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].

Colorblindness and Eligibility for Courses – FTII – Admission Criteria – Supreme Court held that individuals with colorblindness are permitted to enroll for all courses offered by FTII – The Committee formed to examine the issue recommended that colorblind individuals should not be barred from any courses – Reasonable accommodations and assistance can enable colorblind candidates to successfully complete the courses – The Court emphasized the importance of inclusivity and the collaborative nature of film and television creation [Paras 1-42].

Decision: Appeal allowed – Colorblind individuals are eligible for all courses at FTII – FTII directed to modify its curriculum to accommodate colorblind candidates and make reasonable accommodations where necessary – Specific color grading modules in the curriculum to be made elective [Paras 27-42].

Jurisdiction of Civil Courts – Retrospective Application of Rent Control Act – Applicability to Pending Suits – Appellants contested a decree for possession passed by a civil court after the Rajasthan Rent Control Act, 2001 became applicable – Supreme Court held that the Act does not bar the execution of a decree passed by a civil court if the suit was filed before the Act's applicability – The Act only restricts the jurisdiction of civil courts from the date it became applicable to the area – The rights of parties are determined based on the law at the time of filing the suit [Paras 8-10, 28-30].

Execution of Decrees – Civil Court's Authority – Decrees Passed Prior to Rent Control Act – Civil courts retain authority to pass decrees in suits initiated before the Rent Control Act became applicable to the area – Decrees passed by civil courts in such circumstances remain valid and executable – Supreme Court emphasized the principle that rights crystallize at the time of filing the suit, not based on subsequent changes in law [Paras 18-20, 29-30].

Decision: Appeals dismissed – High Court's decision upholding the decree for possession passed by the civil court affirmed – Decree valid and executable despite the subsequent applicability of the Rajasthan Rent Control Act, 2001 to the area in question [Paras 30].

Specific Performance – Execution and Consideration – Admission by Vendor – Once the execution of the agreement to sell and receipt of substantial advance sale consideration were admitted by the vendor, no further proof was required by the plaintiff-vendee – The Trial Court correctly decreed the suit for specific performance – High Court's interference in the decree based on the necessity of cancellation of subsequent sale deeds was misplaced [Paras 2.5, 5.2-5.4].

Fraudulent Sale Deeds – Necessity of Specific Relief – In a suit for specific performance, it is sufficient to implead subsequent purchasers and seek a direction for them to join in the execution of the sale deed – No need to seek cancellation of the sale deeds – The High Court erred in quashing the decree based on the absence of a specific prayer for cancellation [Paras 3.3, 5.6-5.7].

Discretionary Relief – Section 20 Specific Relief Act – High Court’s Reversal – Despite the discretionary nature of relief under Section 20, the Trial Court's findings of admitted execution and receipt of consideration, and the fraudulent nature of subsequent sale deeds, justified the decree for specific performance – The High Court's interference was unwarranted [Paras 5.8, 6].

Decision: Appeal allowed – High Court’s judgment set aside – Trial Court’s decree for specific performance restored – No order as to costs [Paras 6].

Bail Under UAPA – Section 43D(5) – Stringency and Prolonged Incarceration – Appellant denied bail under Section 439 CrPC – Held, UAPA’s Section 43D(5) conditions less stringent than NDPS Act – Appellant in custody for nearly 8 years – Trial progress slow with only 6 of 109 witnesses examined – Prolonged incarceration considered significant – Bail granted with conditions set by the trial court – Observations limited to bail application purposes [Paras 1-11].

Decision: Appeal allowed – High Court’s order denying bail set aside – Appellant to be released on bail subject to conditions set by the trial court [Para 11].

Suspension of Sentence – Pendency of Appeal – Sections 354, 363 IPC and Section 8 of POCSO Act – Appellant convicted for kidnapping and outraging the modesty of a 9-year-old – Trial Court awarded concurrent sentences under IPC and POCSO Act – High Court denied suspension of sentence – Supreme Court allowed appeal noting maximum sentence of three years and delay in hearing appeal – Recognized that prolonged incarceration during appeal pendency without consideration for sentence length and hearing delay can cause irreparable injury [Paras 1-18].

Decision: Appeal allowed – Execution of remaining part of the sentence suspended – Appellant to be released on bail on terms set by Trial Court [Paras 18].

Permission for Medical Courses – Requirements Under Central Council Act – Regulatory Compliance – CCIM denied permission to respondent medical colleges for postgraduate admissions for 2018-19 due to lack of Central Research Laboratory and Animal House – Karnataka High Court allowed admissions relying on subsequent permission for 2019-20 – Supreme Court held that each academic year requires independent compliance – Deficiencies for 2018-19 cannot be overlooked due to compliance in subsequent years – High Court’s decision flawed as it did not consider legislative scheme of Section 13A of the Act [Paras 1-41].

Non-Recognition of Qualifications – Section 13B – Medical qualifications granted without proper permissions not recognized – Ensures adherence to standards prescribed by the Act – Essential for maintaining educational standards [Paras 28-30].

Decision: Appeals allowed – High Court’s judgments set aside – Writ petitions by Karnataka Ayurveda Medical College and others dismissed – No order as to costs [Paras 40-41].