Civil Law - Oral Partition – Proof Through Boundaries – Not Sufficient – High Court Judgment Set Aside - High Court reversed concurrent findings of Trial and First Appellate Courts based solely on references to boundaries in unrelated sale and mortgage deeds (Ex.A3, A4, B3) – Supreme Court held that such documents relating to other properties cannot be conclusive proof of oral partition of suit property – Held: No reliable evidence of partition or exclusive title of plaintiffs – High Court acted beyond its jurisdiction under Section 100 CPC [Paras 10–14].

Execution of Will – Non-compliance with Statutory Requirements – Will Not Proved - Plaintiffs' claim of title relied upon will dated 16.07.2003 allegedly executed by Arunachalam – Both courts below found will unproved due to non-compliance with Sections 68 of the Evidence Act and 63 of the Succession Act – Supreme Court upheld this finding and held the High Court ignored crucial evidence while erroneously decreeing the suit [Paras 6, 12–13].

Non-Joinder of Necessary Parties – Co-owners Not Impleaded – Suit Bad in Law - Plaintiffs failed to implead co-owners of the suit survey number, despite admitting joint patta with eight others – Courts below rightly held the suit as defective – Supreme Court reaffirmed this conclusion and criticized High Court’s omission of this issue [Paras 6, 9, 13].

Scope of Second Appeal – Interference with Concurrent Findings – Reversal Unjustified - Supreme Court ruled that High Court exceeded its jurisdiction under Section 100 CPC by reappreciating evidence and overturning concurrent findings without substantial question of law – Held: Judgment was perverse and unsustainable [Paras 14–15].

Decision – Appeal Allowed – Trial Court and First Appellate Court Judgments Restored – Suit Dismissed - Judgment of Madras High Court dated 28.07.2022 in Second Appeal No. 351/2021 set aside – Findings of Trial Court and Sub-Judge restored – Plaintiff’s suit stands dismissed – No costs awarded [Paras 15–16].
 

Civil Law - Municipal Council Resolution – Use of Urdu on Signboard – Powers under Section 308 of the 1965 Act – Collector’s Jurisdiction – Application Invalid – Under the amended Section 308, only the Chief Officer of the Municipal Council can approach the Collector to suspend a resolution – Petition filed by an individual was not maintainable under the amended law – High Court rightly held that the Collector lacked jurisdiction [Paras 9-11, 12].

Official Language – Interpretation of the Maharashtra Local Authorities (Official Languages) Act, 2022 – No Express Bar on Additional Languages – Use of Urdu alongside Marathi on signage not prohibited – The Act mandates Marathi for official and public-facing purposes but does not prohibit additional languages such as Urdu [Paras 13-15, 49].

Constitutional Validity – Language and Diversity – Article 345 and Language Use – The Constitution permits States to adopt multiple official languages – There is no restriction against using more than one language for public communication – Use of Urdu recognized under the VIIIth Schedule, and its usage cannot be invalidated solely on that basis [Paras 24-25].

Cultural and Linguistic Harmony – Urdu as an Indian Language – The judgment discusses at length the cultural, historical, and constitutional relevance of Urdu – Court observes that language is not synonymous with religion – Emphasizes linguistic unity and diversity – Rejection of communal interpretations of language identity [Paras 17-23, 27-47].

Decision – No Bar on Use of Urdu – High Court's interpretation upheld – Appeal dismissed – There is no legal basis to prohibit the use of Urdu alongside Marathi on the Municipal Council’s signboard – Display of Urdu does not violate the 2022 Act or any provision of law [Paras 49-50].

Criminal Law – Bail - PMLA – Sanction under Section 197 CrPC – Cognizance Quashed – Bail Granted - The appellant, a retired civil servant, challenged his arrest under Section 3 of the PMLA citing that cognizance was wrongly taken without sanction as required under Section 197 CrPC – High Court quashed cognizance for lack of sanction – Supreme Court noted that no fresh cognizance has been taken, appellant had spent about a year in custody, and trial was unlikely to commence soon due to pendency and vacant Special Court – Held: Bail granted subject to stringent conditions [Paras 2–4, 7].

Delay in Trial – Prolonged Incarceration – Balancing of Rights - Considering over 20 accused, 30+ witnesses, and vacant Special Court under Section 43(1) of PMLA, the Court applied principles from V. Senthil Balaji vs Deputy Director, Directorate of Enforcement (2024 INSC 739) and emphasized that continued detention pending indefinite trial would violate liberty – Co-accused already granted bail in similar facts – Appellant entitled to bail [Paras 4–5].

Conditions of Bail – Potential to Influence Proceedings – Safeguards Imposed - Respondent argued the appellant is influential and may tamper with evidence – Court directed imposition of stringent conditions including surrender of passport, undertaking to attend trial, and right to seek bail cancellation on breach of conditions [Paras 5–8].

Administrative Directions – Vacant Special Court – Mandate to Designate Judge - Court noted Special Court under PMLA was lying vacant and directed the Central Government to immediately designate a Sessions Judge to hear the case under Section 43(1) PMLA – All issues regarding fresh cognizance kept open [Para 9].
 

Criminal Law - Bail Cancellation – Organized Child Trafficking – Improper Exercise of Discretion by High Court – Bail Cancelled - The High Court granted bail to multiple accused in a grave child trafficking case without proper application of judicial principles – Supreme Court held that the High Court's approach was casual, failed to consider the seriousness of offences, and bail orders required interference and cancellation [Paras 37, 67-70, 76-79].

Principles of Bail – Balance Between Liberty and Societal Interest – Discretion Must be Judicious - Reiterating jurisprudence from multiple landmark rulings, the Court emphasized that while liberty is essential, it must be balanced with public interest, especially in heinous offences like child trafficking – Bail orders devoid of reasoning or consideration of relevant factors are unsustainable [Paras 53-63, 74-75].

Absconding Accused – No Monitoring by State – Bail Misused – Bail Revoked - Several accused, once released on bail, absconded and evaded trial – Supreme Court observed that bail orders lacked essential safeguards like police station reporting – Held: Bail orders suffered from non-application of mind and were liable to be set aside [Paras 67-68].

Prima Facie Role of Accused – Direct Involvement in Trafficking – Sufficient Material on Record - Accused Santosh Sao was found to have purchased a trafficked male child for Rs. 4 lakhs; accused Jagveer Baranwal was caught with a trafficked child in his custody; Manish Jain was identified as one of the key operators in the trafficking network – Held: All three had substantial material against them and were not entitled to bail [Paras 69-71].

State Inaction – Failure to Challenge Bail Orders – Court Criticises Laxity - Court expressed deep concern at the State of Uttar Pradesh’s delay and inaction in appealing improper bail orders – Directed remedial action and issued warnings against lax conduct of state authorities [Para 68].

Trial Directions – Expedited Prosecution – Protection for Victims – Monitoring by High Courts - Supreme Court laid down a comprehensive action plan for lower courts, directing speedy committal, framing of charges, day-to-day trial, appointment of special public prosecutors, and police protection for victims – Also directed State and High Courts to take concrete steps for preventing trafficking and expediting related trials [Paras 80-81].

Public Awareness – Parental Vigilance – Institutional Accountability - Supreme Court issued a public message warning parents about the horrors of child trafficking, urging vigilance – Directed suspension of hospital licenses where infants are trafficked, reinforcing institutional accountability [Paras 90-91].

Final Decision – Bail Orders Set Aside – Accused to Surrender – Appeals Allowed - All impugned bail orders passed by the High Court were set aside – Accused directed to surrender and remain in judicial custody – Appeals allowed in their entirety [Paras 79-80].

PIL - Food Labelling – Front-of-Pack Nutrition Labelling (FOPNL) – Mandamus Sought – Direction Issued - The petitioner sought implementation of Front-of-Package Warning Labels on packaged foods to enhance consumer awareness of high sugar, salt, and fat content – The Union of India submitted that the Food Safety and Standards Authority of India (FSSAI) had already notified a draft regulation in 2022 proposing the Indian Nutrition Rating (INR), a star-based FOPNL system, and received over 14,000 public comments – An Expert Committee was constituted to analyze the feedback and recommend changes – The Court acknowledged the steps taken and directed the Expert Committee to finalize and submit its report within three months to enable further regulatory action – Held: Petition disposed with directions for timely compliance and monitoring [Paras 1, 4–8].

Taxation Law – Input Tax Credit – Exemption under Section 7(c) – Prohibition under Section 13(7) – Credit Denied – Dealer claimed entitlement to input tax credit for purchases sold to manufacturer-exporters under Form-E as per exemption notification – Authorities rejected the claim citing Section 13(7) which bars credit where sales are exempt under Section 7(c) – Held: Section 13(7) imposes a clear statutory bar; no input tax credit is allowed for exempt sales to manufacturer-exporters, and interpreting the provision by legislative intent or policy cannot override express legislative language [Paras 2-3, 6-10].

Notifications and Circulars – Interpretation of Notifications dated 24.02.2010 and 25.03.2010 – No Input Tax Credit Benefit to Seller – Appellant’s reliance on these notifications and state policy to justify input tax credit claim was misplaced – Notifications were intended to facilitate manufacturer-exporters and not seller-dealers – The clear wording of Section 13(7) overrides any inferred policy advantage [Paras 3, 9-10].

Statutory Interpretation – Tax Statutes – Plain Meaning Rule – No Role of Legislative Intent – Court held that in the context of taxing statutes, legislative intent or policy is not a valid ground if language is clear – Section 13(7) unambiguously denies input tax credit for transactions exempt under Section 7(c), making dealer’s claim unsustainable in law [Para 9].

Final Decision – Civil Appeal Dismissed – Supreme Court upheld decisions of Assessing Authority, Appellate Authority, Tribunal, and High Court – No entitlement to input tax credit for dealer due to express statutory bar under Section 13(7) of UP VAT Act – Appeal dismissed with no order as to costs [Para 10].

Civil Law - Limitation – Suit Filed to Set Aside Decree after 17 Years – Bar under Article 59 of the Limitation Act – Suit Held Time-Barred – Respondents filed suit in 1982 to set aside a 1965 decree and claim partition – Trial Court and First Appellate Court dismissed the suit as barred by limitation – High Court remanded the matter for retrial on limitation issue – Held: Respondents were aware of earlier proceedings and were party to execution – Limitation is a question of law in this case, and Courts below rightly dismissed the suit as barred by law [Paras 13-16, 23-24].

Second Appeal – Jurisdiction under Section 100 CPC – Remand by High Court Without Deciding Substantial Questions of Law – Set Aside – High Court failed to decide substantial question of law framed at admission and remanded for retrial on limitation – Held: High Court's remand unsustainable as Section 100 empowers it to adjudicate substantial legal issues directly – Framing and non-framing of issues immaterial where parties had full opportunity to contest limitation [Paras 11-12, 18-22].

Procedural Law – Limitation and Framing of Issues – Courts’ Duty under Section 3 of Limitation Act – Even in Absence of Plea or Issue, Court Must Examine Limitation – Trial and Appellate Courts rightly adjudicated limitation based on pleadings, evidence, and statutory mandate – Procedural lapses do not override substantive justice where parties have had fair trial and no prejudice is caused [Paras 19-22].

Final Decision – Appeal Allowed – High Court’s judgment remanding case for fresh trial set aside – Judgments of Trial Court and First Appellate Court dismissing the suit restored – Respondents' claim barred by limitation and no relief warranted – Each party to bear own costs [Paras 23-24].

Service Law – Reservation for Women – Horizontal Reservation under Punjab Civil Services Rules, 2020 – Post Validly Reserved for Women – The appellant challenged the Division Bench's order remanding the matter regarding the validity of reservation of a DSP post under the 'SC Sports (Women)' category – Held: The advertisement reserving the post was validly issued under the 2020 Rules and could not be altered retrospectively based on later-issued roster points – Once selection process began, rules of the game could not be changed midstream [Paras 15-17, 21-24].

Rosters and Amendments – Roster Points Issued Post Advertisement – No Retrospective Application – The private respondent sought quashing of the women's reservation based on the roster introduced after the advertisement’s closing date – Held: Roster system introduced post-deadline cannot affect a concluded process – Amendments to the Rules could not apply retrospectively unless explicitly stated [Paras 13, 16, 24].

Recruitment Process – Changing Eligibility Midway – Prohibited – Once Advertisement No. 14 dated 11.12.2020 was issued with clear eligibility and reservation criteria, no post-facto amendment could alter its terms – Supreme Court reaffirmed the principle that recruitment rules cannot be changed after the process begins, relying on Constitution Bench decision in Tej Prakash Pathak v. High Court of Rajasthan, (2025) 2 SCC 1 [Paras 21-22].

Final Decision – Appeal Allowed – Supreme Court upheld the learned Single Judge's order confirming the validity of the DSP (SC Sports – Women) reservation – Set aside Division Bench’s remand order – Directed compliance within three weeks [Paras 25].

Bail – Anticipatory Bail in Economic Offences – Orders Set Aside – SFIO challenged anticipatory bail granted to several accused by the High Court despite earlier non-bailable warrants and proclamation orders issued by the Special Court – Held: High Court erred in granting anticipatory bail ignoring mandatory provisions under Section 212(6) of the Companies Act and repeated defiance of court summons – Anticipatory bail granted to absconding accused is impermissible unless under exceptional circumstances [Paras 3-9, 23-27].

Economic Offences – Serious Fraud – Cognizable and Non-Bailable Nature – Twin Conditions for Bail Under Section 212(6) – Charges involved fraud of ₹4,120 crores through shell companies – Accused siphoned funds via forged documentation – Held: Section 447 offences are cognizable and attract twin bail conditions – High Court failed to consider these restrictions while granting anticipatory bail [Paras 1, 3, 24-26].

Legal Principles – When Anticipatory Bail Should Not Be Granted – Judicial Discretion Must Account for Abscondence and Public Interest – Court reiterated that anticipatory bail is an extraordinary remedy and should not be granted to accused who obstruct legal process – Cited P. Chidambaram, Jagan Mohan Reddy, Srikant Upadhyay and others to affirm that economic offences require stricter scrutiny and denial of anticipatory bail in normal circumstances [Paras 18-21, 23].

Final Decision – Appeals Allowed in 14 Cases – High Court's anticipatory bail orders quashed – Accused directed to surrender within one week – Appeals against three respondents dismissed where no NBW or proclamation was issued or where bail was granted by Special Court – No opinion expressed on merits of individual cases [Paras 6, 30-31].