Independence of Administrative Bodies – Autonomy and non-interference are essential for the effective functioning of administrative bodies. These bodies must be free from undue interference to carry out their specialized tasks impartially and efficiently [Para 1].

Right to Information Act – Authority to Frame Regulations – Central Information Commission (CIC) has the authority under Section 12(4) to frame the Central Information Commission (Management) Regulations, 2007 – This authority is implied within the broad powers of superintendence, direction, and management of the CIC’s affairs, which includes the formation of benches for efficient case handling [Paras 9-24].

High Court’s Narrow Interpretation – The High Court’s restrictive reading of the RTI Act, focusing on the absence of explicit provisions for the formation of benches, overlooked the broad powers vested in the CIC. A purposive interpretation aligns with the objective of the RTI Act to promote transparency and accountability [Paras 16-22].

Principle of Non-Interference – Emphasized the importance of non-interference in the administrative functions of the CIC for maintaining its integrity and efficacy. The ability to form benches and allocate work among Information Commissioners is crucial for the CIC to manage its workload effectively [Paras 23-24].

Decision: Appeal allowed – Judgment of the Delhi High Court set aside – Chief Information Commissioner’s powers to frame Regulations and constitute Benches of the Commission upheld as within the ambit of Section 12(4) of the RTI Act [Para 25].

Order II Rule 2(3) CPC – Leave to Sue Separately – Respondent sought leave under Order II Rule 2(3) CPC for filing a separate suit for recovery of arrears and damages – Trial Court and High Court found no relinquishment or omission in the first suit to bar the second suit – High Court affirmed separate causes of action for the two suits – Appeal dismissed – Court held that the object of Order II Rule 2(3) CPC is to avoid multiplicity of suits and prevent defendants from being vexed twice for the same cause. However, it does not bar suits based on different causes of action, as was the case here. The respondent had specifically reserved its right to claim arrears and damages in the first suit and had taken leave to file a separate suit. [Paras 4-12, 17-18].

Order VII Rule 11 CPC – Rejection of Plaint – Application under Order VII Rule 11 CPC by appellant for rejection of respondent’s claim for arrears and damages – High Court found no merit in the application – Distinction between relinquishment and omission of claims under Order II Rule 2 CPC emphasized – Appeal dismissed – Court observed that the appellant’s application for rejection of the plaint was based on a misinterpretation of the principles under Order II Rule 2 CPC. The respondent had neither relinquished its claims nor omitted to claim the reliefs sought in the second suit, thus the application under Order VII Rule 11 CPC was rightly dismissed by the lower courts [Paras 7, 12].

Leave and License Agreement – Termination and Subsequent Litigation – Original agreement dated 25.11.2008 superseded by another agreement dated 01.12.2010 – Dispute arose due to default in payment of storage charges – Legal notice issued by respondent on 27.11.2014 – Respondent instituted suit for permanent injunction and possession in O.S. No.101 of 2015 – Appellant filed a commercial suit for declaration regarding extent of the warehouse area – Respondent granted leave under Order II Rule 2(3) CPC to file a separate suit for arrears and damages – Multiple suits filed by both parties leading to the present appeal [Paras 4-11].

Commercial Suit – Separate Causes of Action – High Court’s observation that suits were based on different causes of action – First suit related to possession and permanent injunction – Second suit related to recovery of arrears and damages – No relinquishment or omission of claims – Respondent had reserved its right to claim arrears and damages in the first suit and sought leave to file a separate suit – Distinction between causes of action and claims for different reliefs highlighted [Paras 12, 17].

Precedents and Judicial Reasoning – Reliance on Bharat Petroleum Corporation Ltd. Vs. ATM Constructions Pvt. Ltd., 2023 SCC Online SC 1614 – Court reiterated that suits for possession and suits for claiming damages for use and occupation are based on different causes of action and can be separately maintained – Application of legal principles regarding Order II Rule 2(3) CPC and Order VII Rule 11 CPC – Affirmation of High Court’s detailed reasoning and dismissal of appellant’s contentions [Paras 16-18].

Decision – Appeal Dismissed – Held – The second suit filed by the respondent was maintainable – No infirmity found in the impugned order – Supreme Court affirmed the High Court’s view that both suits were based on different causes of action – Pending applications disposed of [Para 19-20].

Constitutional Law – Article 131 Jurisdiction – State of West Bengal challenges the authority of the CBI to register cases post-withdrawal of consent under Section 6 of the DSPE Act – Issue involves interpretation of Article 131 and its limitations – Supreme Court's original jurisdiction exclusive and includes disputes involving the existence or extent of a legal right [Paras 1-3, 30-31, 44-51, 84].

Legal Framework – Supreme Court Rules, 2013 – Order XXVI Rule 6 applicable for rejecting plaints that do not disclose a cause of action or are barred by law – Provisions analogous to Order VII Rule 11 of the CPC – Duty of court to examine averments in plaint as a whole and reject plaints even without defendant's intervention [Paras 22-29].

Maintainability of Suit – Preliminary Objections – Union of India contends suit is barred due to ongoing appeals under Article 136 – Argument that Article 131 suits should not involve private parties or duplicate issues pending elsewhere – Supreme Court rejects these contentions, affirming maintainability of suit for adjudication on merits [Paras 4-14, 32-43, 67, 78-79, 85].

Federalism – Consent Withdrawal and CBI Jurisdiction – West Bengal's consent under Section 6 of DSPE Act withdrawn – CBI's authority to register cases post-withdrawal questioned – Legal implications on federal structure and state's sovereign powers emphasized – Supreme Court examines constitutional framework and legislative intent behind Sections 5 and 6 of the DSPE Act – Reiterates need for central agencies to respect state jurisdiction absent explicit consent or court order [Paras 6-21, 52-66, 68-77].

Interpretation of Article 131 – Legal Rights vs. Political Disputes – Dispute must involve legal rights, not merely political disagreements – Supreme Court distinguishes between genuine federal disputes and political conflicts – Emphasizes that Article 131 intended to address substantial questions impacting legal rights of states versus central government authority [Paras 108-117].

Decision: Preliminary objections dismissed – Suit to proceed on merits – Supreme Court emphasizes necessity to address core constitutional issues regarding federalism and state immunity from central overreach [Paras 84-85].

Criminal Law – Abetment of Suicide – Appeal against High Court order dismissing revision application against Trial Court’s refusal to discharge – Allegations of harassment and physical abuse by wife leading to husband’s suicide – No proximate link established between alleged conduct and suicide – Essential ingredients of instigation or active role in abetment not proved – Appeal allowed, discharge application granted [Paras 1-15].

Section 306 IPC – Instigation and Abetment – Explanation of essential ingredients of instigation and intentional aid under Section 306 read with Section 107 – Requirement of active role, mens rea, and direct act leading to suicide – No evidence of instigation or active participation by accused wife – High Court order set aside, discharge granted [Paras 7-15].

Marital Dispute and Suicide – Examination of evidence and witness statements – Allegations of physical and mental harassment by wife – Statements from complainant and colleagues of deceased – No substantial evidence supporting the allegations – Arguments by appellant regarding deceased’s alcohol addiction and marital disputes considered – Legal principles reaffirmed [Paras 3-6, 10-13].

Procedural Aspects – Discharge Application – Trial Court and High Court’s rejection of discharge application – Appellate scrutiny of legal standards for discharge under Section 227 Cr.P.C. – Emphasis on absence of prima facie case – Discharge granted [Paras 4, 5, 6].

Decision – Appeal Allowed – Held – Impugned High Court order and Trial Court order rejecting discharge application set aside – Discharge application allowed [Para 15].

Adverse Possession – Limitation and Burden of Proof – Appellant-State claimed ownership based on adverse possession since 1958 following the donation of land for constructing a Veterinary Hospital – Trial Court decreed possession in favor of plaintiff due to lack of proof of donation – First Appellate Court reversed, acknowledging adverse possession – High Court restored Trial Court’s judgment, noting the absence of detailed adverse possession claims – Supreme Court found the suit barred by limitation, upholding appellant’s continuous possession as proof of adverse possession and ownership [Paras 1-33].

Vague Pleadings – Rejection of Suit – High Court failed to consider that plaintiff’s vague plaint lacked specific dates and details regarding construction awareness, allowing circumvention of the limitation law – Supreme Court criticized the vague plaint for lacking material particulars necessary for the case [Paras 15-18].

Ownership Presumption – Section 110 of Indian Evidence Act – Burden of proof for ownership lies on the respondent challenging the appellant’s possession – Possession since 1958 indicated ownership, supported by documentary evidence – Plaintiff’s inability to rebut this presumption resulted in the dismissal of the suit [Paras 30-32].

Decision: Appeal allowed – High Court judgment set aside – First Appellate Court’s dismissal of the plaintiff’s suit confirmed [Paras 33-34].

Quashing of Criminal Proceedings – Defective Vehicle – Compensation in Lieu of Replacement – The High Court quashed the FIR against the respondents for alleged cheating in the sale of a defective BMW car, but directed the replacement of the vehicle with a new one. The Supreme Court, noting the prolonged nature of the dispute and the manufacturer’s compliance willingness, directed a compensation payment instead. It held that the High Court’s direction for vehicle replacement was unjustified once it concluded no cheating was established [Paras 1-15].

Exercise of Article 142 – Compensation Awarded – The Supreme Court invoked Article 142 to grant substantial justice by directing the manufacturer to pay Rs 50 lakhs to the complainant, considering the vehicle’s depreciation and the refusal to accept a replacement. The court emphasized the need for practical resolutions to long-pending disputes [Paras 12-14].

High Court’s Order – Quashing Justified, Replacement Unwarranted – While agreeing with the quashing of the proceedings due to insufficient evidence of cheating, the Supreme Court found the High Court’s direction for replacement incongruous and instead settled the matter with a compensation directive [Paras 10-15].

Decision – Appeals Disposed Of – Held – The High Court’s order for quashing the complaint is sustained; however, its direction for replacing the vehicle is set aside. The manufacturer is directed to pay Rs 50 lakhs to the complainant by August 10, 2024. Compliance with this payment will render all claims satisfied [Para 15].

Civil Procedure – Inherent Powers of Court – Admission of Insufficiently Stamped Document – Trial court admitted a General Power of Attorney (GPA) as evidence without objection, which was later challenged for being insufficiently stamped. Supreme Court held that the trial court can recall the admission of such a document using inherent powers under Section 151 of the CPC, even if initially admitted without judicial determination. The court must ensure documents comply with the stamp duty requirements to prevent fiscal loss to the state [Paras 1-22].

Stamp Duty – Examination and Impounding of Instruments – GPA insufficiently stamped; trial court admitted it without judicial determination. Supreme Court emphasized the mandatory nature of Sections 33 and 34 of the Karnataka Stamp Act, 1957, requiring judicial scrutiny of stamp duty compliance, regardless of objections from parties. Absence of such scrutiny permits the court to revisit the admission of the document to enforce stamp duty obligations [Paras 10-14, 18-22].

Admissibility of Document – Judicial Determination Requirement – Admission of a document in evidence without judicial consideration of its stamp duty sufficiency is void. Supreme Court clarifies that without judicial determination at the time of admission, Section 35 of the Karnataka Stamp Act, 1957, barring further questions on stamp duty sufficiency, does not apply [Paras 12-16, 19].

Decision: Appeal allowed – High Court order set aside – Trial court's order restored, directing the respondent to pay deficit stamp duty and penalty. Trial court to proceed expeditiously with the civil suit [Paras 22-23].

Consumer Law – Definition of Consumer – Appeals centered on whether vehicles purchased by a company for the use of its directors fall within the definition of "commercial purpose" under Section 2(1)(d) of the Consumer Protection Act – National Commission held that purchases for the personal use of directors did not amount to "commercial purpose" – Supreme Court upheld this interpretation, confirming that such purchases are not for profit-generating activities and hence do not exclude the buyer from being a consumer [Paras 1-17, 26-29].

Commercial Purpose – Dominant Purpose Test – The Court reiterated that the determination of "commercial purpose" depends on the facts and circumstances of each case – Emphasized that the dominant purpose of the purchase must be examined – Purchases for personal use of directors not linked to profit generation are not considered "commercial purpose" [Paras 11-16, 29].

Defects in Goods – Deficiency in Service – Respondents-complainants reported defects in vehicles, particularly overheating issues – National Commission found the appellants liable for deficiencies in service – Supreme Court upheld the finding, directing compensation to the complainants [Paras 18-25, 30-37].

Unfair Trade Practice – Misrepresentation – National Commission found that appellants misrepresented the safety features of the vehicles, constituting an unfair trade practice under Section 2(1)(r) of the Consumer Protection Act – Supreme Court agreed, awarding compensation for unfair trade practice [Paras 31, 34, 39].

Decision – Appeals Partly Allowed and Dismissed – Supreme Court modified the National Commission's order to permit the respondent to retain the vehicle and directed the appellant to refund a reduced amount considering the long usage of the vehicle – Other appeals dismissed, confirming the National Commission's orders on deficiencies and unfair trade practices [Paras 40-40(II)].

Civil Law – Revocation of Power of Attorney – Implied Revocation – Appellant and respondent No. 1 (sisters) purchased property together; appellant later executed a power of attorney (PoA) in favor of respondent No. 1. Appellant retired and returned to India, participating in a sale deed with respondent No. 1. Supreme Court held that this participation amounted to an implied revocation of the PoA, invalidating a subsequent sale deed executed by respondent No. 1 alone in favor of her husband, respondent No. 2 [Paras 1-25].

Property Law – Validity of Sale Deed – Non-Receipt of Consideration – The sale deed executed by respondent No. 1 in favor of respondent No. 2 lacked consideration. The Supreme Court confirmed the trial court's finding that the sale deed was void ab initio due to non-receipt of consideration, affirming the appellant’s half-share in the property [Paras 23-24].

Limitation – Suit for Declaration – The appellant filed the suit within the limitation period, as the right to sue first accrued when she gained knowledge of the impugned sale deed. The Supreme Court rejected the respondent’s plea that the suit was time-barred [Paras 15-15.1].

Decision: Appeal allowed – Judgment and decree of the trial court confirmed – Trial court directed to explore the possibility of determining the market value of the appellant's half share in the property and proceed accordingly. If consensus on market value is not reached, the trial court to proceed with final decree proceedings and execution in accordance with the law [Paras 25-26].