Arbitration – Scope of Judicial Interference – Sections 34 and 37 of the Arbitration Act – Arbitral award granting idle time compensation for Backhoe Dredger (BHD) was upheld under Section 34 by Single Judge – Division Bench under Section 37 reversed award interpreting contract differently – Supreme Court held that appellate jurisdiction under Section 37 is narrower and cannot extend beyond Section 34 – Reversal of award unsustainable [Paras 20–22, 30–32, 36–38, 50–52].

Arbitration – Contract Interpretation – Tribunal’s view prevails – Tribunal interpreted Clauses 38, 41.1, 41.2, and 51.1 of License Agreement to uphold idle time claim for BHD – Court reiterated that tribunal's interpretation, when reasonable and accepted under Section 34, cannot be revisited under Section 37 – Deployment of BHD not contrary to contract terms – Award is a speaking award without patent illegality [Paras 29, 39–49].

Arbitration Law – Public Policy and Patent Illegality – No violation of public policy or fundamental principles of justice found – Arbitral award not suffering from patent illegality – Respondent’s reliance on Ssangyong Engineering misplaced – Award based on valid reasoning and evidence [Paras 28, 41–44].

Arbitration – Contractual Compensation – Clause 38 not exhaustive – Tribunal rightly found that BHD, even if not classified as major dredger, was entitled to idle time compensation under Clause 51.1 – Licensing terms did not bar such claims for minor equipment – Tribunal's view held as plausible and within its jurisdiction [Paras 42–48].

Decision: Appeal allowed – Division Bench judgment under Section 37 set aside – Arbitral award in favour of appellant-Dredging India restored – No order as to costs.

Criminal Law – Bail – Accused summoned under Section 319 Cr.P.C. – Parameters for grant of bail – Appellant named in FIR but not charge-sheeted – Subsequently summoned as accused on application under Section 319 Cr.P.C. based on deposition of eyewitnesses – Appellant arrested pursuant to non-bailable warrant and bail rejected by High Court – Held: While considering bail of a person added as an accused under Section 319 Cr.P.C., Court must assess existence of strong and cogent evidence of complicity – Standard higher than prima facie case for framing charge but short of proof beyond reasonable doubt – Nature of offence, quality of evidence and likelihood of absconding or tampering to be considered – Appellant entitled to bail [Paras 14, 17].

Criminal Trial – Section 319 Cr.P.C. – Summoning of additional accused – FIR against nine accused – Charge-sheet against three accused – Six dropped by police – Trial court partly allowing Section 319 application and summoning three accused including appellant – Order under Section 319 Cr.P.C. not challenged and attained finality – Trial against newly added accused to proceed afresh after framing of charges [Paras 6–9, 11].

Bail – Parity – Co-accused granted anticipatory bail – Two co-accused summoned under Section 319 Cr.P.C. granted anticipatory bail by High Court – State’s appeal seeking cancellation of anticipatory bail – Held: No case made out for cancellation as co-accused have complied with conditions and appeared before trial court regularly – Appeal by State dismissed [Paras 15, 18–19].

Criminal Appeal – Scope of observations in bail proceedings – Clarification – Observations confined only to consideration of bail and anticipatory bail – Trial court to decide the case independently and uninfluenced by observations made by Supreme Court [Paras 20–21].

Decision: Appeal filed by MD Imran @ D.C. Guddu allowed – Appellant directed to be released on bail on terms and conditions to be imposed by trial court – Appeal filed by the State of Jharkhand dismissed – Pending applications disposed of.

Motor Accident Claim – Compensation – Assessment under Section 166 MV Act – Appellant injured in a motor accident originally claimed under Section 163A – Tribunal and High Court awarded Rs.2,12,800 and Rs.2,23,000 respectively – Supreme Court held that despite reference to Section 163A, pleadings and claim amount established the claim was under Section 166 – Hence, just compensation principles to apply [Paras 2, 5].

Income Computation – Minimum Income – Appellant claimed Rs.8,000/month as a salesman but failed to produce proof – Court relied on Ramachandrappa v. Royal Sundaram to fix income at Rs.5,000/month for 2005 accident, considering inflation and self-employment – Future prospects at 40% and multiplier of 17 (age 27) applied – Total loss of income recomputed accordingly [Paras 3, 6, 8].

Disability Assessment – Improper Reduction by High Court – Disability assessed at 60% by medical expert and accepted at 50% by Tribunal – High Court reduced to 40% without appeal by Corporation – Supreme Court held reduction unjustified and restored 50% disability as assessed by Tribunal [Para 7].

Decision: Appeal allowed – Compensation recomputed to ₹7,14,000 for loss of income – Additional conventional heads as per Tribunal/High Court upheld – Interest at 7.5% p.a. – Respondent to pay within 3 months [Paras 8–10].

Criminal Law – Bail – PMLA – Prolonged Incarceration – Appellant accused of orchestrating massive bank fraud and money laundering of ₹673.35 crores – Arrested on 09.07.2024, prosecution complaint filed on 06.09.2024 – Out of 28 individuals, only appellant was arrested – Trial yet to commence – No cognizance taken – Court held that continued detention without trial violated Article 21 of Constitution – Appellant entitled to bail despite gravity of economic offence [Paras 6-12, 15-19].

Right to Speedy Trial – Delay in Trial – High Court proceedings initiated by ED caused 8-month stay on trial – Appellant in custody for 16 months and 20 days – Court held that State’s inability to conduct timely trial cannot justify indefinite pretrial detention – Bail granted due to violation of fundamental right under Article 21 [Paras 18-19, 21].

Witness Tampering Allegation – Credibility – Allegation that appellant influenced witness Ms. Anuradha Kapur was rejected – Court found appellant had been in custody even before she was named as witness – Allegation deemed “wholly incredulous” [Para 20].

Economic Offences – Bail Jurisprudence – Court reiterated that not all economic offences can be grouped as a single class to deny bail – Cited various precedents including P. Chidambaram, Senthil Balaji, and Manish Sisodia – Held: Bail can be granted where investigation is complete, evidence is documentary, and trial is delayed [Paras 15-18].

Decision: Appeal allowed – Impugned judgment of Delhi High Court dated 19.08.2025 set aside – Appellant granted regular bail with conditions to be fixed by Trial Court – Directed to surrender passport and remain available on phone – Not to leave India without permission [Paras 23-25].

Service Law – Recruitment Process – Retrospective Amendment of Rules – Impermissibility – Recruitment to the post of Assistant Engineer governed by Bihar Engineering Services Class–II Recruitment Rules, 2019 – Selection under 2019 Rules based solely on marks obtained in written examination – After completion of written examination and publication of provisional merit list, State introduced Rule 8(5) by 2022 Amendment Rules granting weightage for contractual experience and age relaxation with retrospective effect from 06.03.2019 – Held, retrospective application of amended rule to ongoing recruitment process is impermissible – Rules of the game cannot be changed after the game has begun [Paras 22–25, 29–36].

Constitution of India – Article 309 – Power to Amend Rules Retrospectively – Limitations – State has power to legislate retrospectively under proviso to Article 309 – Such power not unbridled – Cannot be exercised to take away accrued or vested rights or to arbitrarily disturb a recruitment process which has substantially progressed – Retrospective amendment altering basis of selection after publication of provisional merit list held unconstitutional [Paras 36–37, 41–42].

Public Employment – Selection Criteria – Legitimate Expectation – Candidates participated in recruitment process on basis of declared criteria under 2019 Rules – Written examination conducted and merit list published – Legitimate expectation arose that appointments would be finalized on same criteria – Retrospective introduction of additional marks for contractual experience violates fairness, transparency and Articles 14 and 16 of the Constitution [Paras 34, 37–39].

Service Jurisprudence – Provisional Merit List – Effect – Though inclusion in provisional merit list does not confer indefeasible right to appointment – Distinction between right to appointment and right to be considered as per notified rules – Provisional nature of merit list relates only to document verification and not to alteration of eligibility or evaluation criteria – Recasting of merit list on basis of amended rules held arbitrary [Paras 37, 40].

Executive Instructions vs Statutory Rules – State relied on General Administration Department Memos of 2018 and 2021 providing weightage to contractual employees – Held, executive instructions cannot override statutory recruitment rules in force at time of advertisement – Absence of any reference to such policy in 2019 Advertisements disentitles State from applying it retrospectively [Para 39].

Precedent – Rules of the Game Doctrine – Reaffirmation of principles laid down in K. Manjusree v. State of A.P. and Constitution Bench decision in Tej Prakash Pathak v. Rajasthan High Court – Eligibility criteria and selection benchmarks cannot be altered after commencement of recruitment process unless expressly permitted by rules – Alteration after completion of written examination violates Article 14 [Paras 30–33].

Relief and Directions – Judgment of Patna High Court dated 05.07.2023 set aside – Recruitment pursuant to 2019 Advertisements directed to be finalized strictly in accordance with unamended 2019 Rules – Final merit list to be drawn on basis of written examination marks alone – Appointments to be completed within two months – Appointments already made pursuant to High Court judgment liable to be dealt with in accordance with law – Liberty reserved to State to continue such appointees against available or supernumerary posts without disturbing merit list [Paras 43–45].

Connected SLP (C) No. 8231 of 2025 – Challenge to vires of Rule 8(5) itself not examined in present appeal – High Court directed to decide CWJC No. 18429 of 2025 independently on merits – All contentions kept open [Paras 1–5 of SLP order].

Decision: Civil Appeal allowed – Impugned judgment of High Court set aside – Retrospective application of Rule 8(5) to 2019 recruitment quashed – Selection to be finalized under unamended 2019 Rules – Special Leave Petition (Civil) No. 8231 of 2025 disposed of with directions.

Criminal Law – Quashing - Multiple FIRs – Civil Dispute Given Criminal Colour – Petitioners accused of misappropriation of refund amount – Three separate proceedings initiated on identical facts – Two proceedings either stayed or withdrawn – Final report in FIR No. 396/2025 concluded no evidence against petitioners – Held: Initiation of multiple criminal cases on same cause of action impermissible – Proceedings except Tajganj FIR closed [Paras 1-7].

Quashing of FIR – Final Report Filed – No Arrest – Chargesheet in Agra case (FIR 396/2025) concluded allegations not substantiated – Petitioners not to be arrested – Directed to appear before jurisdictional court and be granted bail on same day – Recognized that continuation of prosecution cannot result in custodial harassment in absence of incriminating material [Paras 5-8].

Corporate Insolvency – Complainant Representation – Complainant company undergoing insolvency – Interim Resolution Professional impleaded – IRP permitted to represent complainant and summon former officials for trial if required [Paras 4, 9].

Judicial Comity – Proceedings in Different Jurisdictions – Parallel complaints in Delhi and Agra – Delhi proceedings stayed or treated as not pressed – Court directed closure of Karkardooma proceedings and disposal of pending criminal revision as not pressed – Upheld principle that litigants should not harass opponents through multiple jurisdictions [Paras 6-7].

Decision: Special Leave Petition disposed of – Petitioners granted protection from arrest – Directed to appear before jurisdictional court and be granted bail – All other criminal proceedings on same facts closed – IRP allowed to participate in proceedings [Paras 7-10].

Public Auction – Highest Bid – Arbitrary Cancellation – Impermissibility – Industrial plot measuring 3150 sq. mtrs auctioned by Ghaziabad Development Authority through two-bid system – Appellant’s technical and financial bids accepted – Appellant declared highest bidder with bid 15.23% above reserve price – Auction subsequently cancelled on ground that higher prices were fetched for smaller plots in same scheme – Held, cancellation based on irrelevant and extraneous considerations – Expectation of a higher price cannot justify cancellation of an otherwise valid auction [Paras 23–28, 32].

Administrative Law – Article 14 – Arbitrariness in State Action – State instrumentality cancelling auction without fraud, collusion or illegality in process – Comparison of bid for large plot with bids of much smaller plots held arbitrary, irrational and discriminatory – Action violates Article 14 – State authorities must act fairly, transparently and consistently in auction matters [Paras 27–29].

Public Auction – Reserve Price – Sanctity of Process – Uniform reserve price fixed for both smaller plots and subject large plot owing to lower demand for large plots – Bid higher than reserve price crystallises rights and obligations of parties – Once highest bid accepted and no infirmity found, authority under legal obligation to proceed with allotment [Paras 25–27].

Tender Conditions – Rewriting After Bid Opening – Prohibited – Ground of “low bid compared to smaller plots” not mentioned in auction brochure – Introducing new criteria after opening of bids amounts to rewriting tender conditions – Such post-auction benchmarking held impermissible in law [Paras 11–14, 23].

Legitimate Expectation – Right to Fair Treatment – Though no indefeasible right to allotment arises merely by being highest bidder – Highest bidder has right to non-arbitrary, fair and reasonable treatment – Cancellation without notice or hearing and on irrelevant grounds defeats legitimate expectation [Paras 14, 21, 29].

Natural Justice – Cancellation Without Notice – Financial bid cancelled behind the back of the appellant – Mere refund of earnest money does not cure illegality – Absence of show-cause notice and opportunity of hearing reinforces arbitrariness [Paras 14, 28–29].

Judicial Review – Auction / Tender Matters – Scope – Courts ordinarily show restraint and give “fair play in the joints” to State in contractual matters – However, where decision is arbitrary, irrational or based on irrelevant considerations, judicial interference warranted – Present case falls within exception justifying interference [Paras 16–18, 28].

Precedent – Eva Agro Feeds Applied – Reaffirmed principle that mere expectation of securing a higher price in re-auction is no ground to cancel a valid auction – Arbitrary cancellation erodes sanctity and credibility of auction process [Paras 22, 28, 32].

High Court – Error in Dismissing Writ Petitions – High Court erred in holding that appellant had no enforceable right merely because allotment letter was not issued – Failed to distinguish between absence of indefeasible right and right to fair, non-arbitrary treatment – Impugned orders unsustainable [Paras 19, 27–29].

Relief – Directions Issued – Cancellation of auction quashed – High Court orders set aside – Appellant directed to re-deposit earnest money – GDA directed to issue allotment letter and conclude auction process within stipulated time [Paras 32–33].

Decision: Appeals allowed – Impugned orders of Allahabad High Court dated 24.05.2024 and 15.07.2024 set aside – Cancellation of appellant’s bid quashed – GDA directed to allot plot to appellant upon re-deposit of earnest money.

Criminal Law – Cheating and Criminal Conspiracy – Multiple Victims – Same Transaction – Allegations of inducement and cheating of 1,852 investors pursuant to a single conspiracy to dupe public by false representation of divine powers to multiply money – One FIR registered and remaining complaints treated as statements under Section 161 CrPC – Held, where allegations disclose a single conspiracy with unity of purpose and design, multiple acts of cheating may form part of the same transaction – Registration of a single FIR in such circumstances is legally permissible [Paras 9–11, 18–21].

Criminal Procedure – FIRs – Multiplicity vs Consolidation – High Court held that each deposit constitutes a separate transaction requiring separate FIRs – Supreme Court disagreed – Law does not mandate registration of separate FIRs where subsequent information relates to same cognizable offence or same transaction – Subsequent complaints can be treated as statements under Section 161 CrPC – Multiple FIRs in such cases would lead to unnecessary multiplicity of proceedings [Paras 13–16, 21].

Criminal Procedure – Premature Reference under Section 395(2) CrPC – Reference made by Additional Sessions Judge during pendency of investigation – Held, reference was premature as it was not possible at that stage to determine whether offences formed part of same transaction – Question of consolidation of FIRs or charges arises only after investigation, at the stage of framing of charges [Paras 8, 20–21].

Same Transaction – Tests – Reaffirmation of settled principles – Unity of purpose or design, proximity of time and place, and continuity of action are relevant tests – Tests not required to be cumulatively satisfied – Determination depends on facts of each case – Magistrate to apply these tests on basis of material collected during investigation [Paras 11, 19–20].

Charges and Trial – Sections 218 to 223 CrPC – General rule under Section 218 CrPC mandates separate trial for distinct offences – Sections 219 to 223 CrPC are exceptions permitting joint trial – Where offences form part of same transaction, joint charges and trial permissible under Sections 220(1) and 223(a) & (d) CrPC – If not, separate trials required, subject to statutory limits on joinder of offences [Paras 19–20].

Sentencing – Multiple Offences – Sentencing to be governed by Section 71 IPC read with Sections 31 and 325 CrPC – If offences tried together as part of same transaction, punishment to follow accordingly – Issue of proportionality and concurrency of sentences to be considered by Trial Court on established facts [Paras 3, 22].

Rights of Complainants – Protest Petitions – Even where multiple complainants are treated as witnesses in a single FIR, their right to file protest petitions is preserved – Magistrate duty-bound to consider such protest petitions if closure report is filed or discharge is contemplated [Paras 13, 22].

High Court Judgment – Interference Warranted – Answers given by Delhi High Court to Questions (a) and (b) holding that separate FIRs and charge sheets were mandatory held erroneous – Set aside – Matter left to Magistrate to decide applicability of “same transaction” doctrine at appropriate stage [Paras 21–23].

Decision: Appeal allowed – Judgment dated 08.07.2019 of the Delhi High Court in Criminal Reference No. 1 of 2014 set aside insofar as it answered Questions (a) and (b) – Registration of single FIR upheld – Issue of consolidation of charges/trial to be decided by Magistrate in accordance with law.

Medical Education – Admission under Sports Quota – Criteria Manipulation – Appellants challenged change in sports quota policy post-issuance of prospectus for NEET UG-2024 – Initial eligibility limited to Classes XI and XII – Changed mid-process to include Classes IX and X based on representation by father of top-ranked candidate – Supreme Court held: change was arbitrary, lacked transparency, and violated settled admission norms – Held to be vitiated by conflict of interest and lack of disclosure [Paras 1-4, 15-18, 20-23, 33-36].

Administrative Law – Doctrine of Fairness – Change in Admission Criteria – Court reiterated that ‘rules of the game cannot be changed after the game has begun’ – Held: Midstream change to sports achievement criteria after applications were submitted violates principles of non-arbitrariness and fairness under Article 14 – State bound to finalize policy prior to admissions – Opaque flexibility invites arbitrariness and nepotism [Paras 18, 31-32, 36-38].

Conflict of Interest – Manipulation of Policy by Interested Party – Representation by Roller Skating Coach (father of top-ranked candidate) led to policy change – He concealed his daughter’s beneficiary status – Court found lack of probity and transparency – Held: Entire policy modification for session-2024 stands vitiated due to undisclosed personal interest and undue influence [Paras 20-22, 33, 38].

Relief – Rearrangement of Seats – Appellants Divjot Sekhon and Shubhkarman Singh were unfairly denied seats in government medical colleges – Court directed swapping of seats: appellants to be allotted seats held by beneficiaries of tainted policy – Respondents Kudrat Kashyap and Mansirat Kaur to be shifted to private colleges originally allotted to appellants – Studies and fees paid to remain undisturbed [Para 40].

Prospective Challenge – Policy Continuation in 2025 – Appeal by 2025 aspirants (Agrima Mann & others) on identical grounds not granted immediate relief – Court held issue remains open – Liberty granted to file fresh proceedings before High Court with necessary parties [Paras 41-42].

Decision: Appeals allowed – 2024 sports quota policy change quashed – Appellants to be accommodated in government medical colleges – Respondents who benefitted from unlawful change to be shifted to private colleges – Policy change in 2025 left open to challenge – Costs to be borne individually [Paras 38-42].