Review Petition – Delay Condonation – High Court dismissed review petition and application for condonation of 71 days delay – Supreme Court condoned the delay, stating a liberal view should be taken for such short delays – Case remanded to High Court to decide review on merits [Paras 3-4, 16].

Doctrine of Merger – Maintainability of Review – Distinction between SLP dismissed with reasons and without reasons – If SLP dismissed without reasons, no merger occurs, and review of High Court judgment is maintainable – Supreme Court reaffirmed no merger when SLP is dismissed without reasons, allowing for High Court review [Paras 6-9].

Legal Precedent and Stray Observations – Supreme Court clarified that stray observations in judgments do not constitute precedents – Emphasized focus on legal principles over perceived affronts – Rejected the idea that review petition filed post-SLP dismissal affronts Supreme Court's order [Paras 12-14].

Decision – Appeal allowed – High Court's order set aside – Delay in filing review petition condoned – Matter remanded to High Court for decision on merits [Para 16].

Reservation in Single Post Cadre – Legality – High Court quashed inquiry into alleged malpractices in the selection process for Principals – Supreme Court affirmed that the post of Principal in each aided/affiliated institution being a single post in the cadre is not amenable to reservation – Emphasized that reservation in single post cadres is impermissible as it amounts to 100% reservation, violating Articles 14 and 16 of the Constitution [Paras 39-49].

Government's Power to Inquire – Validity – High Court quashed order appointing an enquiry officer – Supreme Court left open the question whether the government could direct an enquiry under Section 6 of the Uttar Pradesh Higher Education Services Commission Act, 1980 or under Article 154 of the Constitution – Directed the High Court to examine all aspects of the selection process in pending writ petitions [Paras 22-23, 50-52].

Implementation of Appointments – Supreme Court allowed the appointed candidates to receive full benefits of their posts during the pendency of the writ petitions – Directed that the selected candidates be impleaded as parties to the pending writ petitions before the High Court for a comprehensive examination of the selection process [Paras 51-53].

Decision – Appeals disposed of with specific directions – High Court's orders on reservation affirmed – State's inquiry into the selection process quashed – Matter remanded to the High Court for detailed examination of the selection process – Interim benefits to appointed candidates upheld [Paras 53-54].

Euthanasia – Legality – Petitioner, in a persistent vegetative state for 37 years, sought permission for euthanasia – Supreme Court deliberated on the issue of passive euthanasia and the role of the judiciary in sanctioning it – Held that passive euthanasia is permissible under exceptional circumstances with the approval of the High Court, which must act as parens patriae [Paras 1-144].

Passive Euthanasia – Procedure – Supreme Court laid down guidelines for High Courts to follow when considering passive euthanasia – High Court to constitute a Bench of at least two judges to decide, seeking the opinion of a committee of three doctors – Views of near relatives, next friend, and doctors to be considered [Paras 128-144].

Parens Patriae Doctrine – Explained the doctrine as the inherent power of the state to act as guardian for those unable to care for themselves – Applied to cases involving incompetent persons unable to make decisions regarding withdrawal of life support [Paras 128-132].

Decision: Petition dismissed with observations – Supreme Court recommended Parliament to consider the feasibility of deleting Section 309 of the IPC, which criminalizes attempted suicide – High Courts authorized to permit passive euthanasia under specified conditions until legislation is enacted [Paras 143-144].

Land Acquisition – Invocation of Emergency Provision – Appellants challenged acquisition of agricultural land for construction of district jail, claiming lack of urgency and unjustified invocation of Section 17(4) of the Land Acquisition Act – High Court upheld acquisition, dismissing writ petition – Supreme Court found no real urgency justifying dispensation of Section 5A inquiry, quashed notifications [Paras 1-42].

Constitutional Law – Public Purpose and Right to Property – Concept of public purpose must align with welfare state principles – Expropriatory legislation must be strictly construed – Right to property, though not fundamental, remains a significant legal and human right, and abridgement requires strict adherence to legal procedures [Paras 15-25].

Procedure under Land Acquisition Act – Section 5A Inquiry – Recognized as a substantial right providing landowners an opportunity to object – Dispensation of this right requires demonstrable urgency – In absence of urgency, Section 17(4) cannot be invoked merely on executive assertion [Paras 26-41].

Decision – Appeals allowed – Held – Notifications under Sections 4 and 6 relating to appellants' land quashed – Appellants' possession to remain undisturbed except in accordance with law [Paras 41-42].

Euthanasia – Legality – Petitioner, in a persistent vegetative state for 37 years, sought permission for euthanasia – Supreme Court deliberated on the issue of passive euthanasia and the role of the judiciary in sanctioning it – Held that passive euthanasia is permissible under exceptional circumstances with the approval of the High Court, which must act as parens patriae [Paras 1-144].

Passive Euthanasia – Procedure – Supreme Court laid down guidelines for High Courts to follow when considering passive euthanasia – High Court to constitute a Bench of at least two judges to decide, seeking the opinion of a committee of three doctors – Views of near relatives, next friend, and doctors to be considered [Paras 128-144].

Parens Patriae Doctrine – Explained the doctrine as the inherent power of the state to act as guardian for those unable to care for themselves – Applied to cases involving incompetent persons unable to make decisions regarding withdrawal of life support [Paras 128-132].

Decision: Petition dismissed with observations – Supreme Court recommended Parliament to consider the feasibility of deleting Section 309 of the IPC, which criminalizes attempted suicide – High Courts authorized to permit passive euthanasia under specified conditions until legislation is enacted [Paras 143-144].

Land Acquisition – Invocation of Emergency Provision – Appellants challenged acquisition of agricultural land for construction of district jail, claiming lack of urgency and unjustified invocation of Section 17(4) of the Land Acquisition Act – High Court upheld acquisition, dismissing writ petition – Supreme Court found no real urgency justifying dispensation of Section 5A inquiry, quashed notifications [Paras 1-42].

Constitutional Law – Public Purpose and Right to Property – Concept of public purpose must align with welfare state principles – Expropriatory legislation must be strictly construed – Right to property, though not fundamental, remains a significant legal and human right, and abridgement requires strict adherence to legal procedures [Paras 15-25].

Procedure under Land Acquisition Act – Section 5A Inquiry – Recognized as a substantial right providing landowners an opportunity to object – Dispensation of this right requires demonstrable urgency – In absence of urgency, Section 17(4) cannot be invoked merely on executive assertion [Paras 26-41].

Decision – Appeals allowed – Held – Notifications under Sections 4 and 6 relating to appellants' land quashed – Appellants' possession to remain undisturbed except in accordance with law [Paras 41-42].

Motor Accident Claims – Compensation – Appellant, injured in a motor vehicle accident, awarded compensation by MACT which was marginally enhanced by the High Court – Appellant contended that MACT and High Court failed to adequately compensate for loss of future earnings and applied an incorrect interest rate – Supreme Court held that compensation should be based on the structured formula in the Second Schedule to the Motor Vehicles Act for just and fair determination [Paras 1-12].

Compensation for Future Earnings – Multiplier Method – Appellant’s monthly income considered for applying the multiplier as per the Second Schedule – Court found that MACT and High Court erred in not using the multiplier method appropriately – Appellant entitled to compensation for loss of future earnings calculated using correct multiplier based on age [Paras 13-14].

Interest Rate – Appellant claimed interest rate should be 9% – Supreme Court found the claim reasonable and adjusted the interest rate from the previously awarded 7.5% to 9% [Paras 14-15].

Decision:

Appeal Allowed – Held – Total compensation of Rs. 443,000/- awarded including Rs. 5,000/- for hospitalization, special diet, attendant, and transportation, and Rs. 22,209/- for purchase of medicines – Interest at 9% to be paid by respondents jointly and severally – High Court's judgment set aside [Paras 14-15].

Specific Performance – Contract Law – Appellant filed a suit for specific performance of a contract to sell 1/3rd share in property by Respondent's power of attorney holder – Respondent denied execution of power of attorney for alienation, asserting it was for management only – Trial Court decreed the suit, High Court reversed, setting aside the decree based on inadequate consideration and rise in property value – Supreme Court found High Court erred in not addressing the validity of the power of attorney and proper application of law [Paras 2-24].

Admissibility and Proof of Documents – Secondary Evidence – Trial Court’s acceptance of a photocopy of the power of attorney without proper foundational evidence was incorrect – Respondent only admitted signature, not contents – Supreme Court emphasized the need for strict adherence to provisions for secondary evidence and the requirement of proving documents’ authenticity and relevance [Paras 10-12].

Judicial Review – Appellate Court Obligations – High Court failed to comply with Order 41 Rule 31 CPC by not formulating proper points for determination and independently assessing evidence – Supreme Court highlighted the appellate court’s duty to fully consider and adjudicate issues raised, providing well-reasoned findings [Paras 16-19].

Equitable Relief – Discretion and Fairness – Specific performance being discretionary relief, courts must consider fairness and balance – Issues of inadequate consideration and property value rise should be weighed against contractual obligations and proven conduct of parties – High Court’s failure to properly address discretionary factors noted [Paras 20-23].

Decision:

Appeal Allowed – Held – High Court’s judgment set aside – Matter remitted to High Court for fresh decision in accordance with law, to be expedited given long pendency – Directions issued to ensure proper adjudication on all relevant issues, including power of attorney validity and compliance with evidentiary standards [Paras 23-24].

Inter-State Sales – Section 3(a) CST Act – Assessee engaged in manufacturing and selling electrical fans and other goods – Contended that goods transported to out-of-state depots were stock transfers not subject to CST – High Court dismissed revision, affirming transactions as inter-State sales – Supreme Court examined whether transactions were inter-State sales or branch transfers, scrutinizing agreement between Assessee and Usha Sales Ltd. (UIL) [Paras 1-12].

Nature of Transactions – Sales Agreement – Agreement required Assessee to supply goods to UIL's godowns across states – Indents from UIL specifying model and quantity triggered movement of goods – Goods moved to fulfill contractual obligations under agreement – Movement of goods in pursuance of contract constitutes inter-State sales, not branch transfers [Paras 21-23, 39-40].

Presumption of Inter-State Sales – Legal Burden – Section 3(a) CST Act presumes inter-State sale if sale occasions movement of goods across states – Assessee bears burden to rebut presumption with evidence of stock transfers for self-consumption – Evidence indicated transactions were for fulfilling sales agreement, reinforcing inter-State sale presumption [Paras 17-20, 34-36].

Judicial Review – Fact-Finding by Lower Authorities – Findings of assessing authority, Tribunal, and High Court confirmed by Supreme Court – No perverse or erroneous conclusions found in evaluation of voluminous correspondence and transactional evidence – Supreme Court upheld findings of inter-State sales based on detailed assessment of contractual and transactional context [Paras 38, 45].

Decision:

Appeal Dismissed – Held – Transactions deemed inter-State sales under Section 3(a) of Central Sales Tax Act – High Court's dismissal of Assessee’s revision petition affirmed – No order as to costs [Paras 45-46].