Taxation Law - Central Goods and Services Tax Act 2017 - Sections 2(52) 7 9 and 15 - Online Gaming and Actionable Claims - Revenue challenged common judgment of Karnataka High Court which quashed show cause notices issued to Gameskraft Technologies for allegedly misclassifying betting transactions as services instead of actionable claims - Revenue contended that staking money on any game including skill games transforms activity into betting and gambling taxable at twenty eight percent on face value - Assessees argued that online rummy and fantasy sports are games of skill protected under Constitution and only platform fees constitute consideration - Supreme Court observed that essential element of betting and gambling is staking value on uncertain outcomes regardless of underlying skill - Court held that once element of betting enters the activity it attracts characteristics of betting and gambling for GST - Held - Activities on online gaming platforms involving staking upon uncertain outcomes constitute supply of actionable claims within GST framework - Karnataka High Court judgment set aside - show cause notices restored - [Paras 1-86].

Civil Law - Goods - Central Goods and Services Tax Act 2017 - Section 2(52) - Interpretation of Actionable Claims - Assessees contended that actionable claims only arise from sovereign grants and must be enforceable in law - Supreme Court noted Section 2(52) includes actionable claims within definition of goods - Definition under Transfer of Property Act 1882 includes contingent beneficial interests in movable property - Online gaming involves participants acquiring contingent interests in prize pools upon staking - Held - Inclusion of actionable claims within definition of goods is constitutionally valid and covers interests arising from betting or gambling transactions - [Paras 51.1-52.13].

Civil Law - Interpretation of Statutes - Central Goods and Services Tax (Amendment) Act 2023 - Entry 6 of Schedule III and Rules 31B and 31C - Retrospectivity - Assessees argued that 2023 amendments introduced a fresh levy on online money gaming and casinos - Court found that taxability of such transactions already existed under pre-amendment framework through Rule 31A - Amendments merely provided specific valuation methods and statutory definitions to remove ambiguity - Held - Amendments introduced in 2023 are clarificatory and explanatory in nature and consequently operate retrospectively - [Paras 66-67.1].

Civil Law - Valuation - Central Goods and Services Tax Rules 2017 - Rules 31 31A and 31C - Casino Gaming - Casino operators challenged demand based on Gross Bet Value and absence of machinery provisions prior to Rule 31C - Revenue resorted to best judgment assessment using house advantage percentages - Supreme Court observed that GST is a tax on supply and not on profits or net revenue - Rule 31C refined valuation by linking it to amount paid for purchase of chips or tokens - Held - Recourse to Rule 31 and best judgment methodologies permissible in absence of records - actual computation for casinos must now be aligned with retrospective Rule 31C - [Paras 80-83.8].

Writ Law - Jurisdiction - Constitution of India - Article 32 and 226 - Alternative Remedy - Respondents argued that Special Leave Petitions were not maintainable due to availability of alternative remedy before Division Bench - Supreme Court noted the dimensions of nationwide constitutional controversy involving transferred cases and common questions of law - Held - In view of the commonality of interlinked issues and substantial revenue implications the Court exercised jurisdiction to provide final authoritative determination - [Paras 1-14].

Decision: Civil appeals preferred by Revenue allowed – Common judgment of Karnataka High Court set aside – Show cause notices restored – Writ petitions and Transferred Cases of assessees dismissed – 2023 amendments held retrospective – Valuation of online gaming and casinos to be governed by Rules 31B and 31C respectively – Time for submitting replies to show cause notices fixed at eight weeks.

Service Law - Promotion - Recruitment Rules - Appellants being Head Constables in Andaman and Nicobar Police Department challenged the 2008 and 2010 Rules which introduced matriculation and selection tests for promotion to ASI-Executive - During litigation 2016 Rules were notified substituting previous rules and restoring 100 percent seniority-cum-fitness basis without educational hurdles - Tribunal dismissed the original application as infructuous noting that the 2016 Rules satisfied the appellants' prayers - High Court set aside the Tribunal's order holding that vacancies must be filled as per rules prevailing when they accrued while relying on Marripati Nagaraja - Supreme Court noted that the previous principle in Y.V. Rangaiah was expressly overruled in State of Himachal Pradesh v. Raj Kumar - Held - Public servants do not possess a vested right to be considered under old rules - Right to be considered for promotion is governed exclusively by rules in force at the time the promotion is considered - High Court judgment set aside - [Paras 1-32].

Service Law - Applicability of Rules - Vested Rights - Rule in force at time of consideration - Dispute over whether old vacancies must be filled under repealed 2010 Rules or new 2016 Rules - Court relied on Raj Kumar precedent - Held - There is no rule of universal application that vacancies must be filled on the basis of the law existing when they arose - Government is entitled to take a conscious policy decision to restructure cadres for efficiency - Candidates only have a right to be considered in light of the rule in force on the date consideration takes place - [Paras 18-24].

Service Law - Statutory Interpretation - Word Substitution - Effect of amendment by substitution - Analysis of the impact of 2016 Rules on 2010 Rules - Held - Substitution typically results in the repeal of the earlier provision and its replacement by the new provision - The process involves the old rule ceasing to exist and the new rule being brought into its place - Unless a contrary intention is shown the new rule becomes the sole legal basis for regular promotions - [Paras 28-30].

Service Law - Ad hoc Promotion - Vested Rights - Respondent Nos. 1 to 28 were promoted on an ad hoc basis subject to the outcome of litigation - Held - Ad hoc promotions with explicit riders denying seniority do not confer permanent rights - Such promotions are not completed acts and do not create vested rights to retain positions once rules are substituted - [Paras 27-29].

Decision: Civil Appeal allowed – Judgment of the High Court dated 10.08.2016 set aside – Existing vacancies of ASI-Executive directed to be filled under the 2016 Rules within two months.

Civil Law - Specific Performance - Code of Civil Procedure 1908 - Section 100 - Scope of Second Appeal - Appellant-purchaser entered into sale agreement for Rs 9.30 lakhs and paid Rs 9 lakhs as earnest money - Trial Court decreed specific performance finding agreement genuine - First Appellate Court denied specific performance citing lack of readiness and willingness - High Court in Second Appeal modified order holding agreement was merely security for a different transaction - Supreme Court held that High Court exceeded jurisdiction under Section 100 CPC by reversing concurrent findings of fact on genuineness of agreement without finding perversity or material illegality - Held - High Court cannot reappreciate evidence just to replace findings of lower courts especially when two inferences are possible - appeal allowed - [Paras 2-16].

Civil Law - Specific Performance - Specific Relief Act 1963 - Section 16(c) - Readiness and Willingness - Plaintiff paid 93 percent of total sale consideration - Legal notice issued shortly after four-month stipulated period - Suit filed within limitation - High Court and First Appellate Court denied relief stating delay in issuing notice proved lack of readiness - Supreme Court observed that readiness and willingness must be gathered from entirety of facts including overall conduct - Payment of substantial portion of consideration and filing suit within limitation demonstrate continuous willingness - Held - In India mere delay cannot be ground for refusing specific performance if suit is filed within limitation period - plaintiff sufficiently established continuous readiness - [Paras 17-21].

Decision: Appeal allowed – Impugned High Court judgment and First Appellate Court judgment set aside – Trial Court judgment and decree for specific performance dated 21.12.2012 restored.

Civil Law - Merger Control and Disclosure Obligations - Competition Act 2002 - Sections 6(2) and 31(1) - Regulations 9(4) and 9(5) - Comprehensive Notification - Appellant acquired 49 percent stake in Future Coupons Private Limited (FCPL) - The transaction was notified via Form I and approved by CCI on 28.11.2019 - Subsequently CCI received complaints from Future Group alleging non-disclosure of strategic intent over Future Retail Limited (FRL) and inter-connected Business Commercial Agreements (BCAs) - CCI issued a show cause notice and later passed an order keeping the 2019 approval in abeyance while imposing penalties - Supreme Court scrutinized the contemporaneous regulatory record and found that copies of the FRL Shareholders Agreement and BCAs were already on record during the original review - CCI had previously queried FRL-linked overlaps and conducted a retail-market assessment - Held - Regulation 9(4) does not make the sufficiency of notice depend upon the notifying party's adoption of the regulator's later characterization - once instruments and linkages are disclosed and assessed at the ex ante stage the functional requirement of a single comprehensive notice is satisfied - a later disagreement on labels or interpretive emphasis cannot convert an approved filing into non-notification - [Paras 145-161].

Civil Law - Penalties for Non-Notification - Competition Act 2002 - Section 43A - Failure to give notice - CCI and NCLAT held that failure to characterize specific agreements as transaction documents amounted to failure to notify the complete combination - Supreme Court held that Section 43A is a penal provision restricted to the statutory default of failing to give notice under Section 6(2) - it cannot be expanded into an omnibus penalty for every alleged deficiency in drafting or presentation in a notice that was actually filed- processed- and adjudicated - where the relevant agreements were on record and processed in a single review culminating in approval the jurisdictional premise for Section 43A is not satisfied - Held - imperfect characterization is not synonymous with non-notification - [Paras 162-180].

Civil Law - Misrepresentation and Materiality - Competition Act 2002 - Sections 44 and 45 - Internal Communications as Evidence - CCI relied on internal emails of the appellant predating the final agreements to find suppression of true commercial intent - Supreme Court observed that penal liability cannot rest on pre-execution internal formulations which were superseded by binding transaction documents - combination review is grounded in the executed structure and operative rights created thereby - materiality must be tested against the CCI's ability to perform its statutory ex ante assessment - since the original approval order itself recorded engagement with retail-sector overlaps the premise that CCI was disabled from assessing the transaction was negated - Held - findings of suppression and misrepresentation not sustainable without demonstrating a mismatch between required and furnished information that actually affected the regulatory review - [Paras 181-217].

Civil Law - Jurisdictional Limitation - Competition Act 2002 - Proviso to Section 20(1) - Finality of Combinations - CCI issued show cause notice in June 2021 regarding a transaction that took effect in December 2019 - Supreme Court held that the proviso to Section 20(1) imposes a strict jurisdictional limitation prohibiting the initiation of any inquiry into a combination after the expiry of one year from the date it has taken effect - this limitation cannot be defeated by characterizing an inquiry into combination merits as something else - directions to keep an approval in abeyance and compel re-notification effectively reopen the combination review - Held - post-facto steps whose operative effect is to reopen merger review after the statutory period are barred by limitation - [Paras 218-234].

Civil Law - Statutory Power of Regulator - Competition Act 2002 - Section 31 and Section 45(2) - Approval in Abeyance - CCI kept its 2019 approval order in abeyance - Supreme Court held that the CCI is a creature of statute and lacks inherent power of review or recall unless expressly conferred - Section 31(1) provides for approval as a terminal decision and does not contemplate a provisional category of approval kept in suspended animation - Section 45(2) is a penal adjunct and cannot be used as an independent source of substantive power to nullify a concluded approval - Regulation 5(5) is part of the procedural machinery for pending notices and cannot revive an exhausted notice process - Held - directions issued lacked statutory basis and undermined the predictability essential to the merger control regime - [Paras 235-257].

Civil Law - Natural Justice - Show Cause Notice - Scope and Consequence - Show cause notice dated 04.06.2021 focused on contradictions in narrative but did not foreshadow the directions to keep approval in abeyance or compel fresh Form II filing - Supreme Court observed that the final order rested on a materially sharpened case and expanded factual reliance - fairness requires that proposed directions affecting legal rights and settled positions be clearly disclosed as part of the case to be met - NCLAT's endorsement cannot retrospectively supply the notice that natural justice requires at the first instance - Held - impugned proceedings vitiated for breach of principles of natural justice - [Paras 258-280].

Decision: Appeal allowed - Judgment of NCLAT dated 13.06.2022 and CCI order dated 17.12.2021 set aside - Refund of any deposited penalty ordered with 6 percent simple interest - No order as to costs.

Civil Law - Insolvency and Bankruptcy - Insolvency and Bankruptcy Code 2016 - Section 62 - Letter of Intent - Conditional acceptance - Appellant being the Promoter of the Corporate Debtor challenged the validity of the Letter of Intent issued by the Resolution Professional alleging it was conditional because of clauses making it subject to pending third-party applications and employee litigation risks - Appellant also contested the reduction of time for submitting the performance guarantee from 45 to 7 days - The NCLT and NCLAT dismissed the objections holding that the appellant was aware of litigations during Committee of Creditors meetings and had expressly agreed to the terms - The Supreme Court found the stand of the appellant bereft of merit observing that stipulations regarding judicial decisions are part of the legal reality and do not allow an applicant to renege - Held - The objections were a clear subterfuge to shift blame on the Committee of Creditors for the unwillingness of the appellant to implement the plan - Appeals dismissed - [Paras 1-22].

Civil Law - Doctrine of Election - Insolvency and Bankruptcy Code 2016 - Section 31 - Approbate and Reprobate - Appellant participated in various Committee of Creditors meetings and initially requested the issuance of a Letter of Intent but later raised preliminary objections regarding its conditional nature to avoid performance guarantee obligations - Supreme Court applied the doctrine of acquiescence and election noting a party cannot blow hot and cold or accept benefits while denying validity - Held - The conduct of the appellant was an indirect attempt to renege from the plan after it had been approved by the Committee of Creditors - [Paras 26-30].

Civil Law - Resolution Plan - Insolvency and Bankruptcy Code 2016 - Sections 30 and 31 - Irrevocability - Once the Committee of Creditors after applying its commercial wisdom has approved a resolution plan the successful resolution applicant is prohibited from negotiating further or seeking modifications - The only remaining conditionality is the approval of the adjudicating authority which has limited jurisdiction under Section 31 - Held - A submitted resolution plan is binding and irrevocable between the Committee of Creditors and the successful resolution applicant to ensure the purpose of the Code is achieved - [Paras 31-32].

Civil Law - Liquidation - Insolvency and Bankruptcy Code 2016 - Section 33 - Commercial Wisdom - The Committee of Creditors voted for the liquidation of the Corporate Debtor with a voting majority of 99.61 percent after the successful resolution applicant failed to comply with the terms of the Letter of Intent - Appellant challenged the liquidation as being contrary to Section 33 - Supreme Court observed that the Committee of Creditors is statutorily empowered to decide on liquidation at any time before the confirmation of the resolution plan as per the explanation to Section 33 clause 2 - Held - The decision of the Committee of Creditors is a business decision taken in exercise of commercial wisdom and is not amenable to judicial review - [Paras 36-42].

Decision: Appeals dismissed – All interim orders stand vacated – Respondent No. 3 Liquidator directed to proceed with the remaining part of the liquidation in accordance with the Code.

Criminal Law - Murder and Rape - Indian Penal Code 1860 - Sections 34-201-302-376 and 376(2)(g) - Conviction for rape and murder of 55 year old woman based on circumstantial evidence - Trial Court awarded death sentence which was confirmed by the High Court - Prosecution case rested on the last seen together theory and recovery of incriminating articles - Supreme Court found that the two youths were only seen asking for directions and were not seen in the company of the deceased - Identity of the sketch artist was withheld and no Test Identification Parade was conducted despite the accused being strangers - Recoveries of a shirt pocket and ornaments were found to be suspicious and potentially planted - Forensic evidence was inconclusive as the blood group detected was common and the accused's group was not tested - Medical evidence suggested an inability of the accused to perform intercourse - Held - The chain of circumstances was not complete and could not exclude the hypothesis of innocence - Conviction set aside and appellants acquitted - [Paras 1-93].

Evidence Law - Circumstantial Evidence - Indian Evidence Act 1872 - Section 3 - Principles of proof - In cases resting solely on circumstantial evidence the prosecution must prove each link beyond reasonable doubt and the chain must be so complete as to lead to the irresistible conclusion that the accused alone is the perpetrator - Mere suspicion cannot take the place of legal proof - Held - Prosecution failed to establish an unbroken chain pointing unerringly towards the guilt of the accused - [Paras 39-42].

Criminal Law - Identification - Code of Criminal Procedure 1973 - Section 161 - Test Identification Parade - Failure to conduct TIP when accused were strangers to witnesses - Witnesses were shown the accused while in police custody before dock identification - Held - Failure to hold TIP materially undermines the credibility of the prosecution version and diminishes the evidentiary value of dock identification - [Paras 55-57].

Evidence Law - Forensic Evidence and Chain of Custody - Indian Evidence Act 1872 - Section 27 - Recovery of articles - Delay in transmission of seized articles to Forensic Science Laboratory without explanation - Lack of evidence regarding safe custody in malkhana - Shirt pocket matching was found doubtful as the pocket appeared carefully unpicked and not violently torn - Held - Integrity of forensic samples becomes doubtful in the absence of a proved chain of custody and scientific reports based thereon lose evidentiary value - [Paras 70-80].

Criminal Law - Motive and Medical Evidence - Indian Penal Code 1860 - Section 376 - Medical condition of accused - Examining doctor deposed that Accused No 1 suffered from a medical condition making sexual intercourse impossible - No DNA profiling conducted to establish source of semen or connect it to the appellants - Held - Theory of motive for satisfying carnal desire becomes highly doubtful and fails to inspire confidence - [Paras 85-87].

Decision: Appeals allowed – Conviction and sentence passed by the Trial Court as affirmed by the High Court are set aside – Appellants acquitted of all charges and directed to be released from custody forthwith.

Civil Law - Motor Accident Claim - Motor Vehicles Act 1988 - Section 166 - Compensation - Deduction of Statutory Ex-gratia Benefits - Deceased was a 25-year-old Constable in Haryana Police - Tribunal awarded 37,30,680 rupees with 8 percent interest - High Court reduced the total award to 7,70,400 rupees after deducting 29,21,400 rupees being the financial assistance payable under the Haryana Compassionate Assistance to the Dependents of Deceased Government Employees Rules 2006 - High Court held that the mother was not eligible for assistance under the 2006 Rules and the father was a retired pensioner not dependent - Appellants contended that deduction caused financial hardship and the mother's entitlement under the Act could not be settled against assistance she never received - Supreme Court examined the conflict between the Shashi Sharma principle of avoiding dual benefits and the requirement of awarding just compensation under the Act - Held - while the 2006 Rules assistance is deductible to prevent duality of loss of income - such deduction cannot be used to negate the entitlement of a dependent mother who is ineligible for state assistance under the 2006 Rules because the deceased was survived by a widow and child - Statutory rules must be strictly interpreted and cannot result in the illegal enrichment of the insurance company at the cost of a dependent parent - High Court's order modified to add the mother's one-third share of 11,30,600 rupees back to the award - total compensation enhanced to 19,01,000 rupees - [Paras 1-26].

Civil Law - Duality of Benefits - Motor Vehicles Act 1988 - Section 166 - Set-off of Ex-gratia Assistance - Haryana Compassionate Assistance Rules 2006 - Rule 5 - Interpretation of precedent - Principle established in Shashi Sharma dictates that financial assistance equivalent to last drawn salary for a specific period is meant to provide immediate socio-economic support - Held - such payments are deductible while computing compensation under the head of loss of dependency to ensure compensation does not exceed actual pecuniary loss - however - benefits like future escalation of income and other statutory exclusions like family pension or life insurance must remain unaffected and cannot be deducted - [Paras 13-15, 19-21].

Civil Law - Dependency Entitlement - Family Pension Scheme 1964 - Para 4 - Eligibility of Parents - Conflict between state rules and welfare legislation - Under Rule 3 of the 2006 Rules eligibility for assistance is determined by the 1964 Scheme which excludes parents if the deceased employee left behind a widow or child - Deceased was survived by a widow and a daughter - Held - the mother is not an eligible family member for the ex-gratia financial assistance but remains an admitted dependent under the Motor Vehicles Act - the independent legal injury suffered by the mother cannot be ignored - just and adequate compensation requires that her one-third share of the assessed loss of dependency be awarded regardless of the deductions applied to other eligible family members - [Paras 16-18, 22-25].

Decision: Appeal disposed of – Total compensation enhanced to 19,01,000 rupees – Mother's share of 11,30,600 rupees added to the High Court's award – Respondents directed to pay the amount within eight weeks with interest as awarded by the Tribunal.

Civil Law - Chronic Litigation - Abuse of Process - Miscellaneous application arising from Registrar order dated 16.10.2025 in a matter involving land compensation claims - Applicant claiming to be a Sanyasi sought further relief for land allegedly encroached by the State in 2002 - Litigation history revealed SLP(C) No. 9085 of 2016 was dismissed in 2021 noting that 0.202 hectares of land was already allotted to the applicant in 2005 - Applicant subsequently filed a recall application, a Writ Petition in the High Court of Allahabad, a Contempt Petition, and a Review Petition, all of which were dismissed or withdrawn - Undisputed facts established that against an original plot of 11000 sq. feet, the applicant received an allotted plot of 21000 sq. feet and monetary compensation totaling INR 7,58,575 - Applicant had already constructed an Ashram and Temple on the allotted land - Court found that the grievance was remedied long ago and the matter had attained finality - Held - The applicant is a chronic litigant whose actions constitute a sheer wastage of precious judicial time - Miscellaneous application dismissed - Direction issued that no future litigation regarding this subject matter shall be entertained by any Court - [Paras 1-10].

Civil Law - Costs - Judicial Restraint - Repeated Filing - Applicant's conduct found to be an abuse of the legal process deserving of heavy costs - Court observed that the applicant appeared in person and claimed to be a Sanyasi - Held - Keeping in view the applicant's status as a Sanyasi, the Court refrained from imposing financial costs while dismissing the application - [Paras 8-9].

Decision: Miscellaneous Application dismissed – No orders as to costs – Direction issued that no litigation in respect of the present subject matter shall be entertained by any Court in future.

Writ Law - Road Safety and Trauma Care - Constitution of India - Article 21 - Right to Life - Petitioners filed writ seeking Mandamus for robust emergency care mechanism - argued that lack of quick access to trauma care is a major fatality cause - emphasized that right to trauma care is integral to right to life - Union submitted that it acts as enabler through schemes like PM RAHAT and Good Samaritan Rules - implementation by States is fragmented - Court observed that sustained efforts by Union and States in unison are required to reduce preventable deaths - Held - Right to trauma care recognized as part of Article 21 - interim directions issued to States and UTs for technical integration of ambulance helplines into universal number 112 - implementation of medical rescue protocols - adoption of standardized EMT curriculum - [Paras 1-13].

Writ Law - Good Samaritans - Motor Vehicles Act 1988 - Section 134A - Protection from legal harassment - Petitioners highlighted bystander hesitation due to fear of police summons or legal proceedings - referred to previous judgment in Savelife Foundation v. Union of India regarding protection guidelines ratified through the 2019 Amendment - Held - All States and UTs directed to establish functional physical and digital Good Samaritan Grievance Redressal Systems with designated nodal authorities at State and District levels within three months - [Paras 5-12].

Writ Law - Emergency Medical Services - Central Motor Vehicles Rules - Rule 125H - Ambulance Standards and GPS Integration - Direction sought for compliance with National Ambulance Code and GPS tracking - Held - States directed to ensure full Automotive Industry Standard 125 (AIS-125) compliance for all ambulances - mandate Vehicle Location Tracking Device (VLTD) fitment - real-time integration with helpline 112 - conduct periodic structured audits regarding response times and quality of care - [Paras 2-12].

Writ Law - Cashless Treatment Scheme - Motor Vehicles Act 1988 - Section 134A - PM RAHAT Scheme - Petitioners prayed for cashless schemes for road crash victims - Union already framed uniform national scheme known as PM RAHAT - Held - All States and UTs directed to fully operationalize PM RAHAT scheme within eight weeks including hospital designation - on-boarding of State Health Agencies - deployment of district-police on electronic Detailed Accident Report (eDAR) - non-implementation to be treated as violation of the MV Act - [Paras 11-13].

Decision: Interim directions issued – States and Union Territories directed to ensure time-bound compliance – Matter listed after four months for compliance reports.