Tenancy Law  – Karnataka Rent Act – Eviction – Landlord-Tenant Relationship Dispute – Sections 27(2)(a),(e),(g),(o) and 43 – Appeal Allowed – Landlord filed eviction; Rent Controller allowed based on rent receipts; HC reversed citing lack of proof of ownership – Held: Rent Controller rightly proceeded once rent receipts acknowledged; title dispute outside Rent Controller’s scope – HC exceeded revisional jurisdiction – Order of Rent Controller restored – [Paras 3–11].

Landlord-Tenant Relationship – Prima Facie Proof – Section 43 – Rent receipts signed by landlord serve as prima facie evidence of relationship – Once produced, Rent Controller must proceed with hearing – Only when no receipts/lease or documents are doubtful, parties must be relegated to civil court – [Paras 6–8].

Scope of Revisional Jurisdiction – High Court’s Interference Improper – Revisional Court cannot re-appreciate evidence or embark on fact-finding – High Court erred in rejecting jural relationship by questioning landlord’s lineage/title – [Paras 9–11].

Decision – Appeal allowed – Judgment of Karnataka High Court dated 31.03.2021 set aside – Order of Rent Controller dated 01.09.2017 directing eviction restored – Pending applications dismissed – [Para 11].

Review Jurisdiction – Scope under Section 114 and Order 47 CPC – Review Order Quashed – The Appellant sought amendment of a preliminary decree to claim her rightful share as a coparcener after the 2005 Amendment to the Hindu Succession Act – The Trial Court dismissed the plea; High Court initially allowed the revision, recognising her 1/3rd coparcenary right – In a subsequent review, the High Court reversed its prior order and remanded the matter for fresh trial – Held: The review order went beyond the permissible scope under Order 47 Rule 1 CPC by reassessing facts and reaching fresh conclusions – Review jurisdiction is limited to correcting apparent errors, not reappreciating evidence or substituting views – The High Court's review amounted to an appeal in disguise and was unsustainable [Paras 13–20].

Coparcenary Rights of Daughters – Retrospective Application of HSA 2005 – Right Recognised – Appellant, being a daughter of a coparcener alive at the time of commencement of HSA 2005, is entitled to equal share – The original preliminary decree was passed ex parte and without impleading her – She has a legitimate claim to 1/3rd share and additional share through a will – Her right is not barred by estoppel or limitation – Held: Daughter’s coparcenary right is birthright and enforceable even after preliminary decree, as final decree was yet to be passed [Paras 3–7, 10].

Jurisdictional Overreach – Review vs. Appeal – Error of Law – The impugned review order failed to identify any “error apparent on the face of the record” and instead conducted a re-evaluation of the entire case – Held: Such exercise falls outside the scope of review jurisdiction – Review order set aside; order in CRP dated 23.09.2022 restored [Paras 15–19].

Final Decision – Appeal allowed – High Court’s review order dated 19.10.2024 set aside – Order dated 23.09.2022 in CRP No. 1439 of 2019 restored – Trial Court directed to dispose of pending applications within three months [Para 20].

Section 125 of the Electricity Act - Change in Law – Pro rata allocation of coal – Sections 62 & 63, Electricity Act – Appeals dismissed – Challenge to APTEL order upholding CERC’s direction that coal supplied under firm and tapering linkage is for the station as a whole and costs of alternate coal (import/open market) due to shortfall be apportioned pro rata based on energy supplied – Held: Allocation under SLC-LT approvals/LOAs and FSA terms is plant-wide and not PPA-specific – Haryana Utilities and GRIDCO cannot claim exclusivity or priority – CERC’s methodology sustained – Appeals dismissed [Paras 31–34, 40, 45–46].

Section 125 Electricity Act – Scope confined to substantial question of law via Section 100 CPC – Judicial restraint over concurrent expert findings – Two expert bodies (CERC and APTEL) rendered concurrent, reasoned findings based on documents and policy – No perversity, arbitrariness, or statutory breach shown – Interference unwarranted [Paras 18–25].

Fuel Supply Agreements and SLC-LT decisions – Interpretation – FSA Clause 4.1.1 ties ACQ to percentage of generation under long-term PPAs – Clause 4.2 earmarks coal “for use at Power Plant (3x350 MW)” – SLC-LT minutes (14.02.2012) and LOAs (25.07.2008 and 08.07.2009) demonstrate station-level allocation including tapering linkage for all three beneficiaries – MCL clarifications confirm coal release against total PPA capacity, not segregated PPA-wise [Paras 31–33, 35].

Appropriation claim rejected – Haryana’s contention that its 300 MW must be met entirely from firm linkage and that tapering/imported coal costs fall on GRIDCO/Bihar rejected – Such reading is contrary to plant-wide allocation, would disadvantage Odisha/Bihar consumers, and violates parity among equals – Pro rata allocation avoids cross-subsidy and aligns with Energy Watchdog [Paras 32–34].

Necessary and proper party – GRIDCO not necessary party in Section 63 Change in Law proceedings – Its PPA is under Section 62 (cost-plus) with tariff determined separately – Proceedings under Sections 62 and 63 are distinct – Non-impleadment did not vitiate CERC orders – GRIDCO’s priority claim based on earlier PPA execution/COD untenable in face of plant-wide allocation [Paras 41–45].

Judicial deference to sectoral expertise – Court reiterates restraint where expert bodies have applied regulations/policy following stakeholder processes – Unwarranted appeals impose carrying costs ultimately borne by consumers – Need to curb such litigation emphasized [Paras 19–23].

Decision – Civil Appeal No. 1929 of 2020 (Haryana Utilities) and Civil Appeal No. 3429 of 2020 (GRIDCO) dismissed – APTEL judgment dated 20.12.2019 upholding CERC order dated 20.03.2018 affirmed – Payment of supplementary bills with late payment surcharge as per PPA sustained [Paras 40, 45–46].

Anticipatory Bail – Allegations of Rape and Sexual Assault – IPC Sections 376(1), 377, 354A – Bail Granted - The appellant, alleged to be a spiritual leader, was accused of sexually exploiting a married woman and others – The FIR was lodged after delay, and the High Court had rejected anticipatory bail – Supreme Court noted earlier grant of interim protection and found the case suitable for anticipatory bail – Held: Order of High Court set aside; anticipatory bail granted with conditions including cooperation in investigation and restraint from tampering with evidence [Paras 1-3].

False Implication – Allegations of Conspiracy and Blackmail – Delay in Filing FIR - Appellant contended that the complainant and her husband fabricated the case using videos to create false evidence for ulterior motives – Further claimed the relationship was consensual – Held: Without commenting on merits, Supreme Court found grounds sufficient for anticipatory bail as the FIR was belated and under suspicious circumstances [Paras 2-3].

Serious Allegations – Accused as Spiritual Leader – Court Balances Liberty and Investigation – The complainant alleged that the appellant misused his position as a godman to exploit women – The Court recognized the seriousness but emphasized liberty and fair process – Held: Conditional anticipatory bail appropriate; liberty not to be misused, and any breach would lead to cancellation [Paras 2-3].

Decision – Appeal Allowed – Anticipatory Bail Granted – The Supreme Court set aside the Bombay High Court’s order and granted anticipatory bail on furnishing ₹25,000 cash security with two sureties – Directions issued for cooperation and non-interference with evidence – Held: Non-compliance would lead to cancellation of bail [Para 3].

Anticipatory Bail – Modification of Conditions – Judicial Propriety – Respondent No. 1 accused in 31 criminal cases involving serious financial offences under IPC and BUDS Act – High Court granted anticipatory bail subject to condition not to leave India without prior permission – During pendency of SLP challenging said bail order, respondent filed application before High Court seeking permission to travel abroad – High Court allowed modification and released passport without disclosing to Supreme Court that such relief had been sought – Held: Conduct of respondent undermines judicial discipline and violates comity between courts – All orders passed by High Court modifying bail conditions during pendency of SLP stayed [Paras 1–11].

Judicial Discipline – Hierarchical Judicial System – Supreme Court emphasized that though High Courts are not subordinate, once a matter is under challenge and seized by the Supreme Court, High Courts must exercise restraint from modifying or passing orders that may prejudice pending proceedings – Reference made to Tirupati Balaji Developers v. State of Bihar and Chhavi Mehrotra v. DGHS highlighting the need for deference and avoidance of parallel jurisdictional exercise [Paras 8–10].

Suppression and Misconduct – Respondent’s Failure to Inform Supreme Court – Though respondent filed application before High Court on 06.07.2025, no disclosure made to Supreme Court when case was listed on 14.07.2025, 25.07.2025, and 25.08.2025 – Counter affidavit dated 14.07.2025 silent on application for modification – Held: Court expresses grave displeasure and issues notice to respondent as to why pre-arrest bail should not be cancelled due to concealment [Paras 12–13].

Interim Directions – Respondent No. 1 restrained from leaving India without permission of Supreme Court – Directed to surrender her passport immediately – Response to show-cause notice to be filed within three weeks with relevant documents [Paras 13–15].

Decision: Orders passed by High Court in Crl.MC No. 6178/2025 and Crl.M.A. No. 1/2025 modifying bail conditions stayed – Show cause notice issued to respondent regarding cancellation of anticipatory bail – Case listed for further orders on 26.09.2025.

Anticipatory Bail – Modification During SLP Pendency – High Court's Jurisdiction Restrained – Stay Issued - The petitioners challenged the anticipatory bail granted to respondent no. 1 in 31 criminal cases related to financial fraud – Despite pendency of SLP, the High Court permitted modification of bail condition allowing travel abroad – Held: Such modification during pendency of appeal before Supreme Court is impermissible and violates judicial discipline – Orders dated 12.08.2025 and 23.08.2025 stayed [Paras 1-11].

Judicial Discipline – High Court Should Exercise Restraint During Pendency of SLP – Doctrine Clarified – Supreme Court reiterated that once an SLP is admitted and notice issued, High Courts must not pass orders that may circumvent or frustrate the proceedings before the apex court – Held: Proper administration of justice demands mutual respect between courts in a hierarchical system – Precedents from Tirupati Balaji Developers and Chhavi Mehrotra relied upon to reinforce judicial propriety [Paras 8-10].

Concealment of Material Facts – Conduct of Accused Under Scrutiny – Show Cause Issued - Respondent No. 1 failed to inform the Supreme Court of filing applications before the High Court for modification of bail terms – Affidavit filed before Supreme Court omitted this material fact – Held: Court expressed grave displeasure and issued notice to explain why anticipatory bail should not be cancelled for suppression of facts [Paras 12-13].

Passport and Travel Restriction – Interim Direction – Supreme Court Mandates Compliance - In view of pending investigation in 31 criminal cases, the Court directed respondent no. 1 to immediately surrender her passport and not to leave India without prior permission – Held: Travel restriction reinstated pending further hearing [Para 15].

Motor Accident Claim – Causal Connection Between Accident and Death – Claim Rejected - The deceased, an Excise Guard, died of pulmonary embolism five months after sustaining leg and finger fractures in a road accident – Supreme Court upheld High Court’s finding that there was no proximate or direct causal link between the accident and death – Held: Death not attributable to accident injuries; post-surgical complications with pre-existing diabetes and hypertension more likely cause [Paras 1-11].

Expert Evidence – Doctor’s Testimony Inconclusive – Medical Opinion Favoured Natural Cause - PW-1, the plastic surgeon, opined the death was due to myocardial infarction, and though stated long bed rest could trigger embolism, he admitted to no post-mortem and acknowledged cardiac risk factors – Held: Absence of conclusive medical evidence and lack of post-mortem weakens claimants’ case; expert's deposition supported natural medical cause [Paras 6-7].

Preponderance of Probability – Not Established – No Clear Nexus Between Injury and Death - Supreme Court reiterated that even in civil cases requiring lesser standard of proof, the causal connection must meet preponderance of probability – Held: Injuries were not serious; death occurred after successful skin grafting – No evidence of extended immobility or bed rest [Paras 8-11].

Final Disposition – High Court Judgment Affirmed – Claim for Death Compensation Denied - Tribunal’s finding of causality reversed by High Court based on medical evidence – Supreme Court declined to interfere, holding the reasoning sound and based on expert medical testimony – Held: No compensation payable for death; claimants still entitled to compensation for injuries [Paras 11-12].

Motor Accident Claim – Functional Disability – Medical Board Certificate – Acceptance Limited - Claimant suffered hemipelvectomy and produced 90% disability certificate – Supreme Court accepted the medical evidence but held that for compensation purposes, 50% functional disability was rightly assessed by High Court based on actual earning capacity and use of prosthetic limb – Held: Functional disability determines loss of income, not the medical percentage per se [Paras 7-8].

Loss of Income – Income Tax Returns Accepted – Estimation Based on Documentary Evidence - The Court found that income tax and sales tax returns submitted prior to the accident could not be disregarded – Held: Income of ₹1,91,000 (net of tax) for 2007-08 accepted; applying multiplier of 18 and 50% disability, total loss of income calculated at ₹17,19,000 [Paras 8-9].

Future Prospects – No Addition Permitted – Functional Earning Capacity Sufficient - The claimant, fitted with a prosthetic limb, could continue his business and did not require enhancement for future prospects – Held: 40% addition for future income prospects disallowed, as loss already compensated through disability-based income loss [Para 9].

Medical Expenses – Full Reimbursement Allowed – Lack of Reasoning by Lower Courts Cured - Tribunal awarded ₹3.39 lakh and High Court increased to ₹8 lakh without reasoning – Supreme Court allowed full ₹12.54 lakh based on vouchers submitted – Held: Entire verified medical expense payable in absence of valid rebuttal by insurer [Para 10].

Future Medical Expenses – Replacement of Prosthetic Limb – Additional Compensation Awarded - Recognizing that prosthetic limbs need periodic replacement and servicing, though no authenticated receipts were filed, the Court granted ₹10 lakh towards future medical needs – Held: Compensation must include realistic provision for ongoing disability management [Paras 12].

Compensation Recalculated – Enhancements Over High Court Award - Supreme Court restored ₹1 lakh for attendant expenses and ₹4.70 lakh for initial prosthetic limb purchase omitted by High Court – Combined total compensation recalculated and awarded at ₹48,44,790 with 6% interest from date of application, after deducting amounts already paid [Paras 11, 13-14].

PIL - Anand Karaj marriages—Section 6, Anand Marriage Act—States/UTs directed to notify rules within 4 months—Till then, registration to be facilitated under existing marriage registration frameworks without discrimination—Union of India to coordinate and file compliance report—Petition disposed with time-bound directions [Paras 11–16].

Constitutional Duty – Registration of Marriages – Section 6 of the Anand Marriage Act imposes a positive duty on States to establish registration machinery for Anand Karaj marriages – Duty not optional or contingent on population size – Non-notification frustrates legislative intent of 2012 amendment [Paras 7–8].

Civil Consequences of Registration – Marriage certificates enable proof of status for residence, maintenance, inheritance, succession, and enforcement of monogamy – Particularly safeguard rights of women and children – Unequal access across jurisdictions violates equal treatment [Para 9].

Harmonisation with Existing Frameworks – Until rules are notified, general marriage registration frameworks must accept Anand Karaj marriages on the same footing as other marriages – Certificate to record that marriage was solemnised by Anand Karaj where parties so request [Para 10].

General Directions – (i) All States/UTs without rules to notify within 4 months; (ii) immediate registration under existing laws without discrimination; (iii) States with rules to issue clarifications within 3 months; (iv) Nodal officer to be designated within 2 months; (v) Union of India to coordinate and circulate model rules, and file consolidated status report in 6 months [Para 12].

Special Directions – Goa: Interim registration under civil registration offices; Union to extend Anand Marriage Act within 4 months; Goa to frame rules within 4 months thereafter [Para 13]. – Sikkim: Interim registration under 1963 Rules; Union to consider extension under Article 371F(n); Sikkim to notify rules within 4 months after extension [Para 14].

Decision – Writ petition disposed of with directions—Time-bound rule-making mandated—Interim facilitation under existing frameworks ordered—Compliance affidavits to be filed by States/UTs; Union to file consolidated status report in 6 months [Paras 15–16].