Civil Procedure – Counter-Claim – Late Filing – Counter-claim filed 13 years after written statement – Single Judge allowed counter-claim to avoid multiplicity of proceedings – Division Bench set aside order for lack of opportunity to plaintiffs – Supreme Court restored Single Judge’s order, emphasizing counter-claim filed before issues framed – Late counter-claim permitted in exceptional circumstances before commencement of plaintiff’s evidence – Procedural laws should aid justice, not obstruct it [Paras 1-19].

Principles from Ashok Kumar Kalra Case – Timeliness – Counter-claim generally filed with written statement – Court discretion to allow late counter-claim considering factors like period of delay, reason for delay, and prejudice to opposite party – Not typically allowed after issues framed – Supreme Court found no prejudice or undue delay here, counter-claim necessary for comprehensive adjudication [Paras 13-13.1].

Decision – Appeal allowed – Division Bench order set aside – Single Judge order restored – Suit to proceed from current stage with counter-claim on record – No costs [Paras 18-19].

Specific Performance – Readiness and Willingness – Compliance of "readiness and willingness" under Section 16(c) to be in spirit and substance, not merely in form – High Court's finding of compliance affirmed – Plaintiff had made specific pleadings and provided evidence of readiness and willingness to perform contractual obligations [Paras 1-88].

Limitation Act – Article 54 – Suit filed within prescribed limitation period – Time for performance not essence of contract in immovable property cases – Equity principle of delay not applicable if suit within limitation period – High Court's conclusion on limitation upheld [Paras 9-12].

Discretion under Section 20 of Specific Relief Act – Grant of specific performance is discretionary – Consideration of readiness and willingness, conduct of parties, hardship to defendant – High Court's decision to grant specific performance justified – Directions for additional payment to respondent in light of substantial increase in property value since agreement [Paras 13-24].

Decision – Appeal dismissed – High Court's decree for specific performance confirmed with additional payment directions – Respondent to deposit additional amount within eight weeks, appellant to execute sale deed upon deposit [Para 24].

Criminal Law – Quashing of Cognizance – Misappropriation of stocks worth Rs. 16,99,648/- – High Court directed further investigation into the role of the appellant, a District Manager, despite his exoneration in departmental proceedings – Supreme Court upheld the High Court's order for further investigation but expunged remarks prejudicial to the appellant – Investigation to be concluded impartially and independently [Paras 1-24].

Section 482 CrPC – Inherent Powers of High Court – High Court justified in exercising inherent powers to direct further investigation – Such powers to be used sparingly, with circumspection, and in exceptional cases – Observations prejudicial to appellant's case deleted to ensure fair investigation [Paras 11-21].

Right to Fair Investigation – Article 21 of the Constitution – Ensuring fair and just investigation is fundamental – High Court's order for further investigation deemed necessary to secure the ends of justice – Investigation to be conducted impartially, without influence from expunged remarks [Paras 13-19].

Decision – Appeal dismissed with modifications – Further investigation ordered by High Court to continue without prejudice from specific observations – Matter left open for examination by investigating agency, sanctioning authority, and concerned court at relevant stages [Para 21-22].

Income Tax – Employee Contribution – Deduction of Employees' Contributions to PF/ESI – Section 36(1)(va) vs. Section 43B – Contributions must be deposited on or before the due date specified in the respective acts for deduction eligibility – Distinction between employer's contribution (Section 36(1)(iv)) and employees' contribution (Section 36(1)(va)) upheld – Non-obstante clause of Section 43B does not override the specific condition in Section 36(1)(va) – High Court's interpretation upheld [Paras 30-54].

Principles of Interpretation – Strict Construction of Tax Statutes – Deduction provisions in tax statutes must be strictly complied with – No equitable considerations in tax statutes – Parliament's intent in distinguishing employer's and employees' contributions in the IT Act emphasized [Paras 46-50].

Decision – Appeals dismissed – High Court's decision that employees' contributions to PF/ESI must be deposited by the due date under the respective acts for the amounts to be deductible under Section 36(1)(va) affirmed [Para 54].

Land Acquisition – Compensation – Jammu and Kashmir State Land Acquisition Act, 1990 – Acquisition proceedings initiated under the State Act of 1990 – High Court directed compensation as per the Act, 2013 – Supreme Court held Act, 2013 not applicable to State Act of 1990 – Compensation to be determined under the State Act of 1990 – High Court's order set aside [Paras 5-6].

General Clauses Act – Section 6 – Saving of rights, liabilities, and obligations under repealed laws – Order 2019 issued post-Act 2013 – Rights and liabilities under State Act of 1990 continue under General Clauses Act – No application of Section 24(1)(a) of Act, 2013 to State Act of 1990 [Para 5.3].

Order of Status Quo – Impact on Award Declaration – Award not declared due to High Court's stay order – High Court's reliance on non-declaration of award for compensation under Act, 2013, erroneous – Period of stay to be excluded in determining applicability of Act, 2013 [Para 5.4].

Decision – Appeals allowed – High Court's judgment directing compensation under Act, 2013 quashed – Matter remanded to High Court to decide writ petitions on other grounds challenging land acquisition proceedings under State Act of 1990 – Applicability of Act, 2013 concluded and not to be reopened [Para 7].

Land Acquisition – Public Purpose – Karnataka Industrial Areas Development Act, 1966 – Land acquisition for private companies – Acquisition upheld when for public purpose and in furtherance of Act's objectives – Regulations permit land allotment to single company for industrial development with State Government's consultation – Acquisition for MSPL and AISL upheld as consistent with statutory requirements [Paras 28-41].

Environmental Clearance – Acquisition Validity – Karnataka Industrial Areas Development Act, 1966 – Environmental clearance obtained subsequently validates acquisition – Absence of clearance at acquisition time not fatal when eventual clearance granted – Clearance from MOEF and KSPCB considered [Paras 25-33].

Procedural Compliance – Notification Validity – Simultaneous issue of notifications under Sections 1(3), 3(1), and 28(1) of 1966 Act upheld – Procedure under Section 28, including objection consideration, complied – No evidence of undue haste or non-application of mind [Paras 33-35].

Single Company Acquisition – Public Purpose – Acquisition for a single company's industrial project valid under 1966 Act – Board empowered to allot land to individual companies with State Government approval – Allotment to MSPL and AISL in furtherance of industrial development objectives [Paras 37-41].

Judicial Review – High Court Overreach – Division Bench’s inclusion of value judgments on policy views criticized – High Court’s quashing of notifications overturned – Emphasis on statutory interpretation and procedural adherence [Paras 42-44].

Decision – Appeals allowed – High Court's quashing of acquisition notifications reversed – Acquisition proceedings for MSPL and AISL validated – Environmental and procedural compliance confirmed [Para 24-44].

Criminal Law – Issuance of Process – Section 204 CrPC – Requirement for reasoned order – Magistrate must provide reasons for concluding prima facie case against accused – Issuance of process is not an empty formality – Order of Magistrate set aside for lack of reasons [Paras 28-30].

Vicarious Liability – Section 34 of Drugs and Cosmetics Act – Specific Averments Required – Directors' liability for company's offence requires specific averments of their role in conduct of business – Merely being a director insufficient for prosecution – Detailed role and responsibility must be specified in complaint – Complaint against directors lacking such details quashed [Paras 13-24].

Procedural Compliance – Drug Manufacturing – Compliance with Rule 76 of Drugs and Cosmetics Rules – Active direction and supervision by approved competent technical staff – Directors not responsible for day-to-day supervision unless specified – Letters from technical staff confirming compliance [Paras 6-10].

Decision – Appeal allowed – High Court and CJM's orders quashed – Complaint against appellants dismissed for lack of specific averments and procedural irregularity – Complaint to proceed against other accused as per law [Paras 31-32].

Service Law – Seniority Determination – Officiating Period Exclusion – Seniority calculation must exclude period spent in a promotional post on officiating basis unless specified otherwise in rules – Officiating service cannot count towards length of service in a particular post for seniority purposes – Appellants' seniority claim based on officiating service rejected [Paras 12-14].

Nagaland SCERT Service Rules, 2003 – Eligibility Criteria – Five years continuous service in feeder grade required for promotion – Appellants failed to meet eligibility criterion of continuous service in feeder grade as per 2003 Rules – Regularization of service after 2003 Rules' operationalization must comply with rule stipulations [Paras 13-15].

Judicial Review – DPC Recommendations – Limited judicial interference with Departmental Promotion Committee (DPC) recommendations unless exceptional circumstances – Previous High Court remand for fresh DPC consideration complied with – Fresh DPC recommendation favoring appellants overturned due to non-compliance with eligibility criteria [Paras 7-9].

Decision – Appeal dismissed – Seniority of appellants cannot be computed including officiating period – Respondent No. 4's seniority maintained as per valid regularization date – Authorities to re-compute seniority based on this judgment [Paras 16-18].

Contempt of Court – Deliberate Disobedience – Allegation of willful disobedience of the Supreme Court's order directing absorption of employees in Telangana Power Utilities – Non-compliance by Telangana Power Utilities with the Concluding Final Report submitted by One Man Committee [Paras 1-9].

Compliance with Court Orders – Absorption of Employees – TS Genco, TS Transco, TSSPDCL, and TSNPDCL directed to absorb petitioners as per the list approved by the One Man Committee – Orders issued to pay salary and service benefits to petitioners from the date they were relieved by Andhra Pradesh Power Utilities [Para 9].

Judicial Review – Finality of One Man Committee Report – Allocation list prepared by the One Man Committee held binding on all parties – Telangana Power Utilities' repeated objections and non-compliance deemed as contempt of court [Paras 8-9].

Decision – Contempt petition allowed – Telangana Power Utilities held guilty of contempt for non-compliance – Additional opportunity given to comply with the court's previous directions within two weeks – Further orders on sentence to be decided based on compliance [Para 9].