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or allotting forest land without Central Government approval – High officials bypassed this requirement citing an outdated precedent – Held: Such actions were contrary to statutory mandate and Supreme Court's binding orders, rendering the allotment void ab initio [Paras 22-38].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].

Civil Law - Commercial Suit – Section 12A of Commercial Courts Act – Mandatory Nature – Rejection of plaint not justified – The suit was filed in 2019 without pre-institution mediation as mandated by Section 12A of the Commercial Courts Act – Relying on the prospective applicability of the Patil Automation decision, the Court held that suits filed prior to 20.08.2022 are not liable for rejection under Order VII Rule 11 CPC – Held: Rejection of plaint was unjustified; the High Court rightly directed the matter for mediation [Paras 5-13, 34-38, 46-48].

Doctrine of Prospective Overruling – Application to Section 12A Compliance – Relief sustained – The Court affirmed that the mandate laid down in Patil Automation applies prospectively – It ruled that suits instituted prior to 20.08.2022 without pre-institution mediation cannot be dismissed solely on that ground – The rejection would otherwise result in hardship and procedural prejudice [Paras 47-48, 54].

Urgent Interim Relief – Interpretation under Section 12A Proviso – Non-Applicability in Facts – The Court clarified that the proviso to Section 12A permitting bypass of mediation only applies where urgent interim relief is sought – In the instant case, no such relief was prayed – However, since the suit was instituted before the enforcement of the mandate, rejection was not warranted [Paras 35, 42-45].

Infrastructure Deficiency – Principle of Lex Non Cogit Ad Impossibilia – Applied in Favour of Appellant – The Court acknowledged that mediation infrastructure was lacking at the time of suit filing – Applied equitable maxim that law does not compel a man to do the impossible – Held: Procedural lapse excused in view of institutional shortcoming [Paras 15, 18-19, 49-53].

Decision – Appeal Dismissed – High Court Order Affirmed – The Supreme Court upheld the High Court’s direction to keep the suit pending and refer the matter for pre-institution mediation – Held: The approach of the High Court was proper and the appeal warranted no interference [Paras 4, 26, 55].

Motor Accident Claim – Liability of Insurer – Duty limited to monetary compensation – High Court’s directive for lifetime support set aside – The High Court directed the insurer to provide prosthetic limbs, motorized wheelchair, travel expenses, and ensure ongoing support – Held: Insurer’s statutory role is limited to indemnifying loss in monetary terms, and not to maintain lifelong support infrastructure – Directions contrary to statutory framework and unsustainable [Paras 2-4, 6].

Compensation – Disability and Future Needs – Additional Rs.12 lakhs awarded – Expenses quantified for future wellbeing – The victim suffered 100% functional disability due to loss and impairment of both lower limbs at age 22 – Held: A prosthetic limb costing approx. Rs.2 lakhs, replaced every 5 years, and wheelchair costing Rs.40,000 require long-term provision – Court awarded Rs.12 lakhs with 6% simple interest to cover future expenses and mobility needs [Paras 5, 7-8].

Appeal by Insurer – No bar on grant of just compensation – High Court’s enhancement restructured – Though the appeal was filed by the insurer and not the claimant, the Supreme Court upheld the right to restructure compensation in monetary terms, in lieu of specific services previously directed – Held: The Court is merely converting non-monetary directions into quantified award and not increasing compensation beyond High Court’s intent [Paras 8-9].

Final Directions – High Court Order Set Aside – Award modified and appeal disposed – The Supreme Court set aside the High Court’s directions and substituted them with quantified compensation payable within two months – Directions given to respondent to furnish account details for online transfer – Pending applications also disposed [Paras 9-12].

Civil Law - Electricity Act - Jurisdiction of CERC – Powers under Section 79 – Regulatory Order Valid – Held: CERC has dual functions of regulation and adjudication – Even in absence of regulations under Section 178, CERC is empowered to regulate tariff matters between parties under Section 79 – Grant of liberty to claim compensation falls within such regulatory scope [Paras 43-48, 60-63].

Maintainability of Writ Petition – Alternative Remedy Available – Writ Petition Improperly Admitted – The High Court entertained the writ despite availability of appellate remedy under Section 111 – No violation of natural justice, no constitutional question involved, and no lack of jurisdiction shown – Held: High Court erred in applying Whirlpool exception – Writ petition was not maintainable [Paras 64-66].

Compensation for Delay – Transmission Charges – Regulatory Function Not Adjudication – CERC’s direction to allow appellant to claim transmission charges for unutilized assets due to respondent’s delay addressed a regulatory gap – Such order was not an adjudication on liability, but regulation to fill a lacuna in the 2014 Tariff Regulations – Held: Ad hoc regulatory action permissible and valid [Paras 55-60].

Decision – Appeals Allowed – Writ Petitions Dismissed – Supreme Court set aside the High Court’s order admitting the writ petitions – Clarified that respondent may raise factual challenge on merits before APTEL if it chooses to appeal – No determination on actual liability was made [Paras 65-66].

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 Law - MSMED Act vs. Arbitration Act – Statutory Override – Appeal Allowed - The Court held that arbitration proceedings under Section 18 of the MSMED Act override contractual arbitration clauses, including those specifying seat and venue – MSMED Act being a special legislation prevails over the Arbitration Act – Arbitral jurisdiction validly exercised by Delhi Facilitation Council and Delhi Arbitration Centre despite agreement specifying Bengaluru as the seat – Karnataka High Court’s contrary finding set aside [Paras 2, 8–10, 13].

Arbitration – Jurisdiction of Facilitation Council – MSME Location Determinative – Appeal Allowed - The Court reaffirmed that under Section 18(4) of the MSMED Act, the jurisdiction for arbitration is determined by the location of the MSME supplier – The appellant being located in Delhi conferred valid jurisdiction on the Delhi Facilitation Council – Appointment of arbitrator through Delhi Arbitration Centre upheld [Paras 10–11].

Contractual Clause – Cannot Override Statutory Mechanism – Appeal Allowed - Clauses in the agreement stipulating Bengaluru as the seat of arbitration were held ineffective once the statutory scheme of MSMED Act was invoked – The overriding effect under Section 24 and the non-obstante clauses in Section 18(1) and 18(4) made the private agreement subordinate to statutory mandate – High Court’s reliance on contractual seat rejected [Paras 6, 9].

Decision – High Court Order Set Aside – Arbitration to Proceed in Delhi - The Supreme Court set aside the order dated 22.04.2024 of the Karnataka High Court – Directed arbitration to continue under Delhi Arbitration Centre as initiated by the Delhi Facilitation Council – Merits of the dispute left open for determination by the arbitrator [Paras 12–14].

Custom Law - Customs Exemption – Administrative Circular Cannot Override Statutory Notification – Appeal Allowed - The Supreme Court held that Circular No. 10/2004-Cus., which expanded the scope of excluded goods under Notification No. 53/2003-Cus., was legally unsustainable – Such a circular cannot add conditions or restrict exemptions granted by a statutory notification under Section 25 of the Customs Act – Held: Circular had no legal consequence and could not deny exemption to crude degummed soyabean oil [Paras 30–36, 58(i)].

Manufacture – Crude Degummed Soyabean Oil is Distinct Product – Not Agricultural – Appeal Allowed - The Court found that the process to extract crude degummed soyabean oil from soyabean constituted ‘manufacture’ resulting in a distinct, marketable product – Rejected the High Court’s view that crude oil retained the identity of soyabean – Held: Crude degummed soyabean oil is not an agricultural product and thus not excluded from exemption under Notification No. 53/2003 [Paras 40–57, 58(ii)-(iv)].

EXIM Policy – Entitlement Under Duty-Free Scheme – Benefit Restored – Appeal Allowed - The appellant, a recognized status holder, was entitled to duty-free import benefit under the 2002–2007 EXIM policy – Import through MMTC and the classification under Chapter 15 supported their claim – Demand of duty by Customs and High Court’s order upholding it were both quashed [Paras 5–8, 58(v)–60].

Electricity Act – Connection Agreement and Liability – Sole Responsibility of Applicant – Appeal Allowed - The Supreme Court held that under the Connection Agreement dated 02.07.2021, BHP Ltd., as the sole applicant, bore full liability to HPPTC Ltd. for Bay construction and O&M charges – Respondents No. 2 and 3, not being parties to the agreement, could not be held contractually liable by HPPTC Ltd. – Any recovery from these parties was BHP Ltd.'s internal matter governed by a separate Internal Tripartite Agreement – The Appellate Tribunal for Electricity erred in holding otherwise [Paras 21–24, 28–30].

Doctrine of Privity – Applicability to Electricity Transmission Contracts – Third Parties Not Liable – Appeal Allowed - The Court reaffirmed that under the doctrine of privity, parties not signatory to a contract (Respondents 2 and 3) could not be held liable by a party (HPPTC Ltd.) for obligations under said contract (Connection Agreement), even if they benefitted from its execution – Tribunal’s reasoning failed to consider this foundational contractual principle [Paras 26–29].

Decision – APTEL Order Set Aside – State Commission Order Restored - The Supreme Court set aside the judgment of the Appellate Tribunal for Electricity dated 17.03.2023 – Restored the Himachal Pradesh State Electricity Regulatory Commission’s Order dated 27.12.2022 – Appeal by HPPTC Ltd. allowed with no order as to costs [Paras 30–31].

Criminal Law – Quashing of FIR – Appellants, members of a political party, sought quashing of FIR registered under Section 3(1) of the UP Gangsters & Anti-Social Activities (Prevention) Act, 1986 – FIR dated 30th April, 2023, based on a prior incident dated 10th October, 2022, wherein appellants were already booked under IPC Sections 147, 148, 149, 427, 307, 323, 504, 506 and Section 7 of Criminal Law Amendment Act – High Court dismissed the writ petition seeking quashing – Supreme Court held that invocation of UP Gangsters Act was unwarranted in absence of any subsequent criminal activity between the first FIR dated 11th October, 2022, and the gang chart prepared on 29th April, 2023 – No evidence of organized crime, habitual behavior, or intent to gain undue advantage [Paras 3, 4, 5, 9, 14, 16, 19, 20, 22, 29, 30].

Gangsters Act – Applicability – Definition of ‘Gang’ under Section 2(b) requires a group engaged in anti-social activities with objective of disturbing public order or gaining undue pecuniary, temporal or material advantage – FIR merely refers to a single protest incident triggered by an inflammatory post on religion – No evidence of hierarchical structure, systematic planning or continuity of criminal acts – Held, appellants' participation in spontaneous protest does not constitute membership of a gang under the Act – Invocation of the Gangsters Act was colorable exercise of power [Paras 11, 12, 14, 16, 17, 18, 22, 25].

Mala Fide Intention – Political Vendetta – Registration of FIR under the Gangsters Act occurred just days after appellant’s family member filed nomination for Nagar Panchayat elections – Appellants had filed a prior representation anticipating false implication – Supreme Court observed that FIR appeared politically motivated and a misuse of statutory powers [Paras 5.4, 21, 24].

Constitutional Safeguards – Personal Liberty – Court reiterated that extraordinary statutes abridging procedural safeguards must be invoked with strong evidentiary foundation – Absence of fresh criminal conduct or continuing threat rendered invocation of Gangsters Act arbitrary and violative of Article 21 of the Constitution – Procedural fairness underlined as essential [Paras 23, 24, 25].

Decision: Appeal allowed – Judgment of High Court set aside – FIR dated 30th April, 2023, and all consequential proceedings quashed – Pending proceedings in earlier FIRs CC No. 294 of 2022 and CC No. 296 of 2022 to continue unaffected – Pending applications disposed of [Paras 29, 30, 31, 32].