Arbitration Law – Jurisdiction of High Court – Section 37 of the Arbitration Act – The Supreme Court held that the High Court exceeded its jurisdiction under Section 37 of the Arbitration Act by entering into the merits of the claim and setting aside the award passed by the arbitrator and the order passed by the Additional District Judge – The High Court had a limited scope of interference and was not permitted to re-evaluate the merits of the claim as if deciding an appeal against a trial court judgment [Paras 7-8].

Arbitral Award – Public Policy – The Court reiterated that an award can only be set aside if it is against the public policy of India, which includes being contrary to the fundamental policy of Indian law, the interest of India, justice or morality, or if it is patently illegal – None of these exceptions were applicable in the present case [Paras 8-8].

Decision – Appeal allowed – The Supreme Court set aside the impugned judgment and order of the High Court – The award passed by the arbitrator and the order of the Additional District Judge under Section 34 of the Arbitration Act were restored [Paras 9-10].

Criminal Law – NDPS Act – Cancellation of Bail – The Supreme Court held that confessional statements recorded under Section 67 of the NDPS Act are inadmissible in the trial of an offence under the Act – Bail granted to the accused (A-2) was cancelled due to the conscious possession of commercial quantities of psychotropic substances – High Court orders granting bail to other accused upheld due to lack of substantial material connecting them to the allegations at the time of arrest [Paras 1-13].

Application of Section 67 of the NDPS Act – Confessional Statements – Confessional statements recorded under Section 67 are inadmissible – Reliance on such statements for arrest and prosecution not permissible – Court emphasized the need for substantial evidence beyond confessions [Paras 9-10].

Section 37 of the NDPS Act – Bail Conditions – Stringent conditions under Section 37 must be met for granting bail – Reasonable grounds to believe the accused is not guilty and not likely to commit any offence while on bail – High Court's findings on these conditions reviewed [Paras 7-8].

Decision: Appeals disposed of – Orders granting bail upheld for respondents except for A-2 – Bail for A-2 cancelled and directed to surrender – Observations limited to bail cancellation proceedings, not affecting the trial [Para 13].

Land Law – Ceiling on Land Holdings – Applicability to Government Grants – Provisions of the Ceiling Act are applicable to land held by grantees of the Government under lease agreements – Grantee, being a lessee from the Government, has no right to transfer the land without fulfilling the conditions stipulated in Clause 9 of the lease deed – Sub-lessees cannot claim independent rights as tenure holders contrary to the terms of the government grant – Appeals dismissed [Paras 1-33].

Government Grants Act – Transfer of Land – Conditions for Transfer – Lease conditions specifically exempt sub-leases made in the ordinary course of agriculture from certain transfer conditions – However, sub-lessees do not acquire independent tenure rights unless conditions stipulated in the lease are fulfilled – High Court upheld the decision of the ceiling authorities [Paras 22-26].

Decision: Appeals dismissed – Sub-lessees continue to be ostensible holders of land, while the government grantee remains the real holder – No independent tenure rights for sub-lessees under the terms of the government grant – No order as to costs [Para 33].

Criminal Law – Murder – Cancellation of Bail – High Court released the accused on bail in a case involving the brutal murder of the appellant's husband – Supreme Court found the High Court's orders unsustainable as they did not consider the gravity of the offences and the evidence against the accused – Bail orders set aside and accused directed to surrender – State criticized for not appealing against the High Court's orders – Duty of Director of Prosecution emphasized [Paras 1-11].

Role of the State and Director of Prosecution – Importance of prompt action – State failed to protect the victim's rights by not challenging bail orders – Director of Prosecution holds a crucial role in the administration of justice – Prompt decision-making necessary to maintain rule of law – Observations to be communicated to State authorities for corrective measures [Paras 11].

Decision: Appeals allowed – High Court's orders releasing the accused on bail quashed – Accused directed to surrender within one week – Non-bailable warrants to be issued if they fail to surrender – Copy of order to be sent to State authorities for further action [Paras 10-11].

Arbitration – Interference with Arbitral Award – Scope of Jurisdiction – The High Court’s interference with the arbitral award based on an alternative view was not justified – The Appellate Court correctly held that the learned Single Judge exceeded his jurisdiction by questioning the interpretation of the Implementation Agreement clauses given by the Sole Arbitrator – Arbitration award restored [Paras 1-21].

Interest on Arbitral Award – Compound Interest – The decision of the Division Bench to award only simple interest based on a misinterpreted precedent was reversed – Hyder Consulting (UK) Ltd. case affirmed the arbitrator's authority to award compound interest [Paras 4-6].

Merger of Agreements – Memorandum of Understanding (MoU) and Implementation Agreement – The MoU dated February 10, 1992, merged with the Implementation Agreement dated August 22, 1997 – The disputes under both documents were referable to arbitration under the Implementation Agreement [Paras 8-11].

Termination of Agreement – Premature Termination – The State prematurely terminated the Implementation Agreement before the stipulated period, misinterpreting Clause 4 – The Sole Arbitrator's interpretation upheld as it was logical and reasonable [Paras 12-22].

Decision: Civil Appeal No. 10341 of 2011 partly allowed – Civil Appeal No. 10342 of 2011 dismissed – Findings on interest component and premature termination upheld – Parties to bear their own costs [Paras 23].

Criminal Law – Appeal against Acquittal – Interference by Appellate Court – High Court reversed the conviction and sentence awarded by the Fast-Track Court – Supreme Court upheld the High Court's decision, noting substantial contradictions in the prosecution's case and testimonies – Emphasis on cautious approach by appellate courts in interfering with orders of acquittal – Judgment of High Court justified [Paras 1-54].

Prosecution Witnesses – Credibility – Evidence of prosecution witnesses found inconsistent and unreliable – Key witness, the informant, did not support the prosecution's case during the trial – Evidence reappraised, revealing significant discrepancies and unsubstantiated allegations against the accused [Paras 48-56].

Perjury Proceedings – High Court's Direction – High Court directed initiation of perjury proceedings against the informant (PW-7) – Supreme Court set aside this portion of the judgment, noting the overall context and the informant's unreliable testimony [Paras 57].

Decision: Appeals partly allowed – Judgment of acquittal by the High Court upheld – Direction to initiate perjury proceedings against the appellant set aside – Other parts of the High Court's judgment affirmed [Para 58].

Criminal Law – Common Intention – Section 34 IPC – The Supreme Court held that mere common intention per se does not attract Section 34 IPC sans an action in furtherance of that intention – It was emphasized that a person may withdraw from a common intention – High Court and trial court judgments examined for proper application of Section 34 IPC [Paras 18-36].

Prosecution Witnesses – Credibility – Significant contradictions in the testimonies of prosecution witnesses – Key witness (PW6) improved his version during the trial, leading to doubts about his credibility – Evidence insufficient to implicate A3 and A4 under Section 34 IPC [Paras 32-34].

Applicability of Section 34 IPC – Misapplication in Trial – The court noted that A3 and A4's statements did not suffice to attract Section 34 IPC – The evidence did not support the conclusion that A3 and A4 were aware A1 had a gun – Trial court’s reasoning found flawed regarding Section 34 IPC [Paras 34-36].

Decision: Appeals by A3 and A4 allowed – Conviction under Section 34 IPC set aside – Judgment of the High Court confirming the trial court's decision reversed as to A3 and A4 – Appeal by the de facto complainant dismissed – Parties to bear their own costs [Paras 37].

Tax Law – Electricity Duty – Exemption Provisions – The Supreme Court held that charitable educational institutions are not exempt from electricity duty under the Maharashtra Electricity Duty Act, 2016 – The omission of Section 3(2)(iiia) from the 1958 Act in the 2016 Act indicates the legislative intent to exclude such exemptions – High Court's interpretation leading to an absurd result was rejected – Appeal allowed [Paras 1-15].

Interpretation of Taxing Statutes – Strict Interpretation – Taxing statutes, particularly exemption provisions, must be interpreted strictly and literally – Ambiguities in exemption provisions are resolved in favor of the revenue – Changes in statutory language between the 1958 and 2016 Acts signify a deliberate legislative shift [Paras 9-11].

Legislative Intent – Clear Language – The clear and unambiguous language of Section 3(2) of the 2016 Act does not support the exemption for charitable educational institutions – The Court emphasized that legislative intent is reflected in the plain meaning of the statute's words [Paras 11-12].

Decision: Appeal allowed – High Court's judgment exempting the respondent charitable educational institutions from paying electricity duty set aside – It is held that such institutions are not exempt from electricity duty under the 2016 Act – No order as to costs [Paras 14-15].

Education – Admission – Reservation Policy – The Supreme Court addressed challenges to the reservation policy in the AIQ seats under NEET for OBC and EWS categories – Upheld the 27% reservation for OBC and 10% for EWS in AIQ seats – Directed the commencement of counseling based on the existing criteria, with future applicability subject to final adjudication [Paras 1-8].

Reservation in AIQ Seats – NEET-PG and NEET-UG – Validity of OBC and EWS Reservation – Court accepted the Pandey Committee’s recommendation to retain the existing EWS criteria for the current admission year to avoid dislocation of the admission process – Counselling to proceed under the existing notification dated 29 July 2021 [Paras 6-7].

Judicial Review – Interim Measures – Court emphasized the need for a detailed interim order on EWS criteria while maintaining the urgency of commencing the counseling process – The decision on the prospective validity of EWS criteria to be subject to final hearing [Paras 6-7].

Decision: Writ petitions partly allowed – 27% reservation for OBC and 10% for EWS in AIQ seats upheld – Counselling to proceed with existing EWS criteria for the 2021-2022 admission year – Validity of EWS criteria for future admissions subject to final hearing in March 2022 [Para 7].