Financial Crisis – COVID-19 Impact – Sree Padmanabha Swamy Temple faced financial crisis due to lockdown and lack of income – Routine rituals and salaries continued despite closure – Administrative Committee reported financial constraints and sought aid from Trust and Government [Paras 1A].

Special Audit – Compliance with Supreme Court Order – Special audit for 25 years directed by Supreme Court commenced – Issues with audit cooperation from related Trusts – Court emphasized necessity of audit to ensure transparency and proper fund utilization [Paras 1B, 1B.3, 5-6].

Trust's Independence – Miscellaneous Application by SPSTT – SPSTT claimed independence from Temple administration – Argued audit beyond Court's directive – Supreme Court rejected claim, citing interlinkages and necessity for comprehensive audit as per previous orders and directions [Paras 2-3, 6-7].

Decision – Application Partly Allowed – Held – Reiterated necessity of special audit of Sree Padmanabha Swamy Temple and SPSTT – Directed completion within three months – Ensured cooperation from SPSTT – Addressed financial crisis and audit compliance [Paras 6-10].

Industrial Disputes – Dismissal of Workmen – Disciplinary proceedings during conciliation – Supreme Court held Section 33(2)(b) ID Act applicable where misconduct not connected with the dispute – Misconduct related to vandalism of employer's property – Rejected Assistant Commissioner's finding requiring prior approval under Section 33(1)(b) – Appeal allowed, approval granted for dismissal under Section 33(2)(b) [Paras 10-14].

ection 33 Distinction – Connected vs. Unconnected Misconduct – Explained distinction between Section 33(1) requiring prior approval for misconduct connected with dispute and Section 33(2) permitting dismissal for misconduct not connected with the dispute – Emphasized factual determination of connection with the dispute – Supreme Court reiterated legislative history supporting balanced approach [Paras 9-11].

Compliance with Section 33(2)(b) – Confirmed compliance with Section 33(2)(b) requirements – Found no contrary evidence or findings – Reversed lower courts' misapplication of Section 33(1)(b) [Paras 13-14].

Decision – Appeal Allowed – Held – High Court judgment set aside – Approval granted for dismissal under Section 33(2)(b) – Clarified no impact on entitlements of deceased workmen's legal representatives [Paras 14-15].

Arbitration – Appointment of Arbitrator – Parties agreed on existence of arbitration agreements – Disputes arose under Construction Management Agreements – Respondents denied arbitrable dispute under said agreements, claimed it arose under Share Purchase Agreements – Supreme Court held disputes fell under CMAs' arbitration clauses – Narrow scope of review under Section 11(6) – Appointment of Justice (Retd.) R.V. Raveendran as sole arbitrator allowed [Paras 18-32].

Arbitration Clauses – Distinction and Application – Share Purchase Agreements contained SIAC arbitration clause with seat at Singapore – Construction Management Agreements contained Indian arbitration clause with seat at New Delhi – Supreme Court emphasized interpreting agreements harmoniously – Disputes related to construction obligations and fee payment fall under CMAs – Held Rajapura SPA/Southern Homes SPA arbitration clauses do not override CMAs' clauses [Paras 24-31].

Consolidation of Proceedings – Connected Agreements – RCMA and SCMA interlinked regarding fee computation and construction obligations – Supreme Court left consolidation decision to sole arbitrator – Emphasized avoiding conflicting awards and efficient resolution [Paras 34-35].

Decision – Petitions Allowed – Held – Appointment of sole arbitrator Justice (Retd.) R.V. Raveendran – Disputes to be resolved under arbitration clauses of CMAs – Arbitrator to decide on consolidation of proceedings – Fees as per Fourth Schedule of the Arbitration and Conciliation Act, 1996 [Paras 36-37].

NDPS Act – Bail Conditions – High Court granted bail based on absence of contraband possession and error in statement translation – Supreme Court held High Court failed to adhere to Section 37(1)(b) NDPS Act requirements – Emphasized need for "reasonable grounds" to believe accused not guilty and not likely to commit offences on bail – Set aside High Court order [Paras 17-21, 30-34].

Conscious Possession – Defined and Distinguished – Highlighted principles from previous cases on conscious possession and its relevance in drug-related offences – Supreme Court noted respondent's continuous travel with co-accused and involvement in communication supporting conscious possession [Paras 12, 22-24].

Procedural Compliance – Section 42 NDPS Act – Addressed respondent's argument on non-compliance with Section 42 – Held compliance was prima facie met, as information was recorded and communicated timely – Clarified that such procedural issues should be examined during trial [Paras 27-29].

Decision – Appeal Allowed – Held – High Court's bail order set aside – Respondent's bail application dismissed – Directed respondent to surrender forthwith – Emphasized strict adherence to statutory provisions for bail in NDPS cases to prevent misuse [Para 34-35].

Constitutional Law – Articles 14 and 16 – Educational Qualifications – Classification – Circular issued by Kolkata Municipal Corporation prescribing separate conditions for diploma and degree holders for promotion to supernumerary Assistant Engineer posts – Supreme Court upheld the classification as reasonable and in line with past promotion practices – Distinguished between equal opportunity and reasonable classification based on educational qualifications for administrative efficiency [Paras 1-5, 16-27].

Judicial Review – Classification and Promotion – Limited Scope – Court's scrutiny extends only to examining the reasonableness and rational basis of classification – Does not interfere with administrative policy unless arbitrary – Educational qualifications as a criterion for classification upheld as valid for enhancing administrative efficiency [Paras 18-19, 28-32].

Administrative Efficiency – Valid Ground for Classification – Previous judgments supported classification based on educational qualifications to achieve efficiency in public services – Classification not arbitrary if it bears a nexus to the objective sought to be achieved [Paras 16-20, 33-36].

Decision – Appeal Dismissed – Held – Circular prescribing separate conditions for promotion to supernumerary posts upheld – Classification based on educational qualifications found reasonable and not violative of Articles 14 and 16 – High Court’s decision affirmed [Paras 43-44].

Civil Procedure Code – Rejection of Plaint – Order VII Rule 11 – Court’s Power – Power to reject a plaint is drastic and must be exercised in clear cases where the plaint fails to disclose a cause of action or is barred by law – Plaintiffs sought declaration of entitlement to firm’s assets and dissolution of firm – High Court rejected plaint for lack of cause of action and legal tenability – Supreme Court upheld High Court’s decision emphasizing stringent adherence to Order VII Rule 11 CPC to prevent sham litigation [Paras 1-5, 13-22].

Cause of Action – Meaningful Reading – Required to examine entire plaint meaningfully, not formally – If meaningful reading shows vexatious and meritless claims with no clear right to sue, rejection under Order VII Rule 11 CPC warranted – Emphasis on preventing unnecessary protraction of meritless cases to save judicial time [Paras 14-15].

Partnership Firm – Legal Provisions – Sections 40, 42, 43, 44 of Indian Partnership Act, 1932 – Dissolution of firm possible only under specified conditions – Plaintiffs, not being partners, cannot seek dissolution – Clauses of Partnership Deed indicated firm’s continuation despite partners’ deaths – Reliefs sought legally untenable [Paras 10-11, 18].

Decision – Appeals Dismissed – Held – High Court’s order upheld – Reliefs sought in plaint found legally untenable based on meaningful reading of plaint and relevant legal provisions – Rejection of plaint appropriate under Order VII Rule 11 CPC to prevent futile litigation [Paras 22].

Service Law – Misuse of Service Weapon – Departmental Proceedings – Respondent dismissed for firing service weapon causing death and injury – Acquitted in criminal trial due to lack of evidence – Reinstated but later faced departmental inquiry – Evidence from departmental witnesses confirmed misuse of official weapon – High Court’s reinstatement order overturned due to erroneous interference with disciplinary findings – Supreme Court emphasized difference in standards of proof between criminal and departmental proceedings [Paras 3-4, 15-20, 29].

Judicial Review – Scope and Limitations – High Court exceeded jurisdiction by reappreciating evidence in disciplinary proceedings – Judicial review limited to ensuring fairness, compliance with principles of natural justice, and absence of procedural irregularities – Findings based on substantial evidence and adherence to procedures should not be disturbed [Paras 22-23].

Evidence and Procedure – Adequacy of Evidence – Disciplinary findings upheld based on testimonies and circumstantial evidence – Oral testimonies corroborated misuse of service weapon – Burden of proof in departmental inquiries based on preponderance of probabilities, not beyond reasonable doubt – High Court’s reliance on absence of physical evidence misplaced given circumstances and procedural context [Paras 19-20, 28-29].

Decision – Appeal Allowed – Held – High Court’s order set aside – Original dismissal order reinstated – Emphasized importance of maintaining discipline within armed forces and respecting disciplinary authority’s findings unless procedurally flawed [Para 30].

Encroachment – Land Measurement Dispute – Plaintiff alleged defendants encroached land purchased in 1995 – Trial Court dismissed suit, noting defendants possessed land since 1969 and plaintiff acknowledged encroachment in sale deed – Appellate Court upheld dismissal – High Court ordered surveyor measurement, findings indicated defendants encroached 38 R (40888 sq. ft.) land – High Court failed to independently address substantial question of law based on surveyor’s findings – Supreme Court held High Court's omission critical, remanded case for reconsideration of substantial question of law [Paras 2-11].

Substantial Question of Law – Requirement of Findings – High Court must record findings on formulated substantial questions of law – Lacking specific determination on critical legal issue leads to failure in legal scrutiny – Importance of addressing contradictions in land occupation vs. sale deed areas emphasized – Court’s assessment should integrate new evidence from surveyor report [Paras 10-11].

Decision – Appeal Allowed – Held – High Court’s judgment set aside – Case remanded to High Court for addressing substantial question of law within six months – Urged expeditious resolution due to prolonged litigation [Paras 12-13].

Service Law – Change of Date of Birth – Delay and Laches – Application for change of date of birth in service records must comply with relevant statutory provisions – Karnataka State Servants (Determination of Age) Act mandates application within three years from date of birth recording or within one year from Act commencement – Employee's application made 24 years post-joining and 16 years post-Act adoption, thus invalid – Supreme Court upheld rejection based on delay and laches, emphasizing no entitlement as matter of right despite cogent evidence – High Court’s grant of relief was erroneous and unsustainable [Paras 7-12].

Legal Precedents – Judicial Consistency – Referenced cases reinforce stringent scrutiny for date of birth alterations at service end – Emphasized need for procedural compliance and rejection of applications causing systemic disruptions and prejudicing other employees’ promotions – Referenced cases include Bharat Coking Coal Ltd. v. Shyam Kishore Singh, Home Deptt. v. R. Kirubakaran, and Life Insurance Corporation of India v. R. Basavaraju [Paras 9.1-9.4].

Decision – Appeals Allowed – Held – High Court judgment set aside – Application for date of birth alteration rejected due to delay and non-compliance with statutory provisions – Noted judgment's effectuation on respondent's retirement already settled, thus case specifics retained unaffected – Question of law resolved in favor of appellant [Paras 11-13].