Criminal Law – BNSS – Section 175(4) – Interpretation – Not a Standalone Provision – Issue whether Section 175(4) operates independently or in conjunction with Section 175(3) – Held: Sub-sections (3) and (4) are not isolated silos – Power to order investigation flows primarily from Section 175(3) – Section 175(4) provides an additional procedural safeguard where complaint is against a public servant – It neither stands alone nor operates independently of Section 175(3) [Paras 24–26, 31, 37–39, 42].

Statutory Construction – BNSS – Section 175(4) – Not a Proviso – Question whether Section 175(4) is to be read as a proviso to Section 175(3) – Held: Not a proviso – Provision does not carve out an exception but introduces an additional safeguard absent in CrPC – Placement as a sub-section and ability to operate even if Section 175(3) is removed militates against proviso construction [Paras 32–36].

Judicial Magistrate – Power to Order Investigation – Mandatory Preconditions – Magistrate can exercise power under Section 175 only after complainant exhausts remedy under Section 173(4) – Resort to Superintendent of Police is a mandatory statutory step – Direct approach to Magistrate impermissible – Sequential statutory scheme must be respected [Paras 31.1–31.2].

Affidavit – Mandatory Requirement – Complaints Against Public Servants – Though Section 175(4) uses expression “complaint”, term cannot include oral complaints – Context requires written complaint supported by affidavit – Affidavit requirement under Section 175(3) read with Section 333 BNSS applies equally to Section 175(4) – Any other interpretation would defeat safeguard laid down in Priyanka Srivastava [Paras 37.4–37.9, 41, 44].

Public Servants – Additional Threshold Protection – Legislative Intent – Section 175(4) introduced to prevent frivolous or vindictive complaints against public servants – Requires Magistrate to call for report from superior officer and consider explanation of accused public servant – Protection operates at pre-investigation stage and is distinct from sanction requirement under Section 218 BNSS [Paras 27–30, 40].

Lalita Kumari – FIR Registration – Limited Applicability – Principles of mandatory FIR registration govern police action under Section 154 CrPC / Section 173 BNSS – Once matter reaches Magistrate under Section 175 BNSS, statutory procedure therein governs – Lalita Kumari does not override Magistrate’s duties under Section 175 [Paras 16–19].

Judicial Magistrates – Discretion under Section 175(4) – Practical Guidelines – Where prima facie offence appears connected with discharge of official duties, Magistrate must follow Section 175(4) safeguards – Where doubt exists, Magistrate should err on side of caution – Where act clearly unrelated to official duty, Magistrate may proceed under Section 175(3) alone – Magistrate may reject complaints that are absurd, improbable or untenable with recorded reasons [Paras 45–48].

Writ Jurisdiction – Article 226 – Premature Interference – Bar – Single Judge erred in entertaining writ petition while proceedings under Section 175 were pending before JMFC – Judicial order calling for report under Section 175(4) could not be interfered with in writ jurisdiction – Directions issued without challenge to Magistrate’s order held impermissible [Paras 49–53].

Judicial Orders – Recall by Magistrate – Impermissibility – Single Judge’s directions effectively compelled Magistrate to recall his own judicial order – Such power unknown to criminal procedure – Magistrate’s subsequent FIR direction rendered unsustainable [Paras 52–53].

Public Servants – Discharge of Official Duties – Fact-Dependent Determination – Whether alleged acts arose in discharge of official duties requires factual assessment – Writ court cannot undertake magisterial fact-finding – Issue must be left open for determination by JMFC under statutory procedure [Paras 54–57].

Decision: Appeal dismissed – Judgment of Division Bench upheld – Order of Single Judge set aside – Magistrate to proceed strictly in accordance with Sections 175(3), 175(4) and 333 BNSS – No direction for immediate FIR registration – Appellant granted liberty to raise all contentions before JMFC – Parties to bear their own costs.

Criminal Law – Sect 302 IPC – Murder - Circumstantial Evidence – Reversal of Acquittal – Limits of Appellate Interference – Trial Court acquitted the accused holding that prosecution failed to establish a complete chain of circumstances – High Court reversed acquittal holding that the five golden principles in Sharad Birdhichand Sarda were satisfied – Supreme Court held that appellate court must first examine whether the view taken by Trial Court was a possible and reasonable view – Acquittal strengthens presumption of innocence and cannot be lightly disturbed – High Court erred in substituting its own inferences without dislodging the Trial Court’s reasoning [Paras 2–6, 31–32].

Circumstantial Evidence – Last Seen Theory – Requirement of Proximity – Prosecution alleged deceased was last seen with accused on evening of 18.02.2006 – No witness proved actual seeing together of deceased and accused immediately prior to death – Statements relied upon were hearsay or merely indicated intended meeting – Auto-rickshaw driver’s testimony unreliable due to absence of test identification parade and prior police identification – Held: Last seen theory not established as proximity to time of death not proved [Paras 10–15].

Medical Evidence – Cause of Death – Inconclusive Opinion – Post-mortem suggested asphyxia by strangulation – Cross-examination revealed possibility of death by hanging – Absence of classical signs of strangulation such as cyanosis or blood clots – Medical evidence not conclusive of homicidal death – Held: Inconclusive medical opinion cannot sustain conviction without strong corroborative circumstantial evidence [Paras 9–12].

Recovery of Dead Body – Section 27 Evidence Act – Discovery Not Proved – Prosecution claimed accused led police to graveyard where body was exhumed – No disclosure statement recorded – Independent witnesses did not support accused’s presence at exhumation – Conflicting testimony on date of recovery – Held: Discovery not attributable to accused under Section 27 and cannot be treated as incriminating circumstance [Paras 17–18].

Recovery of Weapon – Rope – Forensic Evidence – Failure of Proof – Rope allegedly recovered at instance of accused – Recovery witnesses denied disclosure statement – Rope recovered from open place already accessed earlier – Forensic report did not show blood, human tissue or hair – Held: Recovery highly doubtful and not reliable as incriminating evidence [Paras 18–19].

Seizure of Articles – Identification of Property – Failure to Link with Crime – Alleged recovery of belongings of deceased from accused – Articles not identified by father of deceased – Some seizure witnesses turned hostile – Laptop admittedly handed over earlier to friend – Held: Seizures failed to establish nexus with crime [Paras 20–22].

Confessional Statements – Section 164 CrPC – Voluntariness and Evidentiary Value – Confessions retracted – Serious discrepancies in recording dates and language – Magistrate failed to inform accused of right to legal assistance – Confession of A1 exculpatory and incriminating co-accused – Confession of A2 not amounting to admission of guilt – Held: Confessions unreliable, not voluntary and lacking corroboration – Cannot form basis of conviction [Paras 23–30].

Criminal Jurisprudence – Confession – Requirement of Corroboration – Confession must be direct acknowledgment of guilt – Partial or exculpatory statements not confessions in law – In absence of independent corroborative evidence, conviction impermissible – Reliance placed on Pyarelal Bhargava and Kanda Pandyachi [Paras 29–30].

Decision – Appeals allowed – Judgment of High Court set aside – Acquittal recorded by Trial Court restored – Accused directed to be released forthwith if not required in any other case – Bail bonds cancelled [Paras 32–33].

Service Law – Reservation – Migration to Open Category – Relaxation in Qualifying Examination – Reserved category candidates excluded from general merit list despite securing higher marks in TAIT on ground of availing TET relaxation – Held: Relaxation in qualifying examination only enables entry into zone of consideration and does not affect merit determined in main examination – In absence of express prohibition in recruitment rules, such candidates are entitled to migrate to open category [Paras 3, 19, 28, 32].

Eligibility vs Merit – Distinction – TET as qualifying examination and TAIT as merit-based selection – Relaxation in TET marks affects only eligibility and not inter se merit – Merit must be determined solely on performance in main examination without any concession – Level playing field maintained as no relaxation granted in TAIT [Paras 13, 28].

Reservation Principles – Concessions and Level Playing Field – Concessions like relaxation in qualifying marks are intended to bring candidates within zone of consideration and cannot be treated as advantage in final selection – Such concessions do not dilute merit-based competition [Paras 19(i), (ii)].

Non-Migration Rule – Applicability – Principle barring migration applies only where candidate does not meet essential eligibility criteria or where recruitment rules expressly prohibit migration – Where rules are silent, migration permissible – Administrative instructions cannot override statutory scheme [Paras 19(iii)-(v), 31].

Erroneous Reliance on Precedent – High Court relied on precedent dealing with failure to meet essential eligibility criteria – Supreme Court held such reliance misplaced as relaxation in TET was statutorily permitted and did not affect eligibility – Distinction between lack of eligibility and permissible relaxation reiterated [Paras 30-31].

Administrative Instructions – Validity – Commissioner’s directions issued on date of merit list restricting migration based on executive interpretation held unsustainable – Cannot override recruitment framework or settled legal principles [Paras 29-31].

Decision: Appeals allowed – Impugned High Court judgment set aside – Authorities directed to include appellants in open category merit list if they secured marks higher than last selected general category candidate – No order as to costs [Paras 33-35].

Motor Accident Compensation – Appeal by Insurer – Dismissal Without Merits – Tribunal awarded ₹2,72,03,416/- to 22-year-old claimant with 100% functional disability – Insurer’s first appeal dismissed by High Court solely on ground that local manager had given undertaking before Executing Court to satisfy award – No adjudication on merits – Held: Undertaking to comply with award cannot be treated as waiver of statutory right of appeal – High Court erred in not examining legality and correctness of compensation – Matter remitted for fresh consideration [Paras 10, 14–15].

Execution Proceedings – Coercive Attachment – Tribunal issued warrants under Order XXI Rule 43 CPC attaching office furniture, fixtures and computers of insurer – Action taken in haste despite insurer being public sector undertaking – Held: Procedure adopted lacked fairness and judicial application of mind – Alternative modes of recovery available – Coercive steps cannot deprive party of appellate remedy [Paras 11, 13–13.2].

Appellate Jurisdiction – First Appeal on Facts and Law – High Court, as first appellate court, obligated to examine award on law and facts – Mere statement of claimant’s counsel regarding undertaking insufficient to dismiss appeal – At most relevant for stay of execution – Failure to exercise jurisdiction warranted interference under Article 136 [Paras 14–14.1].

Review Petition – Order XLVII Rule 1 CPC – Review dismissed solely reiterating existence of undertaking – Supreme Court held that review rejection also unsustainable since foundational order itself erroneous [Paras 12.2, 15].

Interim Direction – Pending Remand – Considering non-disbursement of compensation and delay likely in remand, Supreme Court directed insurer to release ₹1,00,00,000/- to claimant within four weeks – Directions in Parminder Singh v. Honey Goyal, (2025) 9 SCC 539 to be followed [Para 16].

Judicial Administration – e-Courts and Handwritten Orders – Supreme Court deprecated practice of handwritten and illegible order sheets by Tribunal despite e-Courts project – Directed Registrar General to place order before Chief Justice and circulate to other High Courts for corrective steps – Emphasized transition towards paperless courts [Paras 17–19].

Decision: Appeals allowed – Impugned orders dated 19.11.2025 and 06.01.2026 set aside – Matter remitted to High Court for fresh decision on merits within six months – Direction to release ₹1,00,00,000/- to claimant – Pending applications disposed of.

Criminal Law - Bail – Regular Bail – Abetment of Suicide and Dowry Death Allegations – Appellant husband accused under Sections 108 and 80 BNS and Sections 3 and 4 of Dowry Prohibition Act in connection with death of wife – High Court rejected bail solely on seriousness of offence – Supreme Court examined FIR, case diary statements, post-mortem and surrounding circumstances – FIR initially alleged mental harassment due to alleged extra-marital relationship leading to suicide – No allegation of dowry demand in FIR or initial statements – Dowry allegations surfaced only in subsequent statements – Improvement in prosecution version noted – Held: Subsequent introduction of dowry allegations weakens prima facie case at bail stage [Paras 13–15].

Criminal Law – Abetment of Suicide vs. Murder – Medical Evidence – Post-mortem revealed multiple ante-mortem injuries including injection marks – Query report opined injuries (needle pricks, scratches) could be self-inflicted – No injury conclusively established as cause of death – Deceased was an anaesthetist and death prima facie due to Atracurium Besylate Injection – Absence of clear medical evidence pointing towards homicidal death – Held: At bail stage, material does not conclusively indicate murder [Paras 10–12, 15].

Evidence – Electronic Evidence – Suicide Note and Audio Recording – Recovery of photograph of handwritten suicide note, WhatsApp chats and audio recording indicating marital discord and emotional distress – Contents suggest suspicion of extra-marital affair and threat of self-harm – Held: Material indicates strained marital relationship but does not, by itself, establish abetment or homicidal intent for purposes of denying bail [Paras 10, 15].

Dowry Death – Prima Facie Assessment at Bail Stage – Allegations of demand of money/dowry absent in FIR and first statements of parents and brother of deceased – Allegations introduced later in investigation – Court cautioned against treating such improved statements as determinative at bail stage – Held: Prima facie case of dowry death not strong enough to justify continued incarceration [Paras 14–15].

Bail Jurisprudence – Post Charge-Sheet Custody – Appellant in custody since 25.03.2025 – Charge-sheet filed and charges framed – Appellant a dentist, not a hardened criminal – No likelihood of absconding or non-cooperation with trial – Continued detention not justified merely on gravity of allegations – Held: Bail deserved with conditions [Paras 15–16].

Decision: Appeal allowed – Order of High Court rejecting bail set aside – Appellant directed to be released on regular bail subject to conditions imposed by Trial Court – Appellant to cooperate with trial and not influence witnesses – Observations confined to bail consideration and not to affect merits of trial [Paras 16–17].

Property Law – Registered Sale Deed – Sham Transaction – Presumption of Validity – Threshold for Interference – Registered sale deed carries a strong presumption of validity and genuineness – Registration is a solemn act lending sanctity and certainty to title – Courts should not lightly or casually declare a registered deed to be sham – Burden lies heavily on the party challenging the deed to establish with cogent pleadings and evidence that it was never intended to be acted upon [Paras 31–33].

Evidence Act – Sections 91 & 92 – Oral Evidence – Scope and Limitation – Oral evidence barred where terms of registered document are clear and unambiguous – Exception permitting oral evidence applies only where plea is that document itself was never intended to operate – Mere allegation of nominal or sham nature, without strict proof, insufficient to override statutory bar [Paras 34–37, 41].

Civil Procedure – Pleadings – Order VI Rule 4 CPC – Rigorous Pleading Standard – Allegation that a registered deed is sham requires clear, specific and material particulars akin to fraud – Clever drafting creating illusion of cause of action impermissible – Absence of particulars and internal inconsistencies render claim unbelievable [Paras 34–35, 38–41].

Transfer of Property Act – Section 58(c) – Mortgage by Conditional Sale – Statutory Test – For a transaction to qualify as mortgage by conditional sale, condition of reconveyance must be embodied in the same document effecting the sale – In absence of such condition, transaction cannot be treated as mortgage – Sale deed dated 12.11.1971 held not to be a mortgage by conditional sale [Paras 44–49].

Sale Deed vs. Mortgage – Intention of Parties – Determination – Clear recitals of absolute transfer, full consideration, symbolic delivery of possession, and execution of contemporaneous registered rental agreement establish intent of outright sale – No ambiguity warranting resort to extrinsic evidence [Paras 43–45, 55, 58].

Conduct of Parties – Subsequent Events – Evidentiary Value – Payment of rent for fourteen months under registered lease and failure to seek reconveyance at earliest opportunity negate plea of mortgage – Delay in filing suit and silence in reply to legal notice undermine claim of sham transaction [Paras 52–54, 73].

Admissions – Reply to Legal Notice – Effect – Written reply admitting tenancy, default in rent and conceding right of eviction constitutes strong admission – Plea that reply was issued without understanding contents not pleaded and therefore rejected [Paras 41, 73–75].

Consideration – Inadequacy – Effect on Validity – Mere allegation of inadequacy of consideration does not render sale deed void – In absence of proof that no consideration passed, registered conveyance cannot be invalidated [Para 60].

Mutation and Municipal Records – Relevance – Non-mutation of purchaser’s name and subsequent payment of municipal taxes by vendor do not defeat title under registered sale deed – Revenue and municipal entries do not confer ownership [Paras 61–65].

Appellate Interference – Error by High Court – High Court erred in misapplying Gangabai v. Chhabubai and in discarding statutory presumptions attached to registered instruments – Judgment of first appellate court restoring validity of sale deed upheld [Paras 72–75].

Decision: Appeal allowed – Judgment of High Court of Karnataka dated 04.02.2010 set aside – Judgment of First Appellate Court dated 13.12.1999 restored – Suit O.S. No. 39 of 1977 dismissed with costs – Sale Deed and Rental Agreement dated 12.11.1971 held genuine and intended to be acted upon.

Insolvency and Bankruptcy Code – Section 60(5) – Residuary Jurisdiction – Limits – NCLT’s jurisdiction under Section 60(5)(c) extends only to questions of law or fact arising out of or in relation to insolvency resolution or liquidation proceedings – Jurisdiction cannot be invoked to adjudicate independent civil or proprietary disputes lacking direct nexus with insolvency – Adjudicating Authority cannot assume power to declare title to intellectual property merely because dispute surfaces during CIRP [Paras 24–26, 37].

Resolution Plan – Binding Nature – Sanctity and Finality – Once a resolution plan is approved by the Committee of Creditors and Adjudicating Authority under Section 31 IBC, it constitutes the charter governing rights and obligations of all stakeholders – NCLT cannot grant rights beyond or contrary to what is recognised in the approved plan – Any declaration conferring additional proprietary rights amounts to impermissible modification of the plan [Paras 19–23, 38].

Trademark Dispute – Declaration of Ownership – Impermissibility during CIRP – Approved resolution plan itself recorded existence of rival claims over trademark “Gloster” and merely reflected beliefs and understanding of Resolution Applicant – In absence of adjudication under appropriate forum or avoidance proceedings, NCLT could not declare trademark as asset of Corporate Debtor or vest ownership in SRA [Paras 11–16, 37–40].

IBC – Sections 43, 45 and 46 – Preferential and Undervalued Transactions – Mandatory Procedure – Adjudicating Authority cannot suo motu invoke Sections 43 or 45 to invalidate transactions in absence of a formal application by Resolution Professional or eligible party under Section 47 – Avoidance of transactions requires specific pleadings, rigorous scrutiny and compliance with principles of natural justice – Summary findings by NCLT held perverse and unsustainable [Paras 42–49].

Resolution Professional – Statutory Role – Failure to Initiate Avoidance Proceedings – Resolution Professional bears statutory responsibility to examine and move appropriate applications in respect of preferential or undervalued transactions – Failure to do so cannot be cured by collateral adjudication while deciding unrelated application under Section 60(5) [Paras 13–15, 48–49].

Section 60(5) IBC – Embassy Property and Gujarat Urja Explained – Embassy Property reiterated that NCLT cannot usurp jurisdiction of civil courts or statutory authorities in matters dehors insolvency – Gujarat Urja carved a narrow exception where dispute arose solely due to insolvency – Trademark ownership dispute herein pre-existed insolvency and did not arise solely from CIRP, thus falling outside Section 60(5) [Paras 26–31, 37].

Trademark Registration during Moratorium – No Automatic Vesting – Registration of trademark during CIRP does not conclusively determine ownership where title itself is disputed – Issues of assignment, effectiveness, moratorium and statutory compliance require adjudication before competent forum under Trade Marks Act or civil law [Paras 40–41].

Natural Justice – Adjudication beyond Pleadings – Illegality – Declaring assignment void as preferential or undervalued without pleadings, notice or opportunity of defence violates principles of natural justice – Parties cannot be rendered worse off in proceedings initiated by them [Paras 44–47].

Decision: Civil Appeal No. 2996 of 2024 dismissed – Civil Appeal No. 4493 of 2024 disposed of – Finding of NCLT declaring trademark “Gloster” as asset of Corporate Debtor set aside – Observations of NCLAT declaring vesting of title in GCL also set aside – All issues of trademark ownership left open to be decided by appropriate forum uninfluenced by observations herein – No order as to costs [Paras 50–52].

Foreign Trade Regulation – Delegated Legislation – Enforceability – Gazette Publication Mandatory – Notification imposing Minimum Import Price (MIP) on steel products uploaded on DGFT website on 05.02.2016 but published in Official Gazette on 11.02.2016 – Held that delegated legislation acquires force of law only upon publication in the Official Gazette as mandated by Section 3 of the FTD&R Act – Uploading on website or prior knowledge cannot substitute statutory mode of promulgation – Law to bind must first exist and be duly published [Paras 16–19, 23].

Interpretation of Statutory Notification – “Date of this Notification” – Expression occurring in Para 2 of Notification No. 38/2015–20 – Held that “date of this Notification” necessarily means the date of its publication in the Official Gazette and not the date of signing or website upload – Notification cannot operate in a fragmented or anticipatory manner – Rights and obligations arise only from Gazette publication [Paras 12, 19–22].

Foreign Trade Policy – Transitional Protection – Para 1.05(b) – Imports earlier freely permitted but subsequently restricted – Transitional safeguard available where irrevocable Letters of Credit were opened prior to imposition of restriction – Para 1.05(b) expressly incorporated into Para 2 of the Notification – Held that appellants who opened irrevocable Letters of Credit before 11.02.2016 and complied with registration requirement are entitled to protection – Denial would defeat certainty in trade and object of parent statute [Paras 20–22].

Minimum Import Price (MIP) – Letters of Credit – Commercial Certainty – Appellants opened irrevocable Letters of Credit on 05.02.2016 prior to Gazette publication – Imposition of MIP based on unpublished notification would offend rule of law and erode commercial confidence – MIP held inapplicable to imports covered by such Letters of Credit [Paras 21–22].

High Court Judgment – Interference by Supreme Court – Delhi High Court held that website uploading constituted sufficient notice though Gazette publication occurred later – Supreme Court set aside High Court judgment – Held that statutory requirement of Gazette publication cannot be diluted by alternative modes of notice – Appeals allowed [Paras 19, 24–25].

Decision: Appeals allowed – Impugned judgment dated 21.12.2018 quashed and set aside – Notification held operative only from 11.02.2016 – Appellants entitled to benefit of Para 1.05(b) of FTP – No order as to costs.

Writ Jurisdiction – Delay and Disputed Facts – Article 226, Constitution of India – High Court Erred – High Court entertained a writ petition filed after a gross and unexplained delay of over 10 years, involving seriously disputed questions of fact, despite previous similar litigation being withdrawn – Such belated petitions with disputed facts are generally not maintainable under Article 226 – The High Court's approach was self-contradictory and erroneous [Paras 30, 36, 41, 61, 70].

Contract Law – Apartment Buyers' Agreement – Fraud/Misrepresentation – High Court Erred – High Court's finding that developers duped buyers by misrepresenting facts in the Apartment Buyers' Agreement was conjectural and unsupported by foundational pleadings or credible evidence – The agreement itself was not challenged in the writ proceedings, and allegations of fraud were raised belatedly in a rejoinder – Such conclusions are unsustainable in law [Paras 61, 62, 77, 86-87].

Urban Planning Law – De-licensing of Land Use – Haryana Development and Regulation of Urban Areas Act, 1975 – Legally Permissible – High Court held that "de-licensing" of residential land for commercial purposes was without statutory authority – However, the DTCP's subsequent detailed reasoned order (5th August 2021) found such de-licensing and re-licensing for commercial use to be legally permissible, supported by prior legal opinion and retrospectively validated by Section 3(3A) of the 1975 Act, introduced by the Haryana Development and Regulation of Urban Areas (Second Amendment and Validation) Act, 2020 – The Supreme Court found the High Court's conclusion on this point erroneous [Paras 43-45, 51, 71, 83, 86].

Environmental Law – Jurisdiction of NGT – National Green Tribunal Act, 2010, Section 14 – NGT Lacked Jurisdiction – NGT intervened in issues related to building plan violations and land use changes that were already subject to High Court proceedings – The Supreme Court held that these issues did not constitute a "substantial question relating to environment" under Section 14 of the NGT Act, 2010, and were intrinsically connected to matters under adjudication before the High Court – NGT was not justified in interfering with such issues [Paras 94, 102, 104, 105, 107].

Criminal Procedure – CBI Investigation Direction – Code of Criminal Procedure, 1973, Section 173(2) – Uncalled For – High Court's direction for a CBI investigation was based on unverified and inconclusive material – While CBI's subsequent chargesheet found misrepresentation in the Apartment Buyers' Agreement, it found no criminality in the de-licensing process – The direction was deemed uncalled for, and the High Court's judgment prejudiced the outcome of the pending criminal trial [Paras 37, 38, 75, 76].

Judicial Review – Effect of Subsequent Administrative Orders – Prejudice to Pending Litigation – High Court Erred – The DTCP, pursuant to a High Court direction in a connected writ petition, passed a detailed reasoned order on 5th August 2021, ruling out illegality in the developer's actions – This order is under challenge in a separate pending writ petition – The High Court's impugned judgment, by quashing the earlier orders, prejudiced the outcome of this pending writ petition and foreclosed available defenses of the appellants-developers [Paras 28, 39, 42, 63, 71, 74, 78].

Decision: Appeal allowed – Impugned judgment dated 10th July, 2020 rendered by the High Court is set aside – Proceedings before the NGT shall remain in abeyance till disposal of Civil Writ Petition No. 6047 of 2025 before the High Court, which shall proceed uninfluenced by this judgment – No order as to costs [Paras 77, 78, 79, 109, 110, 111].