Civil Procedure – Rejection of Plaint – Limitation – Plaintiffs filed suit in 1987 challenging tenancy order and sale certificate from 1963 and 1954 respectively – Claimed lack of notice and fraud in proceedings – Supreme Court emphasizes limitation as a mixed question of fact and law, asserting that claims of knowledge at a particular time must be accepted at Order 7 Rule 11 stage – Courts erred in rejecting plaint without considering evidence on plaintiffs' lack of notice [Paras 10-14].

Jurisdiction – Section 85 and 85A of Maharashtra Tenancy and Agricultural Lands Act – Bar of Civil Court jurisdiction not absolute – Section 85A mandates Civil Court to refer issues to competent authority under Act before deciding suit – Plaintiffs alleged fraud and collusion in tenancy proceedings – Civil Court required to examine these claims and possible exemption under Section 88-B before rejecting plaint [Paras 20-25].

Decision – Appeal allowed – Judgments of trial court and High Court set aside – Suit restored to file – No order as to costs [Para 26].

Service Law – Judicial Appointments – Criminal Antecedents – Candidate involved in multiple criminal cases acquitted, but not honorably – High Court allowed writ petition for appointment to Civil Judge post – Supreme Court emphasized the importance of judicial officers’ integrity and public confidence – Found committee's decision to deny appointment based on antecedents justified – High Court's interference unwarranted [Paras 2-30].

Public Employment – Judicial Discretion – Employer’s Right to Assess – Employer's discretion to assess candidate’s suitability considering antecedents – Acquittal not always equivalent to clean slate – Importance of maintaining high standards for judicial appointments highlighted – Supreme Court found no fault in committee's process and decision [Paras 22-30].

Decision – Appeal allowed – High Court’s order set aside – Respondent's appointment as Civil Judge (Junior Division) not endorsed – No order as to costs [Paras 31-33].

Criminal Law – Murder vs. Culpable Homicide – Distinction – Incident where the appellant was accused of running over a police officer after a truck inspection – Appellant initially convicted under Section 302 IPC – Supreme Court reevaluated circumstances, noting absence of premeditation and direct animus – Conversion of conviction to Section 304 Part I IPC justified, considering the act was in the heat of passion without clear intention to kill [Paras 9-16].

Criminal Intent – Analysis – Accused's reaction to police officer boarding the truck seen as instinctive and disproportionate rather than intentional murder – Evidence did not support deliberate action to kill – Supreme Court highlighted need for nuanced understanding of intent in such cases [Paras 11-15].

Decision – Conviction altered from Section 302 IPC to Section 304 Part I IPC – Sentence modified to 10 years of rigorous imprisonment instead of life imprisonment – Fine maintained as directed by lower courts [Para 16].

Civil Procedure – Disclosure and Discovery – Commercial Suits – Appellant sought to place additional documents on record under Order VII Rule 14(3) CPC – Commercial Court and High Court dismissed the application – Supreme Court analyzed Order XI Rule 1 applicable to commercial suits, emphasizing the need to disclose all documents in possession at the time of filing – Additional documents discovered later can be filed within 30 days with the court's leave – Rigour of establishing reasonable cause for non-disclosure at the time of filing applies only to documents in possession [Paras 7-8].

Document Production – Commercial Courts Act – Applicability – Application under Order VII Rule 14(3) CPC misapplied as Order XI Rule 1 governs commercial suits – Plaintiff allowed to file additional documents discovered after the plaint within 30 days – Documents in possession at filing require reasonable cause for later submission – Supreme Court granted leave to file invoices found later but rejected inclusion of other voluminous documents not filed initially due to plaintiff's negligence [Paras 8.1-8.5].

Decision – Appeal partly allowed – High Court's order set aside to permit filing of additional invoices – Application to file other documents dismissed due to lack of reasonable cause for non-disclosure at initial filing – No costs [Paras 9-10].

Arbitration Law – Interim Measures – Appeal against High Court’s order directing Commercial Court to adjudicate applications under Section 9 of the Arbitration Act post-constitution of an Arbitral Tribunal – Court’s power to entertain applications under Section 9(1) once the Tribunal is constituted – Supreme Court held Section 9(3) restricts court's role unless the remedy under Section 17 is inefficacious – Emphasized the process of consideration under Section 9(3) ends once the application is entertained and under active consideration by the court [Paras 1-12, 93-101]​​.

Definition of "Entertain" – Court interpreted "entertain" to mean considering an application on merits – High Court's direction to Commercial Court to proceed with adjudication upheld – Court emphasized that legislative intent behind Section 9(3) is to minimize judicial intervention once an Arbitral Tribunal is constituted [Paras 94-108]​​.

Decision – Appeal partly allowed – Clarification provided that efficacy of relief under Section 17 need not be considered by the Commercial Court as the application under Section 9 was already entertained and considered – Commercial Court directed to complete adjudication without reevaluating the remedy under Section 17 [Paras 102-108]​​.

Municipal Law – Demolition of Building – Appeal against demolition order under Section 322 of Karnataka Municipal Corporations Act, 1976 – Building demolished within three days of notice – High Court held demolition lacked statutory notice period – Supreme Court upheld High Court’s finding but modified compensation amount – Notice served on 6.1.1995; demolition on 9.1.1995 – Court emphasized statutory tenants' rights under the Rent Act cannot override public safety measures under the Municipal Corporations Act [Paras 1-10, 34-44]​​.

Double Protection under Rent Act and TP Act – Applicability – Statutory tenants under Rent Act cannot claim double protection under Transfer of Property Act – Tenants must seek remedies within the framework of the Rent Act, not under the general provisions of the TP Act – Court held statutory tenant’s rights arise solely under the Rent Act [Paras 24-32]​​.

Decision – Appeals allowed in part – High Court order set aside – Both suits dismissed – Appellant ordered to pay Rs. 5 lakhs as compensation for demolition without adequate notice – Compensation payable to legal heirs of deceased plaintiff within two months [Paras 43-44]​​.

Criminal Law – Abetment of Suicide – Appellant convicted under Section 306 IPC and Section 4(b) of the Tamil Nadu Prohibition of Harassment of Women Act for allegedly causing his wife's suicide – Incident involved both the appellant and his wife consuming pesticide, with the appellant surviving – Supreme Court held mere harassment without any active role or positive action proximate to the time of occurrence insufficient for conviction under Section 306 IPC – Emphasized the requirement of instigation or facilitative action leading to the suicide – Conviction and sentence by lower courts set aside [Paras 1-10]​​.

Application of Section 113-A Evidence Act – Not applicable – Marriage duration of 25 years excluded presumption of abetment under Section 113-A [Para 8]​​.

Decision – Appeal allowed – Conviction under Section 306 IPC and Section 4(b) of Tamil Nadu Prohibition of Harassment of Women Act quashed – Appellant's bail bonds discharged [Para 11]​​.

Insolvency Law – Limitation for Appeals – Appellant sought to file an appeal beyond the 45-day period allowed under Section 61(2) of the IB Code – NCLAT dismissed the appeal, holding it lacked jurisdiction to condone delay beyond 15 days – Supreme Court upheld NCLAT's decision, emphasizing the strict statutory limits on condoning delay in insolvency proceedings [Paras 1-13]​​.

Article 142 of the Constitution – Application in Insolvency Cases – Appellant argued for delay condonation under Article 142 due to substantial public interest and fraud allegations – Supreme Court held Article 142 cannot be used to circumvent explicit statutory limitations – Highlighted the principle that law prevails over equitable considerations when statutory provisions are clear [Paras 5.1-5.4, 6.5, 7-11]​​ .

Decision – Appeal Dismissed – Supreme Court affirmed NCLAT's decision not to condone the delay – Reinforced the binding nature of statutory limitations in insolvency cases [Para 13]​​ .

Compassionate Appointment – Eligibility of Divorced Daughter – Appeal against High Court's decision directing consideration of respondent’s application for compassionate appointment – Respondent’s mother, a government employee, died while respondent was married – Respondent obtained divorce after mother’s death and applied for compassionate appointment – Supreme Court held that, under Rule 3 of the 1996 Rules, only an "unmarried daughter" or "widowed daughter" at the time of the deceased’s death is eligible – Divorce obtained after death does not change eligibility – High Court’s direction quashed [Paras 1-9]​​.

Interpretation of Rules – Norms for Compassionate Appointment – Court emphasized adherence to specific eligibility criteria laid down in Rules 2 and 3 of the 1996 Rules – "Divorced daughter" not included in the definition of dependent under these rules – Compassionate appointment norms prevailing at the time of the deceased’s death are applicable [Para 8.1]​​.

Marriage Status at Time of Death – Importance in Determining Dependency – Supreme Court noted respondent was married at the time of the deceased’s death, thus not qualifying as a dependent "unmarried daughter" or "widowed daughter" – Subsequent divorce did not retroactively change status [Para 8.3]​​.

Decision – Appeal allowed – High Court's judgment and order set aside – Writ Petition dismissed – No order as to costs [Para 9]​​.