Civil Law - Banking Regulation - Banking Regulation Act 1949 - Section 36AAA - Constitutional Law - Article 243ZL - Multi-State Co-operative Bank - Supersession of Board of Directors - Appellants challenged RBI order superseding BoD and subsequent extensions beyond original five-year term arguing that constitutional mandate under Article 243ZL limits supersession to six months - High Court upheld RBI action holding BR Act applicable and proviso to Article 243ZL as an independent provision - Supreme Court held that the third proviso to Article 243ZL(1) is a substantive, independent provision that incorporates the BR Act into the constitutional scheme for co-operative banks - RBI's power under Section 36AAA is not circumscribed by the six-month limit and is intended to safeguard depositor interests and banking solvency - Extension of supersession orders beyond the original tenure is permissible within the five-year aggregate limit - Held - RBI has statutory authority to supersede boards of multi-State co-operative banks without being restricted by the six-month period prescribed for other co-operative societies - [Paras 1-34].

Civil Law - Statutory Interpretation - Banking Regulation Act 1949 - Section 36AAA - Doctrine of Incorporation - The third proviso to Article 243ZL(1) explicitly makes the BR Act applicable to co-operative societies carrying on banking business - The expression shall also apply is additive and non-restrictive - The legislative intent behind the BR Act and the internal architecture of Article 243ZL confirm that multi-State co-operative banks remain subject to the expert regulatory oversight of the RBI - Held - Supersession power under Section 36AAA is a vital tool for preventing mismanagement and protecting public interest - [Paras 21-33].

Civil Law - Election and Tenure - Banking Regulation Act 1949 - Section 36AAA(7) - Multi-State Co-operative Bank - Administrator powers - The Administrator is mandated to call for elections only upon the expiration of the supersession period specified by the RBI - The tenure of the original Board of Directors does not restrict the RBI's power of supersession - The outer limit of five years serves to prevent indefinite deferment of elections while prioritizing banking stability - Held - The challenge to extensions of the supersession order is meritless - [Paras 35-38].

Decision: Appeals dismissed – Judgment of the High Court affirmed – No order as to costs.

Constitutional Law - Scheduled Tribes - Constitution of India - Article 142 - Invalidation of Caste Certificate - Appellant secured employment as Junior Engineer in 1994 based on Tokre Koli Scheduled Tribe certificate - Scrutiny Committee later invalidated certificate and confiscated it based on pre-constitutional records of ancestors as Koli - High Court upheld committee order - Supreme Court found no error in findings regarding caste status but invoked extraordinary powers under Article 142 to protect retiral and pensionary benefits due to over three decades of service and retirement - Held - caste claim invalidation affirmed but retiral benefits protected - [Paras 1-16].

Service Law - Protection of Pensionary Benefits - Constitution of India - Article 142 - Equitable relief - Despite annulment of caste certificate the Court exercised discretion to ensure appellant is not deprived of retiral benefits after superannuation following three decades of service - Held - relief granted for limited purpose of computation and release of benefits only - [Paras 12-15].

Evidence Law - Caste Verification - Documentary Evidence - Pre-constitutional records of father and grandfather recorded as Koli - Held - such records possess high probative value to invalidate claims of specific Scheduled Tribe status - [Paras 4-7].

Decision: Appeal allowed in part – The order invalidating the caste certificate of the appellant as belonging to the Tokre Koli Scheduled Tribe is upheld – The appellant is protected only for the limited purpose of receiving his retiral and pensionary benefits, to be released within six months.

Writ Law - Public Interest Litigation - Electricity Act 2003 - Section 135 - Maintainability - Petitioner challenged the locus standi of respondent no 1 to initiate PIL regarding electricity supply agreements and alleged violation of captive user status - High Court rejected the preliminary objection citing prima facie substance in allegations and the necessity to bring full facts to notice of JBVNL despite respondent no 1 not being privy to the agreement - Supreme Court held that in the peculiar facts of the case the High Court decision to adopt an interim measure to allow participation in JBVNL inquiry is not perverse and does not warrant interference under Article 136 of the Constitution - Held - Special Leave Petition disposed of with liberty to the High Court to consider the scope of third-party intervention at the final hearing stage - [Paras 1-16].

Civil Law - Regulatory Framework - Electricity Act 2003 - Sections 79, 86 and 94 - Electricity regulatory regime - Electricity Act is an exhaustive code for matters concerning electricity and the regulatory bodies are empowered to ensure transparency - High Court directed to consider the comprehensive statutory framework and the regulatory regime while passing the final order - Held - interim direction for participation does not imply conversion of inquiry into a court or tribunal hearing but a means to collect information for initiating necessary action - [Paras 9-13].

Decision: Special Leave Petition disposed of – Interim order of the High Court remains undisturbed pending final adjudication – JBVNL to proceed with inquiry without treating the third-party participation as a substitute for a judicial hearing.

Criminal Law - Murder and Sexual Offence - Indian Penal Code 1860 - Sections 302, 201, 377 - Appellant convicted by Trial Court and High Court based on circumstantial evidence - Theory of last seen and extra-judicial confession - Supreme Court observed missing links in chain of circumstances - Discrepancies in testimony of witnesses regarding date of police encounter and alleged purchase of items - No DNA evidence linking accused to rectal swab - Disclosure statement held unreliable as it led to no new discovery - Held - Prosecution failed to prove guilt beyond reasonable doubt - Conviction set aside - [Paras 1-50].

Evidence Law - Circumstantial Evidence - Indian Evidence Act 1872 - Theory of last seen - Prosecution witnesses failed to establish consistent account of deceased being in company of accused - Suggestion during cross-examination cannot substitute for conclusive evidence - Held - Last seen theory not established by reliable testimony - [Paras 21-23, 33-36].

Evidence Law - Extra-Judicial Confession - Reliability - Extra-judicial confession made to Sarpanch held weak piece of evidence - Absence of independent corroboration - Discrepancy between date of alleged confession and testimony of witnesses stating police had already apprehended accused - Held - Confession does not inspire confidence - [Paras 18, 31-33, 43].

Evidence Law - Discovery - Indian Evidence Act 1872 - Section 27 - Recovery of incriminating articles - Accused allegedly identified spot after police had already prepared site plan - No new facts discovered pursuant to disclosure statement - Held - Section 27 not satisfied - [Paras 38-40, 44].

Evidence Law - Forensic Report - Expert opinion - Lack of DNA matching between semen on accused underwear and rectal swab of deceased - High Court erred in shifting onus of proof to accused to establish difference - Held - Prosecution failed to establish incriminating link - [Paras 45].

Decision: Appeal allowed - Judgment of conviction and order on sentence set aside - Appellant acquitted of all charges and directed to be released forthwith.

Civil Law - SARFAESI Act - Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act 2002 - Sections 2, 13, 14 - Applicability of SARFAESI Act to assigned debts - Appellant bank acquired loan accounts from an NBFC that was not a notified financial institution at the time of original lending - Borrower challenged bank's right to invoke SARFAESI Act measures - High Court held bank could not invoke the Act for such debts - Supreme Court held that once a debt is live and owing- the SARFAESI Act applies when the current holder is a bank or financial institution- it makes no difference if the loan was originally from an entity not covered by the Act- the assignee bank is entitled to invoke recovery measures - Held - Judgment of Bombay High Court set aside - appeals allowed in part - [Paras 1-41].

Civil Law - Banking Law - SARFAESI Act - Section 13 - Secured creditor - Meaning of secured debt - Assignment of non-performing assets - Acquisition of a non-performing secured loan account by a bank from an entity not covered by the SARFAESI Act clothes the loan account with the attributes of a secured debt covered by the Act - Held - Assignment of debts is a permissible activity under the Banking Regulation Act and RBI guidelines - [Paras 28-37].

Decision: Civil Appeal No. 8531 of 2015 allowed - Other appeals dismissed - S.A. No. 39 of 2014 restored to the file of the Debts Recovery Tribunal, Nagpur for adjudication on merits subject to deposit of Rs 25 lakh by the respondents.

Civil Law - Divorce - Hindu Marriage Act 1955 - Section 13(1)(ib) - Desertion - Appellant-husband sought divorce alleging wife deserted him since December 2005 - Trial Court held desertion proven but dismissed petition - High Court reversed finding on desertion claiming lack of animus deserendi - Supreme Court held that refusal of the respondent to return to the matrimonial home without reasonable cause, coupled with continuous separation since 2005, established animus deserendi and desertion - Held - Marriage dissolved by decree of divorce - [Paras 1-25].

Civil Law - Matrimonial Law - Hindu Marriage Act 1955 - Section 13 - Permanent Alimony - Supreme Court in exercise of its jurisdiction to do justice between parties directed the appellant to pay a sum of Rs 7,00,000 as permanent alimony to the respondent-wife within three months - Held - Failure to pay within stipulated time to attract 9 percent interest per annum - [Paras 24-25].

Civil Law - Matrimonial Law - Hindu Marriage Act 1955 - Irretrievable breakdown - The Court observed that while not invoking Article 142 of the Constitution, the principle of irretrievable breakdown is instructive where the marriage has become a fiction due to prolonged separation - Held - Compelling parties to continue in such marriage fails to serve the ends of justice - [Paras 21-22].

Decision: Appeal partly allowed – Marriage between parties dissolved by decree of divorce under Section 13(1)(ib) HMA – Appellant directed to pay Rs 7,00,000 as permanent alimony within three months or face 9 percent interest thereon – No order as to costs.

Civil Law - Securities Regulation - Securities Contract (Regulations) Act 1956 - Section 9 - Professional Clearing Member - Liquidation of collaterals upon Trading Member default - Appellant-PCMs liquidated securities pledged by a defaulting Trading Member to recover losses - NCL Committee directed restitution of securities to individual clients of the TM - SAT upheld the order - Supreme Court held that the PCM had no statutory obligation to verify individual client positions and lacked visibility of such positions due to the prevailing regulatory framework of the time - Held - The Committee lacked jurisdiction to order restitution as a penalty under the Act which prohibits money-based penalties and restitution in this context - Appeals allowed - [Paras 1-58].

Civil Law - Natural Justice - Securities Appellate Tribunal - Restitution order - The Committee imposed a restitution penalty without issuing a prior show-cause notice regarding such specific relief - Held - The order is vitiated by violation of principles of natural justice and is statutorily impermissible - [Paras 9-44].

Civil Law - Investor Rights - F&O Segment - Speculative nature of derivative trading - Investors knowingly participated in illegal schemes offered by the TM - Investors sought recovery of securities from PCM - Held - Investors knowingly entered into illegal arrangements with the TM for fixed returns and cannot lay a claim against the PCM for losses resulting from their own voluntary participation in speculative and prohibited activities - [Paras 30-55].

Decision: The appeals stand allowed and the impugned orders of the MCSGF Committee and the SAT are set aside – Civil Appeal No. 4238 of 2026 is rejected as not maintainable.

Criminal Law - Juvenile Justice - Juvenile Justice (Care and Protection of Children) Act 2000 - Section 7A - Claim of juvenility - Appellant convicted under Section 201 Part II IPC for causing disappearance of evidence - Plea of juvenility raised after conviction attained finality - High Court rejected plea citing bar of finality of litigation and limitation of inherent power under Section 482 CrPC - Supreme Court held that juvenility is a jurisdictional fact going to the root of the matter - High Court erred in over-relying on technical shackles when statutory benefit of juvenility was denied - Appellant proved minor on date of occurrence by school and panchayat records - Conviction and sentence set aside as illegal - [Paras 1-35].

Criminal Law - Procedural Law - Code of Criminal Procedure 1973 - Section 482 and 362 - Inherent powers of High Court - Recall of judgment - Court can exercise inherent power to prevent abuse of process or to secure ends of justice - Mistake of Court leading to denial of statutory right of a juvenile must be remedied - Ex debito justitiae mandate - High Court has power to recall order resulting in miscarriage of justice - [Paras 27-34].

Criminal Law - Juvenile Justice - Parens Patriae - Welfare of children - State duty to protect children from criminal stigma - Legislative intendment to extend benefit of JJA even if claim raised after final disposal - Courts obliged to adopt purposive interpretation - [Paras 10-24].

Decision: Appeal allowed – Judgment of conviction and sentence dated 21/12/2005 passed against the appellant set aside – Appellant discharged from bail bonds liability.

Constitutional Law - Right to Trade - Constitution of India 1950 - Article 19(1)(g) - Petitioners challenged state-wide ban on purse seine fishing in territorial waters - State of Tamil Nadu relied on conservation of juvenile stocks and existing 1983 Act - Expert Committee recommended non-blanket ban with regulated access - Union of India notified 2025 EEZ Rules - Court held that State and Union possess co-equal and autonomous powers in their respective legislative spheres - Failure to process applications in timely manner creates impermissible unwritten ban - Court directed State to streamline verification for EEZ access while maintaining regulatory compliance - Held - Regulated purse seine fishing permitted with compliance to both state and central regimes - [Paras 1-18].

Administrative Law - Cooperative Federalism - Tamil Nadu Marine Fishing Regulation Act 1983 - Sustainable Harnessing of Fisheries in the Exclusive Economic Zone Rules 2025 - Jurisdiction over maritime zones - State legislates for territorial waters and Union for EEZ - Requirement for coordinated action between Issuing Authority and Verifying Officer to prevent administrative paralysis - Held - Both authorities must act in tandem to protect rights of stakeholders - [Paras 13-16].

Decision: I.A. No. 190882/2024 stands disposed of – Parties to be governed by 2025 EEZ Rules and 2020 Marine Fishing Regulation Rules – State Government directed to frame rules designating specific transit channels for purse seine vessels after considering Expert Committee recommendations – State directed to expedite verification of pending applications.