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]​​.

Land Acquisition – Compensation Determination – Appeals against High Court’s judgment reducing compensation for acquired land from Rs. 112,000 per acre to Rs. 88,400 per acre – Notification under Section 4 issued on 06.06.1988 for acquiring land for a spinning mill – Reference Court considered sale deed dated 24.05.1979 and added 12% annual increase with a 25% cut, determining compensation at Rs. 112,000 per acre – High Court reduced cut to 15% and recalculated compensation – Supreme Court upheld High Court's determination, emphasizing the caution needed when relying on old sale deeds and justified applying a 10% annual increase due to regional instability and militancy [Paras 1-7]​​.

Cumulative vs. Flat Rate Increase – Court emphasized cumulative rate increase should generally be applied when determining compensation based on past transactions, but noted exceptions due to local circumstances such as prolonged regional instability affecting land prices [Para 6.3]​​.

Deduction for Development – Supreme Court upheld 15% deduction for development charges due to the agricultural nature of the land and its location, deeming it appropriate given the size and intended industrial use of the acquired land [Para 6.5]​​.

Decision – Appeals dismissed – Supreme Court found no reason to interfere with the High Court’s judgment – Compensation determined at Rs. 88,400 per acre upheld – No order as to costs [Paras 7]​​.

Administrative Law – Jurisdiction – Appeal against High Court of Uttarakhand’s dismissal of writ petition challenging Labour Court's award – Respondent's termination deemed illegal by Labour Court with reinstatement and back wages ordered – Writ petition originally filed in High Court of Allahabad – Post-creation of State of Uttarakhand, jurisdiction transferred to Uttarakhand High Court – Allahabad High Court allowed withdrawal of writ petition with liberty to file fresh writ in Uttarakhand High Court – Uttarakhand High Court dismissed fresh writ on grounds of jurisdiction and laches – Supreme Court held Allahabad High Court's order permitting withdrawal and refiling in appropriate jurisdiction was valid – High Court of Uttarakhand directed to hear the case on merits [Paras 1-5]​​.

Jurisdiction and Transfer of Cases – Judicial Orders vs. Administrative Orders – Supreme Court noted judicial propriety demands respect for orders of Coordinate Benches – Observed that judicial orders permitting transfer or refiling of cases should be respected unless explicitly challenged and set aside – Emphasized administrative orders for transfer of cases under Section 35 are distinct from judicial orders addressing procedural aspects [Paras 3.1-3.3, 4]​​.

Decision – Appeal allowed – Impugned judgment of Uttarakhand High Court set aside – Writ petition restored for hearing on merits – Directed High Court of Uttarakhand to expedite hearing and disposal within six months [Paras 5]​​.