Tenancy Law – Ownership Certificate – Protected tenant granted ownership certificate under Section 38E of the Tenancy Act – Appeals against occupancy rights withdrawn as inconsequential after ownership certificate issuance – Ownership vests unambiguously with protected tenants – Purchasers divested of ownership rights – Certificate undisputed by purchasers [Paras 1-21].

Interim Injunction – Grant of Interim Protection – Respondent’s application for interim injunction initially dismissed by trial court – High Court reversed trial court's decision based on prima facie possession and title of respondent supported by ownership certificate and mutation records – Supreme Court upheld High Court's decision granting interim injunction pending suit disposal [Paras 1-21].

Prior Suit and Injunction – Impact of Prior Suit – Previous suit by respondent’s vendor dismissed as withdrawn without recording possession findings – High Court correctly noted prior suit’s dismissal had no bearing on present suit’s maintainability – Previous dismissal of injunction application due to land being open and vacant [Paras 12-16].

Decision: Special Leave Petition dismissed – High Court’s order granting interim injunction affirmed [Para 19].

Land Acquisition – Notification under Section 48(1) – Notification for acquisition under Section 4(1) of the Land Acquisition Act 1894 takes away individual’s property rights, while a Notification under Section 48(1) confers benefits – Such notifications do not warrant notice or hearing to landowners – If anyone is aggrieved, it would be the beneficiary of the acquisition (Parishad) – Appeals allowed, High Court's order set aside, and writ petitions dismissed [Paras 1-27].

Fraud and Misrepresentation – Landowners obtained Notification under Section 48(1) by making false representations – Once the land was released, they started selling it, contradicting their earlier claims of religious sentiments and cemeteries – Notifications secured by fraud do not confer vested rights and can be rescinded [Paras 15, 24-25].

General Clauses Act, Section 21 – Power to issue Notification includes power to rescind – Notification under Section 48(1) is administrative, not quasi-judicial, allowing application of Section 21 of the General Clauses Act – Government can rescind such Notifications without fresh acquisition process [Paras 10, 20-23].

Decision: Appeals allowed – High Court’s orders set aside – Writ petitions dismissed – Parishad may proceed to implement the public purpose for which the land was acquired – No order as to costs [Para 27].

Burden of Proof – Full and Final Settlement – Defendants admitted receipt of Rs. 1,050,000/- and partial repayment of Rs. 500,000/-, claimed it as full and final settlement – No written proof of settlement – Oral evidence of mediators insufficient without documentary evidence – Defendants failed to prove the onus of settlement – Plaintiff entitled to recovery despite discrepancies in her evidence [Paras 16-18].

Unauthorized Withdrawals – Business Dealings – Plaintiff alleged unauthorized withdrawals and transfers totaling Rs. 5,450,000/- by defendants – Defendants claimed amounts as investments in real estate business and partially as gratuitous payment – Defendants failed to produce business accounts to justify the amounts – Affidavit claiming gratuitous payment lacked plaintiff's signature and contradicted claims of settlement – Defendants' plea of gratuitous payment and full settlement not credible [Paras 19-24].

Indian Contract Act, 1872 – Section 70 – Non-gratuitous Acts – Defendants admitted receipt of money from plaintiff – Failed to prove payment was gratuitous – Defendants bound to compensate plaintiff for the amounts received and benefits enjoyed under Section 70 [Paras 25-27].

Decision: Appeals allowed – High Court’s judgment and decrees set aside – First Appellate Court’s judgment and decrees restored – Plaintiff entitled to costs of Rs. 50,000/- – Amount deposited by appellant with interest to be released to her [Para 28].

Condonation of Delay – Appeal against Order – Respondent's delay of 1011 days in preferring the Second Appeal condoned by the High Court – No sufficient or satisfactory explanation provided for the delay – Courts cannot entertain belated and stale claims on equity grounds – Delay defeats equity – The High Court failed to exercise discretion judiciously – Appeal allowed and delay condonation set aside [Paras 1-9].

Judicial Discretion – Sufficient Cause – Application for condonation of delay requires a sufficient cause – Mere absence of willful negligence is not enough – The High Court's reasoning was not germane to the case – Judicial discretion must be exercised based on established legal principles [Paras 6-8].

Precedents and Legal Principles – Referenced cases emphasize that limitation laws serve public policy and promote legal certainty – The expression “sufficient cause” should not be liberally interpreted where negligence, inaction, or lack of bona fides is apparent – Previous cases cited include Ramlal Motilal and Chhotelal vs. Rewa Coalfields Ltd., P.K. Ramachandran vs. State of Kerala, Pundlik Jalam Patil vs. Executive Engineer Jalgaon Medium Project, and Basawaraj vs. Special Land Acquisition Officer [Paras 7.1-7.5].

Decision: Appeal allowed – High Court’s order condoning the delay set aside – Second Appeal No. 331 of 2021 dismissed due to delay – No order as to costs [Para 9].

Criminal Law – Murder Conviction – Prosecution's burden to prove guilt beyond a reasonable doubt – Conviction based on interested and related witnesses' testimony – Court found inconsistencies in the prosecution's case, including discrepancies in witness statements, the manner of arrests, and lack of independent corroboration – High Court erred in confirming the death penalty without sufficient scrutiny – Appeals allowed, acquittal of all appellants ordered [Paras 1-86].

Burden of Proof – Section 27 of Evidence Act – Recovery of weapons and clothes allegedly used in the crime – Prosecution failed to provide independent witnesses for recoveries – Statements related to confessions inadmissible – Inconclusive forensic reports further weaken the prosecution's case – Accused benefit from reasonable doubt principle [Paras 54-57, 69-72].

Judicial Scrutiny – Death Penalty – Trial Court and High Court failed to exercise the necessary care and caution – Judgment based on conjectures and surmises – Proper legal standards for scrutiny in capital punishment cases not followed – Convictions and sentences set aside [Paras 72-83].

Decision: Appeals allowed – Conviction and death sentences of Momin Khan (A-1), Jaikam Khan (A-3), and Sajid (A-4) set aside – Appellants ordered to be released forthwith if not required in any other case – Appeal filed by P.W.1-Ali Sher Khan against acquittal of Nazra (A-2) dismissed [Paras 84-85].

One Time Settlement (OTS) Scheme – Non-Performing Asset (NPA) – Bank initiated proceedings under SARFAESI Act – Respondent's loan account categorized as NPA – Respondent applied for OTS which was rejected by the bank due to eligibility criteria – High Court issued a writ of mandamus directing bank to consider the application positively – Supreme Court held that no borrower can demand OTS as a right – Bank's discretion under commercial wisdom to grant OTS based on eligibility and recoverability – High Court's direction set aside [Paras 1-13].

Judicial Review – Article 226 – Writ of Mandamus – High Court cannot compel a financial institution to grant OTS – Grant of OTS subject to bank's discretion and guidelines – Borrower’s capacity to pay and recoverability of loan crucial – Judicial interference limited to procedural propriety not commercial decisions [Paras 11-12].

Commercial Decisions – SARFAESI Act – Recovery Proceedings – Proper scrutiny required for declaring NPA – Auctioning of mortgaged property as a recovery method – Courts respect commercial wisdom of banks in financial matters – Encouraging honesty and fairness in loan repayment [Paras 8-10].

Decision: Appeal allowed – High Court’s judgment and mandamus directing the bank to consider the OTS application positively set aside – Bank’s decision to reject OTS application upheld – No order as to costs [Para 13].

Arbitration Award – Setting Aside of Arbitral Award – Order passed by Facilitation Council without following arbitration procedure – Council’s order was challenged in writ petition – High Court dismissed the petition – Supreme Court held that the order of the Facilitation Council was a nullity as it bypassed mandatory arbitration procedure under MSMED Act and Arbitration and Conciliation Act – Appeal allowed, Council’s order set aside – Matter remanded to Council for arbitration proceedings as per law [Paras 1-14].

MSMED Act – Section 18 – Conciliation and Arbitration – Council must conduct conciliation before arbitration – Provisions of Arbitration and Conciliation Act apply to arbitration under MSMED Act – Council's failure to initiate arbitration after conciliation renders its order invalid – Proper opportunity to be given to parties for arbitration [Paras 7-13].

Judicial Review – Article 226 of the Constitution – Writ of Mandamus – High Court’s power to issue writ for non-compliance with statutory provisions – Court held that writ can be issued where statutory procedures are not followed – High Court erred in dismissing the petition without considering procedural lapses [Paras 12-13].

Decision: Appeal allowed – High Court’s judgment and Facilitation Council’s order set aside – Case remanded to Facilitation Council for fresh arbitration proceedings as per statutory requirements – No order as to costs [Para 14].

Examination Question – Validity – Question regarding the Panchayati Raj Minister in Uttar Pradesh at the time of the exam was ambiguous due to the minister's recent death – Commission decided to award marks to candidates who chose the correct answer as per the pre-death scenario or left it unanswered – Respondent who chose an incorrect option sought relief – Supreme Court held the Commission's decision was not palpably arbitrary – High Court's direction to delete the question or award marks to the respondent set aside [Paras 1-15].

Judicial Review – Examination Decisions – Supervisory jurisdiction – Court’s role not to act as an appellate body in exam matters unless decisions are palpably perverse – Commission’s rationale of awarding marks to candidates who answered correctly based on the information before the death or left unanswered upheld [Paras 12-14].

Precedents and Principles – Cited cases on exam question disputes – Guru Nanak Dev University v. Saumil Garg and Others (2005) 13 SCC 749 – Kanpur University Through Vice Chancellor v. Samir Gupta (1983) 4 SCC 309 – Emphasis on maintaining examination integrity and fairness without undue interference unless absolutely necessary [Paras 9-10, 13].

Decision: Appeal allowed – High Court’s judgment set aside – No order as to costs [Para 15].

Market Fee – Liability on Imported Produce – Respondent, engaged in selling processed spices, imports agricultural produce from outside Karnataka, processes it, and sells within the appellant's market area – Market fee levied under Section 65(2) of the Karnataka Agricultural Produce Marketing (Regulation and Development) Act of 1966 – Exemption not applicable to imports processed and sold within the market area – Explanation to Section 65(2) excludes such imports from exemption – Respondent liable to pay market fee [Paras 1-16].

Legal Interpretation – Harmonious Reading of Provisions – Section 65(2) of the Act mandates market fee on processed agricultural produce imported from outside the state and sold within the market area – Sub-section (2-A)(ia) obliges importer to collect market fee from purchaser and pay it to the committee – Respondent's argument of exemption on processed goods rejected [Paras 7-12].

Precedents and Principles – Referenced judgments affirming liability of market fees on processed agricultural produce sold within the market area – G. Giridhar Prabhu & Ors. v. Agricultural Produce Market Committee (2001) 3 SCC 405 – Gujarat Ambuja Exports Limited & Anr. v. State of Uttarakhand & Ors. (2016) 3 SCC 601 – ITC Ltd. v. State of Karnataka & Ors. 2005 SCC OnLine Kar 86: 2005 AIHC 2950 [Paras 13-15].

Decision: Appeal allowed – High Court’s judgment set aside – Writ Petition No. 11816 of 2009 dismissed – No order as to costs [Para 16].