Workmen's Compensation – Interest on Compensation – Delay in Payment – The Supreme Court held that the High Court erred in interfering with the award of interest on compensation after dismissing the insurer's appeal on the ground of limitation. Once the appeal was dismissed for delay, there was no occasion for the High Court to entertain it on merits. Section 4A of the Workmen's Compensation Act mandates that the Commissioner shall direct the employer to pay interest at 12% or at a higher rate if the employer does not pay the compensation within one month from the date it fell due [Paras 5-6].

Judicial Error – High Court's Inexplicable Decision – The High Court's decision to delete the interest award despite dismissing the appeal due to an unexplained delay of 619 days was deemed a serious judicial error. This necessitated the intervention of the Supreme Court to rectify the erroneous order and restore the interest awarded by the Commissioner [Paras 5-6].

Decision – Appeal Allowed – The Supreme Court set aside the High Court's order deleting the interest on the compensation. The award of interest as ordered by the Additional Labour Commissioner-cum-Commissioner Workmen Compensation was restored. Additionally, costs were imposed on the respondent insurer for compelling the appellants to approach the Supreme Court due to the High Court's erroneous order [Paras 6-8].

Domestic Violence – Jurisdiction of Magistrate – The Domestic Violence Act allows filing of complaints in a court where the aggrieved person resides, either permanently or temporarily – Supreme Court held that the Metropolitan Magistrate, Bengaluru, has jurisdiction as the respondent resides within its territorial limits [Paras 10-11].

Prima Facie Case – Allegations of Domestic Violence – Court found no specific allegations against appellants Nos. 3 to 13 – Criminal case of domestic violence against these appellants quashed – Proceedings to continue against appellants Nos. 1, 2, and 14 [Paras 9-11].

Decision: Appeal partly allowed – Criminal Misc. No. 53 of 2015 quashed against appellants Nos. 3 to 13 – Proceedings to continue against appellants Nos. 1, 2, and 14 in accordance with law [Para 11].

Environmental Law – Adjudicatory Functions – Role of NGT – The Supreme Court held that the National Green Tribunal (NGT) cannot abdicate its adjudicatory functions to administrative expert committees. While expert committees can assist the NGT in its fact-finding role, the ultimate adjudication must be by the NGT. Sections 14 and 15 of the NGT Act entrust adjudicatory functions to the NGT, and these functions cannot be delegated [Paras 15-17].

Jurisdiction and Powers of NGT – Restoration of Environment – The Court emphasized that the NGT is vested with broad powers under Section 15(1)(c) of the NGT Act to provide for restitution of the environment. The NGT, being a specialized body with judicial and expert members, is empowered to address complex environmental issues, including the awarding of compensation and the implementation of remedial measures [Paras 11-12, 16].

Decision – Appeal Allowed – The Supreme Court set aside the impugned order of the NGT, which had directed the appellants to approach a committee rather than continue with the proceedings. The Court restored OA No. 81 of 2014 (WZ) to the file of the NGT and directed it to commence hearings from the stage reached before the impugned order was passed. The appeal was allowed, and the NGT was instructed to take appropriate action based on the merits of the case [Paras 18-21].

Taxation – Exemption Notification – Conditions for Eligibility – The Supreme Court held that while exemption notifications should be liberally construed, the beneficiary must fall within the ambit of the exemption and fulfill the conditions thereof. If any conditions laid down in the notification are not fulfilled, the application of the notification does not arise. The Court emphasized that an exception or an exempting provision in a taxing statute should be construed strictly, and it is not open to the court to ignore the conditions prescribed in industrial policy and exemption notifications [Paras 14.1-14.4].

Doctrine of Promissory Estoppel – Application in Taxation – The Court rejected the High Court's application of the principle of promissory estoppel, stating that in taxation matters, each assessment year/period is independent. The principle of promissory estoppel does not apply where the eligible unit has not fulfilled the conditions of the exemption notification. The Court reiterated that statutory provisions providing for exemption have to be interpreted in light of the words employed in them, and there cannot be any addition or subtraction from the statutory provisions [Paras 19-20.4].

Penalty for Breach of Conditions – The Supreme Court upheld the imposition of penalty on the respondent for failing to fulfill the eligibility criteria and for breach of the declaration in Form No.26. The Court noted that the penalty is leviable under Section 45 of the Gujarat Sales Tax Act, 1969, where the difference between the tax paid and the tax assessed exceeds twenty-five percent. The respondent's act of transferring raw materials to an ineligible unit (Essar Power Limited) after availing the exemption was found to be a deliberate violation [Paras 23-23.2].

Decision – Appeal Allowed – The Supreme Court set aside the impugned judgment and order of the High Court, as well as the Tribunal's order. The Court held that the respondent was not entitled to the exemption from payment of purchase tax as it did not fulfill the eligibility criteria/conditions mentioned in the original Entry No.255(2) dated 05.03.1992 and there was a breach of the declaration in Form No.26. The orders setting aside the penalty imposed by the Assessing Officer were also quashed and set aside. The Assessing Officer's order levying the demand of purchase tax and imposing the penalty was restored [Paras 24-25].

Consumer Law – Jurisdiction of Consumer Forums – Revisional Jurisdiction – The Supreme Court held that the NCDRC exceeded its jurisdiction under Section 21(b) of the Consumer Protection Act, 1986 by calling for and relying on an additional report from the respondent-bank during the pendency of the revision application. The NCDRC's revisional jurisdiction is limited and should only be exercised in cases of jurisdictional error, failure to exercise jurisdiction, or material irregularity [Paras 8-9].

Limitation Act – Section 5 – Inapplicability to Civil Suits – The Court noted that the NCDRC's observation permitting the appellant to file an application under Section 5 of the Limitation Act, 1963 in a civil court was erroneous. Section 5 of the Limitation Act does not apply to the institution of civil suits, and the NCDRC's direction was based on a misinterpretation of the law [Para 12].

Principle of Natural Justice – Evidence and Reports – The Court criticized the NCDRC for seeking and relying on a report from the respondent-bank at the revisional stage without providing an opportunity for the appellant to respond. The report, produced at the revisional stage, was not available to the lower forums and should not have influenced the NCDRC's decision [Paras 10-11].

Decision – Appeal Allowed – The Supreme Court set aside the NCDRC's order and restored the State Commission's order, which had partly allowed the respondent-bank's appeal and confirmed the rest of the Consumer Forum's order. The NCDRC's reliance on additional evidence and erroneous application of the Limitation Act warranted the intervention of the Supreme Court [Paras 12-13].

Criminal Law – Quashing of Complaint – Section 482 CrPC – The Supreme Court held that allowing the criminal proceeding to proceed for offences under Sections 494 and 495 of the IPC would constitute an abuse of process. The Family Court had conclusively determined that the appellant did not have a subsisting marriage when she entered into the second marriage with the respondent. This finding, having attained finality, precluded further criminal proceedings based on the same facts [Paras 15-16].

Jurisdiction of Family Court – Determination of Marital Status – The Family Court, vested with the jurisdiction to determine the matrimonial status of a person under Section 7(1) of the Family Courts Act, 1984, had adjudicated the issues and declared the purported divorce null and void. The High Court's conclusion that the matter was highly contentious and needed to be tried on evidence was erroneous [Para 15].

Decision – Appeal Allowed – The Supreme Court set aside the impugned judgment of the Gauhati High Court and allowed the appellant's petition to quash the complaint. The criminal complaint pending in the Court of SDJM(S) II Kamrup (M) Guwahati was quashed [Paras 16-17].

Consumer Law – Delay in Possession – Non-compliance with ABA – Appellant failed to deliver possession of apartments in the promised state and time – NCDRC ordered refund with interest – Supreme Court upheld NCDRC’s decision based on breach of representation by the developer [Paras 1-26].

Building Plan Approval – Fire NOC Requirement – Appellant argued possession date starts from Fire NOC receipt – Court referenced Abhishek Khanna case, confirming possession period starts post Fire NOC – Delay in possession justified refund [Paras 17-20].

Interim Orders – Compliance – NCDRC interim order for possession not adhered to by appellant due to incomplete construction – Supreme Court affirmed NCDRC's refund order given non-compliance [Paras 21-22].

Decision: Appeals dismissed – NCDRC's orders for refund with interest upheld – Appellant failed to comply with ABA and interim orders, justifying refund and interest.

Constitutional Law – Reservation in Education – Constitutional validity of OBC and EWS reservation in AIQ seats – Permissibility under Article 15(5) – Reservation in postgraduate medical courses not prohibited – Reservation as a means to ensure substantive equality and address structural barriers faced by disadvantaged classes – Constitutional amendment and legislative provisions upheld [Paras 1-29].

Merit and Reservation – Reconceptualization of Merit – Merit not solely based on exam scores – Structural inequalities and socio-economic factors influencing merit – Reservation ensuring equal opportunity and addressing historical disadvantages – Merit as a social good advancing equality [Paras 17-29].

Judicial Precedent – AIQ Reservation – Development of AIQ seats through judicial decisions – No prohibition on reservation in AIQ seats for OBCs and EWS – Analysis of relevant cases and constitutional provisions [Paras 30-31].

Decision: Writ petitions challenging the validity of OBC and EWS reservation in AIQ seats dismissed – Constitutional validity of reservation provisions upheld – Reservation to be implemented in the current and subsequent academic years as directed by the court.

Service Law – Promotion Regulations – ESIC Recruitment Regulations 2015 vs. DACP Scheme – High Court erred in applying DACP Scheme over ESIC Recruitment Regulations 2015 for teaching cadre promotions – ESIC Recruitment Regulations 2015, being statutory, have precedence over DACP Scheme – Concession by appellant’s counsel before CAT irrelevant as legal position is clear [Paras 1-27].

Statutory Regulations – Precedence over Executive Instructions – DACP Scheme as executive instruction cannot override statutory ESIC Recruitment Regulations 2015 – Recruitment advertisements referencing DACP Scheme do not supersede statutory regulations – High Court’s reliance on DACP Scheme misplaced [Paras 10-25].

Estoppel and Concessions – No Estoppel against Statutory Provisions – Concession by appellant’s counsel before CAT not binding – Legal errors in concession do not affect statutory interpretation – Appeals court bound by correct legal position irrespective of lower court concessions [Paras 23-25].

Decision: Appeal allowed – High Court judgment set aside – Promotions to be governed by ESIC Recruitment Regulations 2015 – Revised seniority list to reflect promotions as per ESIC regulations, not DACP Scheme