Civil Law - MSMED Act – Limitation Act Applicability – Conciliation and Arbitration Proceedings – Section 18 MSMED Act – Partial Applicability of Limitation Law – Supreme Court held Limitation Act applies to arbitration under Section 18(3) MSMED Act, preventing recovery of time-barred claims through arbitration – However, Limitation Act does not apply to conciliation under Section 18(2) MSMED Act – Time-barred claims can be settled through conciliation based on party agreement and Section 25(3) of Contract Act – High Court decision set aside partially to this extent [Paras 1-54].

Arbitration Proceedings – Section 18(3) MSMED Act – Section 43 ACA Applicable – Non-Applicability of Section 2(4) ACA – Supreme Court affirmed applicability of Section 43 ACA to arbitration under MSMED Act owing to special deeming provision in Section 18(3) and overriding effect under Section 24 MSMED Act – Time-barred claims held non-maintainable in arbitration proceedings [Paras 35-43].

Conciliation Proceedings – Section 18(2) MSMED Act – Time-Barred Claims Allowed – Conciliation proceedings held non-adjudicatory and voluntary in nature – Time-barred claims can be pursued for amicable settlement under conciliation proceedings despite expiration of limitation period – Settlement agreements under conciliation valid and enforceable under Section 25(3) Contract Act [Paras 25-34].

Acknowledgment of Debt – Section 22 MSMED Act – Balance Sheet Entries – Disclosure of unpaid amounts in buyer’s financial statements does not automatically amount to acknowledgment under Section 18 Limitation Act – Whether an entry amounts to acknowledgment depends on factual context and legal compliance with Section 18 Limitation Act [Paras 49-50].

Decision – Appeals Partly Allowed – Supreme Court upheld High Court’s decision on applicability of Limitation Act to arbitration proceedings – Reversed High Court’s holding on conciliation, allowing settlement of time-barred claims through conciliation – Supreme Court clarified that suppliers can seek recovery through conciliation even after expiry of limitation but arbitration remains bound by limitation period – Appeals partly allowed [Paras 51-52].

Civil Law - Inheritance Rights of Tribal Women – Right to Equality under Constitution – Sections 2(2) of the Hindu Succession Act and Section 6 of the Central Provinces Laws Act, 1875 – Appeal Allowed – The Supreme Court allowed the appeal of the legal heirs of a tribal woman, overturning the concurrent findings of the Trial Court, First Appellate Court, and High Court which denied them inheritance rights – It was held that in absence of any established custom excluding women from inheritance and non-applicability of Hindu Succession Act to Scheduled Tribes, justice, equity, and good conscience must prevail – Court directed equal property rights for the female legal heirs, restoring the constitutional mandate of equality – Judgments of the courts below set aside [Paras 3, 6, 13, 15, 17, 19, 20, 28-29].

Customary Law – Burden of Proof – Exclusionary Custom not Proved – The Court held that both appellants and respondents failed to establish any customary law governing succession among the Gond tribe – In absence of any specific law or proven custom, courts cannot presume exclusion of women from inheritance – The High Court and subordinate courts wrongly assumed patriarchal customs, which cannot be inferred without proof [Paras 4-9, 13].

Repeal of Statute – Continuing Application of Justice, Equity and Good Conscience – Section 6 of the Central Provinces Laws Act, 1875 – Repeal of the 1875 Act does not affect accrued rights – Supreme Court held that accrued inheritance rights remain unaffected post repeal due to savings clause – The High Court erred in dismissing claims on the ground of repeal [Paras 15-17].

Gender Equality – Constitutional Mandate of Article 14 – Right to Equal Share in Ancestral Property – The Supreme Court reinforced the application of gender equality under Article 14 – Denial of succession rights solely based on gender without proven exclusionary custom was held unconstitutional – Reference made to landmark constitutional jurisprudence on equality to extend rights to female heirs [Paras 20-29].

Final Decision – Judgments of the Trial Court, First Appellate Court, and High Court were set aside – Appeal allowed in favour of the appellants, granting equal share in ancestral property to legal heirs of tribal woman – Costs not awarded [Para 29].

Succession Law  – Section 63 of the Indian Succession Act – Will Dispute - Suspicious Circumstances – Proof of Free Disposing Mind – Appeals Dismissed – The appellant, propounding a Will executed by his deceased uncle Maya Singh, was granted decree of ownership of suit land by the Trial Court and First Appellate Court – High Court reversed concurrent findings on grounds of suspicious circumstances, particularly the non-mention of testator’s wife and lack of reasons for her disinheritance – The Supreme Court upheld the High Court’s decision, affirming that such omissions raised serious doubts regarding the genuineness of the Will and negated proof of free disposing mind of the testator – Appeal dismissed and High Court’s finding upheld [Paras 1, 8, 18-22].

Execution of Will – Standard of Proof – Requirement to Dispel Suspicion – The Court reiterated that when a Will is surrounded by suspicious circumstances, mere proof of signatures or registration is insufficient – Propounder must dispel doubts to the satisfaction of the court and establish the Will was executed voluntarily by the testator – In this case, suspicious circumstances remained unrefuted, rendering the Will invalid [Paras 11-13].

Inheritance Rights of Spouse – Disinheritance without Justification – Constitutional and Legal Scrutiny – The Court observed that failure to mention a lawful spouse and absence of justification for her exclusion from inheritance in the Will is a significant suspicious factor – Given evidence of harmonious relationship between testator and his wife, unexplained disinheritance suggested possible undue influence by the propounder, vitiating the Will [Paras 19-20].

Concurrent Findings Reversed by High Court – Judicial Conscience Principle Upheld – The Supreme Court endorsed the High Court’s reversal of concurrent findings, holding that courts have a solemn duty to scrutinize Wills in light of equity and fairness, especially when the natural heir is excluded without explanation – Suspicion was not rebutted, and the appeals were dismissed affirming the High Court's decree in favour of the respondent-wife [Paras 18-22].

Decision – Appeals Dismissed – The Supreme Court affirmed the High Court's judgment declaring the first respondent as the rightful owner and in possession of the suit land – Appeals dismissed with no costs awarded [Para 22].

Criminal Law - Bribery and Conspiracy Allegation – Demand and Acceptance of Illegal Gratification – Sections 7, 13(1)(d), 13(2), Prevention of Corruption Act – Appeal Allowed – The appellant, an Assistant Administrative Officer, was accused of demanding bribe along with a superior officer for claim settlement in an insurance matter – Initially acquitted by the Trial Court, conviction was later reversed by the High Court based on inference from phone calls and trap proceedings – The Supreme Court found serious contradictions in the prosecution’s version, including absence of direct demand proof, inconsistencies in trap procedure, and flawed reliance on circumstantial evidence – Held: Conviction set aside, Trial Court’s acquittal restored due to lack of credible proof of demand and acceptance beyond reasonable doubt – Acquittal. [Paras 1, 24-39].

Reversal of Acquittal – Standard of Appellate Interference – Double Presumption of Innocence – The Court reaffirmed the legal principle that in appeals against acquittal, the High Court must proceed cautiously and interfere only when Trial Court’s findings are perverse or unreasonable – Held: Trial Court’s view based on evidence inconsistencies was reasonable; High Court erred in reversing acquittal without addressing material gaps – Supreme Court reinstated the presumption of innocence of the appellant [Paras 24, 34-36].

Evidentiary Gaps and Investigative Lapses – Contradictory Evidence Regarding Trap Proceedings – The Court highlighted three critical inconsistencies: unexplained participation of the SP in trap proceedings, inconsistency in seized articles (white shirt appearing moss-coloured), and contradiction in chemical test results on a whisky box without prior application of phenolphthalein – Held: Prosecution failed to maintain evidentiary integrity, rendering conviction unsustainable [Paras 30-33].

Demand and Acceptance Not Established – Application of Neeraj Dutta Doctrine – The Court applied the principle laid down in Neeraj Dutta v. State (2023) on the requirement of clear proof of demand and acceptance in bribery cases – Held: Demand not proved by credible direct or circumstantial evidence, benefit of doubt must flow to the accused [Paras 24-28, 38].

Final Decision – Appeal Allowed – Supreme Court allowed the appeal, set aside the High Court judgment convicting the appellant, restored Trial Court’s acquittal order, and directed refund of fine if deposited – Appellant acquitted of all charges [Para 39].

Motor Accident Compensation – Principle of Pay and Recover – Section 166 of Motor Vehicles Act – Appeal Allowed – The appellants, legal representatives of the deceased, challenged rejection of insurer’s liability to pay compensation due to the status of the deceased as gratuitous passenger and non-payment of premium for such coverage – The Supreme Court held that despite policy restrictions, the principle of “pay and recover” must apply, directing the insurer to pay compensation to claimants first and recover the same from the owner – Held: Insurer liable to pay the enhanced compensation to claimants and recover from vehicle owner, applying equity principles [Paras 13-18, 22].

Driving Licence Validity – Commercial Vehicle Driven with LMV Licence – Driver Exonerated – Although the vehicle involved was a commercial one (TATA 407 Truck), the Court affirmed that no special endorsement was required as the driver possessed a valid Light Motor Vehicle (LMV) licence, and the vehicle’s weight did not exceed 7500 kg – Held: Driver held not liable due to valid licence coverage under recent constitutional bench judgment [Paras 10, 19].

Enhanced Compensation – Revision of Conventional Heads – Compensation Increased – Supreme Court applied the principle laid down in Pranay Sethi and subsequent rulings to enhance compensation under conventional heads such as loss of estate, loss of consortium, and funeral expenses by 10% considering periodical revisions – Compensation enhanced from ₹19,53,000/- to ₹26,97,500/- with 6% interest per annum [Paras 20-21].

Decision – Appeal Allowed – The Supreme Court allowed the appeal filed by claimants, modified the compensation award, held insurer liable to pay the revised compensation with interest and recover from the vehicle owner, with direct payment directed into claimants’ bank accounts [Paras 22-23].

Service Law - Family Pension – Death in Harness of Substitute Railway Employee – Completion of One Year’s Service – Pension Entitlement Recognized – Appeal Allowed – The Appellant, widow of a substitute railway employee who died after 9 years and 8 months of service, was denied family pension by Railway Authorities citing non-regularisation and less than 10 years of service – Supreme Court held that under Rule 75(2)(a) read with Rule 18(3) of the Railway Services (Pension) Rules, 1993, family pension is payable to the family of a temporary railway servant who dies after completing one year of continuous service – Observed that the deceased had obtained temporary status and was eligible for family pension on par with temporary employees – Held: Denial of family pension unsustainable, appeal allowed [Paras 1-12].

Qualifying Service for Family Pension – 10-Year Minimum Tenure Not Applicable for Temporary Status – Clarification Issued – Supreme Court clarified that the 10-year qualifying service rule is applicable for superannuation pension, but in the case of death in harness after one year of service, family pension cannot be denied to dependents – Held: Disqualification based on the three-month shortfall from ten years violates the beneficial scheme of pension rules, purpose being to protect the deceased’s dependents [Paras 10-11].

Relief under Article 142 – Award of Ex-Gratia Compensation – Supreme Court invoked powers under Article 142 to award additional ex-gratia amount of ₹5,00,000 to the appellant in view of prolonged litigation and hardship faced by the widow after death of breadwinner – Directed payment of arrears of pension along with regular monthly pension within four months [Paras 13-14].

Decision – Appeal Allowed – Orders of Tribunal and High Court Set Aside – Supreme Court allowed the appeal, set aside decisions of Central Administrative Tribunal and Patna High Court, directed immediate disbursal of pension benefits to the appellant along with ₹5 lakh ex-gratia compensation [Paras 14-15].

Criminal Law - Murder – Section 302 of the IPC - Conviction Based on Ocular and Medical Evidence – Multiple Murders Committed Due to Suspicion of Infidelity – Conviction Upheld - The appellant was convicted of murdering five family members, including three minor children, his wife, and sister-in-law, with a chopper based on clear eyewitness testimonies, voluntary confession, and medical evidence – Courts below correctly found the accused guilty of premeditated, barbaric murder without any sudden provocation – Supreme Court upheld the conviction as there was no perversity or misreading of evidence [Paras 1-10].

Death Sentence – Application of ‘Rarest of Rare’ Doctrine – Consideration of Reformative Possibility – Death Sentence Commuted to Life Imprisonment – Though the crime was heinous, the Court found mitigating circumstances in the accused’s background – Reports revealed absence of prior criminal antecedents, good conduct in jail, participation in literacy programmes, psychological struggles, and potential for reformation – Applying the principle of giving benefit of doubt in sentencing, death penalty was substituted with life imprisonment without remission till the natural end of life [Paras 11-17].

Sentencing Guidelines – Compliance with Manoj v. State of M.P. – Requirement for Comprehensive Background Analysis – The Court emphasized adherence to sentencing principles laid down in Manoj v. State of M.P. (2023) 2 SCC 353, requiring socio-psychological, medical, and behavioural assessments before awarding capital punishment – Held: High Court inadequately appreciated these reports while confirming the death sentence, warranting interference on the sentencing aspect [Paras 11-17].

Final Decision – Conviction Upheld, Death Sentence Commuted – Supreme Court partly allowed the appeal by commuting the death sentence to life imprisonment without remission till natural death while affirming the conviction under Section 302 IPC for multiple murders [Paras 17].

Criminal Procedure – Service of Notice under Section 35 BNSS – Electronic Mode Not Permissible – Application Dismissed – The State of Haryana sought modification of the Supreme Court’s earlier order to allow electronic service of notices under Section 35 BNSS – Held: Legislative intent is explicit in excluding investigation-related notices from electronic mode under Section 530 BNSS – Non-compliance with such notices may result in arrest, impacting liberty – Electronic service not legally sustainable [Paras 3, 17, 26-27, 43].

Electronic Communication – BNSS Provisions – Scope Delineated – Legislative Intent Respected – Court held that BNSS expressly permits electronic communication for limited procedures like service of summons with Court seal, communication to witnesses, production of documents, and filing of police reports – Investigative notices affecting liberty require stricter compliance and personal service [Paras 15, 20, 40-42].

Right to Liberty – Article 21 – Protection in Investigative Stage – Court interpreted Section 35(3)-(6) of BNSS as substantively protecting individual liberty – As arrest can follow non-compliance with notice, mode of service must be stringent – Personal service mandated to safeguard constitutional rights [Paras 24-26, 29].

Judicial vs Executive Acts – Summons vs Investigative Notice – Procedural Distinction – Summons issued by Court under Sections 63/71 BNSS differ from notice under Section 35 issued by Investigating Agency – Judicial summons can use electronic communication under strict format – Executive notices impacting liberty cannot [Paras 31-39].

Decision – No Modification of Previous Order – Supreme Court reaffirmed its earlier ruling requiring Standing Orders directing personal service of notice under Section 35 BNSS – Application by State of Haryana dismissed – Prior judgment upheld [Para 44].

Electricity Act - Electricity Tariff – Scope of Note 3 of Regulation 55 – Contractual Obligation to Supply Free Power Beyond 13% Not Affected – Appeal Allowed – The appellant State challenged the High Court’s order that modified the agreed contractual free power supply from 18% to 13% in alignment with CERC Regulations, 2019 – The Supreme Court held that Note 3 of Regulation 55 of the 2019 Tariff Regulations only caps the extent of free power for purposes of tariff calculation recoverable from distribution licensees and beneficiaries – The cap does not restrain or extinguish the contractual obligation to supply free power beyond 13%, which forms part of negotiated consideration for resource allocation – Held: Contractual obligation to supply 18% free power continues unaffected by the 13% cap applicable for tariff computation [Paras 1-24].

Tariff Regulation – Limited Purpose of CERC Regulations – Contractual Free Power Obligations Not Regulated – The Court clarified that CERC Regulations govern tariff computation between generating companies and beneficiaries and cannot be relied upon to alter royalty-based free power obligations agreed with the State Government – Held: The free power clause forms part of the project allotment consideration and remains enforceable as such – The regulatory cap applies only to tariff pass-through and does not rewrite resource contracts [Paras 15-21].

Writ Jurisdiction – Not Maintainable to Modify Concluded Contracts Governed by Sectoral Regulation – The Court held that the High Court exceeded its jurisdiction by entertaining a writ petition seeking to rewrite contractual terms based on tariff regulations – Disputes on tariff are within the exclusive domain of CERC and APTEL – Held: Constitutional Courts must refrain from entertaining parallel remedies when specialized statutory frameworks are available and operative [Paras 26-39].

Role of Sectoral Regulator – Judicial Deference to CERC in Tariff Matters – The Court reaffirmed the established principle that tariff-related determinations, including interpretations of applicable regulations, fall squarely within the regulatory domain of expert bodies like CERC and appellate bodies like APTEL – High Courts should not interfere where regulatory mechanisms exist and have not been duly exhausted – Writ petitions circumventing these remedies are impermissible [Paras 26-39].

Status of State Government – Not a Deemed Licensee – The Court observed that the High Court wrongly assumed the appellant State to be a deemed licensee and a regulated entity under the Electricity Act – Held: Supply of free power as royalty does not make the State a licensee as it involves no trading, transmission, or distribution activity – Obligations arising from sovereign contracts of natural resource allocation are distinct from regulated market relationships under the Electricity Act [Paras 35-38].

Final Decision – Appeal Allowed – High Court’s judgment quashing part of the Implementation Agreement set aside – Contractual right of the State to receive 18% free power upheld – The High Court erred in modifying a sovereign contract through writ jurisdiction – Writ petition held not maintainable and dismissed [Paras 40-41].