Service Law - Appointment on Basis of False Caste Certificate - Employment Secured through False Pretenses - The respondent obtained employment as a Management Trainee (Technical) under the Scheduled Tribe (ST) quota at Bhilai Steel Plant using a false ST certificate. The High-Level Caste Scrutiny Committee later found the respondent belonged to the Halba/Koshti community, categorized as Other Backward Class (OBC), and not the Halba ST community. The respondent’s ST certificate was canceled, leading to his termination and forfeiture of service benefits. The High Court, however, granted relief based on an incorrect application of the ratio in State of Maharashtra vs. Milind, which had been subsequently clarified in Union of India vs. Dattatray​​.

Service Law - Clarification in Dattatray Case - The court clarified that the Milind judgment, which provided certain protections, did not apply to cases where individuals secured public employment through false caste claims. Such wrongful appointments must be canceled to allow rightful candidates to occupy reserved posts​​.

Service Law - Consequences of False Caste Claims - The respondent, having secured employment through a false caste certificate and avoiding participation in the scrutiny process, is not entitled to continue in a post meant for the ST category. He is also disentitled to any pensionary benefits due to his wrongful appointment. Emoluments paid to the respondent, however, should not be recovered​​.

Decision: Appeal allowed - The Supreme Court set aside the High Court's order, reinstating the termination of the respondent. The respondent, being an OBC, cannot retain a post meant for the ST category. The emoluments already paid to the respondent are not to be recovered, but he is not entitled to any pensionary benefits​​.

Motor Vehicles Act, 1988 - Permanent Disability - The claimant, a five-and-a-half-year-old child at the time of the accident, suffered 100% permanent disability due to multiple severe injuries, including cerebral edema, spinal cord injuries, and paralysis. The MACT awarded compensation of Rs. 900,000, which the High Court enhanced to Rs. 2,320,000. The Supreme Court further considered the adequacy of compensation based on the claimant's lifelong needs and disabilities​​.

Compensation Enhancement - Pain and Suffering - The court recognized the claimant's lifelong pain, suffering, and inability to lead a normal life due to the permanent disability. The compensation for pain, shock, and suffering was determined by considering prolonged hospitalization, medical treatment, and the inability to compete in normal life activities​​.

Future Loss of Earnings - The court applied the multiplier method to calculate future loss of earnings, recognizing the claimant's inability to perform professional work similar to others due to physical limitations. The High Court's calculation for only 10 years was deemed inadequate, and the multiplier of 18 was applied to determine the future loss of earnings​​.

Attendant Charges - The court acknowledged the need for lifelong attendant care for the claimant due to the severity of his injuries. The attendant charges were enhanced, applying the multiplier method for a more realistic and reasonable compensation​​.

Decision: Appeal allowed in part - The Supreme Court enhanced the total compensation to Rs. 5,162,000, deducting the amount already awarded by the High Court. The enhanced amount of Rs. 2,842,000 is to carry interest at 6.5% per annum from the date of filing the claim petition until realization​​.

Rent and Eviction - Mesne Profits - Termination of Tenancy - After passing the decree of eviction, the tenancy terminates, and from the said date, the landlord is entitled to mesne profits or compensation for being deprived of the use of the premises. The determination of mesne profits should be equivalent to the market rent required to be paid by a person holding over the property​​.

Rent and Eviction - Mesne Profits - Appellate Court Jurisdiction - The appellate court has the jurisdiction to impose reasonable terms and conditions, including the determination of mesne profits, to compensate the decree holder for the loss occasioned by the delay in the execution of the decree while granting a stay​​.

Old Act vs. New Act - The suit filed under the provisions of the Old Act before the commencement of the New Act continues to be governed by the Old Act, as per Section 32(3) of the New Act. Thus, the provisions of the New Act, including the limit on mesne profits, do not apply to pending suits under the Old Act​​.

Decision: Appeals dismissed - The Supreme Court upheld the High Court's order directing the appellants to pay mesne profits at the rate of Rs. 250,000 per month. The court found the determination of mesne profits just, equitable, and reasonable, considering the location and commercial nature of the property​​.

Disciplinary Proceedings - Nullity - Time Limit - The High Court held that the disciplinary proceedings were nullity as they were not completed within the time limit prescribed by the Tribunal. The Supreme Court, however, clarified that fixing a time limit by the Tribunal does not equate to a statutory mandate that renders proceedings null and void if not adhered to​​.

Extension of Time - The Supreme Court emphasized that Courts/Tribunals have inherent power to extend time periods set for procedural compliance and that such periods are often in terrorem to prevent dilatory tactics rather than absolute cut-offs​​.

Procedural Mandates - The Supreme Court observed that procedural mandates, such as time limits for completing disciplinary proceedings, should not invalidate substantive proceedings unless explicitly stated as a consequence of non-compliance​​.

Decision: Appeal allowed - The Supreme Court set aside the High Court's order and reinstated the Tribunal's order, allowing the respondent to prefer an appeal against the disciplinary authority's order within 30 days, which should be considered on merits without influence from previous observations​​.

Service Law – Direct Recruitment – Inter-se merit list – Preparation of inter-se merit list of selected candidates is inevitable even in the absence of an explicit provision in the rule or policy. The recruitment authority cannot place the candidates inter-se in the select list under the rule of thumb or by adopting a methodology inconsistent with the spirit of Articles 14 and 16 of the Constitution [Paras 15-16, 29]​​.

Service Law – Promotion – Merit-cum-seniority – For promotion based on merit-cum-seniority, seniority by itself is not the only qualification. Comparative merit must be evaluated, with seniority being one of the factors only. Even a junior person may be promoted over seniors based on merit [Para 16]​​.

Rosters and Reservation – Roster points – Roster system is for ensuring the quantum of reservation in the recruitment process. It does not determine the inter-se seniority among those recruited collectively or deemed to be appointed on the same date [Paras 16, 29]​​.

Decision – Special Leave Petition Dismissed – Seniority should be fixed in accordance with merit determined by the Public Service Commission and not based on roster points. High Court's decision affirmed, emphasizing the precedence of merit over roster points for seniority purposes [Paras 32-33]​​.

Criminal Law – Conviction and Sentencing – Appellant convicted for murdering his uncle by striking him with a wooden cot leg ('Bahi') – Incident followed a quarrel the previous day – Trial Court acquitted appellant due to inconsistencies in evidence and delay in FIR – High Court reversed acquittal, emphasizing credibility of eye witnesses and medical evidence – Supreme Court re-evaluated the intention and knowledge, concluding it was culpable homicide not amounting to murder [Paras 1-19]​​.

Criminal Law – Evidence and Testimony – High Court erred in dismissing Trial Court's findings on delay in FIR and credibility of witnesses – Supreme Court noted the complainant's priority to save the victim justified delay – Minor inconsistencies in site plan and bed head ticket not sufficient to overturn otherwise credible eye witness and medical evidence [Paras 10-12]​​.

Criminal Law – Culpable Homicide vs. Murder – Distinction between Section 302 and Section 304 IPC – Absence of intention to kill deduced from circumstances – Single blow with a non-dangerous weapon – Lack of premeditation – Conduct of appellant indicated culpable homicide not amounting to murder (Section 304 Part-II IPC) rather than murder (Section 302 IPC) [Paras 13-17]​​.

Decision – Appeals Partly Allowed – Conviction under Section 302 IPC set aside – Conviction under Section 304 Part-II IPC imposed – Sentence reduced to period already undergone – Appellant to be released if not required in any other case [Paras 18-19]​​.

Service Law – Selection Criteria – The Board of Examiners altered the selection criteria by introducing interviews and merit-based assessments not prescribed by the statutory rules. The eligibility and procedure for promotion from Class-IV to Class-III positions, as per the Executive Council’s rules, emphasized seniority and passing departmental tests without mandating interviews. The Board's unauthorized changes were deemed illegal [Paras 1-12, 14-20]​​.

Service Law – Estoppel and Acquiescence – The Division Bench erred in applying the principles of estoppel and acquiescence over statutory service rules. Statutory rules take precedence over any principle of estoppel. The participation of the appellants in the selection process did not bar them from challenging the unauthorized changes as it violated statutory rules [Paras 22-23, 30-31]​​.

Decision – Appeals Allowed – The judgment of the Division Bench was set aside, and the judgment of the learned Single Judge was restored. BHU was directed to conduct fresh selections for promotion in accordance with the existing rules, ensuring all eligible appellants receive due promotions and consequential benefits. Benefits to be extended to legal heirs of deceased appellants [Paras 32-34]​​.

Court Fees – Suit Valuation – Nature of relief decisive for suit valuation – Market value of property involved in litigation not decisive for suit valuation – Plaintiff entitled to value the relief of injunctions and damages separately – High Court erred in considering market value for determining suit valuation [Paras 1-15]​​.

Injunctions – Suit for Mandatory and Prohibitory Injunctions – Suit for mandatory injunction to remove defendants from property after termination of license maintainable – Valuation for mandatory injunction not required to be at market value of property – Plaintiff valued reliefs appropriately under Section 7(iv)(d) of the Court Fees Act [Paras 9-10, 13-15]​​.

Decision – Appeal Allowed – High Court's order returning plaint for re-filing based on market value set aside – Trial Court's order rejecting defendant's application under Order VII Rule 11 CPC restored – No observations on merits of the case, left open for pending appeal [Paras 14-15]​​.

Constitutional Law – Double Jeopardy – Accused having undergone trial and acquitted of offences under Sections 504 and 506 IPC cannot be subjected to another trial for the same charges on the same facts – Re-trial would violate Article 20(2) of the Constitution and Section 300 CrPC [Para 24.2]​​.

Criminal Procedure – Territorial Jurisdiction – Offences under Section 376 IPC occurred in Delhi and were separate from those under Sections 504 and 506 IPC which occurred in Chamoli – Charges under Sections 504 and 506 IPC, already tried and concluded, do not form the same transaction as Section 376 IPC – Sessions Judge rightly discharged the accused for lack of territorial jurisdiction for Section 376 IPC [Paras 1-26]​​.

Criminal Procedure – Separate Charges – Offences under Sections 504, 506, and 376 IPC not forming part of the same transaction cannot be tried together under Section 220 CrPC – Alleged rape (Section 376 IPC) distinct and separate from alleged insults and threats (Sections 504 and 506 IPC) [Paras 20-22.2]​​.

Decision – Appeal Dismissed – Discharge of the accused under Section 376 IPC by the Sessions Judge upheld – No re-trial for offences under Sections 504 and 506 IPC due to acquittal and bar of double jeopardy [Paras 25-26]​​.