Civil Law - Arbitration - Arbitration and Conciliation Act 1996 - Section 16 - Competence of Arbitral Tribunal - Division Bench of High Court in writ appellate jurisdiction directed Arbitral Tribunal to decide claims strictly in terms of contract - Supreme Court held that such direction travels beyond scope of judicial review under Article 226 of Constitution and impinges upon Arbitral Tribunal's authority under Section 16 to rule on its own jurisdiction including existence of excepted matters - Direction of High Court does not bind Tribunal - Held - Writ court cannot prescribe constraints on Arbitrator's adjudication - [Paras 11-22].

Civil Law - Judicial Review - Constitution of India - Article 226 - Scope of interference - High Court in exercise of writ jurisdiction issued directions to Arbitral Tribunal concerning conduct of proceedings - Supreme Court held that Court cannot enter upon or pre-determine touchstone for adjudication of claims as this falls within the domain of the Arbitrator - Held - Impugned direction set aside as it circumscribes the width of Arbitrator's enquiry - [Paras 18-20].

Civil Law - Arbitration - Arbitration and Conciliation Act 1996 - Section 11 - Judicial scrutiny - Referral stage - Supreme Court clarified that under current legal regime the court's role is limited to prima facie examination of existence of arbitration agreement and not a laborious enquiry into merits or excepted matters - Held - Division Bench erred in attempting to regulate Arbitrator's methodology - [Paras 14-17].

Decision: Appeal disposed of – The direction issued by the Division Bench to the Arbitrator is clarified to not restrict the jurisdiction of the Arbitral Tribunal to adjudicate the dispute including the validity of termination.

Civil Law - Land Acquisition - National Highways Act 1956 - Sections 3A, 3C, 3D, 3E, 3G, 3H and 3J - Dispute regarding computation of solatium and interest for land acquired under NH Act - Appellant contended for benefits under Act of 2013 based on Tarsem Singh-I and Tarsem Singh-II judgments - Respondent argued for computation under Act of 1894 as the award was passed on 11.07.2014 before the applicability of Act of 2013 to NH Act on 01.01.2015 - Supreme Court held that the Act of 2013 became applicable to NH Act acquisitions only with effect from 01.01.2015 - Awards passed before 01.01.2015 must be computed under the Act of 1894 - Compensation determined by Arbitrator on 13.01.2016 pursuant to 2014 award must include benefits under Act of 1894 - Held - Appeal allowed to the extent of directing computation of solatium and interest under Act of 1894 - [Paras 1-27].

Civil Law - Statutory Interpretation - Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act 2013 - Section 105 - Applicability to National Highways Act 1956 - NH Act was included in the Fourth Schedule of Act of 2013 - Act of 2013 provided a one-year hiatus for application of compensation provisions to scheduled enactments - Notification issued subsequently extended the application to NH Act with effect from 01.01.2015 - Held - Acquisitions under NH Act where awards were passed before 01.01.2015 are governed by the compensation provisions of the Act of 1894 - [Paras 9-23].

Decision: Appeal allowed in part – The Arbitrator's compensation award is to be supplemented with solatium, interest, and interest on solatium as per the Act of 1894 – Matter remanded to the Competent Authority for computation and disbursal.

Civil Law - Property Law - Uttar Pradesh Industrial Area Development Act 1976 - Section 12 - Zero Period Policy - Allotment of commercial plot - Development Authority failed to provide 45-metre wide approach road as promised in lease deed and site plan - Land earmarked for access remained encroached and unacquired - Developer unable to complete construction - Authority denied benefit of Zero Period Policy claiming developer had some access and caused delay - High Court directed authority to grant benefits as developer had legitimate expectation of access per sanctioned plan - Supreme Court upheld High Court decision - Held - Policy of enabling private enterprise in nation-building requires authorities to create conducive environment for investment - Argument that some measure of access existed is not ground to deny relief when promised adequate access is unavailable due to authority's failure - Authority directed to grant Zero Period Policy benefits and sanction revised site plan - [Paras 1-46].

Civil Law - Contract Law - Doctrine of Legitimate Expectation - Lease Deed Obligations - Developer entered into lease based on specific site plan featuring 45-metre frontage - Authority failed to remove encroachments on approach road - Held - Authority cannot fasten liability for construction delays on developer when it failed to fulfill its own obligation to provide promised ingress and egress - [Paras 23-42].

Decision: Civil Appeals dismissed - Allahabad High Court judgment upheld - Authority directed to grant Zero Period Policy benefits and approve revised site plan within the stipulated timeline - [Paras 1-46].

Criminal Law - Murder - Indian Penal Code 1860 - Sections 302 and 34 - Appellants were convicted for the murder of the deceased following a quarrel over waterlogging - Prosecution relied on direct evidence of relatives of the deceased - Investigating officer failed to prepare a map of the scene of occurrence or recover weapons - Contradictions in Section 161 statements and inconsistent testimony regarding where the body was taken created a ring of falsity - Supreme Court held that the prosecution failed to establish the guilt of the appellants beyond reasonable doubt and that a hypothesis of innocence existed - Appeal allowed and appellants acquitted - [Paras 1-21].

Evidence Law - Credibility of Witnesses - Indian Evidence Act 1872 - Section 3 - Related witnesses - Mere relationship does not render a witness interested but where there is a ring of falsity in their testimonies a closer scrutiny is warranted - When eyewitnesses provide inconsistent versions regarding the place of occurrence and the disposition of the body their testimony cannot be relied upon - Held - In the absence of corroboration and due to material discrepancies the oral testimony of the relatives is insufficient to sustain a conviction - [Paras 13-20].

Evidence Law - Investigative Lapses - Code of Criminal Procedure 1973 - Section 161 - Failure of the Investigating Officer to conduct a proper reconnaissance of the scene of occurrence or recover physical evidence - Non-recovery of weapons and failure to link the licensed weapon mentioned by witnesses through proper forensic identification - Held - The lack of effective investigation coupled with the suspicious conduct of the prosecution witnesses warrants the benefit of doubt for the accused - [Paras 9-17].

Decision: The criminal appeal is allowed - The judgment of the High Court is set aside - The appellants are acquitted - Appellants shall be released from custody forthwith if not required in any other case - [Paras 21-24].

Civil Law - Arbitration - Arbitration and Conciliation Act 1996 - Section 7(5) - Incorporation of arbitration clause by reference - Appellant initiated arbitration against company and personal guarantors - Respondent no. 2 filed application under Section 16 of 1996 Act for deletion from proceedings claiming to be a non-signatory to the arbitration agreement - Sole Arbitrator and High Court directed deletion holding that personal guarantees did not contain an arbitration clause and lacked specific incorporation - Supreme Court held that loan agreements and personal guarantees were component parts of one composite transaction and the guarantee was a pre-disbursement condition - The deeming fiction in the contract stated that facility agreements form an integral part of the loan agreement - Held - Arbitration clause is incorporated into the personal guarantee - Appeal allowed - [Paras 1-31].

Civil Law - Contract Law - Arbitration and Conciliation Act 1996 - Section 7 - Composite transactions and non-signatories - Parties structured a single transaction through several interconnected instruments - Respondent no. 2 signed the personal guarantee in individual capacity as a mandatory condition precedent to the loan - Court applied principles of commercial reality and party intention to conclude that the guarantee cannot be severed from the dispute resolution framework of the primary loan agreement - Held - Respondent no. 2 is bound to submit to arbitration - [Paras 24-29].

Decision: Appeal allowed – The judgment dated 28.01.2026 passed by the High Court and the order dated 23.10.2024 passed by the Sole Arbitrator qua respondent no. 2 are quashed and set aside.

Civil Law - Service Law - Pensionary Benefits - Punjab School Education Board Act 1969 - Punjab School Education Board (Employees' Pension, Provident Fund and Gratuity) Regulations 1991 - Respondents appointed as clerks and peons on contract or ad hoc basis between 1993 and 1996 - Services regularized by the Board in 2004 pursuant to adoption of Government policy - Employees claimed pre-regularization service as qualifying service for pension and entitlement to old pension scheme - Board contended fresh recruitment and new pension scheme applicability - High Court allowed claims - Supreme Court affirmed findings holding substance of employment and continuity of service prevails over nomenclature - Regularization constituted substantive appointment and service rendered prior to 2004 must be counted as qualifying service for pension - Held - Respondents entitled to choose between old pension scheme or new defined contributory scheme - Appeal dismissed - [Paras 1-34].

Civil Law - Service Law - Regularization - Punjab School Education Board Act 1969 - Respondent-employees engaged on contract or ad hoc basis - Board adopted government regularization policy - Appointment letters issued in 2004 - Board disputed nature of appointment - Apex Court held the intent and effect of engagement amounted to regularization and not fresh recruitment - Nomenclature used in appointment letters cannot negate the actual nature of service - Held - Service rendered prior to 2004 is continuous service and counts towards qualifying service - [Paras 21-25].

Civil Law - Service Law - Pension - D.S. Nakara vs Union of India - 1982 INSC 103 - Pension as deferred wage - Pension is neither a bounty nor ex-gratia payment but a payment for past service rendered - Long and continuous service followed by regularization creates a right to pensionary benefits - Denial of such benefits based on technical or artificial breaks in service is unjustified - Held - Breaks in service that are notional or administrative must be ignored - [Paras 26-30].

Decision: Appeal dismissed – Respondents are entitled to count pre-regularization service as qualifying service and opt for the old pension scheme.

Writ Law - Quo Warranto - Constitution of India - Article 226 - Appointment challenge - Appellants filed for writ of quo warranto against Respondent No 6 alleging appointment secured via forged PhD - High Court dismissed writ holding that Respondent No 6 possessed the mandatory UGC-NET qualification and appellants lacked locus standi as unsuccessful candidates - Supreme Court affirmed findings that PhD was not a mandatory qualification and Respondent No 6 satisfied eligibility criteria through UGC-NET - Court exercised Article 142 powers to direct inquiry into the authenticity of the PhD degree despite upholding the appointment - Held - Petition dismissed but inquiry into documents ordered - [Paras 1-21].

Service Law - Eligibility Criteria - UGC Regulations 2010 - Appointment of Assistant Professor - Dispute over mandatory qualifications - Advertisement stipulated UGC-NET or PhD - Appointee qualified UGC-NET - Held - Appointee did not lack mandatory qualification regardless of the validity of the PhD degree - [Paras 10-15].

Constitutional Law - Powers of Supreme Court - Constitution of India - Article 142 - Inherent powers to do complete justice - Documentary evidence suggested PhD degree was forged or fabricated - Court directed University to conduct formal inquiry complying with natural justice principles despite dismissing the main appeal - Held - Inquiry is necessary to address allegations of fraud at the inception of service - [Paras 18-20].

Evidence Law - Burden of Proof - Quo Warranto - Writ petitioner must produce unimpeachable evidence to shift burden to the appointer - Where document is prima facie fake or forged the court may direct departmental inquiry - Held - Court cannot turn a blind eye to evidence of fraud on record - [Paras 14-19].

Decision: Civil appeals dismissed without disturbing the appointment of the sixth respondent – Maharshi Dayanand University granted liberty and directed to conduct an inquiry into the authenticity of the sixth respondent's PhD degree in accordance with principles of natural justice – Liberty granted to initiate criminal prosecution if the degree is found forged.

Criminal Law - Unlawful Assembly - Indian Penal Code 1860 - Sections 302, 148, 149 and 34 - Seventeen persons accused of ambushing and killing the deceased - Trial Court convicted four accused and acquitted others - High Court in appeal upheld conviction of one accused and acquitted others - Supreme Court set aside acquittal of two accused A6 and A12 holding their involvement proven via specific overt acts and common object - Sustained acquittal of A13 due to lack of substantive evidence despite Section 319 CrPC inclusion - Held - Acquittal of A6 and A12 reversed and conviction restored - [Paras 1-28].

Criminal Law - Common Intention and Object - Indian Penal Code 1860 - Sections 34 and 149 - Mere presence versus active participation - Court held that if presence of an accused with a weapon is established as part of an unlawful assembly they can be roped in for common intention or object even if they did not fire the shot - Held - High Court erred in acquitting A6 and A12 by placing undue weight on the lack of individual overt acts - [Paras 8-9, 23-24].

Evidence Law - Credibility of Witnesses - Indian Evidence Act 1872 - Section 3 - Grain from Chaff - Principle of falsus in uno, falsus in omnibus is not applicable to India - Courts have a duty to separate grain from chaff in analyzing evidence - Deliberate attempt to implicate innocent persons does not necessarily discredit the entire testimony regarding those whose presence and roles are clearly established - Held - Testimony of eyewitnesses PW1, PW10 and PW11 sufficient to establish guilt of A1, A6 and A12 - [Paras 20, 26].

Decision: Appeal allowed in part - Acquittal of A6 and A12 reversed and their conviction/sentence restored - Acquittal of A13 sustained - A6 and A12 granted two weeks time to surrender - [Paras 27-29].

Criminal Law - Prevention of Corruption - Prevention of Corruption Act 1988 - Section 13(1)(d) - Absence of pecuniary advantage - Appellant was store-in-charge accused of certifying false bills for non-supplied medicines - High Court acquitted under various IPC sections but sustained conviction under P.C. Act despite acknowledging lack of evidence regarding pecuniary advantage - Supreme Court held that in the absence of any valuable thing or pecuniary advantage obtained by the public servant or any other person the essential ingredients of Section 13(1)(d) are not satisfied - Conviction cannot be sustained without proof of such gain - Appeal allowed - [Paras 1-10].

Criminal Law - Corruption cases - Evidence - Duty of prosecution - Necessity of establishing essential elements - High Court and Trial Court records showed lack of evidence regarding money trail or illegal gains - Prosecution led voluminous irrelevant evidence failing to prove ingredients of offence - Supreme Court noted that where no pecuniary advantage is gained the department could have resorted to disciplinary proceedings - Held - Conviction set aside due to failure of prosecution to prove essential ingredients of the statute - [Paras 6-8].

Decision: Appeal allowed - Conviction and sentence set aside - Appellant acquitted and directed to be released if not required in any other case - [Paras 9-10].