Civil Procedure – Res Judicata – Section 92 CPC – Representative suit – Suit filed under Section 92 CPC for settling a scheme of administration for a mosque – Ownership of the suit property was an issue – Judgment in the representative suit is binding on all interested parties – Issue of title to the suit property determined in the representative suit bars subsequent suit for declaration of title – Appeal dismissed [Paras 1-47].

Section 92 CPC – Scope – In suits filed under Section 92 CPC, the court may decide on the title to the property if it is necessary for settling the scheme of administration – The judgment in a representative suit binds all interested parties [Paras 32-35].

Determination of Res Judicata – Mixed questions of law and fact – Res judicata can be decided as a preliminary issue if it involves only questions of law – In cases involving mixed questions of law and fact, it may be necessary to conduct a full trial [Paras 19-23].

Previous Suits – Analysis – The earlier suits involved determination of the title to the suit property – The issue of title was directly and substantially in issue and was necessary for the decision – Subsequent suit barred by res judicata [Paras 24-43].

Decision – Appeals dismissed – Suit barred by res judicata – Judgment of High Court affirmed [Paras 46-47].

Arbitration – MSMED Act – Jurisdiction and Procedure – Dispute regarding payment for supply of TMT bars – Facilitation Council dismissed proceedings citing lack of jurisdiction – High Court dismissed writ petition suggesting remedy under Section 34 of Arbitration Act – Supreme Court held Facilitation Council did not follow proper procedure under Section 18 of MSMED Act – Remanded case for proper arbitration proceedings [Paras 1-12].

Special Statute – MSMED Act Overriding Arbitration Act – MSMED Act being special statute, its provisions have overriding effect – Dispute resolution to follow Section 18 of MSMED Act – Facilitation Council first acts as conciliator, failing which arbitration proceedings commence – Arbitration Act provisions apply post-conciliation [Paras 9-10].

Decision – Appeal allowed – High Court's judgment and Facilitation Council's order set aside – Matter remitted to Facilitation Council for fresh proceedings in accordance with Section 18 of MSMED Act – Council to complete proceedings within six months [Paras 12].

Negotiable Instruments Act – Dishonor of Cheque – Complaint under Section 138 of the NI Act for dishonor of cheque – Respondent issued cheque for Rs. 1,50,000 as part repayment of advance – Cheque dishonored due to insufficient funds – Magistrate convicted respondent, sentencing to six months imprisonment and fine – Sessions Court upheld conviction – High Court set aside conviction – Supreme Court restored conviction – Presumption under Sections 118 and 139 in favor of holder of cheque – Respondent failed to rebut presumption – Sentence modified to enhanced fine of Rs. 2,50,000 with default imprisonment [Paras 1-22].

Judicial Review – Scope of Revision – High Court exceeded its jurisdiction in re-evaluating evidence and setting aside concurrent findings of lower courts – Limited scope in revision to interfere only if findings are perverse or incorrect [Paras 16-18].

Presumption of Debt or Liability – Sections 118 and 139 NI Act – Presumption in favor of holder – Burden on accused to rebut presumption by preponderance of probabilities – Respondent failed to provide satisfactory rebuttal evidence [Paras 11-20].

Decision – Appeals allowed in part – High Court's order set aside – Conviction restored with modified sentence of fine Rs. 2,50,000 – Fine to be paid as compensation to appellant – Default sentence of six months simple imprisonment [Paras 21-22].

Non-Release of Prisoners – Delay in Release after Bail – Suo moto proceedings initiated due to reports of non-release of prisoners post bail grant – Adoption of FASTER (Fast and Secured Transmission of Electronic Records) system proposed – Supreme Court directed ensuring internet facility in jails for electronic transmission of orders – Interim communication through State Nodal Officers until full implementation – Amendments to rules and procedures to recognize e-authenticated orders – Directions issued for smooth implementation of FASTER system by coordinating with NIC and State authorities [Paras 1-13].

Judicial Administration – ICT Utilization – Need for efficient transmission of court orders highlighted – FASTER system to transmit e-authenticated copies of orders for compliance – Steps for ensuring internet connectivity and necessary administrative amendments outlined [Paras 7-12].

Decision – Directions issued to Chief Secretaries and other relevant authorities to ensure implementation of FASTER system – Matter listed for further review after two weeks [Para 13].

Toll Plaza – Location and Compliance with Rules – Construction of toll plaza at 194 km of Patna-Bakhtiyarpur section of NH30 challenged – High Court directed relocation citing violation of Rule 8 of 2008 Rules – Rule 8 mandates toll plazas to be beyond 10 km from municipal or town area limits – Supreme Court found that establishment of toll plaza within municipal limits violated Rule 8 – Directions given to shift toll plaza outside specified limits [Paras 1-32].

Judicial Review – Expert Bodies – Limited judicial review on matters decided by expert bodies unless decisions are arbitrary or perverse – DPR by expert body recommended toll plaza location – Judicial deference to expert opinion provided compliance with statutory provisions [Paras 10-15].

Decision – Appeal dismissed – High Court judgment upheld – Toll plaza to be relocated as directed – Compliance with statutory requirements emphasized [Paras 30-32].

SARFAESI Act – Sale Notice Compliance – Appellants challenged the validity of the Second Sale Notice for not adhering to the statutory requirement of a 30-day notice period – Supreme Court held that the notice violated Rules 8(6) and 9(1) of the Security Interest (Enforcement) Rules, 2002, mandating a clear 30-day notice for sale of immovable property – Court emphasized compliance with statutory provisions to protect borrowers' rights and ensure fair procedure [Paras 10-21].

Continuity of Sale Notices – Clarified that once a sale does not occur as scheduled, subsequent sales must follow fresh notice procedures – Supreme Court invalidated the sale held under the Second Sale Notice, affirming that reliance on an earlier notice for subsequent sales without fresh compliance is impermissible [Paras 19-21].

Procedural Irregularity – Importance of procedural fairness highlighted – Court reiterated principles from Mathew Varghese v. M. Amritha Kumar and others (2014) regarding mandatory compliance with notice periods to protect borrowers' right of redemption and ensure transparent and fair auction processes [Paras 15-20].

Decision – Appeals Allowed – Held – Second Sale Notice and consequent sale invalidated – Directed compliance with the statutory 30-day notice requirement for any subsequent sale proceedings – Emphasized the need for adherence to procedural safeguards to ensure justice and fairness [Para 21].

Land Acquisition – Compensation Assessment – Appellants sought higher compensation based on later acquisitions – High Court upheld Reference Court's award – Supreme Court modified compensation to Rs. 28.12 per square yard – Appeals partly allowed [Paras 1-15].

Land Valuation – Comparison with Subsequent Acquisitions – Claim for higher compensation based on 1983 land acquisition rates rejected – Supreme Court held that compensation for later acquisitions not comparable due to subsequent developments and sanctioned plans – Emphasized consistency in valuation for similar time periods [Paras 13-15].

Procedural Fairness – Evidence Submission – Appellants' application to present additional documents under Order XLI Rule 27 CPC dismissed – Supreme Court upheld High Court's approach, ensuring that procedural rules were followed and factual consistency maintained [Paras 5-6].

Decision – Appeals Partly Allowed – Held – Compensation enhanced to Rs. 28.12 per square yard for land acquired in 1976 – Appellants entitled to statutory benefits under the Land Acquisition Act on the enhanced compensation – No order as to costs [Para 15].

Financial Crisis – COVID-19 Impact – Sree Padmanabha Swamy Temple faced financial crisis due to lockdown and lack of income – Routine rituals and salaries continued despite closure – Administrative Committee reported financial constraints and sought aid from Trust and Government [Paras 1A].

Special Audit – Compliance with Supreme Court Order – Special audit for 25 years directed by Supreme Court commenced – Issues with audit cooperation from related Trusts – Court emphasized necessity of audit to ensure transparency and proper fund utilization [Paras 1B, 1B.3, 5-6].

Trust's Independence – Miscellaneous Application by SPSTT – SPSTT claimed independence from Temple administration – Argued audit beyond Court's directive – Supreme Court rejected claim, citing interlinkages and necessity for comprehensive audit as per previous orders and directions [Paras 2-3, 6-7].

Decision – Application Partly Allowed – Held – Reiterated necessity of special audit of Sree Padmanabha Swamy Temple and SPSTT – Directed completion within three months – Ensured cooperation from SPSTT – Addressed financial crisis and audit compliance [Paras 6-10].

Industrial Disputes – Dismissal of Workmen – Disciplinary proceedings during conciliation – Supreme Court held Section 33(2)(b) ID Act applicable where misconduct not connected with the dispute – Misconduct related to vandalism of employer's property – Rejected Assistant Commissioner's finding requiring prior approval under Section 33(1)(b) – Appeal allowed, approval granted for dismissal under Section 33(2)(b) [Paras 10-14].

ection 33 Distinction – Connected vs. Unconnected Misconduct – Explained distinction between Section 33(1) requiring prior approval for misconduct connected with dispute and Section 33(2) permitting dismissal for misconduct not connected with the dispute – Emphasized factual determination of connection with the dispute – Supreme Court reiterated legislative history supporting balanced approach [Paras 9-11].

Compliance with Section 33(2)(b) – Confirmed compliance with Section 33(2)(b) requirements – Found no contrary evidence or findings – Reversed lower courts' misapplication of Section 33(1)(b) [Paras 13-14].

Decision – Appeal Allowed – Held – High Court judgment set aside – Approval granted for dismissal under Section 33(2)(b) – Clarified no impact on entitlements of deceased workmen's legal representatives [Paras 14-15].