability – Enhancement of Compensation – Claimant sustained comminuted fracture of tibia bones of both legs – Original compensation of Rs. 2,108,400/- awarded by Tribunal reduced by High Court to Rs. 737,604/- – Supreme Court reassessed permanent disability at 30%, enhancing compensation to Rs. 1,167,405/- with interest at 6% p.a. – Compensation enhanced under heads of pain and suffering, loss of future amenities, and loss of income during laid up period [Paras 11-13].

Assessment of Disability – General Principles – Consideration of physical injury, inability to lead a full life, and impact on earning capacity – Tribunal to assess permanent disability based on medical evidence and its effect on claimant’s earning capacity – Distinction between percentage of permanent disability and percentage of loss of earning capacity [Paras 5-12].

Decision: Appeal allowed in part – Compensation enhanced to Rs. 1,167,405/- with 6% interest per annum from the date of filing of the claim petition till realization [Para 13].

Property Law – Interest on Outstanding Dues – Noida and Greater Noida Authorities – Supreme Court revisited orders directing reduced interest rates on outstanding dues for all projects other than Amrapali – Original orders (10.06.2020, 19.08.2020, and 25.08.2020) provided relief of reduced interest rates at 8% per annum – High Court ruled these orders lacked jurisdiction and had widespread financial implications not fully considered – Orders recalled [Paras 1-24].

Jurisdiction – Scope of Relief – Supreme Court observed that relief granted in original orders extended beyond scope of Amrapali projects, impacting numerous unrelated builders – Orders based on applications not adequately contested by concerned authorities – High Court emphasized importance of jurisdictional limitations and proper procedural adherence [Paras 10-17].

Financial Impact – Public Interest – High financial burden on Noida and Greater Noida Authorities due to reduced interest rates – Amounts involved significant, totaling over Rs. 7000 crores – High Court found such substantial financial implications required comprehensive consideration and detailed deliberation, beyond summary proceedings [Paras 18-24].

Decision – Applications allowed – Orders dated 10.06.2020, 19.08.2020, and 25.08.2020 recalled – Noida and Greater Noida Authorities to calculate amounts due based on original contractual terms and state government order dated 09.06.2020 – Builders other than Amrapali Group of Companies directed to adhere to original payment terms [Paras 23-24].

Public Interest Litigation – Maintainability – High Court erred in entertaining PILs without verifying credentials and adherence to procedural rules – PILs alleged corruption by Chief Minister without prima facie evidence – Non-disclosure of previous similar petition dismissed with costs – Violation of Rules 4, 4-A, 4-B, and 5 of Jharkhand High Court (Public Interest Litigation) Rules, 2010 – High Court's order quashing PILs upheld [Paras 1-22].

Judicial Review – Abuse of Process – Supreme Court emphasized bona fides of petitioner in PILs – Petitioners must approach statutory authorities first – High Court not a forum for preliminary investigation based on unsubstantiated allegations – PILs dismissed as abuse of judicial process [Paras 10-22].

Credibility of Petitioner – Importance in PILs – Petitioner’s failure to disclose previous similar dismissed petition – Bad faith and ulterior motives inferred – Clean hands doctrine reiterated – High Court's oversight corrected by Supreme Court [Paras 11-22].

Decision – Appeals allowed – High Court's order allowing PILs set aside – PILs dismissed at threshold – Petitioner directed to approach appropriate statutory authorities if genuine grounds exist – No costs [Paras 21-22].

Property Tax – Capital Value System – Amendments to MMC Act, 1888 – High Court upheld amendments but struck down Rules 20, 21, and 22 of 2010 and 2015 Capital Value Rules – Supreme Court reinstated these rules, holding them intra vires the MMC Act – Emphasized legislative competence and rational basis for amendments aimed at modernizing property tax assessment – Appeals allowed, High Court decision set aside [Paras 1-88].

Tax Law – Legislative Competence – State Legislature's power under Entry 49, List II – Adoption of capital value system for property tax assessment upheld – Distinguished from Entry 86, List I – Tax on lands and buildings not encroaching upon central subjects – Supreme Court confirmed validity under state legislative domain [Paras 155-158].

Water and Sewerage Taxes – Vacant Lands – Upheld imposition on vacant lands – Rejected argument that taxes are fees requiring quid pro quo – Affirmed as valid tax measures aimed at revenue generation for municipal services – Recognized statutory framework allowing recovery of charges where services provided [Paras 158-159].

Education Cess – Validity – Submissions challenging levy under Section 140(1)(ca) dismissed – Court confirmed cess as a legitimate municipal tax component – Emphasized comprehensive statutory basis and municipal need for education funding [Paras 160-162].

Decision – Appeals allowed – High Court judgment striking down Rules 20, 21, and 22 of 2010 and 2015 Capital Value Rules set aside – MMC Act amendments and capital value system for property tax assessment upheld – Contempt petition segregated for separate hearing – No costs [Paras 10-12].

Criminal Law – Rape and Murder – Death Penalty – Acquittal – Investigation Lapses – No Test Identification Parade conducted – Witnesses failed to identify the accused during depositions – Prosecution failed to prove arrest, identification, discoveries, recoveries, and medical/scientific evidence – No cogent and clinching evidence to establish guilt beyond reasonable doubt – Appellants acquitted on benefit of doubt [Paras 1-88].

Circumstantial Evidence – Chain of Evidence – Legal standards for conviction based on circumstantial evidence not met – Circumstantial evidence must exclude every hypothesis except guilt of accused – Prosecution's evidence inconsistent and unreliable – Accused acquitted due to failure to form a complete and conclusive chain of evidence [Paras 6-48].

Fair Trial Rights – Cross-examination Deficiencies – Trial Court's passive role resulted in inadequate cross-examination of material witnesses – Accused deprived of fair trial rights – Emphasized active role of trial judges in ensuring justice [Paras 34-35].

Decision – Appeals allowed – Conviction and death penalty quashed – Appellants acquitted and to be set free forthwith unless required in another case – Family of victim entitled to compensation under Section 357(A) Cr.PC [Paras 36-38].