Consumer Protection – Delay in Filing Written Statement – Appellants challenged the rejection of their application for condonation of delay in filing the written statement to a consumer complaint – Written statement required within 30 days, extendable by a further 15 days under Section 13 of the Act – District Forum has no power to extend beyond this period – Appeal dismissed [Paras 1-6].

Jurisdiction – Section 13 of Consumer Protection Act – No jurisdiction for consumer fora to accept written statements beyond 45 days – National Commission's decision aligned with Constitution Bench’s interpretation – Constitution Bench decision applies prospectively, but does not affect complaints filed prior to this decision – Condonation of delay cannot be granted as per precedent [Paras 3-6].

Procedure – Written Statement Submission – Despite sufficient time, appellants failed to file within prescribed limit – Citing precedents, court holds no merit in appeal – No jurisdiction to condone delay [Paras 4-6].

Decision: Special Leave Petition dismissed – Confirmation of the National Commission's decision rejecting condonation of delay in filing the written statement.

Disability Compensation – Heart Ailment – Seaman's claim for disability compensation due to Dilated Cardiomyopathy under the National Maritime Board Agreement – Supreme Court held heart ailment not covered as "injury" under Clause 5.9.F(ii) of the Agreement – Appellant's condition does not fall within the ambit of specified disabilities under either the 1995 or 2016 Disability Acts – Appeal dismissed [Paras 1-19].

National Maritime Board Agreement – Interpretation – Clause 21 covers 100% disability due to injury while in employment – Clause 25 covers severance compensation for those medically unfit for sea service – Appellant's heart ailment not considered an "injury" suffered during sea service – Severance compensation under Clause 25 applicable, not disability compensation [Paras 8-15].

Disability Acts – Applicability – Heart ailment (Dilated Cardiomyopathy) not classified as a disability under the 1995 or 2016 Acts – Definition of disability under Sections 2(i) and 2(s) does not include heart ailments – Appellant not entitled to benefits under Section 47 of the Disability Act [Paras 16-18].

Decision: Appeal dismissed – High Court judgment upheld – Appellant not entitled to 100% disability compensation – Appellant's condition does not qualify as a disability under relevant Acts.

Negotiable Instruments – Dishonour of Cheque – Presumption – High Court reversed acquittal by trial court – Supreme Court held once signatures on the cheque are established, statutory presumption under Sections 118 and 139 NI Act applies – Trial court erred in questioning complainant's evidence on source of funds – Presumption of debt shifts burden to accused – High Court did not err in discarding appellants' defence – Appeal dismissed [Paras 1-22].

Presumption under NI Act – Reverse Onus – Once cheque is signed, presumption of debt or liability applies – Accused must rebut presumption by showing preponderance of probability – Mere denial or claims of blank cheque misuse insufficient – Defence must meet standard of probability [Paras 14-19].

Compensation and Punishment – Object of NI Act includes punitive, compensatory, and restitutive elements – Consistent approach needed in awarding compensation – Fine up to twice the cheque amount with interest generally imposed unless special circumstances exist – In this case, compensation claim not maintainable as respondent did not seek it in High Court – Amount deposited with Supreme Court to be transferred to respondent [Paras 20-22].

Decision: Appeal dismissed – High Court judgment modified to remove imprisonment in light of cheque amount already deposited – Amount of Rs. 11.20 lakhs with interest to be transferred to respondent.

Forest Law – Compensation for Dispossession – Appellants challenged the High Court's direction to pay compensation to respondents for land declared non-vested under the 1971 Act but later as ecologically fragile under the 2003 Act – Supreme Court held respondents entitled to compensation for loss of enjoyment and benefits of the land prior to 2003 enactment – Directed payment of 50% of land value as assessed by the Tehsildar [Paras 1-14].

Ecologically Fragile Lands – Vesting and Compensation – Land declared ecologically fragile under 2003 Act, vesting in government with no compensation payable for the land itself – Supreme Court clarified that respondents' right to compensation for dispossession and lost benefits prior to 2003 Act remains – Judgment of High Court modified to award compensation for loss of benefits [Paras 7-14].

Legal Principles – Right to Compensation – Right to possession and enjoyment of land established by prior judgment – State's inability to restore land necessitates compensation for deprivation period – Equitable relief granted by awarding 50% of assessed land value [Paras 12-14].

Decision: Appeal partly allowed – Judgment of High Court modified – Respondents awarded compensation at 50% of land value as assessed by Tehsildar, payable within three months or with interest thereafter.

Societies – Membership Invalidation – Appellants' membership invalidated by the Registrar as the Managing Committee was facing a no-confidence motion – High Court upheld the Registrar's decision – Supreme Court held appellants had a right to be considered for membership – Matter remitted to newly elected Managing Committee for reconsideration of membership applications on merits [Paras 1-54].

No Confidence Motion – Effect on Managing Committee – Managing Committee's legitimacy questioned due to pending no-confidence motion – Supreme Court held the Managing Committee lost legitimacy to make policy decisions, including admitting new members – Decision to induct members set aside due to illegality and arbitrary nature [Paras 45-51].

Legal Principles – Membership Rights – Members' right to be considered for admission based on eligibility – New Managing Committee directed to consider pending applications for membership afresh – No adverse finding against the eligibility of appellants for membership [Paras 50-53].

Decision: Appeal partly allowed – Order of Registrar and High Court modified – Applications for membership deemed pending and to be reconsidered by newly elected Managing Committee on merits.

Insolvency – CIRP Suspension – Applicability of Section 10A – Appeal against NCLAT ruling that Section 10A bars applications filed for defaults occurring on or after March 25, 2020 – Supreme Court held Section 10A applies retrospectively to defaults occurring on or after March 25, 2020, regardless of when the application was filed – Purpose of Section 10A is to prevent financial distress caused by COVID-19 from leading to insolvency proceedings – Appeal dismissed [Paras 1-27].

Legislative Intent – COVID-19 Impact – Section 10A introduced to provide relief to businesses affected by the pandemic – Proviso to Section 10A prohibits applications for CIRP for defaults during the specified period, emphasizing the protective intent of the legislature [Paras 15-23].

Procedural Interpretation – Filing Date vs. Default Date – Distinction between initiation date and insolvency commencement date under IBC – Section 10A intended to bar initiation of CIRP based on defaults arising within the specified period, regardless of application filing date [Paras 20-26].

Decision: Appeal dismissed – NCLAT's decision affirmed – Section 10A prevents initiation of CIRP for defaults occurring on or after March 25, 2020, for the stipulated period – Appellant's application under Section 9 not maintainable.

Constitutional Law – Right to Marry – Petitioners married without the consent of the woman's family – Woman's father filed a missing person complaint – Police demanded the woman to appear at the police station despite her informing them of her marriage and feeling threatened – Supreme Court held that the consent of family or community is not required once two adults agree to marry – Right to marry is integral to Article 21 of the Constitution – Police conduct in pressuring the petitioners was inappropriate – Proceedings quashed [Paras 1-14].

Individual Autonomy – Dignity and Choice – Court emphasized that individual choice is central to dignity – Consent of the family or community is secondary to the consent of the individuals involved – Autonomy in marriage is part of the fundamental right to life and personal liberty [Paras 9-11].

Police Conduct – Counseling and Guidelines – Court criticized the police for their handling of the case – Directed counseling for the investigating officer and suggested training programs for police on handling such socially sensitive cases – Police should lay down guidelines for managing similar cases in the future [Paras 12-13].

Decision: Writ petition allowed – Proceedings from FIR No. 226/2020 quashed – Police directed to establish training programs and guidelines for handling cases involving marriage against family wishes – Hope expressed for family reconciliation [Paras 14-15].

Constitutional Law – Right to Salary and Pension – COVID-19 pandemic led to financial crisis in Andhra Pradesh – State deferred payment of salaries and pensions – High Court ordered payment with 12% interest – Supreme Court upheld the payment of deferred salaries and pensions but scaled down interest to 6% – Salaries and pensions are rightful entitlements for services rendered and past service, respectively [Paras 1-16].

State Financial Crisis – Deferment of Payments – State's revenue significantly declined due to the pandemic – Government issued orders for deferment, later providing some relaxations – High Court directed payment of deferred amounts, recognizing the financial difficulties but emphasizing lawful entitlement to salaries and pensions [Paras 2-10].

Interest on Deferred Payments – Rate Reduction – While acknowledging the State's financial situation, Supreme Court held that interest should not be punitive – Interest rate reduced from 12% to 6% per annum, applicable to specified categories and all pensioners [Paras 14-15].

Decision: Appeal partly allowed – Deferred salaries and pensions to be paid with 6% interest within thirty days – High Court’s interest rate of 12% reduced – No order as to costs [Paras 15-16].

Service Law – Compulsory Retirement – Bank Manager charged with sanctioning and disbursing loans irregularly without following due procedure – Misappropriation and disbursing loans to units without business, multiple loans to family members – Enquiry Officer found charges proved – Disciplinary authority imposed compulsory retirement, accepted by appellate authority and upheld by Single Judge and Division Bench of High Court – Appeal dismissed [Paras 1-9].

Disciplinary Proceedings – Enquiry and Punishment – Disciplinary authority can tentatively decide on punishment based on Enquiry Officer’s report and indicate proposed punishment in show cause notice – Copy of enquiry report must be provided – No requirement for detailed reasons if disciplinary authority accepts enquiry findings – Proper procedure followed, punishment based on findings [Paras 7-8].

Proportionality of Punishment – Seriousness of Charges – Bank manager’s role critical in handling public money, requires adherence to procedural guidelines – Misconduct grave and serious – Compulsory retirement not disproportionate given the gravity of charges and appellant’s admissions – Appeal dismissed [Paras 8-9].

Decision: Appeal dismissed – High Court’s judgment upheld – Punishment of compulsory retirement affirmed as proportionate and justified based on proven misconduct.