Criminal Law - Probation of Offenders Act – Inapplicability under PoFA Act – Section 20AA prohibits probation – Probation benefit denied - Section 20AA clearly excludes the application of the Probation of Offenders Act and Section 360 of the CrPC to those convicted under the PoFA Act unless the offender is under 18 years of age – The Court held that the provision is explicit, unambiguous, and constitutionally valid – Hence, probation not applicable [Paras 40-42].

Mollification of Sentence – FSS Act Repeal and Savings Clause – Reduced punishment not permitted – Benefit denied - Despite lesser punishment under the FSS Act, the repeal and savings clause under Section 97 preserves penalties under the repealed PoFA Act – The Court held that the presence of such a clause prevents application of lighter sentence from new law – Hence, no reduction in sentence permissible under FSS Act [Paras 43-44].

Adulteration Evidence – Discrepancy in Reports – Sentence converted to fine – Lead appeal partly allowed - In the case of Nagarajan and Selvaraj, the two lab reports on curd adulteration had significant differences—one showing deficiency in fat content, the other meeting the required standard – Applying precedent in C. Mohammed, the Court converted the 6-month imprisonment to a fine of Rs. 30,000 each [Paras 45-46].

Judicial Comity – Reliance on Coordinate Bench despite disagreement – Connected appeal partly allowed - Although the Bench disagreed with the reasoning in A.K. Sarkar & Co., it followed the decision to prevent further litigation, converting Naresh Chandra’s sentence to a fine of Rs. 20,000 in the interest of equity and justice [Paras 47-48].

Decision – Convictions upheld, Sentences modified – Probation relief and sentence reduction under FSS Act denied – However, due to specific factual circumstances and prior rulings, sentences were converted to fines – Appeals partly allowed [Paras 48-51].

Criminal Law - Custodial Death – Demand for Independent Investigation – Local Police Involved – CBI Directed to Take Over – Allegations of police brutality leading to the death of Deva Pardhi in custody prompted a plea by relatives seeking transfer of investigation from local police, who were the accused themselves – Supreme Court found that no arrests were made eight months after FIR and that doctors possibly acted under pressure – Held: Investigation transferred to CBI to ensure impartiality and credibility [Paras 3–32].

Witness Intimidation – Sole Eyewitness Threatened and Implicated – Witness Protection Ordered – Gangaram Pardhi, sole eyewitness to the custodial torture, was being implicated in multiple FIRs post-incident – Court acknowledged threats and coercion and upheld High Court's order shifting him to Central Jail – Held: State authorities directed to provide witness protection as per law [Paras 7, 12, 20, 27, 35–36].

Bail Application – Direction to Approach High Court – Liberty Granted – Supreme Court refrained from directly granting bail but noted ongoing persecution of the eyewitness – Held: Gangaram Pardhi permitted to approach High Court for bail in all implicated cases post-incident; High Court to decide considering present observations [Paras 33–34].

Decision – CBI to Investigate – Witness Protection and Bail Liberty Granted – Supreme Court allowed the appeal in part by transferring the investigation to CBI, directing protection for Gangaram Pardhi, and permitting him to seek bail from High Court with due consideration to the case circumstances [Paras 31–37].

Environmental Law - Reserved Forest Land – Status upheld since 1879 – Fabricated Gazette Notification exposed – Land in Survey No. 20 originally notified as Reserved Forest in 1879 remained so despite partial de-reservation in 1934 – RRCHS relied on a 1944 notification found to be forged – Held: The land retained its Reserved Forest character, and any contrary claim based on forged records is invalid [Paras 12-21].

Forest (Conservation) Act – Prior approval mandatory – Allotment without Central clearance illegal – The 1980 FC Act prohibits State authorities from de-reserving or allotting forest land without Central Government approval – High officials bypassed this requirement citing an outdated precedent – Held: Such actions were contrary to statutory mandate and Supreme Court's binding orders, rendering the allotment void ab initio [Paras 22-38].

Doctrine of Desuetude – Inapplicable to Forest Law – Forest protection laws not rendered obsolete – RRCHS argued land lost forest status due to non-use – Held: Doctrine of desuetude applies only where statutes fall into complete disuse and contrary practices prevail—Neither condition satisfied here—Forest entries actively maintained and enforced [Paras 39-47].

Bonafide Purchaser – RRCHS complicit – Deals predating allotment invalidate claim – RRCHS entered development agreements and took possession before land was even officially allotted – Held: RRCHS was not a bonafide purchaser; the Chavan Family acted as a front—All transactions violated allotment conditions and were legally impermissible [Paras 48-64].

Alternate Land Claim – Not Entitled – Distinction drawn from precedent – RRCHS sought alternate land relying on prior Supreme Court order – Held: Unlike earlier case where State illegally took over private land, here RRCHS acted illegally with full knowledge of violations—No relief can be granted for self-inflicted illegality [Paras 65-74].

Doctrine of Public Trust – Breached by State Officials – Forest land handed over for private profit – State authorities including Minister and Divisional Commissioner colluded to transfer forest land to builders under the guise of resettlement – Held: This was a grave violation of the public trust doctrine and environmental norms—Such conduct undermines constitutional duties of the State [Paras 75-91].

Nationwide Directions – Forest lands under Revenue control to be handed over – Orders issued to all States/UTs – Supreme Court mandated that all forest lands under Revenue Departments be transferred to Forest Departments – Directed recovery or restoration where lands have been illegally allotted for non-forest use [Paras 92-94].

Decision – Allotment cancelled – Environmental clearance quashed – Forest land to be restored – Appeal disposed – Held: The 11.89 ha land allotted in 1998 and later sold to RRCHS was illegally transferred—Environmental clearance issued to RRCHS is quashed—Land to be restored to Forest Department and nationwide steps for forest protection initiated [Paras 95-96].

Arbitration Law - Arbitral Award – Division of Interest Periods – Legality of Granting Separate Interest for Pre-reference and Pendente Lite Periods – Arbitral Discretion Upheld - Arbitral Tribunal’s bifurcation of interest into pre-reference, pendente lite, and post-award periods is not contrary to Section 31(7)(a) – Held: Tribunal is empowered to award varying interest rates over subdivided segments within the larger period from cause of action to award, consistent with statutory scheme and judicial precedents [Paras 30-35].

Compound Interest – Interpretation of 'Sum' in Section 31(7)(b) – Inclusion of Past Interest in Principal for Future Interest Computation – Permissible - Held: Tribunal did not err in treating awarded interest as part of the “sum” under Section 31(7)(b) – Supreme Court affirms legality of awarding post-award interest on a total comprising principal and interest components – Overrules High Court's reliance on SL Arora and upholds Hyder Consulting and UHL Power judgments [Paras 40-44].

Interest Award – Judicial Review Scope – High Court’s Interference with Arbitral Award Unjustified - Division Bench erred in interfering with a well-reasoned arbitral award in absence of manifest illegality – Tribunal had discretion under Section 31(7) and exercised it judiciously – Supreme Court restores award in full [Paras 36, 45-46].

Civil Law - Andhra Pradesh Land Grabbing (Prohibition) Act, 1982 - Land Grabbing – Scope of 'Land Grabbing' and 'Land Grabber' – Interpretation of AP Land Grabbing Act – Criminal Intent Not Mandatory - Under the Act, both narrow and broad meanings of "grab" apply – While mens rea is not always required, unlawful and unauthorized possession or creation of third-party interests suffices – The Court affirmed that the statute covers even non-violent and non-criminal encroachments when done without lawful entitlement [Paras 5-7].

Land Ownership Dispute – Survey Number Mismatch – Registered Titles in Different Survey Numbers – Appellant's Claim Rejected - The appellant claimed title under Survey No. 10 while the land in possession was confirmed by the Commissioner’s report to fall under Survey No. 9 – Held: Possession was unauthorized; appellant failed to rebut the presumption of land grabbing after respondent established prima facie title [Paras 9-12].

Adverse Possession – Lack of Proof of Hostile Possession – Claim Denied - Appellant's claim of adverse possession failed due to absence of proof regarding the start and continuity of hostile possession – Respondent's prompt objection through cooperative society proceedings disproved the claim of adverse, uninterrupted possession [Paras 16].

Jurisdiction and Nature of Proceedings under the Land Grabbing Act – Special Court's Summary Powers Upheld – No Procedural Illegality - Special Court has both civil and criminal jurisdiction – Proceedings follow principles of natural justice and are based on CPC – Burden of proof shifts upon prima facie evidence by complainant – No prejudice caused to appellant due to this scheme [Paras 13-15].

Final Decision – Dismissal of Appeal – Special Court and High Court Findings Affirmed - The Supreme Court found no merit in the appeal – Observed that the appellant failed to rebut the evidence and presumption raised – Appeal dismissed, upholding the findings of the courts below [Paras 17-18].

Civil Law - Arbitration and Conciliation Act, 1996 - Arbitration Clause – Interpretation of Dispute Resolution Clause – Article 20 of Concession Agreement – Arbitration Denied – The Supreme Court examined whether Article 20 of the Concession Agreements executed between Municipal Corporations of Delhi and private contractors constituted a valid arbitration agreement – Held: The clause contemplated a mediation process led by the Commissioner, lacked mutual appointment of an arbitrator, did not satisfy the requirements under Section 7 of the Arbitration and Conciliation Act, 1996, and hence could not be treated as an arbitration clause – Textual references such as “final and binding” were not enough to qualify the process as arbitration in absence of intent, neutral adjudicator, and adversarial procedure [Paras 14-51].

Finality of Decision – Not Indicative of Arbitration – Language referring to decisions as “final and binding” in Article 20 was held insufficient to imply arbitration where the mechanism remained internal and non-judicial – Such decisions can be departmental or administrative in nature and do not imply submission to an arbitral tribunal under the Act [Paras 39-41].

Judicial Censure – Drafting of Arbitration Clauses – Observations on Ambiguity – The Court expressed strong concern over ambiguously drafted dispute resolution clauses that prolong litigation instead of facilitating resolution – It called upon legal practitioners to ensure clarity and warned against professional conduct that leads to unnecessary judicial burden – It emphasized the need for accountability and judicial proactivity in rejecting unclear arbitration provisions [Paras 53-59].

Decision – Appeals Disposed – Article 20 is Not an Arbitration Clause – Judgments of High Court in SMS Ltd. and CCC Ltd. cases set aside – Judgment in DSC Ltd. upheld – Parties permitted to pursue alternative legal remedies [Paras 60-61].

Criminal Law - Dowry Death – Applicability of Section 304-B IPC – Conviction Upheld – The deceased died an unnatural death within 1 year and 4 months of marriage due to traumatic brain injuries – Consistent testimonies from father and brothers of the deceased established dowry harassment and monetary demands by the accused-husband – Held: Essential ingredients of Section 304-B IPC were fulfilled; conviction proper [Paras 27-30, 39].

Presumption under Evidence Act – Section 113-B – Failure to Rebut – Presumption Drawn – Once prosecution proved harassment and unnatural death soon before death, burden shifted to the accused to rebut presumption – Defence of depression due to knee pain and alternate theories of suicide or accidental fall were rejected as unsubstantiated and contradictory – Held: Presumption under Section 113-B validly invoked; defence theories not credible [Paras 20-22, 28, 31, 34-36].

Medical Evidence – Post-Mortem via Affidavit – Curable Irregularity – Medical Officer's Affidavit Accepted – Though medical evidence was recorded by affidavit contrary to Section 296 CrPC, the defence cross-examined the doctor and did not object – Held: No prejudice caused; post-mortem proved cause of death as traumatic head injury due to mechanical violence [Paras 23-26].

Contradictory Defence – Inconsistencies in Accused's Explanation – Defence Rejected – The accused alternated between claiming accidental fall and suicide due to medical condition – Neither theory matched facts including the location of the body and the timing of distress calls – Held: Defence concocted; does not displace prosecution's case [Paras 28-29, 35-36].

Demand for Money for Job – Treated as Dowry – Dowry Demand Proved – Accused demanded Rs. 5 lakhs from deceased’s father to secure employment – Rs. 50,000 was paid; harassment continued thereafter – Held: Such demand, linked to marriage, qualifies as dowry under law [Paras 16-17, 22, 30].

Final Decision – Appeal Dismissed – Conviction and Sentence Affirmed – No infirmity found in reasoning of Trial or High Court – Accused-appellant directed to surrender and serve remaining sentence [Paras 40-42].

Employment Law - Public Employment – Format of Caste Certificate – Format compliance mandatory – Rejection of candidature upheld – Petitioners submitted OBC-NCL certificates in Central Government format rather than in the format required by the State of Uttar Pradesh – Clause 5.4(4) of recruitment advertisement clearly specified the required format and the consequence of non-compliance – Held: Non-submission in the prescribed State format rendered petitioners ineligible for OBC reservation – Authority acted within jurisdiction by excluding petitioners from consideration under OBC category [Paras 14–17].

Recruitment Rules – Non-discretionary application – Procedural fairness does not override explicit requirements – Plea that the Board should have granted a chance to correct the certificate format rejected – Held: Opportunity already existed at the time of application – Procedural fairness does not mean condoning clear procedural defaults – Equal treatment requires adherence to rules by all [Paras 19–21].

Judicial Review – Limited role of Courts – No interference when recruitment norms are unambiguous – Held: Recruitment authority is entitled to frame and implement rules unless proven to be arbitrary or violative of constitutional rights – Courts will not dilute terms of advertisement by equitable considerations unless warranted by exceptional circumstances [Paras 19–20].

Article 141 – Precedent – Summary dismissal of SLPs does not constitute binding law – Reference to previous reliefs granted to similarly situated candidates not helpful – Held: Dismissal of Special Leave Petitions in limine without reasons does not have precedential value – Does not create binding precedent under Article 141 of the Constitution [Para 23].

Decision of the Court – Appeals decided accordingly – Civil Appeal No. 5233 of 2025 (Mohit Kumar) dismissed – Civil Appeal No. 5234 of 2025 (State of U.P.) allowed – Held: Requirement of caste certificate in prescribed State format is justified and non-arbitrary – Rejection of candidature sustained [Paras 24–25].

Arbitration – Objection on Jurisdiction – MP Act Applicability Raised Late – Award Restored – The respondent failed to object to the jurisdiction of the arbitral tribunal during arbitration or in initial Section 34 petition – Only after the L.G. Chaudhary (II) decision was such a ground introduced – Held: In line with precedent, an award cannot be annulled solely on jurisdictional ground if no such plea was raised at the relevant stage – Award restored [Paras 6–9, 36–40].

Jurisdictional Plea – Not Raised Under Section 16 – Considered Waived – In absence of timely objection under Section 16 of the Arbitration Act, a jurisdictional plea is deemed waived – No valid reason shown to excuse delay in raising such a plea – Held: Respondent cannot be permitted to approbate and reprobate – High Court’s annulment of award erroneous [Paras 27–35, 39–41].

L.G. Chaudhary (II) vs. Lion Engineering – No Real Conflict – Limited Exception Carved – While Lion Engineering allows legal pleas on jurisdiction in Section 34, L.G. Chaudhary (II) clarified that MP Act applicability raised post-award without earlier objection will not annul the award – Held: L.G. Chaudhary (II) not per incuriam, reflects conscious carving of exception due to earlier inconsistent precedents [Paras 18–23, 36–37].

Decision – Civil Appeal Allowed – Arbitral Award Restored – High Court’s annulment set aside – Matter remanded to Commercial Court to adjudicate other Section 34 objections without disturbing the award on ground of jurisdiction – Held: MP Act objection cannot be raised post-award without prior challenge [Paras 40–41].