Land Acquisition – Specific Performance – Compensation – The appellant executed an agreement to sell land to the respondent, which was later acquired by the state. The courts below granted specific performance. The High Court modified this to grant compensation awarded under the Land Acquisition Act, with deductions for expenses incurred by the original landowner. The Supreme Court upheld this modification, emphasizing that compensation under the Land Acquisition Act may be deemed an appropriate substitute for specific performance when the contract becomes impossible to fulfill through no fault of the plaintiff. [Paras 1-12].

Specific Relief Act, 1963 – Section 21 – Award of Compensation – When specific performance of a contract becomes impossible due to land acquisition, the court is empowered to award compensation in lieu of specific performance. The compensation amount determined under the Land Acquisition Act is to be taken as the measure of damages, subject to deductions for the landowner's litigation costs. [Paras 7-11].

Decision – Appeal Partly Allowed – The appellant is entitled to Rs. 300,000 from the compensation deposited by the acquiring body, with the balance amount, including interest and solatium, payable to the respondent. The decision of the High Court was modified to this extent, confirming the entitlement of the respondent to the compensation awarded under the Land Acquisition Act, less the specified deductions. [Paras 12-13].

Electricity Supply – Contract Load Reduction – The respondent, a small-scale industry, requested a reduction in its sanctioned electricity load from 4000 KVA to 1325 KVA due to issues such as frequent trippings and load shedding. The Jharkhand State Electricity Board (JSEB) rejected the request, citing an agreement clause preventing load reduction within three years of a fresh agreement. The Supreme Court held that agreements for load enhancement are mere extensions or amendments of the initial agreement. Thus, the respondent's application for load reduction, filed three years after the initial agreement, should have been allowed under Regulation 9.2 of the 2005 Regulations. [Paras 1-21].

Electricity Supply Code – Interpretation of Agreement – The Court emphasized that fresh agreements for enhanced loads are not to be treated as new agreements but as amendments to the initial agreement, in line with the Jharkhand State Electricity Regulatory Commission (Electricity Supply Code) Regulations 2005. This ensures fairness and compliance with regulatory provisions favoring the consumer. [Paras 14-16].

Decision – Appeal Dismissed – The Supreme Court dismissed the appeal, stating that the respondent's application for reduction of load must be deemed allowed under Regulation 9.2, entitling the respondent to all consequential benefits. [Paras 19-21].

Land Acquisition – Specific Performance – Compensation – The appellant executed an agreement to sell land to the respondent, which was later acquired by the state. The courts below granted specific performance. The High Court modified this to grant compensation awarded under the Land Acquisition Act, with deductions for expenses incurred by the original landowner. The Supreme Court upheld this modification, emphasizing that compensation under the Land Acquisition Act may be deemed an appropriate substitute for specific performance when the contract becomes impossible to fulfill through no fault of the plaintiff. [Paras 1-12].

Specific Relief Act, 1963 – Section 21 – Award of Compensation – When specific performance of a contract becomes impossible due to land acquisition, the court is empowered to award compensation in lieu of specific performance. The compensation amount determined under the Land Acquisition Act is to be taken as the measure of damages, subject to deductions for the landowner's litigation costs. [Paras 7-11].

Decision – Appeal Partly Allowed – The appellant is entitled to Rs. 300,000 from the compensation deposited by the acquiring body, with the balance amount, including interest and solatium, payable to the respondent. The decision of the High Court was modified to this extent, confirming the entitlement of the respondent to the compensation awarded under the Land Acquisition Act, less the specified deductions. [Paras 12-13].

Service Law – Termination – Back Wages – The respondent was appointed to a post based on a merit list, but due to an administrative error, another candidate (Respondent No. 2) did not receive the appointment letter and later contested her exclusion. The tribunal ordered the appointment of Respondent No. 2 and termination of Respondent No. 1, which was upheld by the Supreme Court. The Court emphasized the necessity of adhering to tribunal orders and noted the passage of nearly two decades, making it untenable to reinstate Respondent No. 1 or award back wages. The High Court's order to appoint Respondent No. 1 to another vacancy was set aside. [Paras 1-26].

Termination – Natural Justice – The failure to provide Respondent No. 1 an opportunity to show cause before termination was acknowledged, but it was deemed non-fatal due to the binding nature of the tribunal's earlier order and the specific circumstances of the case. [Paras 23-24].

Decision – Appeal Allowed – The Supreme Court set aside the High Court’s order directing the appointment of Respondent No. 1 to another vacancy and upheld the termination as necessitated by compliance with the tribunal's binding order. The claim for back wages was also denied. [Paras 25-26].

Income Tax – Section 80-IA(5) – Deduction – The scope of sub-section (5) of Section 80-IA is limited to the determination of the quantum of deduction under sub-section (1) by treating the eligible business as the only source of income. Sub-section (5) cannot be interpreted to limit the deduction to business income alone. The deduction is computed on the basis of net income from the eligible business, but it is allowed against the gross total income, including income from other sources, subject to the ceiling of the gross total income. [Paras 1-15].

Income Tax Act – Section 80AB – Computation of Deduction – Section 80AB pertains to the computation of the quantum of deductible income in the gross total income. It cannot curtail the width of Section 80-IA. Section 80A(2) stipulates that the aggregate amount of deductions under Chapter VI-A shall not exceed the gross total income of the assessee. [Paras 9-10].

Decision – Appeals Dismissed – The Supreme Court dismissed the appeals, holding that the deduction under Section 80-IA of the Act is not limited to business income. The deduction computed on the profits and gains from the eligible business can be set off against the gross total income, including income from other sources, subject to the ceiling of gross total income. [Para 15].

Penal Code, 1860 – Section 302 read with Section 34 – Murder – Common Intention – The appellants were convicted of murder based on the consistent, natural, and trustworthy testimony of key witnesses. The alleged omissions, such as not seizing the motorcycle or the gold chain of one of the victims, do not discredit the prosecution's evidence. The motive for the crime was established due to prior animosity regarding the payment of rent for a tractor. The prosecution proved beyond reasonable doubt that all accused committed the crime with common intention. Both the trial court and the High Court's decisions were upheld. [Paras 16-22].

Penal Code, 1860 – Section 302 read with Section 34 – Witness Testimony – Minor contradictions do not invalidate the testimony of witnesses. The court emphasized that only contradictions in material particulars can be grounds for discrediting witness testimony. The presence of injured witnesses at the scene and their injuries lend significant weight to their testimonies. The court noted that discrepancies that do not affect the core of the prosecution’s case are not fatal. [Paras 19-20].

Decision – Appeals Dismissed – The Supreme Court dismissed the appeals, agreeing with the concurrent findings of the lower courts that the appellants were guilty of murder with common intention. The Court found no merit in the arguments presented by the defense and upheld the conviction and sentences imposed by the trial court and confirmed by the High Court. [Paras 21-22].

Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 – Section 3(2)(v) – The conviction under this provision requires evidence that the offence was committed on the ground that the victim was a member of a Scheduled Caste or Scheduled Tribe. In this case, the evidence did not establish that the offence was committed solely on that ground. Hence, the conviction under Section 3(2)(v) was set aside. [Paras 1-11, 56-61].

Penal Code, 1860 – Section 376(1) – Rape – The conviction under Section 376(1) was upheld. The testimonies of the witnesses and medical evidence established the guilt of the appellant beyond reasonable doubt. The nature and gravity of the offence, especially considering the victim's disability, warranted the imposition of life imprisonment. [Paras 1-11, 62-63].

Decision – Appeal Partly Allowed – The Supreme Court set aside the conviction under Section 3(2)(v) of the SC/ST Act due to insufficient evidence but upheld the life imprisonment sentence under Section 376(1) of the IPC due to the serious nature of the offence and the victim's vulnerability. [Para 61-63].

Criminal Law – Bail – Grant of Bail – The High Court's decision to grant bail to the accused, a history-sheeter charged with murder and other serious offences, was challenged. The Supreme Court noted the potential threat to witnesses and the safety concerns of victims' families. It emphasized the need for courts to consider the impact of bail on the witnesses and the public, beyond just the parties involved in the case. [Paras 2-8].

Criminal Law – Bail Considerations – The court highlighted several considerations for granting bail, including the nature and gravity of the accusations, the severity of punishment, the potential for the accused to abscond, and the risk of witnesses being influenced or justice being thwarted. The Supreme Court stressed the importance of judicious, cautious, and compliant exercise of discretion by the High Court in line with established precedents. [Paras 9-11].

Decision – Appeal Allowed – The Supreme Court set aside the order of the Allahabad High Court granting bail to the accused, recognizing the importance of safeguarding the life and liberty of victims and witnesses against potential threats from the accused. [Paras 12-13].

Insolvency and Bankruptcy Code, 2016 – Section 14(2A) – Supply of Goods or Services – During the moratorium period, the Interim Resolution Professional (IRP) or Resolution Professional (RP) must ensure that the supply of goods or services critical to protect and preserve the value of the corporate debtor is not terminated, suspended, or interrupted, except where dues are unpaid or as specified. The Supreme Court emphasized that this provision, inserted from 28.12.2019, includes goods or services not covered by Section 14(2). The decision must align with the IBC's objectives and the factual matrix. [Paras 19-22].

Jurisdiction Under Section 482 of Cr.P.C. – The Supreme Court highlighted the limits of the High Court's power under Section 482, Cr.P.C., stating that it cannot overlook statutory dictates, especially those in the IBC. The impugned order allowing the respondent to operate the account without placing Rs. 32.50 lakhs back into the corporate debtor's account was deemed unsustainable. [Paras 24-25].

Decision – Appeal Allowed – The impugned order was modified, allowing the respondent to operate its account only after remitting Rs. 32.50 lakhs into the account of the corporate debtor. The management of the corporate debtor's assets must comply strictly with the IBC provisions. [Para 25].