Arbitration Law  – Scope of Judicial Review under Section 11 – Confined to Existence of Agreement – High Court Erred – Supreme Court reaffirmed that under Section 11(6A) of the Arbitration Act, courts are confined to examining the existence of an arbitration agreement – Determining arbitrability of individual claims is beyond this scope – Any issue of non-arbitrability should be left for the arbitral tribunal – High Court’s exclusion of certain claims held to be erroneous [Paras 6-12].

Excepted Matters – To Be Considered by Tribunal, Not Court at Appointment Stage – Exclusion Set Aside – High Court excluded claims based on contract clauses 50 and 50.2 as “excepted matters” – Held: This was premature and not permissible under Section 11 – Parties may raise such objections before tribunal, which will decide independently [Paras 3, 12-13].

Precedents – Preference for Larger Bench Decisions – Emaar India Overruled by Later Three-Judge Decision – Court held that reliance on Emaar India Ltd. v. Tarun Aggarwal Projects LLP (2023) was misplaced – A more recent three-judge bench in SBI General Insurance v. Krish Spinning (2024 INSC 532), applying In Re: Interplay (2023 INSC 1066), clarified that only prima facie existence of arbitration agreement is to be tested – Jurisdictional limits under Section 11 reaffirmed [Paras 10-12].

Decision – Appeal Allowed – Arbitration to Proceed on All Claims – Supreme Court set aside part of High Court’s order that excluded claims in para 48(ii)-(iv) of claim petition – Held: Tribunal to decide arbitrability without being influenced by High Court’s findings – No costs awarded [Para 13].
 

Limitation Law - Delay Condonation – Re-litigation on Identical Grounds – Delay Not Condoned – Respondents' explanation for 1116 days delay in filing appeal under Order XLI CPC was previously adjudicated under Order IX Rule 13 CPC and dismissed by High Court and Supreme Court – Re-urging same grounds held to be impermissible and an abuse of process – Repetition of insufficient cause cannot warrant fresh consideration under a different provision [Paras 27-30].

Applicability of Precedent – Misapplication of N. Mohan Case – Condonation Set Aside – High Court erroneously relied on N. Mohan v. R. Madhu (2020) 20 SCC 302 to condone delay – Distinguished on facts as defendants in present case had appeared, filed written statements, and later defaulted, unlike in N. Mohan where summons were not served – Hence, reliance misplaced [Paras 25-26].

Concurrent Remedies – Section 96(2) Appeal and Order IX Rule 13 Application – Not Mutually Exclusive but No Duplication of Grounds – Though legally maintainable to file appeal under Section 96(2) post Order IX Rule 13 rejection, same explanation for delay cannot be recycled without new material – Filing under another provision does not reset limitation clock without distinct cause [Para 30].

Limitation Law – Strict Interpretation – Generosity Not Permitted – Limitation law requires strict adherence and cannot be relaxed merely for equity – Absence of bona fide explanation bars condonation – Reference made to Popat Bahiru Goverdhane (2013) 10 SCC 765 and Maniben Devraj Shah (2012) 5 SCC 157 – Delay must be justifiable on record and not based on liberal approach [Paras 28-32].

Decision – Delay Not Justified – Appeal Allowed – Impugned High Court order dated 25.04.2023 condoning delay set aside – Civil Appeal allowed and delay condonation rejected – Appeal disposed with no costs [Paras 34-36].

Criminal Law - Inherent Powers of High Court – Section 482 CrPC – Improper Invocation – Order Reversed – High Court directed release of Rs. 15.90 lakhs in favour of respondent no. 2 despite ongoing investigation and charge sheet indicating need for further probe – Held: High Court exceeded jurisdiction under Section 482 by making findings on factual disputes and interfering with lower court orders when trial was pending – High Court’s order set aside [Paras 9-13].

Investigation Pending – No Premature Clean Chit – Charge Sheet Awaited Interrogation – The role of respondent no. 2 in fraud involving impersonation and share sale still under investigation – Main accused absconding – Held: Releasing sale proceeds would irreparably harm investigation and may prejudice the case – Matter remitted for trial [Paras 4-6, 11-12].

Superdari and Third-Party Funds – Disputed Beneficiary – Sale Value Not Released – Trial Court and Revisional Court refused release of withheld funds due to unresolved criminal liability – Held: Interim release of funds unjustified until conclusion of proceedings – Money to remain with BSE during pendency of trial [Paras 5, 6, 15].

Final Decision – Appeal Allowed – High Court Order Set Aside – No Observations on Merits – Trial Court directed to proceed expeditiously – Interim relief granted to appellant upheld [Paras 13-15].

Accident Claim - Compensation for Motor Accident – Assessment of Income – Reasonable Estimate for Unskilled Worker – Compensation Enhanced - The claimant, a 25-year-old unskilled worker, became bedridden due to an accident while traveling in his employer’s truck – Tribunal assessed income at Rs. 4,500 per month and awarded Rs. 16 lakhs – High Court enhanced income to Rs. 6,000 and compensation to Rs. 25.83 lakhs – Supreme Court applied the principle from Ramachandrappa and Pranay Sethi and accepted Rs. 9,000 as monthly income, applying 140% future prospects and a multiplier of 18 – Held: Loss of future income computed at Rs. 27,21,600, medical expenses of Rs. 2,70,000 and Rs. 6,00,000 for pain and suffering awarded – Total compensation Rs. 35,91,600 [Paras 2, 4-5].

Insurance Liability – Passenger in Goods Vehicle – Contention of Policy Exclusion Not Entertained – No Appeal by Insurer – The insurer argued policy exclusion for goods vehicle passengers – Held: Argument rejected as insurer did not challenge the Tribunal’s finding and no appeal was filed by the insurer – Supreme Court declined to entertain the contention in an appeal for enhancement filed by the claimant [Para 3].

Permanent Disability – Assessment Based on Medical Evidence – 100% Functional Disability Accepted - Medical expert testified disability at 90%, but functionally declared 100% disabled due to vegetative state – Doctor’s cross-examination did not discredit the evidence – Held: High Court right in treating disability as 100% functional for compensation purposes [Para 4].

Final Relief – Modification of Award – Interest and Disbursement Direction - Supreme Court allowed the appeal and modified the award – Directed disbursal of enhanced compensation with 8% interest after deducting previously paid amounts – Payment to be made to claimant's account within two months [Paras 6-7].

Criminal Law - Forgery of Court Record – Tampering After Conclusion of Proceedings – Section 195 CrPC Not Applicable – Appellant accused of fabricating and replacing court records in a civil suit after it was withdrawn – Documents were altered from the record room post-disposal – Held: Since forgery was committed after withdrawal of suit and documents were not in “custodia legis,” Section 195 CrPC does not apply – FIR and prosecution not barred [Paras 12-17].

Jurisdiction to Prosecute – Court's Power to Take Cognizance – Valid Despite Absence of Presiding Officer's Complaint – Appellant argued that no court complaint was filed under Section 340 CrPC – Supreme Court held that FIR was lodged at behest of High Court following vigilance inquiry and hence satisfies requirement under Section 340(3) – Filing by administrative authority valid in such context [Paras 11, 17].

Separate Offences – Distinction Between Pre- and Post-Proceeding Forgery – Alleged offences bifurcated into two: (1) tampering with suit records post-withdrawal, and (2) using forged decree in execution – Held: Tampering after case closure does not impact justice administration – Use of forged decree in execution also occurred prior to production, thus outside Section 195 bar [Paras 10, 13-14].

Misuse of Civil Process – Execution Petition Based on Fabricated Decree – Fraudulent Intent Evident – Appellant withdrew civil suit unconditionally but later filed execution petition based on falsified decree – Bogus documents inserted into record; cheques dishonoured – Court found clear intent to harass and extort money from defendant by fraudulent legal process [Paras 2-6, 12-15].

Decision – Appeal Dismissed – Criminal Proceedings Valid – High Court Ruling Affirmed – Supreme Court upheld High Court's refusal to quash FIR and proceedings – Held: Section 195 CrPC not a shield for post-proceeding forgery – Appeal dismissed as devoid of merit [Paras 18-19].

Civil Law – Tenancy Law - Interim Injunction – Conditions Not Fulfilled – Prima Facie Case Absent – Injunction Set Aside – Supreme Court held that High Court erred in granting interim protection to Respondent No.1 who claimed tenancy based on a family settlement – Question of his rights is sub judice – Respondent failed to establish prima facie title, balance of convenience, or irreparable harm – Interim injunction therefore unsustainable [Paras 15-17].

Ownership Rights – Absolute Owner's Development Cannot Be Blocked by Weak Claim – Balance of Convenience Favors Owner – Appellant, being absolute owner of 22,000 sq. ft., was restrained from redevelopment due to 550 sq. ft. claim – Court held this disproportionately affected owner’s commercial rights and obligations – Balance of convenience tilted toward appellant [Paras 16-17].

Claim Based on Family Settlement – Requires Trial – Not Ground for Interim Possession – Respondent No.1 claimed entitlement based on a mediated family settlement – Supreme Court observed that such claims involve factual disputes and require adjudication in trial – Injunction based solely on such claim not justified [Para 17].

Equitable Relief – Protection Granted by Reserving Unit – Status Quo Partially Balanced – To balance equities, Supreme Court directed appellant to reserve one unit of 550 sq. ft. in the redeveloped property to protect Respondent No.1’s interest, subject to outcome of pending civil suit [Para 19].

Decision – Appeal Allowed – Injunction Order Set Aside – Rights to Be Decided in Pending Suit – Supreme Court allowed appeal, set aside Bombay High Court’s injunction order dated 30.07.2024 – Clarified that Small Causes Court shall decide R.A.D. Suit No. 519/2023 on merits, uninfluenced by this judgment [Paras 19-20].

Competition Law – Dominant Position – Volume-based Target Rebates – Not Discriminatory – The slabbed rebate structure was uniformly applied based on annual purchase volumes – All buyers had equal opportunity to qualify – Rebates justified by operational efficiency of high-temperature continuous furnaces – No foreclosure or discriminatory treatment shown – Held: No abuse under Section 4(2)(a) or (b) of the Act [Paras 32–39].

Functional Rebates and TMLA – Objective Justification Proven – Functional rebate open to all converters agreeing to traceability and no-Chinese tubing conditions – Alleged exclusion unsupported by data – Evidence showed rise in rival converter output and import volumes – Held: Not unfair or restrictive under Section 4(2)(a) and (b) [Paras 40–45].

Margin Squeeze Allegation – Test Not Met – Schott India did not operate in downstream market – Schott Kaisha’s LTTSA did not leave rival converters with unsustainable margins – All independent converters remained profitable – Market showed increased competition and new entry – Held: No violation of Section 4(2)(e) [Paras 46–53].

Tying and Bundling – NGC and NGA Tubes – No Coercion – Aggregated for rebate computation but no requirement to purchase both – Converters had discretion – Rebate design justified by production process – No evidence of foreclosure – Held: Section 4(2)(d) not attracted [Paras 54–58].

Effects-Based Standard – Mandatory Under Section 4 – AAEC must be proven to establish abuse – Court emphasized that effects-based analysis is constitutional and economic necessity – CCI failed to establish adverse impact on competition – Held: Without actual harm, no liability under Section 4 can arise [Paras 59–66].

Natural Justice – Right to Cross-Examination – Violation Found – CCI relied on ex parte statements from conflicted parties without granting Schott India opportunity to cross-examine – COMPAT rightly held this vitiated the findings – Regulation 41(5) mandates fairness – Held: Procedural infirmity was sufficient to invalidate CCI’s order [Paras 68–75].

Final Decision – Appeals Dismissed – CCI’s findings set aside – COMPAT’s decision restored – Alleged abuses not proved and no appreciable adverse effect on competition shown – Kapoor Glass directed to pay ₹5,00,000 costs to Schott India [Paras 77–80].

Criminal Law - Prevention of Corruption Act – Appeal Against Conviction - Demand and Acceptance – Contradictory Evidence – Conviction Set Aside – The accused, a Revenue Inspector, was alleged to have demanded and accepted a bribe of ₹2,000 for conducting a drought damage inspection – The Supreme Court found contradictions in the testimonies of key witnesses including PW1 (complainant) and his wife (DW1), lack of corroboration, and absence of pH reaction on the accused’s hands – Held: The prosecution failed to establish demand and acceptance beyond reasonable doubt [Paras 6, 13, 17, 19-20].

Trap Cases – Standard of Proof – No Independent Corroboration – Benefit of Doubt Given – The Court noted the absence of shadow witness corroboration during the alleged bribe transaction and inconsistencies regarding how the money was placed in the accused's motorcycle bag – Held: Guilt not proved beyond reasonable doubt, and benefit of doubt must be extended to the accused [Paras 17-20].

Presumption under Section 20 – Inapplicability Due to Lack of Proven Demand – Although money was recovered, the Court reiterated that the statutory presumption under Section 20 does not arise unless prior demand is proved – Held: The presumption is not attracted where the foundational fact of demand is missing [Paras 21].

Final Decision – Conviction Reversed – Appeal Allowed – The Supreme Court quashed the judgments of both the Trial Court and the High Court – Held: Conviction and sentence under Sections 7 and 13(1)(d) r/w 13(2) of the Prevention of Corruption Act are set aside, and fine, if deposited, shall be refunded [Paras 22-23].

Civil Law - Contempt of Court – Sub Judice Principle – Freedom of Speech vs. Judicial Sensitivity – Take-Down Order Set Aside – The Supreme Court quashed the Delhi High Court’s interim order directing Wikimedia Foundation to take down certain Wikipedia pages and discussion threads commenting on a pending defamation suit – Held: There was no real or substantial risk of prejudice to the ongoing trial; order was disproportionate and violated constitutional guarantees – Criticism of judicial decisions by media or public, even if robust, is not contempt unless it scandalizes the court or obstructs justice – Judges must avoid hypersensitivity and uphold free speech and public debate on judicial proceedings [Paras 19–35].

Freedom of Expression – Right to Know – Role of Media and Digital Platforms – Judicial Prudence Emphasized – The Court reaffirmed that public debate on sub judice matters is not per se contemptuous – Media and digital platforms like Wikipedia are intermediaries facilitating public knowledge and should not be muzzled through overbroad censorship – Freedom of expression includes criticism of courts and is vital for a healthy democracy – Cited: Sahara India Real Estate, Naresh Shridhar Mirajkar, Swapnil Tripathi, Imran Pratapgadhi [Paras 22–29, 31–34].

Intermediary Liability – Section 79 IT Act – Not Adjudicated – The Court declined to rule on whether Wikimedia qualified for safe harbor protection as an intermediary under IT Act, as it may affect pending trial – Nonetheless, reaffirmed that mere hosting of content not authored by the intermediary is not enough to infer culpability [Para 32].

Decision – Appeal Allowed – High Court Direction to Delete Wikipedia Content Quashed – The Supreme Court allowed the appeal, setting aside the Delhi High Court’s interim direction that Wikimedia take down user-generated pages and discussions – Held: Courts must uphold free speech and not be seen as suppressing critique of judicial actions unless there is real prejudice to justice administration [Paras 33–34].