Criminal Law – Quashing of Proceedings – Money Laundering – Proceedings initiated under PMLA against appellant following seizure of cash and gold by Income Tax Department – Appellant contended no evidence of scheduled offence – High Court dismissed quashing petition – Supreme Court analyzed evidence and procedural lapses, including failure to identify involved bank officials – Proceedings quashed – Appeal allowed [Paras 1-20].

Procedure under Section 482 CrPC – Quashing of Proceedings – High Court’s failure to consider all material evidence – Supreme Court emphasized requirement of strong evidence for continuation of PMLA proceedings – Proceedings quashed due to lack of incriminating material [Paras 14-19].

Evidence – Lack of Identification of Bank Officials – Adjudicating Authority’s observation on absence of identification of bank officials involved in alleged money laundering – Supreme Court found lack of material evidence to support continuation of proceedings under PMLA [Paras 16-18].

Decision – Appeal Allowed – Held – Proceedings under PMLA against appellant quashed – Supreme Court set aside High Court’s order dismissing quashing petition – Emphasized that until allegations are substantiated, appellant is presumed innocent [Para 20].

Land Reforms – Pre-emption Application – Compliance with Section 9 of West Bengal Land Reforms Act – Pre-emptors must deposit entire sale consideration with additional 10% before further enquiry – Non-compliance renders pre-emption application not maintainable [Paras 1-9].

Deposit Requirement – Mandatory Condition – Failure to deposit full sale consideration with additional 10% – Pre-emption application liable to be rejected – High Court erred in allowing deposit of balance consideration at a later stage [Paras 3-9].

Statutory Interpretation – Strict Construction – Right of pre-emption considered a weak right – Provisions enforcing pre-emption must be strictly construed – Compliance with statutory conditions mandatory [Paras 6.1-6.3].

Pre-emption Right – Consideration and Time-frame – Deposit of sale consideration and additional amount is sacrosanct – Inquiry into consideration amount can occur only after initial deposit is made [Paras 24-33].

Decision: Appeal allowed – Held – High Court and First Appellate Court orders set aside – Pre-emption application dismissed – Respondents permitted to withdraw deposited amounts – No order as to costs [Paras 9-10].

Land Acquisition – Compensation Determination – Applicability of Section 24 of 2013 Act – Compensation determined as per circle rate applicable to commercial properties – Award passed in violation of interim stay by Supreme Court – Additional penal interest awarded for delayed payment [Paras 1-33].

Compensation and Interest – Circle Rate for Commercial Properties – Deduction of Development Charges – Compensation to be calculated based on circle rate of Rs. 110,000/- per sq. meter for commercial land – High Court’s deduction of 50% towards development charges set aside [Paras 22-33].

Statutory and Penal Interest – Delay in Payment – Compensation to include statutory interest under Section 34 of 1894 Act and additional 3% penal interest for delay – Total compensation to be paid within six weeks [Paras 31-33].

Decision: Appeal allowed in part – Held – Compensation to be determined based on circle rate of Rs. 110,000/- per sq. meter – No deduction towards development charges – Statutory interest and additional 3% penal interest awarded – Amount to be paid within six weeks [Paras 33].

Constitutional Law – Legislative Competence – Concurrent List – Subject of Arbitration falls under Entry 13 of List III – State Legislature can enact law on arbitration subject to President's assent – State Act reserved for and received President's assent prevails over Central law – State Act within legislative competence of State Legislature [Paras 1-9].

Arbitration – Revocation and Reopening of Awards – State Act – State Act cancelling arbitration clauses and revoking arbitrator’s authority – Provides for suit filing and appeal by State Government against awards – Enactment not arbitrary or discriminatory – Law impacts only specific project agreements [Paras 10-40].

Separation of Powers – Judicial Encroachment – State Act alleged to interfere with judicial power by revoking arbitration clauses – Supreme Court held no encroachment on judicial function – State Act provides for judicial determination of disputes post-revocation [Paras 41-49].

Decision: Appeal dismissed – Held – Kerala Revocation of Arbitration Clauses and Reopening of Awards Act, 1998 upheld as constitutional – Legislative competence affirmed – No violation of separation of powers doctrine – Awards under the Act subject to judicial scrutiny [Paras 50-57].

Criminal Law – Circumstantial Evidence – Conviction based solely on circumstantial evidence requires a conclusive chain of circumstances – The last seen theory, arrest of the accused, recovery of material objects, and call details do not conclusively establish guilt – Conviction based on probabilities and inferences drawn from call records inadmissible without proper certification [Paras 1-23].

Motive and Last Seen Theory – Inconsistent Testimonies – High Court's reliance on call records to establish motive and last seen theory rejected due to inconsistencies and lack of certification under Section 65B of the Indian Evidence Act [Paras 10-22].

Admissibility of Electronic Evidence – Certification Requirement – Call records produced without the mandatory certification under Section 65B(4) of the Indian Evidence Act held inadmissible – Oral evidence in place of certification insufficient [Para 20-21].

Decision: Appeal allowed – Held – Conviction of Ravinder Singh @ Kaku under Sections 302 and 364 IPC set aside due to inconclusive circumstantial evidence and inadmissible electronic evidence – Acquittal of co-accused upheld – Ravinder Singh @ Kaku to be released immediately unless required in any other case – Appeals filed by the State dismissed [Paras 22-23].

Registration of Documents – Duties of Registering Officer – Role of Registering Officer is not merely mechanical – Required to independently verify statutory compliance – Failure to verify powers of attorney and other statutory requirements can invalidate registration [Paras 1-9, 58].

Judicial Review – High Court's Jurisdiction – Under Article 226 – High Court can review actions of Registering Authority to ensure statutory duties are performed – Review is permissible even if other civil remedies are available [Paras 10-54].

Powers of Attorney – Authentication vs. Registration – Distinction clarified – PoA must be authenticated, not necessarily registered – Registering Officer must ensure PoA's compliance with statutory requirements [Paras 13-24, 46].

Civil vs. Writ Jurisdiction – Scope of Challenge – Execution of document to be challenged in civil court – Procedural lapses by Registering Authority can be challenged via writ petition [Paras 53-55].

Decision: Appeals allowed – Held – Registration of sale deed by the Registering Authority set aside due to failure to adhere to statutory duties – Order of the Division Bench reversed – Order of the Single Judge restored [Paras 59].

Income Tax – Reassessment Notices – Transition to New Provisions – High Courts quashed reassessment notices issued under unamended Section 148 after 01.04.2021 – Supreme Court converted such notices into those issued under Section 148A (new provisions) – Directed Revenue to comply with new procedural requirements – Notices deemed to be issued under amended Act to protect public exchequer and reduce litigation [Paras 1-11].

Statutory Interpretation – Finance Act, 2021 – Amendments to Sections 147 to 151 of the Income Tax Act – New provisions remedial and benevolent – Ensure compliance and reduce litigation – New provisions apply to notices issued after 01.04.2021 [Paras 6-7].

Judicial Review – Article 142 of the Constitution – Supreme Court exercised power to provide relief to Revenue and assessees – Avoid multiplicity of proceedings – PAN INDIA application to similar judgments and orders of High Courts [Paras 9-12].

Decision: Appeals allowed in part – Held – Reassessment notices issued under unamended Section 148 deemed to have been issued under Section 148A (new provisions) – Assessing Officers to follow new procedure within stipulated time – High Court orders modified to this extent – Present order applicable PAN INDIA to similar cases and pending writ petitions [Paras 10-12].

Service Law – Recovery of Excess Payments – Misrepresentation and Error – Recovery of increments granted to appellant after ten years of retirement held unjustified – Excess amounts not paid due to any misrepresentation or fraud by appellant – Payments made due to error in interpreting Kerala Service Rules – Equity and judicial discretion favor relief from recovery [Paras 1-16].

Recovery of Benefits – Judicial Precedents – Various precedents affirming that recovery of excess payments not resulting from misrepresentation or fraud is inequitable – Relief against recovery granted in several cases where payments were made due to administrative errors [Paras 9-13].

Decision: Appeal allowed – Held – Recovery of increments after ten years of retirement unjustified – High Court's judgment and recovery notice set aside – No costs awarded [Paras 15-16].

Insurance Law – Terrorism Exclusion Clause – Policy Definitions Govern – Insurance claims cannot be rejected based on the definition of terrorism in penal laws – Exclusion Clause in insurance policy defines terrorism – Rights and liabilities of parties governed by terms of policy – Definitions from penal statutes irrelevant [Paras 1-14].

Consumer Protection – Repudiation of Insurance Claims – Burden of Proof – Insurer must prove exclusion clause applicability – Ambiguities in exclusion clauses construed in favor of insured – Insurer failed to prove act of terrorism as defined in policy [Paras 8-13].

Riot and Violent Means – Policy Coverage – Insurance policy explicitly covers damage caused by riots or violent means – Exclusion Clause improperly applied – Insurer's decision to repudiate policy unsustainable [Paras 14-15].

Decision: Appeal allowed – Held – Impugned judgment and order set aside – Complaint restored to file – Commission directed to decide complaint afresh within four months – Respondent to deposit Rs. 8,900,000/- with Commission within one month – Liberty to appellant to apply for withdrawal of amount pending complaint [Paras 16-18].