Service Law -  Reserved Category Migration – Standing Orders 78 & 85 – Revised Directive No. 29 – DoPT OMs – Two Appeals – Reserved candidates who availed relaxation in age/physical measurements sought migration to UR vacancies – High Courts allowed – Held: Standing Order 85 (Clause 14(f)) bars such migration, overrides Standing Order 78 – DoPT OM does not treat physical standards (height/weight) as “relaxed standard” akin to age/qualification – Appeals decided accordingly – [Paras 8–19, 13–18 of second appeal].

RPF Ancillary Recruitment – Standing Order 85 Prevails – Appeal Allowed – Candidates who availed relaxation in age/physical standards cannot migrate to UR seats even if they scored higher than UR cut-off – Standing Order 85 (Clause 14(f)) partially modified Standing Order 78, creating embargo – HC erred in applying Jitendra Singh v. State of U.P. – Judgment set aside – [Paras 13–19].

CISF Assistant Commandant Recruitment – Physical Standards – Appeal Dismissed – DoPT OM dated 01.07.1998 bars migration only if relaxed standards in age, qualifications, experience etc. were availed – Does not cover physical standards like height/weight varying by gender/ethnicity – Reserved candidate with relaxed height still entitled to be counted against UR seat if merit higher – HC view upheld – [Paras 7–13].

Distinction – Relaxation in Age/Qualification vs. Physical Standards – Legal Principle – Relaxed standards in age/qualification/attempts are “eligibility relaxations” disqualifying migration – But differential physical standards are contextual and not covered under OM – Hence no embargo on migration in such cases – [Paras 12–13, 17–18].

Decision – Civil Appeal arising from SLP (C) No. 20866/2019 (RPF case) allowed – HC judgment dated 29.03.2019 set aside – Reserved candidates who availed relaxation barred from UR seats – Civil Appeal arising from SLP (C) No. 28469/2019 (CISF case) dismissed – HC judgment dated 27.08.2019 upheld – Reserved candidate availing relaxed height permitted to occupy UR seat – Pending applications disposed of – [Paras 19–20, 14].

Tenancy Law  – Karnataka Rent Act – Eviction – Landlord-Tenant Relationship Dispute – Sections 27(2)(a),(e),(g),(o) and 43 – Appeal Allowed – Landlord filed eviction; Rent Controller allowed based on rent receipts; HC reversed citing lack of proof of ownership – Held: Rent Controller rightly proceeded once rent receipts acknowledged; title dispute outside Rent Controller’s scope – HC exceeded revisional jurisdiction – Order of Rent Controller restored – [Paras 3–11].

Landlord-Tenant Relationship – Prima Facie Proof – Section 43 – Rent receipts signed by landlord serve as prima facie evidence of relationship – Once produced, Rent Controller must proceed with hearing – Only when no receipts/lease or documents are doubtful, parties must be relegated to civil court – [Paras 6–8].

Scope of Revisional Jurisdiction – High Court’s Interference Improper – Revisional Court cannot re-appreciate evidence or embark on fact-finding – High Court erred in rejecting jural relationship by questioning landlord’s lineage/title – [Paras 9–11].

Decision – Appeal allowed – Judgment of Karnataka High Court dated 31.03.2021 set aside – Order of Rent Controller dated 01.09.2017 directing eviction restored – Pending applications dismissed – [Para 11].

Insolvency & Bankruptcy Code (IBC) – Homebuyers’ Claims – Resolution Plan – Appeal Allowed – Appellants booked flat in 2010, paid nearly entire consideration; Corporate Debtor (IREO) went into CIRP; claim submitted and admitted by Resolution Professional – NCLT and NCLAT held claim was belated, granted only 50% refund – Held: Once claim is verified and reflected in creditors’ list, cannot be relegated to residual category – Appellants entitled to possession – [Paras 28–37, 39–42].

Homebuyers – Verified Claims – Binding Effect – Once a claim is verified, admitted, and published in creditors’ list, it acquires full legal recognition – To disregard such claims undermines CIRP fairness – Clause 18.4(ii) read with (vi)(a) governs; Clause 18.4(xi) applies only to unverified or uninformed claims – [Paras 32–36].

Resolution Plan – Distinction Between Verified and Belated Claims – Clause 18.4 draws clear lines – Verified claims must be honoured; only unverified/belated ones fall to refund – Misapplication by NCLT/NCLAT corrected – [Paras 34–37].

Equitable Consideration – Protection of Homebuyers – Court emphasised hardships of individual buyers investing life savings – Relegating them to refund despite admitted claims runs contrary to IBC framework – [Para 38].

Decision – Judgment of NCLAT (10.01.2025) and NCLT (26.07.2023) set aside – Respondents directed to execute conveyance deed and hand over possession of Apartment No. GBD-00-001, Block D, IREO Rise (Gardenia), Mohali, within two months – Appeal allowed – No order as to costs – [Paras 39–42].

Section 125 of the Electricity Act - Change in Law – Pro rata allocation of coal – Sections 62 & 63, Electricity Act – Appeals dismissed – Challenge to APTEL order upholding CERC’s direction that coal supplied under firm and tapering linkage is for the station as a whole and costs of alternate coal (import/open market) due to shortfall be apportioned pro rata based on energy supplied – Held: Allocation under SLC-LT approvals/LOAs and FSA terms is plant-wide and not PPA-specific – Haryana Utilities and GRIDCO cannot claim exclusivity or priority – CERC’s methodology sustained – Appeals dismissed [Paras 31–34, 40, 45–46].

Section 125 Electricity Act – Scope confined to substantial question of law via Section 100 CPC – Judicial restraint over concurrent expert findings – Two expert bodies (CERC and APTEL) rendered concurrent, reasoned findings based on documents and policy – No perversity, arbitrariness, or statutory breach shown – Interference unwarranted [Paras 18–25].

Fuel Supply Agreements and SLC-LT decisions – Interpretation – FSA Clause 4.1.1 ties ACQ to percentage of generation under long-term PPAs – Clause 4.2 earmarks coal “for use at Power Plant (3x350 MW)” – SLC-LT minutes (14.02.2012) and LOAs (25.07.2008 and 08.07.2009) demonstrate station-level allocation including tapering linkage for all three beneficiaries – MCL clarifications confirm coal release against total PPA capacity, not segregated PPA-wise [Paras 31–33, 35].

Appropriation claim rejected – Haryana’s contention that its 300 MW must be met entirely from firm linkage and that tapering/imported coal costs fall on GRIDCO/Bihar rejected – Such reading is contrary to plant-wide allocation, would disadvantage Odisha/Bihar consumers, and violates parity among equals – Pro rata allocation avoids cross-subsidy and aligns with Energy Watchdog [Paras 32–34].

Necessary and proper party – GRIDCO not necessary party in Section 63 Change in Law proceedings – Its PPA is under Section 62 (cost-plus) with tariff determined separately – Proceedings under Sections 62 and 63 are distinct – Non-impleadment did not vitiate CERC orders – GRIDCO’s priority claim based on earlier PPA execution/COD untenable in face of plant-wide allocation [Paras 41–45].

Judicial deference to sectoral expertise – Court reiterates restraint where expert bodies have applied regulations/policy following stakeholder processes – Unwarranted appeals impose carrying costs ultimately borne by consumers – Need to curb such litigation emphasized [Paras 19–23].

Decision – Civil Appeal No. 1929 of 2020 (Haryana Utilities) and Civil Appeal No. 3429 of 2020 (GRIDCO) dismissed – APTEL judgment dated 20.12.2019 upholding CERC order dated 20.03.2018 affirmed – Payment of supplementary bills with late payment surcharge as per PPA sustained [Paras 40, 45–46].

Review Jurisdiction – Scope under Section 114 and Order 47 CPC – Review Order Quashed – The Appellant sought amendment of a preliminary decree to claim her rightful share as a coparcener after the 2005 Amendment to the Hindu Succession Act – The Trial Court dismissed the plea; High Court initially allowed the revision, recognising her 1/3rd coparcenary right – In a subsequent review, the High Court reversed its prior order and remanded the matter for fresh trial – Held: The review order went beyond the permissible scope under Order 47 Rule 1 CPC by reassessing facts and reaching fresh conclusions – Review jurisdiction is limited to correcting apparent errors, not reappreciating evidence or substituting views – The High Court's review amounted to an appeal in disguise and was unsustainable [Paras 13–20].

Coparcenary Rights of Daughters – Retrospective Application of HSA 2005 – Right Recognised – Appellant, being a daughter of a coparcener alive at the time of commencement of HSA 2005, is entitled to equal share – The original preliminary decree was passed ex parte and without impleading her – She has a legitimate claim to 1/3rd share and additional share through a will – Her right is not barred by estoppel or limitation – Held: Daughter’s coparcenary right is birthright and enforceable even after preliminary decree, as final decree was yet to be passed [Paras 3–7, 10].

Jurisdictional Overreach – Review vs. Appeal – Error of Law – The impugned review order failed to identify any “error apparent on the face of the record” and instead conducted a re-evaluation of the entire case – Held: Such exercise falls outside the scope of review jurisdiction – Review order set aside; order in CRP dated 23.09.2022 restored [Paras 15–19].

Final Decision – Appeal allowed – High Court’s review order dated 19.10.2024 set aside – Order dated 23.09.2022 in CRP No. 1439 of 2019 restored – Trial Court directed to dispose of pending applications within three months [Para 20].

Anticipatory Bail – Modification of Conditions – Judicial Propriety – Respondent No. 1 accused in 31 criminal cases involving serious financial offences under IPC and BUDS Act – High Court granted anticipatory bail subject to condition not to leave India without prior permission – During pendency of SLP challenging said bail order, respondent filed application before High Court seeking permission to travel abroad – High Court allowed modification and released passport without disclosing to Supreme Court that such relief had been sought – Held: Conduct of respondent undermines judicial discipline and violates comity between courts – All orders passed by High Court modifying bail conditions during pendency of SLP stayed [Paras 1–11].

Judicial Discipline – Hierarchical Judicial System – Supreme Court emphasized that though High Courts are not subordinate, once a matter is under challenge and seized by the Supreme Court, High Courts must exercise restraint from modifying or passing orders that may prejudice pending proceedings – Reference made to Tirupati Balaji Developers v. State of Bihar and Chhavi Mehrotra v. DGHS highlighting the need for deference and avoidance of parallel jurisdictional exercise [Paras 8–10].

Suppression and Misconduct – Respondent’s Failure to Inform Supreme Court – Though respondent filed application before High Court on 06.07.2025, no disclosure made to Supreme Court when case was listed on 14.07.2025, 25.07.2025, and 25.08.2025 – Counter affidavit dated 14.07.2025 silent on application for modification – Held: Court expresses grave displeasure and issues notice to respondent as to why pre-arrest bail should not be cancelled due to concealment [Paras 12–13].

Interim Directions – Respondent No. 1 restrained from leaving India without permission of Supreme Court – Directed to surrender her passport immediately – Response to show-cause notice to be filed within three weeks with relevant documents [Paras 13–15].

Decision: Orders passed by High Court in Crl.MC No. 6178/2025 and Crl.M.A. No. 1/2025 modifying bail conditions stayed – Show cause notice issued to respondent regarding cancellation of anticipatory bail – Case listed for further orders on 26.09.2025.

Motor Accident Claim – Causal Connection Between Accident and Death – Claim Rejected - The deceased, an Excise Guard, died of pulmonary embolism five months after sustaining leg and finger fractures in a road accident – Supreme Court upheld High Court’s finding that there was no proximate or direct causal link between the accident and death – Held: Death not attributable to accident injuries; post-surgical complications with pre-existing diabetes and hypertension more likely cause [Paras 1-11].

Expert Evidence – Doctor’s Testimony Inconclusive – Medical Opinion Favoured Natural Cause - PW-1, the plastic surgeon, opined the death was due to myocardial infarction, and though stated long bed rest could trigger embolism, he admitted to no post-mortem and acknowledged cardiac risk factors – Held: Absence of conclusive medical evidence and lack of post-mortem weakens claimants’ case; expert's deposition supported natural medical cause [Paras 6-7].

Preponderance of Probability – Not Established – No Clear Nexus Between Injury and Death - Supreme Court reiterated that even in civil cases requiring lesser standard of proof, the causal connection must meet preponderance of probability – Held: Injuries were not serious; death occurred after successful skin grafting – No evidence of extended immobility or bed rest [Paras 8-11].

Final Disposition – High Court Judgment Affirmed – Claim for Death Compensation Denied - Tribunal’s finding of causality reversed by High Court based on medical evidence – Supreme Court declined to interfere, holding the reasoning sound and based on expert medical testimony – Held: No compensation payable for death; claimants still entitled to compensation for injuries [Paras 11-12].

Anticipatory Bail – Modification During SLP Pendency – High Court's Jurisdiction Restrained – Stay Issued - The petitioners challenged the anticipatory bail granted to respondent no. 1 in 31 criminal cases related to financial fraud – Despite pendency of SLP, the High Court permitted modification of bail condition allowing travel abroad – Held: Such modification during pendency of appeal before Supreme Court is impermissible and violates judicial discipline – Orders dated 12.08.2025 and 23.08.2025 stayed [Paras 1-11].

Judicial Discipline – High Court Should Exercise Restraint During Pendency of SLP – Doctrine Clarified – Supreme Court reiterated that once an SLP is admitted and notice issued, High Courts must not pass orders that may circumvent or frustrate the proceedings before the apex court – Held: Proper administration of justice demands mutual respect between courts in a hierarchical system – Precedents from Tirupati Balaji Developers and Chhavi Mehrotra relied upon to reinforce judicial propriety [Paras 8-10].

Concealment of Material Facts – Conduct of Accused Under Scrutiny – Show Cause Issued - Respondent No. 1 failed to inform the Supreme Court of filing applications before the High Court for modification of bail terms – Affidavit filed before Supreme Court omitted this material fact – Held: Court expressed grave displeasure and issued notice to explain why anticipatory bail should not be cancelled for suppression of facts [Paras 12-13].

Passport and Travel Restriction – Interim Direction – Supreme Court Mandates Compliance - In view of pending investigation in 31 criminal cases, the Court directed respondent no. 1 to immediately surrender her passport and not to leave India without prior permission – Held: Travel restriction reinstated pending further hearing [Para 15].

PIL - Anand Karaj marriages—Section 6, Anand Marriage Act—States/UTs directed to notify rules within 4 months—Till then, registration to be facilitated under existing marriage registration frameworks without discrimination—Union of India to coordinate and file compliance report—Petition disposed with time-bound directions [Paras 11–16].

Constitutional Duty – Registration of Marriages – Section 6 of the Anand Marriage Act imposes a positive duty on States to establish registration machinery for Anand Karaj marriages – Duty not optional or contingent on population size – Non-notification frustrates legislative intent of 2012 amendment [Paras 7–8].

Civil Consequences of Registration – Marriage certificates enable proof of status for residence, maintenance, inheritance, succession, and enforcement of monogamy – Particularly safeguard rights of women and children – Unequal access across jurisdictions violates equal treatment [Para 9].

Harmonisation with Existing Frameworks – Until rules are notified, general marriage registration frameworks must accept Anand Karaj marriages on the same footing as other marriages – Certificate to record that marriage was solemnised by Anand Karaj where parties so request [Para 10].

General Directions – (i) All States/UTs without rules to notify within 4 months; (ii) immediate registration under existing laws without discrimination; (iii) States with rules to issue clarifications within 3 months; (iv) Nodal officer to be designated within 2 months; (v) Union of India to coordinate and circulate model rules, and file consolidated status report in 6 months [Para 12].

Special Directions – Goa: Interim registration under civil registration offices; Union to extend Anand Marriage Act within 4 months; Goa to frame rules within 4 months thereafter [Para 13]. – Sikkim: Interim registration under 1963 Rules; Union to consider extension under Article 371F(n); Sikkim to notify rules within 4 months after extension [Para 14].

Decision – Writ petition disposed of with directions—Time-bound rule-making mandated—Interim facilitation under existing frameworks ordered—Compliance affidavits to be filed by States/UTs; Union to file consolidated status report in 6 months [Paras 15–16].