Criminal Law – Appeal Against Acquittal – Practice of Pronouncing Orders – The practice of pronouncing only the operative portion of the judgment without a reasoned judgment and issuing the reasoned judgment subsequently is discouraged – Such a practice deprives aggrieved parties of timely judicial redress and undermines judicial discipline – The High Court's judgment, pronounced without reasons and followed by a reasoned judgment after almost five months, is unsustainable and thus set aside [Paras 1-4].

Judicial Discipline – Promptness in Delivery of Judgments – Judicial discipline requires promptness in the delivery of reasoned judgments – The practice of issuing only operative orders without accompanying reasons must be stopped to ensure transparency and accountability in the judicial process [Para 4].

Decision: Appeals allowed – The High Court's impugned judgment and order set aside – The case is remanded to the High Court for fresh consideration and prompt judgment delivery [Para 4.4].

Insolvency and Bankruptcy – Limitation – Acknowledgment of Debt – The provisions of Section 18 of the Limitation Act are applicable to proceedings under the IBC – An acknowledgment in a balance sheet without qualification can extend the period of limitation, provided the acknowledgment is within three years from the original date of default [Paras 13-14].

Judicial Precedent – Overruled Decisions – The decision in V Padmakumar was overruled by the Supreme Court in Asset Reconstruction Company (India) Limited v Bishal Jaiswal – The NCLT and NCLAT decisions, which relied on V Padmakumar, are set aside and the matter is remanded for fresh adjudication in light of the Supreme Court's ruling in Asset Reconstruction Company and other relevant decisions [Paras 8-12].

Decision: Appeal allowed – The judgments of the NCLT and NCLAT are set aside – The matter is remanded to the NCLT for fresh adjudication with directions to dispose of the case expeditiously within three months [Para 16-17].

Victim’s Right to be Heard – Bail Adjudication – Section 2(wa) CrPC – Legal Right to Participate in Proceedings – Appellant challenged the bail granted to the Respondent-Accused in a case involving the death of several farmers – Supreme Court held that a victim under Section 2(wa) of CrPC is entitled to be heard at every stage of proceedings – High Court's failure to hear the victims invalidated the bail order [Paras 16-27].

Grant of Bail – Consideration of Relevant Factors – Principles Governing Bail – High Court's Order Found Faulty – Supreme Court observed that High Court ignored essential considerations such as nature and gravity of the offense, severity of punishment, and likelihood of tampering with evidence – Emphasized the need for judicial discretion to be applied judiciously and not mechanically [Paras 28-37].

Cancellation of Bail – Reassessment by High Court – Direction for Fresh Adjudication – Supreme Court set aside the bail granted by the High Court – Ordered Respondent-Accused to surrender – Directed High Court to reassess bail application afresh, ensuring victims' participation [Paras 38-45].

Decision: Appeal allowed – Bail granted to Respondent-Accused set aside – Matter remanded to High Court for fresh consideration – Respondent-Accused to surrender within a week [Paras 38-46].

Civil Procedure – First Appeal – Order 41 Rule 31 CPC – Duty of First Appellate Court – Supreme Court emphasized that the first appellate court must reappreciate the evidence, consider the arguments, and apply the law – Judgment must reflect conscious application of mind and record findings supported by reasons on all issues – Appellate court failed to discharge its duty leading to remand for proper consideration [Paras 1, 6-9, 14-15].

Judicial Review – Non-Adherence to Legal Principles – Supreme Court criticized the first appellate court for its failure to comply with the principles enumerated under Order 41 Rule 31 CPC – Emphasized the importance of reappreciation of evidence and providing reasoned judgments to avoid far-reaching consequences on the administration of justice [Paras 6-9].

Remand – Proper Disposal of Appeals – Due to failure of the first appellate court, the Supreme Court set aside the impugned judgments and remanded the case back for fresh disposal in accordance with law – Directed the first appellate court to dispose of the appeal expeditiously considering the suit's age [Paras 14-15].

Decision: Appeals allowed – Impugned judgments set aside – Case remanded to the first appellate court for fresh disposal in compliance with Order 41 Rule 31 CPC – Directions for expeditious disposal given [Para 15].

Educational Qualification – Requirement for Appointment – Advertised Qualification – Postgraduate and Bachelor Degrees in History – Appellants challenged the cancellation of their appointments due to having degrees in specialized branches of History rather than History as a whole – Supreme Court upheld the cancellation, affirming that specific educational qualifications mentioned in the advertisement must be met – Expert Committee's opinion considered significant [Paras 1-7].

Judicial Review – Role of Courts – Expert Opinion – Education Law – Courts generally defer to educational institutions and expert committees regarding qualifications – Supreme Court reiterated the limited role of courts in academic matters, emphasizing reliance on expert opinions unless shown to be arbitrary or discriminatory [Paras 6.5-6.6].

Legitimate Expectation – Inapplicability – Prior Similar Appointments – Argument that similar qualifications were accepted in previous appointments rejected – Each selection process evaluated on its own merits, adherence to advertised qualifications necessary to maintain standards [Paras 3.5, 6.7].

Decision: Appeals dismissed – Cancellation of appellants' candidature and selection upheld – Supreme Court agreed with the High Court's decision that candidates did not meet the requisite qualifications as per the advertisement [Paras 7].

Education Law – Eligibility for Absorption – Absorption of Teachers – Post Qualification Teaching Experience – State Government took over a private Ayurvedic College – Screening Committee to assess qualifications and eligibility as of the cut-off date (June 1, 1986) – Supreme Court held that eligibility should be assessed as of the cut-off date and not based on the initial appointment date – High Court's reliance on the initial appointment date for qualification assessment deemed incorrect [Paras 1-27].

Judicial Review – Scope and Limitations – Interpretation of Statutes – Notification and Statutory Provisions – Supreme Court emphasized that the mandate of the statute and the specific notification must be adhered to – High Court's failure to correctly interpret the notification and statute led to an erroneous conclusion [Paras 24-29].

Service Law – Reinstatement and Consequential Benefits – Reinstatement of Teaching Staff – Teachers whose services were terminated found eligible as of the cut-off date – Supreme Court ordered reinstatement with all consequential benefits – Teachers who have reached superannuation to be treated in continuous service for retiral benefits [Paras 30-33].

Decision: Appeals allowed – Termination orders set aside – Appellants reinstated with all consequential benefits – Directions issued for necessary orders regarding reinstatement and release of retiral dues within specified timeframes [Paras 34-36].

Constitutional Law – Right to Life – Compensation for Violation – Meerut Fire Tragedy – Liability of Organizers and State – Petitioners sought compensation for victims of fire tragedy – Supreme Court held that the right to life guaranteed under Article 21 includes the right to compensation for loss of life and personal liberty due to negligence – No statutory provision is required for such compensation – Duty of care expected from the state and organizers is high in public safety matters – Liability shared between organizers and state in the ratio of 60:40 [Paras 1-5, 22].

Commission of Inquiry – Validity and Procedure – Appointment and Findings – Inquiry Commission under the Commission of Inquiry Act, 1952 appointed by the state submitted a report – Supreme Court directed the appointment of a new commission after finding the earlier inquiry flawed due to lack of cross-examination opportunity – New commission found negligence on part of organizers and state authorities – Detailed findings on procedural lapses and lack of compliance with statutory provisions [Paras 2-4, 14, 24].

Compensation – Determination and Distribution – Supreme Court directed the determination of compensation for victims based on principles of just compensation akin to Motor Vehicles Act – Directed the Allahabad High Court Chief Justice to appoint a Judicial Officer for the exclusive task of determining compensation – Compensation already paid by state and organizers to be adjusted – Compensation to be computed in accordance with law and paid promptly [Paras 5, 24-29].

Decision: Writ petition allowed – Supreme Court directed determination of compensation by a Judicial Officer – Liability apportioned between organizers and state – Further hearing after four months for final determination and payment [Paras 30-31].

Exchange Fluctuation Loss – Revenue or Capital Expenditure – Section 37 of Income Tax Act – Appellant challenged the High Court's decision that reversed ITAT's finding – Supreme Court held that the exchange fluctuation loss is incidental to carrying on business and is allowable under Section 37 as revenue expenditure – The funds borrowed in foreign exchange were used wholly and exclusively for business purposes – ITAT’s decision upheld and High Court's judgment set aside [Paras 1-15].

Decision: Appeal allowed – High Court’s decision set aside – ITAT’s decision allowing the entire claim of Rs.35,657,727/- as revenue expenditure restored – Suitable adjustments to be made in the final assessment order [Paras 13-15].

Right to Establish Educational Institutions – Regulatory Measures – Constitutionality of Amended Regulation – Appellant challenged the High Court’s decision striking down the DCI’s amended Regulation 6(2)(h) – Supreme Court held that regulatory measures to ensure proper academic standards, infrastructure, and prevention of maladministration are permissible – The amendment requiring new dental colleges to be attached to medical colleges was found to have a rational nexus with the objective of improving educational standards – The regulation was not violative of Articles 14 and 19(1)(g) of the Constitution [Paras 1-45].

Judicial Propriety – Reconsideration of Proposals – Earlier Writ Petition – Respondent’s earlier writ petition seeking reconsideration of its proposal for establishing a new dental college had been dismissed – Filing a subsequent writ petition challenging the same issue before a Division Bench was improper – Division Bench should not have entertained the writ petition after the single judge's dismissal [Paras 43-44].

Decision: Appeal allowed – High Court’s decision set aside – The notification issued by DCI upheld – Respondent’s writ petition dismissed [Paras 45-46].