Cut-Off Percentile for Admission – Reduction Sought – Petitioners requested a reduction in the cut-off percentile for admission to Super Specialty medical courses due to 940 vacant seats for the academic year 2021-2022. The plea was based on the reduction in cut-off percentiles in previous years and a significant number of vacant seats. The court declined the reduction, emphasizing the importance of maintaining standards for Super Specialty courses [Paras 1-11].

Vacant Seats – NEET Super Specialty Counselling – The court acknowledged the issue of vacant seats in Super Specialty courses but upheld the respondent's decision to maintain the cut-off percentile at 50 for the academic year 2021-2022. The decision was based on ensuring merit and maintaining high academic standards in medical education [Paras 6-10].

Article 32 – Jurisdiction Invoked – The petition under Article 32 was invoked to address the respondents' refusal to lower the eligibility percentile. The court found no extraneous or arbitrary reasoning in the respondents' decision, emphasizing that such policy decisions fall within the domain of academic and administrative authorities [Paras 9-10].

Mop-Up and Stray Vacancy Round – Directed – Despite rejecting the plea for lowering the percentile, the court directed a mop-up and stray vacancy round of counselling to fill the vacant seats, maintaining the eligibility percentile at 50 [Para 10].

Decision: Writ Petition Disposed – The court disposed of the petition, upholding the decision of the respondents while directing an additional round of counselling for vacant seats [Para 11].

Trusteeship – Eligibility Criteria – Residence Requirement – The appellant, a Green Card holder of the United States, contested his disqualification from the position of founder trustee of the respondent-Trust on the grounds of not residing within the "Madras Presidency" as required by the Scheme of Administration (SOA). The Trial Court found the appellant qualified, considering his Indian citizenship, possession of Indian property, and intent to reside in India. However, the High Court reversed this decision, emphasizing the appellant's permanent residence in the U.S.A. and insufficient time spent in India [Paras 1-88].

Green Card Holder – Citizenship and Residence – The Trial Court ruled that holding a Green Card is a privilege and does not automatically terminate Indian citizenship. The appellant provided evidence of residing in India, including an Aadhaar card, Indian passport, property ownership, and bank accounts. The High Court’s view that the appellant’s stay in India was insufficient and did not meet the residency requirement was deemed incorrect [Paras 46-48].

Literal vs. Contextual Interpretation – The High Court's strict interpretation of "resides" was deemed inappropriate. The Supreme Court emphasized a contextual and contemporary understanding of terms, considering advancements in communication and transportation, aligning with the intent and spirit of the SOA to ensure effective participation in Trust affairs [Paras 27-29.1].

Estoppel and Res Judicata – The Supreme Court observed that the principle of estoppel may not apply as the appellant's qualification was not directly adjudicated in earlier litigation. However, the principle of constructive res judicata was relevant as the question of the appellant’s qualification could have been raised in prior proceedings and was not contested by the respondents [Paras 32-32.2].

Decision: Appeal Allowed – The Supreme Court allowed the appeal, setting aside the High Court’s judgment, and restoring the Trial Court's judgment and decree. The appellant was declared entitled to the office of founder trustee, and the appointment of the respondent No. 10 was annulled [Paras 33-34].

Bidding Process – Annulment – Justification – The appeals challenge the annulment of the bidding process for the Nagpur Airport project. The Court considered whether the annulment was arbitrary and without valid reason, focusing on the terms of the RFQ and RFP and the statutory provisions under the Airports Authority of India Act, 1994 [Paras 1-17].

Letter of Award (LoA) – Status as Concluded Contract – The appellants contended that the letter dated 07.03.2019 issued to GMR Airports Limited (GAL) constituted a Letter of Award (LoA) and thus a concluded contract. The Court upheld this view, stating that the LoA created a binding contractual obligation [Paras 24-25].

Arbitrariness – Exercise of Power – The Court scrutinized the reasons provided by the respondents for the annulment, including financial viability and procedural deviations. It was held that the annulment was arbitrary, lacking justifiable grounds, and violative of Article 14 of the Constitution of India, which prohibits arbitrary state action [Paras 30-32].

Public Interest – Financial Considerations – The respondents argued that the revenue share offered by GAL was insufficient compared to the profit earned by MIHAN India Limited (MIL). The Court emphasized that public interest considerations must be balanced with private legitimate interests, and arbitrary decisions cannot be justified merely on financial grounds without substantial evidence [Paras 35-37].

Cabinet Approval – Necessity and Process – The necessity of cabinet approval for leasing airport land was discussed. The Court clarified that the process involves licensing, not leasing, and that objections based on Section 12A of the Airports Authority of India Act, 1994 were misplaced [Paras 39-41].

Decision: Appeals Allowed – The Court allowed the appeals, setting aside the order of annulment, and directed the execution of the Concession Agreement as per the terms of the LoA issued to GAL. The decision of the Nagpur Bench of the Bombay High Court was upheld [Paras 42-47].

Specific Performance – Extension of Time – Consent Decree – The appellant sought the extension of time for payment of sale consideration under a consent decree. The Trial Court allowed the extension, which was later challenged and set aside by the High Court. The Supreme Court reinstated the Trial Court's decision, emphasizing the discretionary power of the court under Section 28 of the Specific Relief Act, 1963, to extend the time for payment to prevent manifest injustice [Paras 3-14].

Section 28 of the Specific Relief Act, 1963 – Discretionary Power – The Court highlighted that Section 28 allows for rescission of the contract if the purchaser fails to pay within the stipulated time but also permits the court to extend the time for payment. This power is discretionary and should be exercised to ensure justice, even in cases involving a consent decree [Para 10].

Rescission and Extension – Complete Relief – The Court noted that Section 28 seeks to provide complete relief to both parties by allowing for rescission or extension of time for payment within the same suit, thus avoiding separate proceedings. The section ensures that the court retains control over the decree for specific performance even after it has been passed [Para 11].

Case Law Reference – The Court referred to Smt. Periyakkal and Ors. v. Smt. Dakshyani (1983) 2 SCC 127, which established that courts could extend the time for payment even in consent decrees to prevent injustice [Para 11].

Decision: Appeal Allowed – The Supreme Court allowed the appeal, setting aside the High Court's judgment and restoring the Trial Court's order that extended the time for the appellant to deposit the balance sale consideration [Para 14].

Arbitration – Group of Companies Doctrine – The petition called into question the applicability of the Group of Companies Doctrine in Indian arbitration law, particularly under Section 8 of the Arbitration and Conciliation Act, 1996. The doctrine's relevance, interpretation, and the extent to which it can bind non-signatory parties to an arbitration agreement were examined and referred to a larger bench for a conclusive determination [Paras 1-50].

Party Autonomy – Corporate Personality – The Court addressed whether principles of party autonomy and corporate personality are adequately safeguarded when applying the Group of Companies Doctrine. It questioned if the doctrine, which involves considering a corporate group as a single economic entity, undermines the distinct legal identities of individual companies within the group [Paras 15-18].

International Jurisprudence – Comparative Analysis – The Court compared the application of the Group of Companies Doctrine in various jurisdictions, noting that while some countries like France accept the doctrine under certain conditions, others like England and the United States are more restrictive. The Court emphasized that the application of the doctrine should be based on the clear intention of the parties to arbitrate [Paras 19-42].

Doctrine of Group of Companies – Relevance in India – The Court analyzed the evolution and application of the doctrine in Indian jurisprudence, starting from the Chloro Controls case. It discussed the necessity for a legal basis to bind non-signatories to arbitration agreements and the implications of expanding the doctrine on the principle of party autonomy [Paras 21-47].

Referral to Larger Bench – Given the fundamental questions raised and the significant impact on arbitration practice, the Court referred the matter to a larger bench to address the following key issues:

a. Whether the phrase 'claiming through or under' in Sections 8 and 11 of the Arbitration Act could be interpreted to include the Group of Companies Doctrine.

b. Whether the Group of Companies Doctrine as expounded in Chloro Controls and subsequent judgments is valid in law [Para 50].

Decision: Matter Referred to Larger Bench – The Supreme Court referred the matter to a larger bench for a comprehensive examination of the Group of Companies Doctrine and its applicability under the Arbitration and Conciliation Act, 1996 [Paras 48-50].

Res Judicata – Preliminary Issue – The trial court was directed by the High Court to frame the preliminary issue of res judicata, a mixed question of law and fact. The Supreme Court held that such an approach is undesirable for ensuring speedy disposal of cases. Order XIV Rule 2 of the CPC mandates the court to pronounce judgments on all issues unless it pertains to the jurisdiction of the court or a statutory bar to the suit [Paras 1-32].

Mixed Issues of Law and Fact – Comprehensive Adjudication – The Court emphasized that issues of res judicata involve both legal and factual determinations. Thus, they cannot be resolved solely on legal grounds without considering the factual matrix. The Court should avoid piecemeal trials to prevent delays caused by potential remands in appellate proceedings [Paras 16-22].

Order XIV Rule 2 – Legislative Intent – The legislative amendments to Order XIV Rule 2 aim to eliminate delays in the judicial process by ensuring that all issues, both legal and factual, are addressed together. This prevents fragmented trials and promotes expeditious resolutions [Paras 7-9].

Judicial Precedents – Interpretation – The Court referred to various precedents, including Major S.S. Khanna v. Brig. F.J. Dillon, which underscores the principle that courts should not decide on mixed issues of law and fact as preliminary issues. The decision in Ramesh B. Desai and Ors. v. Bipin Vadilal Mehta and Ors. reaffirmed this approach, stating that preliminary issues should only be those involving clear questions of law or statutory bars [Paras 6, 15, 21].

Decision: Appeal Allowed – The Supreme Court allowed the appeal, setting aside the High Court’s order. The trial court was directed to record findings on all issues, facilitating a comprehensive appellate review and avoiding unnecessary remands [Paras 34-35].

Acquisition Proceedings – Lapsing Under 2013 Act – The appeal examines if the acquisition proceedings initiated under the Land Acquisition Act, 1894, and concluded, can lapse under Section 24(2) of the 2013 Act when challenged by a subsequent purchaser. The Court held that a subsequent purchaser is not entitled to claim lapsing of the proceedings under the 2013 Act [Paras 1-44].

Section 24(2) of 2013 Act – Conditions for Lapse – The Court emphasized that for acquisition proceedings to lapse under Section 24(2), two conditions must be satisfied: possession not taken and compensation not paid. This decision aligned with the principles laid down in Indore Development Authority v. Manoharlal & Ors., 2020 [Paras 29-31].

Judgment in Personam vs. Judgment in Rem – The Court distinguished between judgments affecting specific parties (in personam) and those affecting the rights of the public (in rem). It concluded that previous judgments like Balbir Singh did not confer rights upon other landowners who did not dispute acquisition proceedings themselves [Paras 36-37].

Possession and Compensation – The Court found that possession of the disputed land had been taken, and compensation had been deposited, thus fulfilling the requirements to prevent the lapse of acquisition proceedings under the 2013 Act. Re-entry by the landowners would be considered trespassing after possession was taken by the state [Paras 30-31, 39-41].

Subsequent Purchasers – Legal Standing – The Court held that subsequent purchasers cannot claim lapsing of acquisition proceedings because their rights are derived from the original landowners, who must have contested the acquisition timely. The legal standing of subsequent purchasers was limited as clarified in Shiv Kumar & Anr. v. Union of India & Ors., 2019 [Paras 42-43].

Decision: Appeal Allowed – The Supreme Court allowed the appeal, setting aside the High Court’s order. The acquisition proceedings were held valid, and the subsequent purchaser's claim for lapsing was rejected. The appellant was directed to refund the amount deposited by the respondent without interest as the deposit was a voluntary offer [Paras 44].

Acquisition Proceedings – Lapsing Under 2013 Act – Subsequent Purchaser – The appeal examines the entitlement of a subsequent purchaser to claim the lapsing of acquisition proceedings under Section 24(2) of the 2013 Act. The Court held that a subsequent purchaser is not entitled to claim lapsing of the proceedings under the 2013 Act [Paras 1-11].

Twin Conditions for Lapse – The Court reiterated that for acquisition proceedings to lapse under Section 24(2) of the 2013 Act, two conditions must be satisfied: possession not taken and compensation not paid. These conditions were laid down in Indore Development Authority v. Manoharlal & Ors., 2020 [Paras 5-6].

Compensation Payment – Tender and Deposit – The Court clarified that compensation must be tendered to the persons interested, and merely depositing the compensation in court without first offering it to the landowner does not fulfill the payment requirement under Section 24(2) of the 2013 Act [Paras 9].

Dismissal of High Court Judgment – The High Court's judgment declaring the acquisition proceedings as lapsed was set aside. The Court found that the subsequent purchaser could not claim the lapse of acquisition proceedings, and the compensation was duly tendered [Paras 10-11].

Decision: Appeal Allowed – The Supreme Court allowed the appeal, setting aside the High Court's judgment, and dismissed the writ petition filed by the respondents [Paras 10-11].

Judicial Misconduct – Disciplinary Proceedings – The appellant, a judicial officer, challenged the punishment order issued by the State based on the High Court’s decision following an enquiry report. The Court upheld the High Court’s findings, emphasizing the need for judicial officers to maintain high standards of integrity, honesty, and probity. It was determined that the appellant had shown undue favor to subsequent purchasers of acquired land, which constituted judicial misconduct [Paras 1-16].

Suspicion and Misconduct – Evidence Required – Mere suspicion cannot constitute misconduct; however, in this case, there was sufficient evidence and material showing the appellant had misconducted himself by passing judicial orders to unduly favor subsequent purchasers. The Court emphasized that judicial orders must be based on facts and applicable law, not extraneous considerations [Paras 14-15].

Disciplinary Review – Judicial Standards – The Court reiterated the principles for disciplinary actions against judicial officers, emphasizing that judicial behavior must be of an exacting standard both inside and outside the court. It underscored that decisions taken for extraneous reasons undermine public confidence in the judicial system [Paras 5-10].

Decision: Appeal Dismissed – The Supreme Court dismissed the appeal, finding no merit in the appellant's contentions and upholding the High Court’s decision to punish the appellant by curtailing his pensionary benefits due to proven judicial misconduct [Para 16].