Arbitration and Conciliation – Validity of Arbitration Clause – Clause 8.28 not constituting arbitration agreement – Clause referred to dispute resolution through negotiation, mediation by Chairmen, and only used the term "arbitration" loosely – No binding intent or finality indicated – Chairmen of parties not neutral arbitrators – Court held that mere use of the word “arbitration” without intent to submit disputes to binding adjudication does not satisfy Section 7 of the Arbitration and Conciliation Act – Held: No valid arbitration agreement existed – Dismissal of Section 11(6) application upheld [Paras 4-6, 13-27]

Contract Law – Interpretation of Dispute Resolution Clauses – Three-tier clause in software agreement involved negotiation, mediation, and court access if unresolved – Clause failed to demonstrate intent to be bound by arbitral decision – Reliance on case law including K.K. Modi, Jagdish Chander, Mahanadi Coalfields to determine essential attributes of arbitration agreement – Held: Clause structured for internal settlement, not formal arbitration [Paras 14-25]

Post-Contractual Correspondence – Effect on Arbitration Agreement – No denial of arbitration clause in respondent’s replies – However, absence of foundational arbitration agreement renders post-notice correspondence irrelevant – Held: No estoppel can operate to create arbitration agreement where none exists – Distinguished Powertech and Visa International cases [Paras 28-31]

Decision: Appeal dismissed – No valid arbitration agreement existed – Appellant permitted to approach civil court for remedy – No costs awarded [Paras 32-34].

Motor Accident Claim - Motor Vehicles Act, 1988 – Section 166 – Compensation – Split Multiplier – Applicability – High Court reduced compensation by applying split multiplier on assumption of post-retirement income reduction – Held: There exists divergence among High Courts on applying split multiplier – Following Sarla Verma v. DTC (2009) 6 SCC 121 and Pranay Sethi (2017) 16 SCC 680, the multiplier must depend solely on age of the deceased – Retirement or superannuation cannot be treated as an “exceptional circumstance” to justify a split multiplier – Split multiplier is foreign to the Motor Vehicles Act and should not be used by Tribunals or Courts [Paras 14–19].

Judicial Discipline – Divergence of Views – Intra-Court Conflicts – Supreme Court expressed concern over inconsistent approaches by coordinate benches within same High Courts, leading to uncertainty for Motor Accident Claims Tribunals – Directed that where conflicting views exist, the matter should be referred to a larger bench to maintain judicial propriety [Para 14].

Motor Accident Compensation – Income Assessment – Future Prospects – Income at the time of death to be taken as base for computation – Future prospects of 15% correctly applied for deceased aged 51 years – High Court failed to comply with directive in Pranay Sethi regarding 10% enhancement under conventional heads every three years – Corrected computation yielded total compensation of ₹47,76,794/- [Paras 19–20].

Directions – Prospective Application – Circulation to High Courts and Tribunals – The ruling on non-applicability of split multiplier to operate prospectively – Registrar (Judicial) directed to circulate copy to Registrars General of all High Courts and to Motor Accident Tribunals for uniform application [Para 22].

Decision: Appeals allowed – High Court judgment dated 28.06.2024 and review orders dated 27.11.2024 set aside – Tribunal award dated 02.04.2014 restored with modification to ₹47,76,794/- compensation and interest @7.5% p.a. – Directions for remittance of compensation to appellants’ bank accounts before 30.11.2025 – Prospective effect clarified [Paras 20–23].

Criminal Law – Quashing of FIR – Allegations under Section 498A IPC and Dowry Prohibition Act – High Court quashed proceedings arising from FIR No.35 of 2024, registered by appellant-wife against husband and in-laws alleging harassment and dowry demand – High Court held non-mention of two specific incidents (dated 22.07.2021 and 27.11.2022) in earlier complaints before FIR suggests afterthought – Supreme Court held: approach of High Court amounted to conducting a ‘mini-trial’, which is impermissible at the stage of Section 482 CrPC – Prime facie case of cruelty and dowry demand made out – FIR not liable to be quashed [Paras 17, 18, 19, 22, 27]

Inherent Powers – Quashing of Criminal Proceedings – Scope of Section 482 CrPC – Supreme Court reiterated that power under Section 482 must be exercised sparingly and in the rarest of rare cases – At stage of quashing, Court must only assess if prima facie allegations constitute cognizable offence – Court cannot go into merits, credibility or genuineness of allegations – Held: High Court exceeded its jurisdiction under Section 482 by evaluating reliability of complainant’s allegations, thus conducting a ‘mini-trial’ [Paras 20, 21, 22, 23, 24, 25, 26]

Dowry Harassment – Delay in Lodging FIR – Delay of one year in filing FIR after initial complaints to Women’s Cell – Respondents argued inconsistencies and delay undermine prosecution case – Supreme Court held: prior complaints disclosed continuous harassment and dowry demands – Mere omission of specific dates in earlier complaints does not negate existence of offence – Delay reasonably explained – Quashing not justified [Paras 13, 14, 19, 27]

Witness Credibility – FIR vs Prior Complaint – High Court concluded FIR was afterthought due to absence of specific incidents in prior complaints – Supreme Court held: High Court erred in judging veracity and motivation of FIR at pre-trial stage – Such evaluation is for trial court – FIR contained detailed and specific allegations that disclose cognizable offences – Quashing unsustainable [Paras 18, 19, 27]

Decision: Appeal allowed – High Court order dated 19.07.2024 quashing FIR No.35 of 2024 set aside – Criminal proceedings against respondents to continue – All defences of the parties left open for trial [Paras 28, 29]

Vehicles – Inter-State permits – Overlap with notified intra-State routes – Chapter VI overrides Section 88 – Inter-State agreement not “law” – Private operators cannot be allowed on overlapping notified routes absent express statutory carve-out – High Court directions set aside – Writ petition dismissed – States directed to confer and consider modifications if MPSRTC winding-up is established [Paras 23, 41-45, 48-50].

Inter-State Agreement vs. Notified Routes – Nature of IS-RT Agreement – An inter-State reciprocal transport agreement under Section 88 is an agreement between States and not “law”; approved schemes and notified routes framed under Chapter VI prevail by virtue of Section 98 – Consequently, private operators cannot ply on any portion of a notified route, even if part of an inter-State route overlaps, unless the scheme permits it – Mysore SRTC (I) view not good law; Constitution Bench in Adarsh Travels followed [Paras 41-45].

Overlapping Routes – Absolute Prohibition – Consistent line of authority reiterated: if a scheme imposes total prohibition on private operators on a notified route, no permit can be granted or renewed for a route that traverses/overlaps—even for a short distance; intersection is distinct from overlap [Para 41].

Question of Law – Framed and Answered – Whether a private operator can be granted a permit under an IS-RT Agreement when a portion of the inter-State route is common to a notified intra-State route? – Answer: No, in view of Chapter VI’s overriding effect and binding precedents [Para 23; Paras 41-45].

Effect of MPSRTC Winding-up – Contractual Clause – IS-RT Agreement contemplated inclusion of Schedule B routes into Schedule A upon MPSRTC’s winding-up; however, absence of clinching proof of winding-up defeats private operators’ claims; relief is “well-nigh impossible” unless winding-up is clearly shown [Paras 43-44].

Court Directions – Gwalior Bench’s directions requiring MP to issue permanent permits and UP to countersign within set timelines set aside; connected orders also set aside; Writ Petition © No. 748 of 2024 dismissed [Paras 4-9, 50(i)-(iii)].

– Cooperative Federalism & Public Interest – Principal Secretaries (Transport) of MP and UP to meet within 3 months to explore working out the IS-RT Agreement, including (i) moving Schedule B routes to Schedule A upon proof of MPSRTC’s winding-up, (ii) considering partial exclusions/modification of approved schemes to avoid public inconvenience, and (iii) prompt permits/countersignature if consensus emerges [Paras 48-49, 50(iv)].

Decision: Appeals allowed; impugned High Court orders set aside; Writ Petition © No. 748 of 2024 dismissed; directions issued to MP and UP to confer as indicated; no order as to costs [Para 50].

Criminal Law – Investigation under Section 156(3) CrPC – Magistrate’s Power – Validity of referral for police investigation – JMFC referred private complaint alleging forgery of E-Stamp and Rent Agreement for police investigation – High Court quashed the referral on the ground of non-application of mind and irregular order – Held: JMFC’s referral was valid as prima facie material existed disclosing cognizable offences – The Magistrate had jurisdiction and exercised discretion judiciously – Use of the word “further” in JMFC’s order did not vitiate the referral – Irregularity, if any, was curable under Section 460 CrPC – Orders of the High Court quashing the investigation unsustainable [Paras 34–39, 43–47].

Forgery and Fraud – Use of fake E-Stamp Paper – Prima facie evidence of conspiracy and forgery – Rent Agreement produced before High Court in earlier civil proceedings found to be on a fake E-Stamp Paper whose serial number actually corresponded to an unrelated Sale Agreement – Held: Existence of prima facie material warranted police investigation – Suppression of material facts and misuse of forged documents before the High Court justified invocation of criminal process [Paras 35–38].

Judicial Review – High Court’s Power under Section 482 CrPC – Scope of interference – High Court erred in interfering at the nascent stage of investigation and substituting its view for that of the Magistrate – As held in Neeharika Infrastructure Pvt. Ltd. V. State of Maharashtra, (2021) 19 SCC 401, criminal proceedings should not be stifled prematurely where prima facie allegations exist [Paras 20, 38–40].

Order under Section 156(3) CrPC – Application of Mind – Principles Reiterated – Reaffirmed that Magistrate may refer complaint to police for investigation before taking cognizance if allegations disclose cognizable offence (Madhao v. State of Maharashtra, (2013) 5 SCC 615; Ramdev Food Products Pvt. Ltd. V. State of Gujarat, (2015) 6 SCC 439) – The JMFC had complied with Priyanka Srivastava v. State of UP, (2015) 6 SCC 287 requirements [Paras 37–39].

Decision: Appeals allowed – Impugned orders of the High Court quashing the investigation set aside – Criminal proceedings restored – Investigation to proceed in accordance with law.

Criminal Law – Anticipatory Bail – Limited Role – Parity – FIR for offences under BNS, POCSO Act, and Prohibition of Child Marriage Act – Allegation against appellant limited to driving the vehicle – Other co-accused granted bail – High Court rejected anticipatory bail – Held: Appellant had no overt act vis-à-vis victim – Anticipatory bail granted on grounds of parity and limited involvement – Bail to be granted on arrest subject to conditions

Bail – Interim Protection – Grant of Interim Protection by Supreme Court on 09.05.2025 – Appeal allowed – Final order confirms interim protection by directing release on bail in the event of arrest – Cash security of Rs. 25,000/- with two sureties imposed – Conditions imposed for cooperation and non-interference with evidence

Criminal Procedure – Section 482 BNSS – Anticipatory Relief – Appellant entitled to invoke Section 482 of BNSS for protection in absence of direct allegations – Observed that presence at the scene or peripheral assistance not sufficient to deny anticipatory relief where others with greater involvement are already on bail

Decision: Appeal allowed – High Court’s order dated 23.04.2025 set aside – Anticipatory bail granted to appellant in the event of arrest – To be released on furnishing cash security of Rs. 25,000/- and two sureties – Directed not to misuse liberty or influence witnesses.

Arbitration – Enforcement of Award – Execution - Objections under Section 47 CPC – Dismissal – Appellant MMTC Limited objected to execution of arbitral award favouring Anglo American Metallurgical Coal Pvt. Ltd., alleging fraud and collusion by its own officials during fixation of coal prices – High Court dismissed objections under Section 47 and application for stay under Order XXI Rule 29 CPC – Held: Mere allegation of fraud on MMTC’s internal decision-making without showing fraud on the arbitral tribunal or the award itself does not render award inexecutable – Award had attained finality, and objections raised did not demonstrate nullity or jurisdictional infirmity as required under Section 47 – Appeal dismissed [Paras 15, 25, 31, 94, 95, 100].

Execution Proceedings – Section 47 CPC – Scope – Narrow compass – Objection to enforcement can only lie on limited grounds such as jurisdictional infirmity or decree being a nullity – Held: Allegations of internal collusion and breach of fiduciary duty, even if true, do not constitute jurisdictional infirmity or render arbitral award a nullity – No fraud on tribunal alleged or proved – Electrosteel Steel Ltd. v. ISPAT Carrier Pvt. Ltd. followed [Paras 21, 23, 24, 25].

Contract – Long Term Coal Supply Agreement – Price fixation clause linked to SAIL/RINL pricing – 5th Delivery Period – Price fixed at US$ 300 PMT – MMTC later claimed fraud by its own officers for agreeing to that price – Held: There was consistent correspondence, board approvals, and prior performance under the LTA – No evidence that decisions were irrational or outside range of reasonableness – Price aligned with SAIL/RINL – Business Judgment Rule applied – Directors’ decisions within permissible commercial discretion [Paras 32, 39, 40, 94].

Company Law – Directors’ Duties – Breach of fiduciary duty – Allegations against MMTC officers for collusion – Held: For a finding of breach of fiduciary duty, conduct must fall outside the bounds of what a reasonably competent director would have done – No such evidence found – Retrospective scrutiny with benefit of hindsight is impermissible – Re Living Images Ltd., Sharp v. Blank, and Maple Leaf Foods v. Schneider Corp. followed [Paras 35, 38, 39, 95].

Criminal Law – FIR against MMTC officials and Anglo – Allegation of corruption and conspiracy – Held: Mere registration of FIR or pendency of criminal proceedings does not render an award inexecutable – Execution cannot be stayed on mere pendency of unproven criminal charges – No finding of fraud by any court or investigating agency till date – FIR is a one-sided version, not evidence of fraud vitiating the award [Paras 85, 90, 94(q)].

Res Judicata – Arbitration Award upheld by Supreme Court – Finality – Re-litigation through Section 47 objections barred – Attempt to revisit issues already adjudicated under Section 34 and 37 of Arbitration Act not permissible – Objections amount to abuse of process – Rahul S. Shah v. Jinendra Kumar Gandhi reiterated – Execution proceedings cannot become a retrial [Paras 31, 94, 97, 98].

Civil Procedure – Order XXI Rule 29 CPC – Stay of execution pending suit – Rejected – Held: Suit seeking to declare award void was itself rejected – Pending appeal against rejection of suit does not justify stay of execution – Objections must stand on independent merit – No exceptional circumstance shown to grant stay [Para 96].

Decision: Appeal dismissed – Section 47 objections rightly rejected – Award held executable – No prima facie case of fraud or collusion made out – Appeal under Order XXI Rule 29 also untenable in absence of pending suit – Costs not awarded [Paras 95, 96, 100].

Arbitration – Delay in Pronouncement – Validity of Award – Public Policy Conflict – Arbitral award pronounced after nearly 3 years and 8 months of reservation without explanation – Arbitrator’s delay resulted in demonstrable indecisiveness, non-application of mind, and denial of effective adjudication – Supreme Court held that while delay alone is not a ground under Section 34, where it materially impacts the quality and fairness of adjudication, it renders the award in conflict with public policy and patently illegal [Paras 1, 19–20, 46–48, 55].

Arbitration – Unworkable Award – Perversity – Incomplete Adjudication – Arbitrator invalidated sale deeds executed by the appellant but declined to determine compensation or finalize reliefs, leaving parties to litigate afresh – Findings held to be contradictory and Award declared ineffective – Held: Arbitrator failed to perform his core function of final dispute resolution, thereby defeating the purpose of arbitration – Award liable to be set aside for being unworkable and perverse [Paras 39–42, 44, 47–48, 55].

Section 14 vs. Section 34 – Independent Remedies – Not Mutually Exclusive – Supreme Court clarified that aggrieved party need not seek termination under Section 14(2) before challenging delayed award under Section 34 – Remedies under Sections 14 and 34 operate independently – Mandate of arbitrator can be challenged post facto under Section 34 based on effects of delay [Paras 15–16, 19–20].

Contractual Interpretation – Clauses 6(a)–(c) of Joint Development Agreement (JDA) – Arbitrator’s interpretation of “fit for occupation” under Clause 6(a) stretched beyond contractual text – Requirements of certificate by architect and application for completion certificate were fulfilled – Arbitrator’s finding of non-compliance held perverse and contrary to terms of JDA [Paras 53–54].

Arbitrator’s Interim Orders – Irreversible Consequences – Equity Consideration under Article 142 – Arbitrator’s interim order in 2010 shifted possession and altered parties' positions – Supreme Court held that reverting to status quo was impossible after 15 years and third-party rights had been created – Invoking Article 142, Court validated previously illegal sale deeds executed by appellant, directed forfeiture of ₹6.82 crore security deposit, and awarded ₹3.18 crore additional compensation to respondents – Ordered final settlement of rights to prevent further litigation [Paras 60–62].

Exercise of Article 142 – Final Settlement to Prevent Injustice – Held: When arbitral award fails to resolve core dispute and perpetuates litigation after extensive delay and altered circumstances, Supreme Court justified in invoking Article 142 to do complete justice – Power exercised in conformity with Gayatri Balasamy and Shilpa Sailesh to bring litigation to an end [Paras 57–60].

Decision: Appeal allowed – Arbitral award set aside – Sale deeds declared valid despite initial illegality – Security deposit of ₹6.82 crores forfeited and additional ₹3.18 crores to be paid by appellant to respondents – On full payment, appellant entitled to possession of its 50% share – Parties to bear own costs [Paras 64].

Tender – Disqualification of Bid – Solvency Certificate – Clause 18 of NIT – Appellant’s technical bid rejected by Krishi Utpadan Mandi Parishad as “haisiyat praman patra” (solvency certificate) was issued by a private architect rather than District Magistrate – NIT did not specify that certificate must be issued by the District Magistrate – Held: Tendering authority cannot import unstated conditions – Rejection of bid dehors terms of NIT and arbitrary – Valuer empanelled with Income Tax Department was competent to issue such valuation certificate – High Court erred in upholding disqualification [Paras 12–15, 18].

Judicial Review – Scope in Tender Matters – Court cannot act as appellate authority in tender evaluation – Intervention permissible only when decision is patently arbitrary or contrary to NIT terms – Rejection of bid for non-DM certificate fell outside tender conditions and hence interfered with [Para 11].

Administrative Law – New Grounds in Counter Affidavit – Rejection order must stand or fall on reasons stated therein – Additional grounds raised subsequently cannot justify the impugned decision – Respondent could not later argue that valuation failed to show encumbrance details when original rejection was solely for non-DM certificate [Paras 16–17].

Interpretation – Meaning of “Haisiyat Praman Patra” – As per Oxford Hindi–English Dictionary, “haisiyat” means capacity, means, or resources – Certificate indicating bidder’s financial capacity suffices unless specific authority prescribed – Valuation certificate showing worth far above ₹10 crores meets requirement [Paras 17, 18].

Tender Reconsideration – Direction – Order of High Court set aside – Mandi Parishad directed to reconsider appellant’s technical bid and, upon verifying that valuation certificate satisfies Clause 18, negotiate with successful bidder or re-award contract accordingly [Para 19].

Decision: Appeal allowed – Rejection of technical bid quashed – Matter remanded to reconsider appellant’s bid per NIT terms [Paras 18–20].