Civil Law – Limitation – Validity of Sale Deed – Plaintiffs claimed 1/3rd share in agricultural land – Alleged that sale deed dated 14.06.1973 executed in favour of defendant was fraudulent and without consideration – Trial Court dismissed the suit as time-barred – First Appellate Court decreed the suit holding that the sale deed was void and suit filed within 12 years under Article 65 Limitation Act, 1963 – High Court affirmed the decree but held Article 59 applied, though suit was still within limitation – Supreme Court clarified that since sale deed was void ab initio, Article 65 (12 years) applied, not Article 59 (3 years) – Appeal dismissed [Paras 3–15, 24–41].

Limitation Act – Article 65 vs Article 59 – Court distinguished between void and voidable instruments – Article 59 applies only to voidable instruments requiring cancellation (fraudulent misrepresentation as to contents) – Article 65 applies to suits for possession based on title where the impugned document is void/void ab initio (fraud as to character or want of consideration) – Plaintiff, not being party to the void transaction, need not seek cancellation – Merely seeking joint possession suffices [Paras 25–29, 31–33].

Evidence – Proof of Fraudulent Sale Deed – Plaintiffs proved that thumb impressions on sale deed were not theirs – Expert testimony unchallenged – Defendant failed to produce original sale deed or prove payment of sale consideration of ₹15,000 – Husband of defendant, alleged to have paid balance ₹6,000, not examined – Attesting witness (brother of defendant) considered biased – Sarpanch attesting witness deceased – Courts held absence of valid execution and want of consideration rendered deed void [Paras 27, 35–38].

Transfer of Property Act, 1882 – Section 54 – Essential element of sale is transfer of ownership for a price – Sale without consideration is void – In present case, defendant failed to prove payment of consideration – Sale deed therefore void, conferring no title [Paras 34–38].

Principles Restated – (i) Void documents need not be cancelled; possession can be claimed under Article 65 – (ii) Burden lies on party relying on sale deed to prove valid execution and consideration – (iii) Limitation runs from date possession becomes adverse, not from date of void deed – (iv) Courts must distinguish between fraudulent misrepresentation as to character (void) and contents (voidable) of document [Paras 28–29, 31–33, 39–40].

Decision – Supreme Court dismissed appeal – Held that sale deed dated 14.06.1973 was void ab initio – Suit filed on 28.02.1984 within 12 years of sale deed was within limitation under Article 65 – High Court erred in applying Article 59 but rightly upheld maintainability of suit – Plaintiffs entitled to joint possession – Appeal dismissed [Paras 40–41].

Advocates Act – Professional Misconduct – Bar Council of India – Suspension for Three Years – Supreme Court dismisses statutory appeal; imposes ₹1,00,000 costs; directs Collector to attach properties for recovery; Bar Council not to renew licence without prior permission; compliance report to Supreme Court upon completion of sentence [Paras 2-6].

Professional Misconduct – Scope of Appellate Interference – Serious, scandalous allegations by advocate – No leniency – Appeal dismissed with costs – The appellant-advocate, found guilty of professional misconduct and suspended for three years by BCI, had made scandalous allegations against the complainant; the Court, noting the serious nature of misconduct and obstinate conduct, refused to interfere or extend leniency; appeal dismissed with cost of ₹1 lakh [Paras 2-3].

Costs – Mode of Recovery – Attachment of Properties – Compensation to Complainant – Direction to Collector – Court directed the Collector, Agra, to attach appellant’s properties to recover ₹1 lakh cost to be paid to respondent within three months – Ensures effective enforcement and compensation to the complainant [Para 4].

Bar Council – Regulatory Consequence – Non-renewal of Licence Without Court’s Permission – To prevent circumvention of disciplinary penalty, the Bar Council was directed not to renew the appellant’s licence without prior permission of the Supreme Court [Para 4].

Post-Sentence Compliance – Reporting Requirement – After the appellant undergoes the sentence already awarded, a report shall be supplied to the Secretary General of the Supreme Court – Ensures oversight and compliance closure [Para 5].

Decision – Appeal Dismissed – Costs and Directions Affirmed – Statutory appeal dismissed; costs of ₹1 lakh imposed; attachment and non-renewal directions issued; matter disposed of accordingly [Paras 3-6].

Civil Law – Counter-Claim – Maintainability – Defendant no.2 sought to file a counter-claim for specific performance of an agreement dated 21.10.2011 and partition of property after issues had already been framed in the suit filed by the plaintiff for declaration and injunction – Trial Court rejected the application citing bar under Limitation Act and principles of CPC, especially Order VIII Rule 6A – High Court reversed the order, allowing the counter-claim citing appointment of Nazir (court officer) as triggering fresh cause of action – Supreme Court held that counter-claim directed solely against a co-defendant is impermissible – Further, counter-claim filed after framing of issues and considerable delay defeats the purpose of speedy trial and is barred by limitation – Held: High Court erred in reversing Trial Court – Counter-claim not maintainable [Paras 7, 8, 14, 17–24, 26, 27].

Counter-Claim – Against Co-Defendant – Not Maintainable – Defendant no.2 filed counter-claim primarily seeking specific performance of agreement executed by original defendant no.1 (now deceased) and secondarily sought partition – No substantial relief was claimed against the plaintiff – Supreme Court reiterated law laid down in Rohit Singh v. State of Bihar and Damodhar Narayan Sawale v. Tejrao Bajirao Mhaske – Counter-claim must be directed against the plaintiff; relief solely against a co-defendant not maintainable – Counter-claim cannot convert the suit into an interpleader action between defendants [Paras 17–23].

Limitation – Delay in Filing Counter-Claim – Issues were framed on 12.02.2019 – Counter-claim filed on 26.07.2021 – Specific performance sought for agreement dated 21.10.2011 – Defendant no.2 remained inactive despite knowledge of plaintiff’s challenge to agreement in 2012 and death of original vendor in 2013 – Cause of action arose in 2012 but counter-claim filed 9 years later – Barred under Article 54 of Limitation Act – Held: Limitation equally applies to counter-claims – Filing after framing of issues not permissible as per Ashok Kumar Kalra v. Wing CDR. Surendra Agnihotri – Trial Court rightly dismissed application [Paras 14, 24–25].

Jurisdiction – Supervisory Powers under Article 227 – High Court interfered with Trial Court’s discretionary order under supervisory jurisdiction – Supreme Court held that High Court failed to establish jurisdictional error – Exercise of Article 227 cannot override findings of Trial Court based on law and limitation – Trial Court correctly applied CPC provisions and precedents – High Court erred in exercising jurisdiction [Paras 13, 15].

Decision: Appeal allowed – Judgment and order of the High Court dated 16.01.2023 set aside – Order of Trial Court dismissing defendant no.2’s application to amend written statement and file counter-claim restored – No order as to costs [Para 27–28].

Public Interest Litigation – Deaths in Beggars’ Home due to Cholera – Article 21 – Constitutional Violation Established – Appellant filed a PIL after media reports revealed deaths and illness of several beggars due to contamination in drinking water at Lampur Beggars’ Home – Authorities failed to ensure sanitary conditions and misrepresented facts – Held: Deaths amounted to violation of the right to life and dignity under Article 21 – Supreme Court recognized the need for judicial intervention and systemic reform [Paras 3-10, 18-20].

Institutional Negligence – Departmental Proceedings – Compliance Noted – Respondents submitted that departmental proceedings were concluded and penalties imposed – Court accepted compliance on that front – However, held that mere disciplinary actions were insufficient without sustained structural reforms and monitoring [Paras 21-22].

Beggars’ Homes – Paradigm Shift in Approach – From Penal to Protective Institutions – Constitutional Reframing – Court held that Beggars’ Homes must be viewed through a constitutional lens, aligned with Articles 38, 39(e), 41, and 47 – Emphasised shift from colonial punitive mindset to rehabilitation and dignity-based frameworks – Institutions must ensure health, freedom, privacy, and humane conditions [Paras 16-16.7].

Right to Life with Dignity – Expanded Interpretation – Article 21 – Applicability to Institutionalised Persons – Reaffirmed that all persons, including those in State custody, are entitled to humane treatment, adequate nutrition, healthcare, and dignity – Denial of such constitutes constitutional breach – Emphasised that beggars, unlike convicts, are not criminals and cannot be treated as such [Paras 15-16.6].

Anti-Begging Laws – Judicial Review – Validity and Purpose – The Bombay Prevention of Begging Act and similar laws in other States examined – Court acknowledged State’s interest in regulating begging but cautioned against criminalising poverty – Enforcement must balance public order with constitutional rights – Reiterated Delhi High Court’s earlier partial striking down of such laws [Paras 17-17.5].

Judicial Monitoring – Long-Term Oversight by Supreme Court – Compliance Recorded – From 2004 onwards, Supreme Court issued multiple detailed directions for improvement in Beggars’ Homes – Continuous monitoring led to structural changes, enhanced hygiene, staffing, vocational training, food quality, and medical care – Final reports showed significant compliance and nil complaints from inmates – Court stressed need for reforms to be sustained across India [Paras 22-22.18].

Final Directions – Nationwide Reform Mandated – Article 21 – Court Issued Model Framework – Directions issued to all States/UTs covering medical screening, disease control, hygiene, infrastructure audits, dietary standards, vocational training, legal aid, child and gender-sensitive provisions, and accountability mechanisms – Directed Union Ministry to issue model guidelines within 3 months – Held: Failure to maintain humane conditions in such institutions constitutes breach of fundamental rights [Paras 23-23.3].

Judgment – Appeal Disposed – Structural Reforms Ordered – Supreme Court partially allowed the appeal – Reiterated State's affirmative duty under Article 21 – Upheld PIL’s maintainability – Issued binding directions to State and Union authorities to overhaul Beggars’ Homes nationwide – Liberty granted to seek further directions if needed [Paras 24-25].

Cruelty – Decree of Divorce – Section 13(1)(ia) of Hindu Marriage Act – Divorce Affirmed – The husband filed for divorce on grounds of mental cruelty; the wife filed counter-allegations including domestic violence – Family Court granted divorce which was upheld by the High Court – Supreme Court observed long-standing acrimony and prolonged separation since 2009, holding that false complaints constituted cruelty – Decree of divorce upheld [Paras 3.2–3.7, 7].

Domestic Violence – Compensation – DV Act Proceedings – Wife Entitled – Though initial complaint under DV Act was dismissed, appellate courts found the husband guilty of domestic violence and directed compensation of ₹2,00,000/-, later enhanced to ₹7,00,000/- – SLP against this enhancement was dismissed by Supreme Court – Proceedings under DV Act thus culminated in favour of wife [Paras 3.3–3.5].

Child Marriage Expenses – Contribution by Father – Reasonable Demand – Appellant-wife sought ₹10,00,000/- for daughter’s marriage – Despite husband’s denial of income, Court held he was capable of contributing – Directed to pay ₹10,00,000/- by 15th October 2025 – Held: Contributing to child’s marriage is a natural parental duty irrespective of spousal disputes [Paras 5–10].

Final Decision – Appeals Partly Allowed – Divorce decree affirmed – Supreme Court directed husband to pay ₹10,00,000/- towards daughter’s marriage expenses, failing which the appeals would be revived – Appeals accordingly disposed of [Paras 10–13].

Legal Metrology – Search and Seizure – Procedural Violations – Quashing of Notices – Appeal Allowed.

Search and Seizure – Legal Metrology Act, 2009 – Appellant (ITC Limited) challenged seizure of 7,600 pre-packed notebooks from its warehouse by Legal Metrology officials for alleged violation of Rule 24(a) of the Legal Metrology (Packaged Commodities) Rules, 2011 – Seizure conducted under Section 15 of the 2009 Act without obtaining warrant or recording “reasons to believe” – High Court’s Division Bench upheld seizure, reversing Single Judge’s quashing order – Held: Seizure was illegal – Officials failed to comply with mandatory safeguards under Section 15 of the 2009 Act and Sections 100(4), 165 of the Cr.P.C – No warrant obtained – No reasons to believe recorded – Single witness (driver) not independent – No urgency or exigency pleaded – Procedural violations vitiated entire action [Paras 11-23].

Criminal Procedure – Application of Cr.P.C to Special Acts – Section 15(4) of the Legal Metrology Act mandates compliance with Cr.P.C for search and seizure – Search requires “reasons to believe” and warrant unless exigency shown – Presence of two independent witnesses mandatory under Section 100(4) Cr.P.C – Held: Procedural safeguards under Cr.P.C applicable unless explicitly excluded – Respondent’s claim of “inspection” without warrant unsustainable – Premises, though commercial, not “public” for warrant exemption – CFC packages stored in warehouse do not constitute “wholesale packages” merely due to bulk [Paras 14-20].

Natural Justice – Violation of Principles – Simultaneous issuance of seizure and compounding notices deprived appellant of opportunity to be heard – No hearing granted – No opportunity for objections – Held: Violation of natural justice evident – Division Bench erred in not appreciating legal necessity of procedural compliance [Paras 7.5, 20.1].

Technical Violation – Rule 24 of 2011 Rules – Packages had declarations affixed as labels instead of being printed – Held: Declarations existed – At best, violation was technical – Supported by Supreme Court’s earlier ruling in State of Maharashtra v. Raj Marketing (2011) 15 SCC 525 – Seizure not justified in absence of material inconsistency in declared particulars [Para 22].

Decision: Appeal allowed – Search and seizure held illegal – Orders passed by Division Bench of High Court and impugned notices/quasi-criminal proceedings quashed – Order of Single Judge restored – No costs [Paras 23-24].

Civil Law - Limitation – Section 5 – Second Appeal by State Instrumentality – High Court condoned delay of 3966 days – Phrase “within such period” in Section 5 construed – Held: “within such period” covers the entire continuum from the date limitation starts running until the actual date of filing, not merely the period after expiry – Delay must be explained for the whole period – Condonation is an exception, not a right – Appeal allowed – Condonation set aside – Directions issued – Sections 3 & 5 Limitation Act applied [Paras 10–14, 15–21, 25–41, 49–51, 64–71, 83–86, 95–115, 261–266].

Interpretation – Section 5 Limitation Act – Meaning of “within such period” – Textual and contextual reading with “after the prescribed period” and “for not preferring … within such period” – Held: the phrase refers to both the original prescribed period and the period post-expiry till filing – Rewa Coal Fields (AIR 1962 SC 361) view treating it as only the post-expiry period held not the correct position – Ajit Singh Thakur (1981) 1 SCC 495 and State of M.P. v. Ramkumar Choudhary, 2024 SCC OnLine SC 3612, followed and explained [Paras 25–41, 50–51, 82–86, 90–94, 98, 113–115].

Condonation Mechanics – “Extension” vs “Exclusion” – Marginal note to Section 5 (“Extension of prescribed period”) – Held: Condonation entails extension of limitation, not exclusion of only the overrun days – Reading “extension” as “exclusion” would distort Section 5 and negate judicial discretion even where sufficient cause is shown – Therefore, sufficient cause must span the entire relevant continuum and not merely the days to be “excluded” [Paras 95–113].

Section 5 – “Sufficient Cause” – Content and Limits – Liberal but disciplined approach – No indulgence where negligence, inaction, want of diligence/bona fides is imputable – “Explanation” vs “Excuse” distinguished – Length of delay is instructive but not determinative – Merits of the underlying case irrelevant at delay stage – Principles in Esha Bhattacharjee summarized and applied [Paras 116–127, 128–134, 135–143, 120–123, 140–143].

Limitation & Public Policy – Section 3 Limitation Act is mandatory – Courts must dismiss time-barred proceedings irrespective of pleas – Law of limitation furthers finality and certainty (interest reipublicae ut sit finis litium; vigilantibus non dormientibus jura subveniunt) – Dura lex sed lex – Liberal condonation cannot be used to defeat Section 3 or institutionalise inefficiency [Paras 58–71, 62–66, 228–235].

Appellate Review of Discretion – When can higher court interfere with condonation? – Two-pronged enquiry: (i) whether “sufficient cause” existed in law and on material; (ii) whether discretion was properly exercised – Interference warranted if contrary to law, capricious, ignores relevant facts, lacks evidentiary support, or misdirects on legal tests – Distinction between deciding condonation and appeal against condonation emphasised [Paras 144–170, 151–157, 161–169].

State Lethargy – No Preferential Treatment – Shift post Postmaster General (2012) – Earlier latitude in Chandra Mani, Lipok AO, K.V. Ayisumma etc. explained – Present position: State/public bodies stand on same footing as private litigants – Bureaucratic red-tapism, file-pushing, or “certificate cases” not sufficient cause absent bona fide diligence – Costs may follow for wastage of judicial time [Paras 171–191, 192–201, 210–219, 229–233].

Temporal Application – Exercise of discretion must be tested against governing law at time of decision; Postmaster General (2012) pre-dated the High Court’s order (2017) – Hence condonation could not rest on earlier liberal line – Change in law during pendency: appellate court may interfere where lower order is contrary to then-prevailing law [Paras 220–227].

Application to Facts – KHB’s 11-year delay – No explanation for period within limitation – Scapegoating of Executive Engineer rejected – No prompt corrective steps despite execution notice (28.03.2011) – High Court erred by considering merits and by treating departmental negligence as sufficient cause – Gross delay prejudices decree-holder and mocks finality – Condonation set aside – Costs imposed – Execution expedited [Paras 236–257, 258–260, 261–266].

Decision – Appeal Allowed – High Court’s order condoning delay of 3966 days quashed – Additional cost of ₹25,000 on Respondent No. 1 payable to Karnataka State Legal Services Authority within 4 weeks (over and above ₹25,000 imposed by the High Court) – Principal Judge (Junior Division), Kalaburagi to conclude execution in E.P. No. 2/2011 within 2 months – Registry to circulate judgment to all High Courts [Paras 261–268].

Coal Policy – Interim Pricing Post-Auction – Background and Challenge – Policy Upheld – After the e-auction system was held unconstitutional in Ashoka Smokeless, CIL issued the Interim Coal Policy dated 15.12.2006 imposing a 20% price hike for non-core sector consumers through linkage – Respondents challenged the policy as arbitrary and sought refund of excess payment made – High Court allowed refund – Supreme Court reversed – Held: Interim Policy was a necessary measure to ensure availability of coal and sustain operations, not arbitrary or profit-driven – The increase was temporary and did not violate Article 14 [Paras 11-15, 83-94, 106-107].

Judicial Review of Economic Policy – Scope and Limitations – Courts Cannot Substitute Economic Wisdom – Supreme Court reaffirmed that economic decisions like price fixation and resource allocation fall within executive domain – Unless found to be unconstitutional or manifestly arbitrary, courts must defer – Pricing policy was based on operational requirements and market dynamics – Courts cannot apply proportionality test to price-based classification [Paras 83-85, 95-99].

Classification – Core vs. Non-Core Sector – Linked Consumers Not a Homogeneous Class – Article 14 Not Violated – Respondents argued that once linked, all consumers formed a single class – Rejected – Held: Core and non-core classification continued to serve valid purposes under national policy for equitable distribution of coal – The linkage system was administrative and did not erase original classification – Price differentiation justified [Paras 100-104].

Price Fixation – Executive Authority under Colliery Control Order – Valid Exercise of Power – Coal India Limited was within its authority under the Colliery Control Order to notify revised prices post e-auction quashing – Ashoka Smokeless did not bar such revision – Policy was made in response to court ruling and to stabilize supply – Not violative of statutory scheme [Paras 109-112].

Refund of 20% Price Increase – Unjust Enrichment – Refund Denied – Even assuming invalidity of price hike, refund not automatic – Respondents failed to prove they bore the burden of excess price and did not pass it on – Refund in such context would result in unjust enrichment – Burden lies on claimant to prove actual loss – High Court erred in mechanically granting refund [Paras 114-139].

Reliance on Undertakings in Earlier Cases – No Independent Refund Right Created – Respondents relied on undertaking given in Somal Pipes to claim refund – Held: Undertaking was conditional and contingent on final adjudication of legality of price hike – Since Interim Policy found valid, refund does not follow [Paras 141-143].

Cited Cases Distinguished – Ashoka Smokeless, Tetulia Coke – Not Applicable to Present Facts – Supreme Court clarified that Ashoka Smokeless dealt with discrimination in e-auction prices – Interim Policy involved fixed price hike without auction – Likewise, refund orders in Tetulia Coke and Domco Smokeless were fact-specific and not binding for Interim Policy price hike cases [Paras 104-122].

Constitutional Principles – Article 39(b) and Resource Allocation – Auction Not Mandatory – Respondents argued that auction is the only constitutional means of resource allocation – Rejected – Court reiterated that while auction is desirable, it is not mandatory – State retains discretion in method of allocation provided it ensures fairness and public interest [Paras 83-85].

Final Judgment – Appeal Allowed – High Court Set Aside – No Refund Payable – The impugned High Court judgment ordering refund of 20% excess price was quashed – Interim Coal Policy held constitutionally valid – Price hike justified – Refund claims denied for failure to establish financial loss and unjust enrichment bar [Paras 144-147].

Anticipatory Bail – Delay in FIR – Allegations of Mutation on Forged Documents – FIR lodged in 2019 regarding mutation entries based on sale deed dated 18.05.1996 executed on forged powers of attorney in names of deceased landowners – Appellants (A5 and A6), Circle Officer and Talathi at the time, certified mutation entries Nos. 15177 and 15180 in 1996, which were later cancelled by Sub-Divisional Officer in 1998 – FIR lodged after more than 20 years – Supreme Court held that long delay cannot by itself efface allegations of misuse of official position in facilitating fraudulent transfer of immovable property [Paras 3–4, 7–9, 11, 13–14].

Official Capacity – Scope of Criminal Liability – Appellants contended that certification of mutation entries was done in discharge of official duty on the basis of facially valid registered sale deed – No role in preparation of forged documents, no dishonest intention, and no personal gain alleged – Supreme Court held that whether appellants shared criminal intent or colluded with beneficiary (A1) is a matter for trial and cannot be conclusively decided at anticipatory bail stage [Paras 5.1–5.2, 9, 12].

Custodial Interrogation – Necessity – Appellants argued case is based on existing documentary evidence and custodial interrogation unnecessary – Court held that even in documentary fraud cases, custodial interrogation may be required to trace the chain of transactions, ascertain complicity, and prevent tampering of records – Appellants had interim protection for nearly six years but did not fully cooperate with investigation – Justification for custodial interrogation upheld [Paras 5.5, 10, 14].

Delay in Bail Adjudication – Constitutional Concerns – Anticipatory bail applications filed in 2019 remained pending in High Court for nearly six years – Interim protection granted continuously until final rejection on 04.07.2025 – Supreme Court strongly disapproved indefinite pendency of bail applications affecting personal liberty – Reiterated earlier rulings (Nikesh Tarachand Shah, Siddharam Satlingappa Mehtre, Satendra Kumar Antil, Rajesh Seth, Sanjay, Rajanti Devi, Kavish Gupta, Amol Vitthal Vahile, etc.) – Directed High Courts and subordinate courts to decide bail/anticipatory bail applications expeditiously, preferably within two months [Paras 15–18.1].

Principles Restated – Anticipatory bail under Section 438 CrPC is a statutory right, not a fundamental right – Courts must balance personal liberty with fair investigation – Prolonged pendency of bail applications amounts to denial of justice – Administrative directions must be issued by High Courts to prioritise bail matters [Paras 16, 16.9, 17–18.1].

Decision – Appeals dismissed – Rejection of anticipatory bail by Bombay High Court upheld – Appellants at liberty to apply for regular bail, which shall be considered on its own merits, uninfluenced by observations in this judgment – Registrar (Judicial) directed to circulate judgment to all High Courts for compliance [Paras 19–20].