Writ Law - Judicial Review - Constitution of India 1950 - Article 226 - Maintainability of writ petition in land disputes - Appellant State issued notice for eviction under 1905 Act - Respondents approached High Court instead of availing statutory remedies of appeal and revision under 1905 Act - High Court entertained writ petition despite serious factual disputes regarding title and possession - Supreme Court held that writ jurisdiction is not the appropriate forum for determining disputed questions of title or possession - Order of the Single Judge and Division Bench set aside - Held - High Court erred in entertaining writ petition when alternative statutory remedies were available and factual controversy existed - [Paras 1-13].

Civil Law - Jurisdiction - Andhra Pradesh Land Encroachment Act 1905 - Section 6 and 7 - Alternative Remedy - Respondents claiming possession through a Trust challenged eviction proceedings via writ petition - Previous proceedings established that title and possession were heavily contested - High Court failed to consider that the 1905 Act provides comprehensive remedy of appeal and further revision - Held - writ court ought not to have exercised jurisdiction in the teeth of pending civil disputes and available statutory mechanisms - [Paras 10-11].

Decision: Appeals allowed - Impugned orders of the Single Judge and Division Bench set aside - State action of locking the premises maintained - Liberty granted to the parties to pursue the pending civil suit on its own merits.

Criminal Law - Corruption - Prevention of Corruption Act 1988 - Sections 7 and 13 - Appellant convicted for demanding and accepting bribe through intermediaries for service-related transfers - Trial Court and High Court convicted the appellant primarily on testimony of approvers - Supreme Court noted lack of independent corroboration of demand and acceptance by the accused himself - Observed that mere recovery of money from intermediaries without proof of nexus and command of the accused is insufficient to sustain conviction - Held - Conviction unsustainable due to lack of proof beyond reasonable doubt - Appeals allowed and appellant acquitted - [Paras 57-88].

Evidence Law - Accomplice Testimony - Indian Evidence Act 1872 - Section 133 and Section 114 Illustration (b) - Evidence of witnesses originally arraigned as accused and granted pardon - Rule of prudence requires independent corroboration connecting the accused with the commission of the offence - Approvers have incentive to shift responsibility - Held - Testimony of approvers remained uncorroborated by independent material or circumstantial evidence regarding the appellant's direct involvement - [Paras 52-55].

Criminal Law - Statutory Presumption - Prevention of Corruption Act 1988 - Section 20 - Foundational facts - Presumption under Section 20 cannot be invoked unless foundational facts of demand and acceptance by the accused are first established - Held - Prosecution failed to establish the foundational facts of demand and acceptance by the appellant - [Paras 47-51].

Criminal Law - Evaluation of Evidence - Neeraj Dutta v. State (Government of NCT of Delhi) - Proof of demand and acceptance remains the gravamen of offences under the Act - Mere circumstantial inference of guilt is impermissible when the circumstances are not incompatible with the innocence of the accused - Held - Prosecution evidence remained speculative regarding the appellant's role - [Paras 49-74].

Decision: Appeals allowed – Convictions set aside – Appellant acquitted of all charges – Bail bonds discharged – Fine amounts ordered to be refunded.

Writ Law - Public Employment - Appointment - Eligibility Criteria - Advertisement - Mandated 10 years work experience as Anganwadi Sevika in the same district - Appellant appointed despite having experience only in a different district based on an erroneous clarification by the Divisional Commissioner - High Court set aside the appointment holding it contrary to the advertisement and the Government Resolution - Supreme Court upheld the High Court decision affirming that an appointment made in disregard of essential qualifications without a specific clause for relaxation amounts to a fraud on the public - Held - High Court rightly interfered with the appointment - [Paras 1-14].

Service Law - Qualifications - Government Resolution - Construction - Mandatory requirement - 10 years experience as Anganwadi Sevika to be acquired in the same district - Divisional Commissioner lacked authority to issue a clarification contrary to the express terms of the Government Resolution - Held - Appointment held to be void for lack of eligibility - [Paras 5-11].

Service Law - Judicial Review - Fraud on Public - Appointment based on incorrect eligibility - Ratio from Distt. Collector and Chairman Vizianagaram Social Welfare Residential School Society v. M. Tripura Sundari Devi applied - Holding that appointing an ineligible candidate ignores other qualified aspirants and perpetuates unfair practice - Held - Appointment did not vest any legal right to continue in the service - [Paras 12-13].

Decision: Appeal dismissed – Impugned judgment of the High Court upheld – Sixth respondent entitled to all benefits – Appellant permitted to complete unfinished work until 30th September 2026.

Tax Law - Settlement of cases - Income Tax Act 1961 - Sections 245C, 245D, 245I - Assessee filed return for AY 2006-07 claiming deduction under Section 80IB(10) - Assessee approached Settlement Commission under Section 245C - ITSC passed final order under Section 245D(4) settling total income - Subsequently Revenue conducted survey and issued notice under Section 148 to disallow Section 80IB deduction - Revenue also moved application under Section 245D(6) alleging misrepresentation which was rejected by ITSC - High Court quashed reassessment notice holding ITSC order as conclusive - Supreme Court upheld High Court view noting that Chapter XIX-A is a self-contained code and assessment settled by ITSC cannot be reopened by Assessing Officer under Section 147-148 except through procedure under Section 245D(6) - Held - Appeal dismissed - [Paras 1-28].

Tax Law - Jurisdiction of Assessing Officer - Income Tax Act 1961 - Sections 147, 148, 245D, 245F - Revenue contended that ITSC order did not specifically adjudicate the Section 80IB deduction hence reopening was permissible - Court held that once ITSC admits application it assumes exclusive jurisdiction and regular assessment machinery remains in abeyance - Piecemeal determination of income is impermissible - Assessing Officer cannot usurp jurisdiction or ignore finality of ITSC order - Held - Reassessment notice was without jurisdiction - [Paras 9-25].

Tax Law - Settlement Commission - Income Tax Act 1961 - Section 245D - Fraud and Misrepresentation - Revenue argued misrepresentation regarding commercial area limits under Section 80IB(10)(vi) - Court noted that Revenue had already availed remedy under Section 245D(6) which was rejected by ITSC after considering material on record - Settlement commission being a specialized body has exclusive authority to decide issues including alleged fraud - Finality clause under Section 245I bars interference unless vitiated by fraud or bias which must be established before ITSC - Held - Order of ITSC rejecting Revenue application attained finality - [Paras 8-26].

Decision: Appeal dismissed – Challenged order of the High Court sustained.

Writ Law - Selection Process - Constitution of India - Article 32 - Challenge to recruitment - Petitioners challenged the selection of Technician Grade-2 (Trainee) Electrical in UPPCL after an earlier Division Bench judgment directed a fresh result based on the timely submission of DOEACC certificates - Petitioners argued that the merit list contained mismatches and that OBC reservation was exceeded - Supreme Court noted that the petitioners confined their grievance to their merit position and failed to prove that candidates less meritorious than them were selected - Court also noted the suppression of material facts regarding identical petitions filed by some petitioners and dismissed the plea for a CBI investigation citing no evidence of wrongdoing - Held - Petition dismissed - [Paras 1-24].

Writ Law - Maintainability - Constitution of India - Article 32 - Suppression of material facts - Petitioner Nos. 8 to 18 had previously filed a writ petition in the Allahabad High Court for identical relief which was disposed of without disclosing the same in the present petition - Held - Non-disclosure of prior litigation amounts to suppression of material facts disentitling the petitioners to any relief - [Paras 12-21].

Writ Law - CBI Investigation - Constitution of India - Articles 32 and 226 - Requirement of pleadings - Petitioners sought an independent CBI inquiry into recruitment without lodging an FIR or providing specific evidence of manipulation - Held - Direction for a CBI investigation is not a matter of routine and requires sufficient material and specific allegations which are absent in the present case - [Paras 23-24].

Service Law - Reservation Policy - General Principles - Selection criteria - Contention that OBC candidates exceeded 50 percent quota - Held - Candidates from reserved categories who score higher marks than the last general category candidate are to be selected in the open category and are not to be counted against the reservation quota - [Para 13].

Decision: Writ petition dismissed – No order as to costs.

Service Law - Disability Pension - Entitlement Rules for Casualty Pensionary Awards 1982 and 2008 - Disability pension for ex-servicemen classified as NANA by Release Medical Board - High Courts and Tribunals frequently granted pension relying on Dharamvir Singh v. Union of India 2013 7 SCC 316 - Union challenged orders contending Entitlement Rules 2008 removed automatic presumption of attributability and mandated causal connection - Court held that while Entitlement Rules 2008 strengthened causal nexus requirement and removed automatic presumption they did not dismantle the claimant-protective structure of the regime - Onus remains on establishment for claims made within 15 years - Held - Court dismissed appeals on merits and delay noting that Medical Board opinion should be scrutinized in detail for reasons and that the 2008 Rules substantially reproduce the 1982 scheme - [Paras 30-40].

Service Law - Burden of Proof - Entitlement Rules 2008 - Rule 7 - Belated claims - Claims preferred after 15 years of discharge - Court held that Rule 7 of the Entitlement Rules 2008 correctly shifts the onus of proof onto the claimant for claims made after 15 years of release by which time service documents are typically destroyed - Held - The proviso to Rule 7 constitutes a valid shift in burden for such cases - [Paras 33-35].

Service Law - Expert Opinion - Medical Board - Judicial Review - Tribunal interference - Court held that opinion of a duly constituted Medical Board is an expert determination and should be given due weight - Courts and Tribunals should not substitute their own views merely because another view is possible - Interference is warranted only when there is a demonstrated defect or absence of reasons - Held - Tribunal must scrutinize the Medical Board's opinion for soundness and legality rather than substituting it - [Paras 18-19, 31, 39].

Decision: Appeals dismissed on grounds of delay and merits – Tribunal directed to scrutinize Medical Board opinions in detail – No order as to costs.

Criminal Law - Extradition and Sentencing - Terrorist and Disruptive Activities (Prevention) Act 1987 - Constitution of India - Article 72 and Article 136 - Sovereign assurance regarding 25-year imprisonment limit - Appellant sought release claiming 26 years 9 months 22 days incarceration by combining undertrial and post-conviction periods and adding jail-earned remissions - Court held that concurrent sentences cannot be counted twice to create an artificial or accelerated computation of the 25-year limit prescribed by sovereign assurance - Sovereign assurance does not convert a life sentence into a fixed-term sentence of 25 years - Held - High Court rightly dismissed the writ petition as the 25-year term is an outer limit to be computed as per earlier Supreme Court directions and does not permit overlapping period benefits or notional addition of remissions to life sentences - [Paras 1-32].

Criminal Law - Remission - Code of Criminal Procedure 1973 - Sections 432 and 433 - Jail-earned remission - Appellant sought to add jail-earned remissions to the 25-year period - Court held that since the appellant stands convicted of life imprisonment and the sovereign assurance does not alter the nature of the sentence to a fixed-term sentence - the benefit of jail-earned remission cannot be notionally added to advance the release date - Held - claim for jail-earned remission is not maintainable as the sentence remains one of life imprisonment - [Paras 20-29].

Criminal Law - Precedent - Law of Precedent - Applicability - Appellant relied on Yovehel v. State of Maharashtra and Union of India v. V. Sriharan @ Murugan and Swamy Shraddananda v. State of Karnataka - Court held these cases materially different as they did not involve sovereign extradition assurances - Held - precedents cannot be applied divorced from the factual and statutory setting in which they were rendered - [Paras 30-31].

Decision: Appeal dismissed in limine – The judgment of the High Court is upheld.

Writ Law - Public Health - Constitution of India - Article 21 and Article 47 - Petitioner sought implementation of Front-of-Package Labelling (FoPL) on high fat sugar and salt (HFSS) foods - Supreme Court previously directed Union and FSSAI to implement clear labelling - FSSAI proposed a phased, red hexagonal label for products high in two or more nutrients - Petitioner challenged the two-or-more threshold as scientifically unsupported and requested mandatory compliance - Court expressed concerns regarding the ambiguity in phases, lack of timelines, potential for increased use of additives, and the adequacy of the proposed label size - Held - FSSAI directed to provide specific responses to queries regarding threshold basis, timeline for phases, scientific justification for nutrient thresholds, and regulation of additives within 10 days - [Paras 1-55].

Civil Law - Food Safety - Food Safety and Standards (Labelling and Display) Regulations 2020 - Regulatory compliance - FSSAI proposed red hexagonal warning labels for HFSS products - Court noted discrepancy between 2024 Guidelines and 2022 Draft Regulations regarding definition of HFSS foods - Court highlighted need for clarity on whether labels should reflect Total Sugar and Saturated Fat as per past stakeholder consensus - Held - FSSAI required to clarify criteria and address concerns on label legibility and pictorial representation - [Paras 9-45].

Writ Law - Nutritional Literacy - Constitution of India - Article 21 - School curriculum - Recognizing the vulnerability of children to unhealthy dietary habits and the increase in overweight school-age children as per UNICEF data - Court enquired into plans for incorporating nutritional literacy and interpretation of food labels into school curriculum - Held - Union of India directed to respond on initiatives for nutritional literacy at the school level - [Paras 51-53].

Decision: FSSAI directed to file a detailed response via affidavit within 10 days on 13 specific queries including timelines, thresholds, labelling standards, and mitigation of artificial additive usage – Matter posted for further hearing on 28/09/2026.

Civil Law - Property Dispute - Code of Civil Procedure 1908 - Section 100 - Suit for declaration of title and permanent injunction over agricultural land - Plaintiffs claimed title via registered sale deed - Defendants claimed title via prior dedication to a religious institution and subsequent adverse possession - Trial Court and First Appellate Court dismissed suit relying on revenue entries reflecting possession as gair marusi bila lagan bawaja Dharam Arth - High Court set aside concurrent findings holding that revenue entries are not proof of title and that defendants failed to prove ingredients of adverse possession - Supreme Court affirmed High Court order noting defendants failed to establish valid dedication or hostile animus required for adverse possession - Held - Appeal dismissed - [Paras 1-44].

Evidence Law - Revenue Records - Code of Civil Procedure 1908 - Section 100 - Evidentiary value - Revenue entries describing possession as gair marusi bila lagan bawaja Dharam Arth - Whether sufficient to establish title by dedication or adverse possession - Held - Revenue records are primarily for fiscal purposes and do not confer title - Entry indicates nature of possession but requires corroboration by substantive evidence to prove ownership or hostile assertion - [Paras 23-25, 32, 42].

Civil Law - Adverse Possession - Limitation Act 1963 - Essential ingredients - Hostile animus - Burden of proof - Defendants claimed title by adverse possession based on long duration of possession by successive Mahants - Held - Mere long possession is insufficient without proving the specific point of time when possession became hostile and repudiated the title of the true owner - Failure to plead and prove commencement of hostile possession defeats the claim - [Paras 28-31].

Civil Law - Appellate Jurisdiction - Code of Civil Procedure 1908 - Section 100 - Powers of High Court - Interference with concurrent findings of fact - High Court set aside findings of lower courts which relied on an erroneous understanding of legal principles regarding dedication and adverse possession - Held - High Court is justified in interfering when concurrent findings are vitiated by misapplication of law or failure to address essential legal ingredients - [Paras 39-41].

Decision: Appeal dismissed – Judgment and decree dated 22.03.2011 passed by the High Court affirmed.