Facts:

The case involves the interpretation of various provisions of the Constitution of India regarding reservation in promotions and the application of the creamy layer principle to SCs and STs.

Issues:

The judgment include the validity of the M. Nagaraj case judgment, the application of the creamy layer principle, the interpretation of relevant constitutional provisions, the object of reservation, and the reservation in promotions for SCs and STs.

Held:

The court held that the judgment in M. Nagaraj case did not need to be referred to a seven-judge bench. However, the requirement for the State to collect quantifiable data showing backwardness of SCs and STs, as mandated by the M. Nagaraj case, was deemed invalid to this extent .

The application of the creamy layer principle to SCs and STs was upheld. Only individuals within SCs and STs who have come out of untouchability or backwardness due to belonging to the creamy layer would be excluded from reservation benefits. This application was seen as consistent with Articles 14 and 16(1) of the Constitution .

The court emphasized a harmonious interpretation of Articles 14, 16, 341, and 342 of the Constitution, clarifying that Parliament has the freedom to include or exclude persons from the Presidential Lists based on relevant factors. Similarly, Constitutional Courts have the authority to exclude the creamy layer from these lists when applying the principles of equality under Articles 14 and 16 .

The court reiterated that the purpose of reservation is to ensure the progress of backward classes of citizens and their attainment of equality with other citizens of India .

The determination of adequate representation in promotional posts for SCs and STs under Article 16(4-A) is left to the discretion of the States, considering the efficiency of administration and the need for reservation at different levels of promotion .

The court clarified that while a proportionality test to the population as a whole may be considered for representation in promotional posts, the language of Article 16(4-A) allows States to determine adequate representation based on the specific context of the promotional post in question.

Facts:

Ambala Bus Syndicate Pvt Ltd appealed against the judgment of the Division Bench of the High Court of Punjab and Haryana at Chandigarh dated April 21, 2011.

The dispute centered around the operation of stage carriages by Ambala Bus Syndicate Pvt Ltd beyond Punjab's territory in light of the 1998 Scheme, as amended in 2001.

Issues:

Whether Ambala Bus Syndicate Pvt Ltd could operate its stage carriages beyond the territory of Punjab under the provisions of the Motor Vehicles Act, 1988, and the Punjab Reorganisation Act, 1966.

The significance and effect of the reciprocal Agreement of 2008 between the Union Territory of Chandigarh and the State of Punjab in permitting the operation of non-air conditioned buses.

Held:

The Court acknowledges the importance of the reciprocal Agreement of 2008, highlighting its provision for counter signature of non-air conditioned buses owned and operated by private operators. The Court finds that the Division Bench overlooked the relevance of this Agreement.

The Court emphasizes that despite the existence of the 1998 Scheme, the reciprocal Agreement of 2008 allowed for the operation of non-air conditioned buses under certain conditions. The Court concludes that unless the reciprocal agreement is superseded or a new scheme is framed by the Union Territory of Chandigarh, the buses operated by Ambala Bus Syndicate Pvt Ltd, provided they meet the conditions stipulated in the Agreement and are renewed by the State of Punjab, cannot be refused counter signature.

Consequently, the Court sets aside the Division Bench's order and restores that of the learned Single Judge of the High Court, allowing Ambala Bus Syndicate Pvt Ltd to continue operating its stage carriages beyond Punjab's territory.

The Court directs that necessary actions be taken within four weeks and disposes of pending applications, with no costs awarded.

Facts:

The respondent filed a suit against the appellants for eviction from the suit premises.

A compromise was reached during the suit, resulting in a consent decree.

The defendants failed to comply with the terms of the decree, leading to execution proceedings.

The Executing Court ordered possession in favor of the plaintiff, but the defendants filed a revision, leading to remand by the revisionary court.

The High Court set aside the revisionary court's order and upheld the Executing Court's decision.

Issues:

Whether the remand by the revisionary court was justified.

Whether additional documents filed by the defendants were relevant in the revisionary jurisdiction.

Held:

The Court found that the revisionary court erred in remanding the case to the Executing Court instead of deciding the revision on its merits.

The court emphasized that remand is warranted only for material issues not decided or procedural lacunae.

The allowance of additional documents was deemed unnecessary as the legality and correctness of the order could be decided based on existing records.

The High Court should have remanded the case to the revisionary court instead of deciding the issue on merits itself.

The revisionary court is directed to decide the revision afresh on its merits, considering relevant legal precedents, within six months. The appeals thus succeed and are accordingly allowed in part.

Facts:

The appellant's wife died along with her child by drowning in a river within seven years of her marriage. The Trial Court convicted the appellant under Section 304-B IPC, which was affirmed by the High Court with a reduced sentence. The appellant contended that there was neither cruelty nor any demand for dowry.

Issues:

Whether the evidence presented in the case warrants interference by the Supreme Court under Article 136 of the Constitution of India?

Held:

The Supreme Court will not reassess the evidence at large in an appeal under Article 136, particularly when it has been concurrently accepted by the High Court and the Courts below.

Interference by the Supreme Court is justified only if something more is shown, such as a violation of principles of natural justice, error of law or procedure, misreading of evidence, or manifestly perverse conclusions by the High Court.

Material in the form of testimony from witnesses PW-1 and PW-3 regarding dowry harassment was present. This included complaints made by the deceased to her father and elder sister about harassment by the appellant.

The presumption under Section 113-B of the Evidence Act for dowry death was applicable considering the circumstances presented in the case.

The trial court's conclusion was based on evidence, including testimony from various witnesses, and was not manifestly perverse. The view taken by the trial court and affirmed by the High Court was warranted by the materials on record.

Decision: The appeal was dismissed, and the conviction under Section 304-B IPC was upheld.

Facts:

The appellant, Ambadevi Sanstha, a registered Public Trust under the Bombay Public Trusts Act, 1950, appealed against judgments and orders of the High Court of Judicature at Bombay, which confirmed the sale order passed by the Joint Charity Commissioner.

The Trust had applied for permission to sell its properties, which was granted by the Joint Charity Commissioner despite objections raised by some trustees and prospective purchasers.

Several irregularities were found in the sale process, including the lack of proper valuation of the properties, failure to fix reserve prices, and acceptance of earnest money before obtaining permission for sale.

Issues:

Whether the sale order passed by the Joint Charity Commissioner was valid and in accordance with the law.

Whether the sale transactions involving public trust properties were conducted in the best interest of the trust and in compliance with legal procedures.

Held:

The Court emphasized the importance of protecting the interest, benefit, and protection of the trust when considering the sale of its properties.

It reiterated that the Charity Commissioner must be objectively satisfied that the sale is necessary for the public trust.

Several irregularities were found in the sale process, including the lack of proper valuation of the properties, failure to fix reserve prices, and acceptance of earnest money before obtaining permission for sale.

The Court annulled the sale transactions and directed the Trust to protect its properties in the future.

It ordered the restoration of possession of the properties to the Trust, emphasizing that the purchasers were not entitled to retain possession as they had enjoyed the properties for an extended period under an illegal sale.

Facts:

Navin Kumar Singh, a Chemical Engineer, was initially appointed in E-2 Grade at Dankuni Coal Complex (DCC), a unit of Coal India Ltd.

Singh requested a transfer to Central Mine Planning and Design Institute Limited (CMPDIL), another subsidiary of Coal India Ltd., which was approved.

Company policy stated that employees who requested inter-company transfers for personal reasons would lose their past seniority in the previous company.

Singh was denied promotion to the E-3 Grade at CMPDIL, as his service at DCC was not considered.

Singh challenged this decision in court, arguing that his service at DCC should be counted for determining his eligibility for promotion.

Issues:

Whether the past service of Navin Kumar Singh at DCC should be considered for determining his eligibility for promotion to the E-3 Grade at CMPDIL despite the inter-company transfer.

Held:

The Supreme Court held that Navin Kumar Singh's past service at DCC should indeed be considered for determining his eligibility for promotion to the E-3 Grade at CMPDIL, despite the inter-company transfer policy. The Court concluded that while the policy stated that seniority would be lost in the new company upon transfer, it did not explicitly address the exclusion of past service for all purposes. Therefore, Singh's past service should be counted for eligibility for promotion, even though his seniority in CMPDIL would start from the date of his joining there.

The Court further clarified that the Office Memorandum dated 5th June, 1985, which addressed issues related to inter-company transfers, did not hinder Singh's claim. The memorandum aimed to ensure fair treatment for transferred employees in terms of promotion opportunities but did not affect the length of service.

Accordingly, the appeals filed by Coal India Ltd were dismissed, affirming the decision of the High Court to grant Singh notional seniority and eligibility for promotion based on his past service at DCC.

Facts:

The case concerned a writ petition challenging the court's authority to issue a mandamus to Parliament to enact legislation to prevent individuals facing serious criminal charges from contesting elections. Additionally, it questioned whether the court could direct the Election Commission to control party discipline by disallowing candidates with criminal antecedents from contesting with party symbols.

Issues:

Whether the court had the jurisdiction to mandate Parliament to enact laws preventing individuals facing serious criminal charges from contesting elections.

Whether the court could direct the Election Commission to control party discipline by disallowing candidates with criminal antecedents from contesting with party symbols.

Held:

The court affirmed that criminalization in politics was a well-known phenomenon in India, with significant implications for democracy.

It was recognized that the Election Commission had been aware of the issue of criminalization in politics since 1998, and various recommendations had been made, although no legislative action had been taken.

The court emphasized that Parliament had the exclusive power to lay down disqualification criteria for membership, as specified in the Constitution and relevant sections of the Representation of the People Act, 1951.

The court clarified that the judiciary could not legislate or add new grounds for disqualification beyond what was specified by the legislature.

While the Election Commission had powers to supervise elections, it must operate within the framework of laws enacted by Parliament.

Directing the Election Commission to disallow candidates with criminal charges from contesting with party symbols would exceed its constitutional mandate.

The court stressed the importance of voters having access to information about candidates' criminal backgrounds and directed candidates and political parties to disclose such information publicly.

The court recommended that Parliament enact legislation to prevent individuals facing serious criminal charges from entering politics, acknowledging the possibility of false cases but suggesting that Parliament address this through appropriate legislation.

Facts:

The case originated from concerns raised by a former Chief Justice of India regarding inhumane conditions in prisons, including overcrowding, unnatural deaths of prisoners, inadequacy of staff, and lack of training for staff. The State initially resisted the petition but later acknowledged the need for reforms.

Issues:

The Court was tasked with addressing the inhumane conditions prevailing in prisons and the necessity for reforms in prison administration to uphold prisoners' rights under Article 21 of the Constitution.

Held:

The Court directed the Ministry of Home Affairs to constitute a Supreme Court Committee on Prison Reforms. The committee was tasked with reviewing various aspects related to prison reforms, including implementation of guidelines, training of prison personnel, conditions of women prisoners, overcrowding, violence prevention, staff inadequacy, establishment of open prisons, and the well-being of children in conflict with the law.

The Court emphasized the significance of public interest litigation (PIL) in addressing social issues and ensuring accountability. It appreciated the efforts of the Amicus Curiae in assisting the case and making valuable suggestions for the recognition and implementation of prisoners' human rights.

Facts:

The arbitrator conducted meetings in Kuala Lumpur and issued an arbitral award in favor of the respondents. The appellant challenged the award under Section 34 of the Arbitration and Conciliation Act, 1996.

Issues:

Whether the seat or venue of arbitration was specified in the arbitration agreement.

The jurisdiction of Indian courts to entertain the application challenging the arbitral award.

Held:

The arbitration clause must be construed holistically to determine the jurisdiction of the court.

If the agreement mentions a venue along with other conditions, it may imply exclusion of Part I of the Arbitration and Conciliation Act.

In this case, the place of arbitration was not agreed upon by the parties. The Arbitral Tribunal was required to determine the place if there was a failure of agreement.

The determination of the place must be clearly stated in the arbitral award.

The term "determination" signifies an expressive opinion, which was lacking in this case.

A "place" can become a "seat" if certain conditions precedent are satisfied. In this case, as the conditions were not satisfied, Kuala Lumpur was not the seat or place of arbitration.

Courts in India have jurisdiction as the determination of the place was not done, and thus, the order of the Delhi High Court was set aside.

Decision: The Supreme Court clarified the distinction between "seat" and "venue" in arbitration agreements and held that Indian courts have jurisdiction in this case since no determination of the place of arbitration was made.