Industrial Disputes Act – Jurisdiction – Civil suits filed by workmen challenging fines imposed by management – Plea to dismiss suit under Order VII, Rule 11 CPC on the ground that the matter should be dealt with under the Industrial Disputes Act – Suit dismissed by lower courts – Supreme Court reaffirmed that disputes arising from the general law of contract can be adjudicated in civil court unless they involve rights created exclusively by the Industrial Disputes Act – Appeal dismissed [Paras 1-13].

Order VII, Rule 11 CPC – Dismissal of Suit – Criteria – Application to reject the plaint under Order VII, Rule 11 CPC – Civil court jurisdiction not ousted if the dispute arises from general contractual obligations – Civil court appropriate forum for disputes not exclusively covered under the Industrial Disputes Act [Paras 4-13].

Decision: Appeals dismissed – Civil Judge directed to expedite the trial of the suit and complete it within six months [Para 12].

Criminal Procedure – Bail – Jurisdiction – Appeal against High Court order which went beyond the scope of Section 439 CrPC – High Court, while granting bail, constituted a committee to recommend criminal justice system reforms – Supreme Court held that jurisdiction under Section 439 is limited to granting or denying bail – High Court's additional directions deemed inappropriate and beyond jurisdiction – Appeal allowed, setting aside the High Court's directions for the committee [Paras 1-12].

Judicial Overreach – Scope of Bail Proceedings – High Court's act of retaining the file post granting bail and issuing directions for systemic reforms deemed overreach – Jurisdiction under Section 439 CrPC does not extend to administrative reforms – Supreme Court emphasizes judiciary's role limited to legal and constitutional issues, not policy-making [Paras 5-11].

Relevant Precedents – Inherent Jurisdiction – Court reiterates that inherent powers under Section 482 CrPC or other judicial tools must not be used to bypass established legal procedures – Refers to past judgments underscoring limits of judicial intervention in policy matters and criminal procedure [Paras 6-9].

Decision: Appeal allowed – High Court order constituting committee for criminal justice reforms set aside – Directions beyond scope of Section 439 CrPC deemed unsustainable [Para 12].

Service Law – Direct Recruitment vs. Promotion and Deputation – Appellants challenged direct recruitment to posts of Administrative Officer/Assistant Assessor and Collector, arguing promotion should be attempted first – Recruitment Rules mandate 50% by promotion and 50% by deputation, failing which direct recruitment can be resorted to – High Court found respondents did not attempt promotion or deputation before advertising for direct recruitment – Supreme Court examined compliance with Recruitment Rules and found Municipal Bodies adhered to the rules by filling promotion quota and attempting to fill deputation quota [Paras 2-11].

Right to Appointment – Candidates' Right – Candidates responding to advertisement do not have an indefeasible right to appointment – Mere appearance in merit list does not guarantee appointment – Municipal Bodies must fill posts as per statutory rules – Direct recruitment only after exhausting promotion and deputation quotas – Appellants' challenge to recruitment process without merit as recruitment rules followed [Paras 12-13].

Judicial Review – Adherence to Recruitment Rules – Supreme Court upheld High Court's view that recruitment process must adhere to recruitment rules – Municipal Bodies followed statutory requirements by filling promotion and attempting to fill deputation quota – Direct recruitment permissible only after such attempts – Appeals dismissed [Paras 13-14].

Decision: Appeals dismissed – Recruitment by direct recruitment upheld after promotion and deputation quotas addressed – Appellants have no vested right to appointment merely by appearing in merit list – Recruitment process in compliance with statutory rules [Paras 13-14].

Industrial Dispute Act – Jurisdiction – Appellant challenged termination as a consequence of non-joining on transferred post – Industrial Court's jurisdiction questioned – High Court held termination disputes fall within Labour Court’s jurisdiction – Appeal dismissed, affirming no jurisdiction of Industrial Court in termination cases linked to unfair labor practices [Paras 1-24].

Unfair Labor Practices – Termination and Transfer – Allegation of unfair labor practices due to termination after failure to join transferred post – High Court found no jurisdiction for Industrial Court in termination matters, stressing statutory provisions – Termination deemed within Labour Court's purview [Paras 10-23].

Malice in Transfer – Allegations of mala fide in transfer rejected – High Court upheld transfer as per employment terms – No personal bias or oblique motive established – Proper procedure followed by employer [Paras 14-20].

Decision: Appeal dismissed – Jurisdiction for termination disputes rests with Labour Court – No evidence of mala fide transfer or unfair labor practices by employer.

Civil Procedure – Suit for possession on the basis of title – Defendants denied the title of Managing Officer and the plaintiff – Defendants' plea of continuous possession without hostile intent – Evidence showed continuous possession since 1963 but not adverse – High Court’s finding of adverse possession legally unsustainable – Judgment and decree of High Court set aside – Suit decreed in favor of plaintiff [Paras 1-16].

Adverse Possession – Requirements – Possession must be hostile, open, and continuous – Denial of true owner’s title necessary – Defendants failed to admit hostile possession or acknowledge true ownership – Long possession alone insufficient to claim adverse possession [Paras 9-16].

Decision: Appeal allowed – High Court judgment and decree set aside – Suit for possession decreed in favor of the plaintiff.

Service Law – Promotion and Medical Fitness – Appeal against High Court decision denying promotion to IG – Appellant reverted to DIG based on medical board categorization – Multiple medical examinations with conflicting categorizations – Reversion without notice or hearing – Supreme Court grants relief under Article 142 for retiral dues computation based on IG rank – No further consideration for promotion to Additional DGP [Paras 1-10].

Natural Justice – Right to be Heard – Reversion from IG to DIG without show-cause notice or hearing violates principles of natural justice – Interim orders maintained appellant in IG rank until retirement – Supreme Court recognizes service in IG rank for nearly four years [Paras 8-9].

Judicial Review – Exercise of Article 142 – Supreme Court exercises Article 142 to direct computation of retiral dues as IG despite conflicting medical board reports – Appellant not entitled to further consideration for promotion to Additional DGP [Paras 9-10].

Decision: Appeal disposed of – Retiral dues to be computed based on appellant’s IG rank at retirement – Sealed cover regarding promotion to Additional DGP to be returned – No further claim for Additional DGP promotion – No order as to costs [Para 10].

Criminal Law – Forgery – Appeal against High Court decision affirming conviction under Sections 467 and 468 IPC – Appellant, a postman, accused of forging the signature of PW-2 on a delivery slip for a registered envelope containing Indira Vikas Patras – Prosecution evidence included testimony from complainant, denial of signature by PW-2, and reports from handwriting experts – Supreme Court reduces sentence to period already undergone due to long passage of time since the incident (1992) [Paras 1-21].

Evidence Law – Handwriting Expert – Reliability – Conviction based on corroborative evidence including expert opinion – Court emphasizes caution in relying solely on handwriting experts – In this case, expert opinions corroborated by other evidence, including PW-2’s denial of the signature, supporting conviction [Paras 13-18].

Judicial Review – Sentencing – Reduction of Sentence – Considering the occurrence in 1992 and appellant's custody for more than 18 months, Supreme Court reduces imprisonment to period already undergone – Conviction upheld but sentence modified [Paras 20-21].

Decision: Appeal partly allowed – Conviction under Sections 467 and 468 IPC confirmed – Sentence reduced to period already undergone – Appellant to be released unless required in any other case [Para 21].

Constitutional Law – Reservation in Promotion – Persons with Disabilities – Supreme Court held that persons with disabilities are entitled to reservation in promotions under Section 33 of the 1995 Act – Distinction between reservations under Article 16(4) and horizontal reservations under Article 16(1) emphasized – Prior Supreme Court judgments in Indra Sawhney and others clarified – Reservation in promotions for disabled persons upheld despite office memorandum limiting such reservations – Appeals allowed and prior judgments set aside [Paras 1-26].

Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995 – Interpretation – Sections 32 and 33 – Identification of posts and reservation in employment for persons with disabilities – Supreme Court emphasized the requirement to provide reservation in promotion once posts are identified for disabled persons – Government directed to comply with statutory provisions and Supreme Court judgments ensuring reservation in promotion for persons with disabilities [Paras 1-10].

Decision: Appeals allowed – Supreme Court judgments in National Federation of the Blind and Rajeev Kumar Gupta reiterated – Office memorandum inconsistent with these judgments struck down – Union and State Governments directed to follow the law as declared by the Supreme Court – Contempt petitions to be listed for hearing [Paras 10-26].

Child Rights – Jurisdictional Conflict – National and State Commissions for Protection of Child Rights – Inquiry into large-scale child trafficking – NCPCR initiated inquiry but WBCPCR claimed prior cognizance – Court emphasizes need for cooperation between Commissions – NCPCR entitled to proceed where State Commission failed to act promptly – Court directs High Court to monitor child protection measures [Paras 1-40].

Functions and Powers – Commissions for Protection of Child Rights Act, 2005 – Both NCPCR and State Commissions empowered to protect child rights – No absolute ouster of jurisdiction – Both Commissions to work in tandem – NCPCR has nationwide jurisdiction; State Commissions have state-specific jurisdiction – NCPCR can inquire into inter-state and international ramifications of child rights violations [Paras 6-13, 36].

Judicial Review – Inquiry and Investigation – Commissions must proactively investigate child rights violations – Mandate to examine, review, and recommend measures for effective implementation of child protection laws – Judicial review to ensure Commissions function effectively and cooperatively [Paras 14-15].

Decision: Appeal partly allowed – NCPCR's inquiry upheld – High Court of Calcutta to monitor child protection issues and implementation of Juvenile Justice (Care and Protection of Children) Act, 2015 in West Bengal – Directions issued for cooperation between National and State Commissions – Registry to communicate judgment to High Court of Calcutta for further action [Paras 38-40].