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].

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].