Environmental Law - Environmental Clearance - Ecologically Sensitive Area - Appellant challenged the environmental clearance granted to Ultratech Cement Limited for limestone mining on grounds of ecological sensitivity, lack of consent from private landholders, and adverse environmental impacts. The clearance was challenged under Section 16 of the NGT Act​​ .

Natural Justice - Composition of NGT Bench - Single Member Bench - The NGT's dismissal of the applications for restoration and condonation of delay was deemed null and void due to the improper constitution of a single member bench. The Supreme Court highlighted the requirement of equal numbers of judicial and expert members on the bench as per Section 4(4)(c) of the NGT Act​​ .

Limitation Period - Environmental Clearance - The period of limitation for challenging the environmental clearance was calculated from the date of publication of the clearance, not from individual knowledge. The NGT Act does not permit condonation of delay beyond 90 days​​ .

Decision - Appeals allowed - The Supreme Court set aside the impugned order of the NGT dated 16 July 2021, and the original order dated 29 January 2018. The matter was remitted to the NGT for fresh disposal. All rights and contentions of the parties, including the issue of limitation, were kept open​​ .

Motor Vehicles Act, 1988 - Compensation - Loss of Love and Affection - Loss of love and affection is comprehended within loss of consortium and should not be awarded as a separate head. The Constitution Bench in Pranay Sethi recognized only three conventional heads under which compensation can be awarded: loss of estate, loss of consortium, and funeral expenses​​.

Motor Vehicles Act, 1988 - Calculation of Compensation - Pecuniary Loss - The Tribunal's methodology of basing the deceased's notional income on her husband's income was upheld. The High Court's approach of using her last drawn salary, three years prior to the accident, was deemed inappropriate​​.

Motor Vehicles Act, 1988 - Deduction for Personal Expenses - The proper deduction for personal living expenses is one-third of the income, as per the precedent set in Sarla Verma v. Delhi Transport Corporation​​.

Motor Vehicles Act, 1988 - Future Prospects - An addition of 40% to the notional income for future prospects was mandated, as the deceased was below 40 years of age​​.

Decision - Appeal allowed - The Supreme Court set aside the High Court's reduction of the pecuniary loss compensation and quantified it to be Rs. 44,10,000. The award for loss of love and affection was subsumed under loss of consortium, with Rs. 40,000 awarded for each appellant, totaling Rs. 1,60,000. The total compensation amount, including funeral and medical expenses, was determined to be Rs. 46,17,350, payable within two months, with an interest rate of 7.5% per annum from the date of filing of the claim till payment​​.

Arbitration and Conciliation – Award Modification – The court held that it is not permissible to modify an arbitral award under Sections 34 or 37 of the Arbitration and Conciliation Act, 1996. The appropriate remedy is to set aside the award and remit the matter to the Arbitrator in terms of Section 34(4) of the Act .

Market Value Determination – The court examined the determination of market value for land acquisition under the National Highways Act, 1956, and its interplay with the RFCTLARR Act, 2013. The court affirmed the High Court’s decision, which upheld the Arbitrator's award based on the market value determined using guidelines issued by the Department of Stamps and Registration, even when such guidelines were notified post the acquisition notification .

Compensation Enhancement – The court highlighted that the SLAO’s award remains an offer of compensation and does not gain the status of a judicial order. The Arbitrator is allowed to consider additional evidence for just compensation even if it was not before the SLAO. The use of subsequent guideline values by the Arbitrator was found justified in determining fair compensation .

Patent Illegality – The court emphasized that an arbitral award may be set aside on grounds of patent illegality only when such illegality goes to the root of the matter. This includes contraventions of the substantive law of India or the Arbitration Act itself. However, erroneous application of law or mere contravention not linked to public policy does not qualify as patent illegality .

Decision: Appeals dismissed – The Supreme Court upheld the High Court's decision, affirming the enhanced compensation awarded by the Arbitrator. The court declined to interfere, noting the limited scope for judicial review under Sections 34 and 37 of the Arbitration and Conciliation Act, 1996 .

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​​.

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]​​.