Arbitration – Patent Illegality – Jurisdiction of Appellate Court under Section 37 – Arbitral award in favour of contractor upheld by Commercial Court – High Court reversed award citing patent illegality – Supreme Court held: Interference under Section 37 must be within the limited scope of Section 34 – Re-appreciation of facts or alternative interpretation of evidence not permissible – High Court acted beyond jurisdiction by substituting its view for that of Arbitrator [Paras 27–30, 38–39, 42]

Arbitrator’s Jurisdiction – Quantum Meruit – Section 70, Contract Act – Extra work done by contractor without agreed price but at request of employer – Arbitrator awarded compensation applying quantum meruit – Held: No rewriting of contract – Price left open as per communication – Award based on evidence and reasonable estimation – Not patently illegal [Paras 36–41]

Evidence – No Evidence vs. Weak Evidence – Arbitrator awarded damages based on oral and documentary evidence including tabular calculations – Supreme Court held: Use of rough estimations and honest guesswork permissible where some evidence exists – Arbitrator’s findings not based on "no evidence" – Award valid [Paras 35, 39, 42]

Judicial Restraint – Interpretation of Contract – Arbitrator is master of facts and contract construction – Even erroneous interpretation not ground for interference unless findings shock judicial conscience or are perverse – High Court erred in reassessing evidence and substituting view [Paras 29, 31–34, 41]

Award Components – Upholding of claims for extra work, idle machinery, and transportation costs – Arbitrator applied reasonable methodology based on materials on record – Supreme Court restored full award including interest [Paras 3.2–3.4, 39–40]

Decision: Appeal allowed – High Court judgment dated 03.05.2023 set aside – Arbitral award dated 15.07.2012 affirmed by Commercial Court restored – No costs. [Paras 43–44]

Forest Conservation – Lease of Forest Land for Agriculture – Illegality – State granted lease of 134 acres 6 guntas of forest land to cooperative society for agricultural purpose – Cultivation involved clearing trees and deforestation – Lease not liable to be extended and could not be continued through representation mechanism – High Court erred in granting liberty to seek continuation/extension through Central Government consideration – Held: permission for non-forest use (agriculture) is barred under Section 2 of Forest (Conservation) Act, 1980 without prior Central approval and continuation would perpetuate illegality [Paras 4, 5, 13-16].

Forest Land – Eviction Proceedings – Possession Taken – After lease termination and dismissal of earlier writ petitions/suits/appeals, Forest Department initiated eviction under Karnataka Forest Act/Manual – Eviction order passed – Department took possession on 23/01/2007 and placed caution boards – Held: once possession reverted to Forest Department, direction allowing respondent to seek continuation of lease is unsustainable [Paras 8-10, 16].

Environment & Forests – Non-dereservation Directions – Binding effect – Reliance on Supreme Court’s continuing mandamus/orders restraining de-reservation and requiring cessation of non-forest activities without Central approval – Held: cultivation on forest land is a non-forest purpose; no permission could be granted to allow such use contrary to Section 2 FCA and Court directions [Paras 11-14].

Relief – Restoration/Reafforestation – Mandatory direction – Appeal allowed – High Court orders set aside insofar as they enabled representation for continuation of lease – Forest Department directed to restore forest on 134 acres by planting indigenous species in consultation with experts – Compliance within 12 months – Matter listed for compliance report on 17/12/2026 [Paras 16-20].

Decision: Appeal allowed – Impugned High Court directions permitting representation for continuation of lease set aside – Forest Department directed to restore forest land by plantation of indigenous trees – Compliance within 12 months – Listed on 17/12/2026 for compliance report.

Civil Law – Injunction – Title and Identification of Property – Rectification Deed – Suit Dismissed – Respondents filed suit for permanent injunction based on BDA auction and rectified sale deed – Trial court dismissed suit for want of title and property identification – High Court reversed based on unproven BDA survey – Supreme Court held rectification deed was executed after 20 years without clear reason – Site No. 66 was never constructed upon, violating auction conditions – Original allotment was in land whose acquisition was later quashed – Held: No title proved, rectification invalid, and no proper survey or boundary identification established – Deed lacked evidentiary value, no Commissioner deputed for identification – High Court erred in reversal – Trial court’s dismissal of suit restored [Paras 2-13].

Evidence – Burden of Proof – Production v. Proof – Survey Document Not Admissible – Survey document produced by plaintiff not authenticated or sealed – Author not examined – Document silent on metes and bounds – Held: Production is not proof – High Court’s reliance on unauthenticated survey unsustainable [Paras 11-12].

Civil Procedure – Bar to Subsequent Suit – Earlier Suit on Same Site and Parties – Plaint admitted earlier suit (O.S. No. 26629 of 2011) regarding same Site No. 66 – Second suit filed without leave of court and with changed survey numbers – Held: Improper exercise of jurisdiction – Plaintiff failed to pursue first suit – No explanation for second suit with altered property description [Para 7].

Land Acquisition – Allotment Based on Quashed Acquisition – Title Non-Est – Original allotment made on acquired land later released back to original owners – BDA had no title to transfer – Subsequent rectification deed unrelated to valid acquisition – Held: Respondents cannot claim rights over land acquired but later restored to appellants’ predecessor – Rectification lacked basis [Paras 8-9, 13].

Decision: Appeal allowed – High Court judgment set aside – Trial court decree dismissing suit for injunction restored.

Succession Law – Validity of Will – Proof of Due Execution – Attestation – Witness Testimony – Exclusion of Legal Heir – Concurrent findings reversed – Will executed by testator excluding one out of nine children due to marriage outside the community – Sole attesting witness (DW-2) examined; trial and appellate courts held execution not proved as DW-2 did not attest to signature of second witness – Supreme Court held that cross-examination revealed DW-2 affirmed presence and signature of both attesting witnesses and testator – Held: Evidence satisfies Section 63(c) Succession Act and Section 68 Evidence Act – Leading questions in cross-examination can carry full probative value – No suspicious circumstances established regarding testator’s soundness of mind or voluntariness – Delay of 21 years in challenging will not fatal – Plaintiff failed to mount evidence or deny will in plaint – Judicial conscience satisfied regarding testator’s intent to exclude plaintiff – Res judicata not applicable due to nature of earlier injunction suit [Paras 2-10, 15, 22-29].

Wills – Exclusion of Heirs – Rule of Prudence – Disposition upheld – Court emphasized that testator’s intention must be respected and not substituted with judicial views – Exclusion of one heir justified by testator’s rationale – No evidence of undue influence, coercion, or fraud – Held: Courts must step into the testator’s shoes, not question motives when proof of will is adequate – Conscience of the court satisfied, will proved [Paras 23, 28-29].

Civil Procedure – Res Judicata – Earlier injunction suit not bar to partition claim – Title and validity of will not in issue in prior suit – Therefore, no estoppel or res judicata applies – Plaintiff not barred from filing partition suit but claim fails on merits due to valid will [Paras 10, 15].

Decision: Appeals allowed – Judgments of High Court and Trial Court set aside – Will held valid and properly executed – Plaintiff not entitled to partition – Suit dismissed [Paras 29-31].

Civil Law – Abatement – Impleadment of Legal Heirs – Delay – Appellant failed to timely implead legal heirs of deceased second respondent, who died in 2017 – Legal heirs’ details were brought on record in 2022, but application for condonation and impleadment filed only in 2024 – High Court dismissed entire revision petition as abated – Held: High Court erred – Abatement of revision against one respondent does not vitiate the entire proceeding when contest survives against remaining respondent – Delay in impleadment, though considerable, should not defeat justice [Paras 2–3, 7–8].

Civil Procedure – Restoration of Proceedings – Cause Survives Against Other Respondents – Held: Civil revision cannot be dismissed in entirety where contest survives against remaining respondents – Legal heirs of deceased respondent, who are desirous of participating, should be permitted to contest – Revision restored and matter remitted to High Court for decision on merits [Paras 8–10, 12].

Litigation Conduct – Laches by Counsel – Equity Consideration – Though there was laxity by counsel in taking timely steps to implead legal heirs, Court invoked equitable jurisdiction to avoid miscarriage of justice – Ensured full hearing of all parties, including legal heirs of deceased [Paras 3, 11].

Decision: Appeals allowed – High Court order dismissing revision petition set aside – Civil revision restored – Legal heirs of deceased second respondent permitted to be impleaded – Parties to appear before High Court on 23.01.2026 – Revision to be heard on merits.

Labour Law – Industrial Dispute – Termination – Delay in Raising Dispute – Respondent workman raised an industrial dispute after 15 years of termination from service – Labour Court held termination illegal and awarded full back wages – High Court upheld the award – Supreme Court held that although termination was illegal, delay of 16 years in raising the dispute is a relevant factor – Relief moulded to award only lump-sum compensation in lieu of reinstatement and back wages [Paras 2–13].

Industrial Disputes Act – Delay and Moulding of Relief – Court reiterated that delay in raising an industrial dispute does not per se bar relief, but is a valid ground to deny full back wages or reinstatement – Employer's failure to challenge reference under Article 226 does not estop them from raising delay before Labour Court – Relief moulded based on decisions in Ajaib Singh, Mohan Lal, and Shahaji – Held: Lump-sum compensation of ₹2,50,000 awarded instead of reinstatement or full back wages [Paras 6–11, 13].

Judicial Review – Challenge to Reference under Article 226 – High Court has jurisdiction to quash stale references – However, absence of such challenge does not preclude employer from raising delay before Labour Court – Distinction maintained between delay in making reference and consequences of delay in adjudication under ID Act [Paras 6–9].

Decision: Appeal allowed in part – Finding of illegal termination upheld – Orders of reinstatement and full back wages set aside – Respondent entitled to compensation of ₹2,50,000 to be paid within two months – Interest at 7% p.a. if delayed.

Criminal Law – Rape and Murder – Circumstantial Evidence – DNA Match – Conviction Confirmed – Deceased last seen in same vicinity as accused – Witnesses (PWs 4, 5, 6) corroborated presence and suspicious behaviour of accused – Blood-stained clothes, victim’s shrieks, and disappearance of accused from village strengthened prosecution’s chain – Medical and DNA evidence matched A1 and A2 – Time of death matched with eyewitness accounts – Held: Circumstantial evidence forms a complete and cogent chain to establish guilt under Sections 302 and 376D read with Section 34 IPC – Conviction confirmed [Paras 5-12].

SC/ST Act – Caste-Based Offence – Absence of Knowledge of Victim’s Caste – Acquittal under SC/ST Act Provisions – Though caste of deceased was proved, prosecution failed to show that accused knew her caste – No acquaintance or motive related to caste established – Held: Essential ingredient under Sections 3(1)(w)(i) and 3(2)(v) of SC/ST Act not proved – Conviction under SC/ST Act unsustainable – Acquittal directed [Paras 2, 13-14].

Evidence Act – Section 27 – Improper Recovery – Confessional Statements in Police Custody – No Concealment – Knife, mobile phone and cash alleged to be recovered not admissible under Section 27 – No independent concealment shown – Recovery from person during arrest, not based on disclosure – Confession made in police presence inadmissible – Held: Recovery and confessional evidence unreliable – Conviction under Section 404 IPC against A2 set aside [Paras 6-8, 14].

Sentencing – Life Imprisonment – Remission – Modification from Whole-Life Sentence to 25 Years – Trial Court imposed death sentence; High Court reduced it to imprisonment till last breath – Supreme Court found mitigating factors: A2 had no past criminal record, was 40 years old, had a dependent family, and showed reformation in custody – Held: Case not in ‘rarest of rare’ category – Sentence modified to 25 years rigorous imprisonment without remission under Section 302 read with Section 34 IPC – Sentence under Section 376D read with Section 34 IPC to run concurrently [Paras 15-16].

Legal Aid – Direction for Appeal of Co-Convicts – Supreme Court noted that other two co-accused were convicted identically but had not filed appeals – Directed Telangana Legal Services Authority to assist in filing appeals for them via Supreme Court Legal Services Committee [Para 19].

Decision: Appeal partly allowed – Conviction under IPC upheld – Conviction under SC/ST Act and Section 404 IPC set aside – Sentence under Section 302 modified to 25 years without remission – Sentence under Section 376D to run concurrently.

Arbitration – Section 11 – Consortium Agreements – Existence of Arbitration Agreement – Referral to Arbitral Tribunal Upheld – First respondent (Tecpro Systems Ltd.), a member of a three-party consortium, invoked arbitration individually under Clause 22.2 of General Conditions of Contract – Appellant objected that only the Consortium could invoke arbitration, not individual member – Supreme Court held: At referral stage under Section 11(6-A), court’s role is limited to prima facie satisfaction of existence of arbitration agreement – Complex issues of party status, authority, consortium dissolution, and maintainability are to be adjudicated by Arbitral Tribunal under Section 16 – Held: Prima facie arbitration agreement existed and invocation not barred at referral stage – High Court order constituting Tribunal upheld [Paras 2, 14-19, 21].

Arbitration – Consortium Member’s Standing – Joinder of Non-Signatory – Prima Facie Test – Kompetenz-Kompetenz – Court emphasized limited jurisdiction under Section 11(6-A) – Referral court need not decide whether the member is a “veritable party” or “legal successor” to consortium – Such issues to be examined by AT applying doctrines of competence-competence and group of companies – Reference to Cox & Kings, Duro Felguera and Interplay Constitution Bench cases – Held: Consortium dissolution, insolvency, or loss of leadership by member does not automatically preclude referral – No “mini-trial” to be held at referral stage [Paras 15-18].

Contract Law – Incorporation by Reference – Arbitration Clause in GCC Validly Incorporated – Arbitration clause in GCC validly incorporated into Purchase Orders through reference – Despite separate jurisdiction clause in POs, not inconsistent with arbitration – Held: Arbitration clause survives as operative mechanism under composite contract – Distinguished from separate contractual regime argument [Paras 11.1, 14].

Judicial Discipline – Similar Arbitration Already Proceeding in Related Matter – Judicial Consistency Emphasized – Supreme Court noted similar arbitration proceedings were allowed in related case involving Telangana State Power Generation Corp. – Objections there also dismissed – Held: No reason to adopt contrary view when consortium and contract structure are materially the same [Paras 11.3, 20].

Decision: Civil Appeals dismissed – Order appointing Arbitral Tribunal affirmed – Tribunal to decide all objections including maintainability under Section 16.

Criminal Law – Quashing of FIR – Abuse of Process – Appellant, former Minister and Chairman of Committee for Regularisation of Unauthorised Occupation, challenged FIR registered by Anti-Corruption Bureau alleging illegal grant of government land – Earlier complaints on same allegations investigated twice by Lokayukta and closed – FIR registered after preliminary inquiry by ACB – Held: Continuation of proceedings amounted to abuse of process of law and warranted quashing [Paras 2–6, 13–15, 21].

Sanction for Prosecution – Public Servant – Mandatory Prior Approval – Government Order governing ACB mandated prior approval even before commencement of investigation in respect of acts done in discharge of official duties – No sanction obtained before preliminary inquiry or registration of FIR – Held: Investigation itself was barred in law – FIR and all consequential proceedings vitiated – Case squarely covered by Bhajan Lal category of express legal bar [Paras 16–17].

Quashing Jurisdiction – Principles – Section 482 CrPC and Article 226 – Scope of interference reiterated – Inherent and extraordinary powers to be exercised sparingly but justified where proceedings are manifestly illegal, barred by law or tainted with mala fides – Held: High Court erred in refusing to quash FIR despite existence of statutory bar and abuse of process [Paras 12, 16–17].

Mala Fides – Political Vendetta – Repeated Complaints – Three complaints filed over span of years by persons affiliated to rival political party on same cause of action – Earlier complaints closed after detailed inquiries – FIR lodged after more than a decade from alleged acts and close to election period – Held: Cumulative circumstances disclose political motivation and colourable exercise of criminal process [Paras 18–19].

Delay – Criminal Proceedings – Effect – Though delay alone not fatal in corruption cases, unexplained and inordinate delay coupled with repeated closure of complaints and political rivalry strengthens inference of malice – Held: Proceedings liable to be quashed on ground of mala fides even apart from absence of sanction [Paras 19–20].

Role of Lokayukta and ACB – Jurisdictional Overlap – Lokayukta’s earlier reports exonerating appellant held relevant – Abolition of ACB and transfer of cases back to Lokayukta reinforced position that FIR could not survive – Held: Investigative findings of Lokayukta could not be ignored mechanically [Paras 14–15].

Public Land Allotment – Welfare State – Constitutional Perspective – Court emphasised State’s trustee role in allotment of land to weaker sections and necessity of non-arbitrary action – However, criminal prosecution must still conform to procedural safeguards and constitutional limitations – Held: Welfare objectives cannot justify illegal prosecution [Paras 11, 20].

Connected Appeal – Beneficiary of Land Allotment – Once FIR against main accused quashed and allotment upheld by competent authority, continuation of proceedings against beneficiary unsustainable – Held: FIR and proceedings quashed in connected appeal as well [Paras 22–23].

Decision: Appeals allowed – FIR in Crime No. 5/2018 dated 08.01.2018 registered by Anti-Corruption Bureau, Karnataka, and all consequential proceedings quashed – Impugned judgments of the High Court set aside – Pending applications disposed of [Paras 21–23].