Consumer Protection – Transitional Provisions – Applicability of Acts – Complaints filed before the commencement of the Consumer Protection Act, 2019 governed by the 1986 Act – Requirement under the 2019 Act for deposit of 50% of awarded amount not applicable to complaints filed under the 1986 Act – Appeal to be heard under provisions of the 1986 Act [Paras 2-4, 6, 27, 34].

Statutory Interpretation – Right to Forum – Right to forum is procedural and not a vested right – Section 6(e) of the General Clauses Act protects pending legal proceedings for enforcement of accrued rights but does not save the right to a particular forum [Paras 7, 25].

Judicial Review – Precedents – Several judgments, including Hoosein Kasam Dada (India) Ltd. v. State of Madhya Pradesh, Garikapati Veeraya v. N. Subbiah Choudhry, and Neena Aneja v. Jai Prakash Associates Ltd., support that onerous conditions for appeal under the new law do not apply to cases initiated under the old law [Paras 8-11, 16-17, 25].

Decision – Appeal allowed – NCDRC order upheld but application to appeal governed by provisions of the 1986 Act – Deposit condition under the 2019 Act not applicable to appeals filed under the 1986 Act [Paras 34].

Juvenile Justice – Plea of Juvenility – Rule 12(3)(iii) – Birth certificate from municipal authority or panchayat relevant for determining juvenility – School record not deemed reliable if procured solely to support plea – Appellant failed to provide birth certificate in initial application – Plea of juvenility must be bona fide – Appellant’s reliance on dubious documents leads to rejection of juvenility claim [Paras 6-7, 8-9, 11-13, 37-38].

Evidentiary Value – Birth Certificate and School Records – Certificate issued after application under Section 7A deemed arranged and unreliable – School leaving certificate issued by unregistered school and bearing anomalies considered fabricated – Medical Board’s ossification test indicating age 23-24 years not conclusive but relevant [Paras 8-14, 15-17, 19-22].

Family Register – U.P. Panchayat Raj Rules – Entries in family register relevant but not conclusive – Family register maintained under statutory duty carries evidentiary value – Entries consistent with other records upheld as reliable evidence against juvenility claim [Paras 23-27, 32-36].

Legal Principles – Statutory Interpretation – Liberal interpretation of beneficial legislation must not favor fraudulent claims – Courts to ensure genuine reliance on statutory provisions for juvenility determination – Consistency with Supreme Court precedents in interpreting age determination procedures under JJ Act [Paras 18, 28-31, 38-39].

Decision – Appeal dismissed – High Court’s order upheld – Appellant to stand trial as an adult [Para 39].

Corporate Law – NCLT Proceedings – Continuation Beyond 8th Stage – Future Retail Limited (FRL) granted liberty to approach High Court for continuation of NCLT proceedings beyond the Meeting of Shareholders and Creditors – High Court directed to consider contentions and pass appropriate order uninfluenced by present observations – Parties' submissions regarding the impact on ongoing arbitration and regulatory decisions considered [Paras 1-16].

Regulatory Approvals – Amazon-Future Group Dispute – Arbitration – Emergency Arbitrator’s orders and High Court enforcement orders reviewed – CCI’s revocation of initial Amazon-FCPL share purchase noted – Continuation of NCLT proceedings essential for FRL due to imminent threat of insolvency and potential impact on employees – High Court to ensure procedural balance between parties [Paras 2-13, 15-16].

Judicial Process – Remand to High Court – Directions issued for expeditious resolution – Interim relief considerations acknowledged with directives to maintain fairness in ongoing NCLT and regulatory processes – NCLT to resume upon High Court's further order [Paras 16-17].

Decision – Civil Appeals disposed of – FRL authorized to approach High Court for further NCLT proceedings – High Court to pass orders considering all contentions and maintaining procedural balance [Para 17].

Administrative Law – Regulations – Quashing of Regulations for Lack of Approval – Council of Architecture issued regulations without the Central Government's approval as mandated by Section 45(1) of the Architects Act – High Court quashed the regulations – Supreme Court emphasized the necessity of Central Government approval for regulations under Section 45(1) – Appeal allowed, High Court's order set aside [Paras 1-20].

Legislative Interpretation – Section 21 vs. Section 45 – Minimum standards of architectural education can be prescribed by the Council of Architecture not only by regulations but also otherwise – However, if prescribed by regulations, Central Government approval is mandatory – Court held that Section 21 does not override the requirement of approval under Section 45(1) [Paras 9-15].

Locus Standi – Challenge by Society – Respondent society comprised of teaching faculty members challenged the regulations – Court held that the society had locus standi to challenge regulations affecting their professional standards and employment conditions – Emphasized the need for proper procedural adherence in issuing regulations [Paras 16-19].

Decision: Appeal allowed – High Court's order quashing the "Minimum Standards of Architectural Education Regulations, 2017" set aside – Writ petition by the respondent society dismissed [Para 20].

Urban Planning – Reservation of Land – Lapsing of Reservation – Land reserved under Development Plan for public purposes not acquired for over ten years – Owners issued purchase notice under Section 127 of MRTP Act – No steps taken for acquisition within one year – Reservation deemed to have lapsed – High Court erred in directing acquisition post-lapse – Appeals allowed, High Court order set aside [Paras 1-20].

Financial Constraints – Unsuitability of Land – Corporation not financially capable of paying huge compensation for unsuitable land – Land flood-affected and not usable for reserved public purposes – High Court’s direction to acquire land unjustified [Paras 15-17].

Appropriate Use of Power – Planning Authority’s Duty – While preparing Development Plan, Authority must ensure reserved land is suitable for public purposes – Lapsing of reservation under statutory provisions must be acknowledged – Writ of mandamus directing acquisition post-lapse is improper [Paras 9-11, 12-14].

Decision: Appeals allowed – High Court’s order quashing reservation and directing acquisition set aside – Reservation deemed to have lapsed, writ petition dismissed [Para 20].

Civil Procedure Code 1908 (CPC) - Commercial Suits - Time Limit for Filing Written Statement and Consequences of Default: Strict timelines for filing a written statement are mandated, with a maximum of 120 days allowed from the date of service of summons. Beyond this period, the defendant forfeits the right to file the written statement, and no court can extend this time​​.

Commercial Courts Act, 2015 - Application of CPC Provisions: Emphasizes that the Commercial Court must adhere to the CPC's provisions as amended by the Commercial Courts Act, particularly concerning the timelines for filing written statements and the consequences of failing to meet these deadlines​​.

Judicial Interpretation - Rules of Procedure and Justice: While procedural rules are intended to facilitate justice rather than punish, the court reiterated that, for commercial disputes, strict adherence to timelines is necessary to ensure efficiency and effectiveness in litigation. Exceptions to this rule are limited and require compelling reasons​​.

Impact of COVID-19 on Procedural Timelines: References to the Supreme Court's orders in Suo Motu Writ Petition (Civil) No. 3 of 2020, which extended limitation periods due to the pandemic, highlight the exceptional circumstances where procedural timelines may be adjusted​​.

Decision: Appeal dismissed. The court upheld the strict timelines for filing written statements in commercial suits and reiterated that no extensions beyond 120 days are permissible under the amended CPC provisions applicable to commercial disputes​​.

Insurance Law – Theft of Vehicle – Repudiation of Insurance Claim – Delay in Intimation: When the complainant lodged the FIR immediately after the theft and the police, after investigation, arrested the accused and filed a challan, the insurance company could not repudiate the claim solely based on the delay in notifying the insurance company of the theft. The Supreme Court held that the claim should not be denied if the theft claim is found genuine and the FIR was promptly filed​​.

Judicial Precedent – Contradictory Decisions – Three Judge Bench Clarification: Addressed conflicting judgments on whether delay in informing the insurance company disentitles the claimant. The three-judge bench in Gurshinder Singh vs. Shriram General Insurance Company Ltd. clarified that mere delay in intimation, when the FIR is lodged immediately and the claim is genuine, cannot be a ground for repudiation​​.

Contractual Obligations – Interpretation of Insurance Contracts: The court emphasized that the rules of interpretation applicable to general contracts also apply to insurance contracts, with specific nuances. The term "immediate" notice should be interpreted in context, and prejudice to the insurer is a key factor in determining compliance with the duty to cooperate​​.

Decision: Appeal allowed – The repudiation of the insurance claim by the insurance company was set aside. The NCDRC's order was found erroneous and was overturned, reinstating the orders of the District Forum and the State Commission that favored the insured​​.

Banking Law – Removal from Service – Appeal Against Removal: The appellant, a branch officer, sanctioned a loan limit of Rs. 150,000, later reduced to Rs. 75,000. There was no financial loss to the bank; the decision was in the bank's interest. The appellant had an unblemished service record for 28 years. The punishment of removal for the charges proved was found to be too harsh and disproportionate. The court substituted the punishment from removal of service to compulsory retirement, entitling the appellant to all benefits available under compulsory retirement​​.

Promotion Claim – Appeal Against Dismissal: The appellant sought promotion from Scale II to Scale III from the date juniors were promoted. The High Court did not address this claim independently but dismissed it following the removal order. The Supreme Court remanded the matter to the High Court for a fresh decision on merits​​.

Decision: Appeals allowed – The punishment was modified from removal of service to compulsory retirement. The High Court's dismissal of the promotion claim was set aside, and the matter was remanded for fresh consideration​​.

Land Acquisition – Notification – Pending Proceedings: The acquisition and notifications under Sections 4 and 6 of the Land Acquisition Act were already under consideration in other proceedings before the High Court. To avoid conflicting orders and ensure consistency, all appeals concerning the same acquisition should be heard together. The High Court erred in deciding the present appeal separately​​.

Judicial Efficiency – Avoidance of Conflicting Orders: The Supreme Court emphasized the importance of judicial efficiency and the avoidance of conflicting orders. It held that when multiple proceedings involve the same subject matter, they should be consolidated and heard together to ensure a coherent and just outcome​​.

Decision: Appeal allowed – The High Court's order was set aside. The matter was remanded to the Division Bench of the High Court to be heard along with other related appeals​​.