Public Safety – Stray Dog Menace – Suo Motu – National Directions – SC mandates States/UTs to secure institutional areas, remove stray animals from highways, create patrol systems, ensure anti-rabies medication, install helplines, and implement ABC Rules uniformly – Non-compliance to invite serious consequences including contempt [Paras 5-11, 12-33].

Stray Dogs – Compliance by States & UTs – Amicus Report – Court takes on record summary highlighting deficiencies in compliance affidavits and directs all States/UTs to file additional, comprehensive affidavits—Lethargy to be viewed seriously [Paras 5-7].

Highway Safety – Cattle & Stray Animals – Adoption of Rajasthan High Court Directions – SC reaffirms High Court of Rajasthan’s mandate requiring municipal, PWD, transport departments and NHAI to jointly remove stray cattle/animals from National and State Highways—Continuous surveillance, 24×7 patrol teams, relocation to shelters, and helpline numbers mandated nationwide [Paras 8-11].

Right to Life – Article 21 – Hazardous Public Spaces – SC observes alarming increase in dog-bite attacks in educational institutions, hospitals, sports complexes, ISBTs, bus stands, and railway stations—Recognizes systemic administrative failure and threat to citizens, especially children, elderly, patients, and commuters [Paras 12-17, 19-24].

Animal Birth Control (ABC) Rules – Implementation Failures – Court notes persisting inefficacy of Capture–Sterilise–Vaccinate–Release (CSVR) model due to poor municipal execution—Uncontrolled dog population continues to endanger public health despite statutory framework [Paras 14-16, 22-23].

Institutional Areas – Nationwide Mandate – States/UTs to identify all educational institutions, hospitals, stadiums, bus depots/ISBTs and railway stations—Premises to be secured with fencing, gates, barriers, and structural safeguards within 8 weeks—Nodal Officers to be designated for each institution [Paras 25(A)-(C)].

Municipal Vigil & Removal Protocol – Municipal bodies to inspect institutional premises every three months—Every stray dog found in institution to be removed, sterilised, vaccinated and shifted to shelters—Crucially: Such dogs shall NOT be released back to same location to ensure dog-free institutional zones [Paras 25(D)-(E)].

Health Measures – Mandatory Stock – Hospitals to compulsorily maintain anti-rabies vaccines and immunoglobulin—Education Ministry to ensure awareness programmes in schools on preventive behaviour and first aid [Paras 25(F)-(G)].

Sports & Transport Facilities – Enhanced Vigil – Stadiums to deploy dedicated staff for round-the-clock prevention of dog entry—Railway authorities, transport corporations, and municipal bodies to ensure strict perimeter control, waste management, and regular inspections in bus stands/depots and railway stations [Paras 25(H)-(I)].

Animal Welfare Board of India – SOP Mandate – AWBI to issue detailed nationwide SOPs for prevention and management of stray dogs in institutional premises within four weeks [Para 25(J)].

Compliance & Accountability – Chief Secretaries and NHAI Chairperson to file affidavits within 8 weeks—Union of India also directed to secure all centrally-administered institutions—Non-compliance may lead to suo motu contempt proceedings [Paras 26-33].

Criminal Law – Quashing of FIR on basis of settlement – Section 482 CrPC – Property dispute involving allegations under Sections 406, 420, 465, 467, 468, 471, 120B, 294(b) and 506(2) IPC – High Court dismissed application under Section 482 CrPC seeking quashing of FIR registered at Halol Town Police Station, District Panchmahal – During pendency of SLP, parties entered into a written settlement dated 23-06-2025 – Supreme Court, by order dated 08-09-2025, took note of settlement, recorded obligation to hand over half portion of the property to complainant, and directed jurisdictional court to appoint a bailiff to deliver possession of the agreed property and submit report – On counsel for both sides conceding that parties will abide by terms of settlement and that disputes inter se stand resolved, Supreme Court set aside impugned High Court order and quashed FIR and all proceedings emanating therefrom in terms of the settlement – Held: Criminal proceedings arising out of essentially private property dispute liable to be brought to an end when parties have fully and voluntarily settled their disputes and agreed to honour settlement, including transfer of possession through court process [Paras 2-3, 6-8].

Criminal Procedure – Compliance with settlement – Court-directed delivery of possession through bailiff – In view of settlement providing that half of the property be given to complainant, Supreme Court found it appropriate, before closing criminal proceedings, to ensure that possession of the property described in settlement is actually delivered – Jurisdictional court directed to appoint bailiff to take possession and submit report within two weeks – Interim protection granted that no coercive steps be taken against petitioners meanwhile – Bailiff’s report ultimately received showing execution of settlement between parties – Held: Once possession in terms of settlement is delivered and settlement is duly executed, criminal proceedings can be quashed as continuation thereof would be an abuse of process in the context of a purely private dispute [Paras 3, 4, 6-8].

Judicial Administration – Non-compliance with Supreme Court’s directions – Explanation by High Court Registry – Despite earlier orders dated 08-09-2025 and 06-10-2025 directing production of bailiff’s report, the same was not forwarded to Supreme Court – Court on 27-10-2025 issued notice to Registrar General of High Court of Gujarat to explain why Judges of trial court had not sent report despite two orders, and warned that, in absence of report, Court would be constrained to seek presence of jurisdictional Judge and District Judge – Registrar General subsequently filed affidavit dated 01-11-2025 explaining delay as lapse on part of officers posted in Registry – Explanation placed on record and matter proceeded on basis of now-available bailiff report and executed settlement – Observed: Lapses in administrative compliance with orders of Supreme Court must be explained by concerned High Court Registry and may invite notice and directions from Court [Paras 4-6].

**Special Leave Petition – Conversion into Criminal Appeal – Effect of settlement post-grant of leave – Leave granted and SLP converted into criminal appeal – Settlement between parties having been recorded, Court treated all disputes inter se as resolved and disposed of appeal by setting aside High Court order and quashing FIR and all proceedings – Pending interlocutory applications also disposed of – Held: Once leave is granted and appeal is on board, Supreme Court can mould relief in terms of subsequent settlement duly accepted by parties, including quashing of FIR and setting aside orders impugned before it [Paras 1-2, 7-9].

Decision: Appeal allowed – Impugned order of the High Court dated 01.03.2024 in Criminal Miscellaneous Application No. 4140 of 2024 set aside – FIR No. 11207028210655 of 2021 dated 31.08.2021 registered at Halol Town Police Station, District Panchmahal, Gujarat, and all proceedings emanating therefrom quashed in view of settlement dated 23.06.2025 – Parties bound to abide by terms of settlement – Pending applications, if any, also disposed of [Paras 7-9].

Arbitration – Public Policy – Patent Illegality – Arbitral Award Set Aside – Arbitrator awarded reimbursement for second regular meals and welcome drinks to caterers despite express contract and circulars stating otherwise – Supreme Court held that this amounted to rewriting the contract – Held: Arbitrator failed to consider binding policy decisions of Railway Board which governed the MLA and exceeded his jurisdiction under Section 28(3) of the Act – Award found to be patently illegal and in conflict with public policy of India – Set aside under Section 34(2A) and 34(2)(b)(ii) [Paras 62–72].

Contract – Government Policy – Supremacy of Railway Board Circulars – No Unilateral Deviation Permissible – Circulars dated 23.10.2013 and 06.08.2014 formed basis of contract and fixed rates for meals and services – Clause 21.1 of Master Licence Agreement gave precedence to Railway policy over other contractual provisions – Held: No deviation permissible from binding Railway Board circulars – Arbitrator’s contrary interpretation was unjustified [Paras 56–60, 68–69].

Arbitration – Scope of Interference under Sections 34 and 37 – Limits of Judicial Review Reaffirmed – Court reiterated limited grounds of interference under Section 34(2A) – Held: Courts cannot reappreciate evidence or correct errors of law unless award shocks conscience or contravenes fundamental policy – Arbitrator’s findings that ignored binding government policy warranted judicial interference [Paras 63–67].

Interest – Arbitrator’s Award on Lump Sum Interest Set Aside – Arbitrator Awarded Interest from 01.01.2018 on Entire Claim Though Claims Arose Periodically – Division Bench rightly held that interest award was erroneous – Supreme Court: In light of full setting aside of award, interest claim becomes infructuous [Paras 43, 72].

Catering Contracts – Welcome Drink Charges – Reimbursement Denied – Bid documents and Clause 8.1 of MLA permitted menu changes – Circulars contemplated welcome drink as part of service without separate charges – Held: No entitlement to separate payment – Arbitrator’s award unjustified [Paras 60–61, 71].

Decision: Appeals of IRCTC allowed – Arbitral award dated 27.04.2022 (corrected on 26.07.2022) and Delhi High Court’s judgments dated 13.08.2024 and 10.02.2025 set aside – Cross appeals filed by caterers dismissed – Parties to bear own costs.

Criminal Procedure – Arrest – Communication of Grounds – Mode, Timing, and Language – Arrest without written communication of grounds violative of Articles 21 and 22(1) – Arrest and remand thereby rendered illegal – Minimum requirement: Written grounds of arrest to be furnished at least two hours before production for remand – Applies to all offences including under BNS 2023 [Paras 46–58].

Constitutional Law – Grounds of Arrest – Article 22(1) Violation – Arrest declared illegal if grounds not furnished in writing – mandatory communication of grounds of arrest under Article 22(1) of the Constitution and Section 47 BNSS 2023 (formerly Section 50 CrPC 1973) – Supreme Court holds that the right to be informed of the grounds of arrest is a fundamental right and must be meaningfully communicated in writing in the language understood by the arrestee – Oral communication deemed insufficient, except in limited exigent circumstances, where delay in furnishing written grounds must be justified and completed at least two hours before production for remand – Held: Arrest and remand without such compliance are illegal [Paras 2, 7, 33–36, 39–41, 46, 49–55].

Procedure for Arrest – Mode and Timing of Communication – Arrest in Exceptional Situations – Supreme Court clarifies that written grounds of arrest must be furnished to arrestee in all cases, including offences under BNS 2023 (formerly IPC 1860), UAPA, PMLA, or other statutes – Exception carved out for flagrant arrests during commission of crime or in exigent circumstances – In such cases, oral communication at the time of arrest permitted, but written grounds must be furnished within a reasonable time, and in no case later than two hours before production before magistrate for remand – Remand papers must include such grounds and note cause for any delay – Held: This framework balances fundamental rights and law enforcement needs [Paras 7, 41, 48–54].

Fundamental Rights – Article 21 and 22 – Personal Liberty and Legal Aid – Right to legal representation and to oppose remand must be made effective by timely communication of grounds of arrest – Supreme Court emphasizes the importance of early access to legal assistance and meaningful opportunity to contest arrest – Cites Suhas Chakma and Ashok v. State of U.P. for reinforcing right to legal aid at pre-remand stage – Communication in a language not understood by arrestee held to defeat the constitutional safeguard under Article 22(1) – Arrest without such safeguards is unconstitutional [Paras 17–20, 35–38, 42–45].

Interpretation of Precedents – Harmonizing Case Law – Court harmonizes earlier judgments – Pankaj Bansal, Prabir Purkayastha, and Vihaan Kumar – Holds that while earlier decisions dealt with special statutes (UAPA, PMLA), the principle of furnishing grounds of arrest in writing applies universally, including to BNS 2023 – Clarifies that Article 22(1) is not offence-specific – Held: Earlier inconsistent High Court views not good law [Paras 9–13, 22–27, 56–58].

Police Powers and Duties – Arrest Procedure – Statutory Compliance under BNSS 2023 – Sections 47 and 48 BNSS mandate informing arrestee and their relatives about the arrest and grounds thereof – Court directs that these duties be recorded in station diary – Magistrates must satisfy themselves that these safeguards have been followed – Emphasizes purpose behind these provisions is to protect liberty, avoid arbitrariness, and reduce custodial abuse – Held: Violation of these procedural duties renders arrest and remand void [Paras 19–21, 47].

Impact of Arrest – Social and Psychological Consequences – Supreme Court acknowledges the deep psychological and societal stigma of arrest – Arrest causes irreversible reputational damage and mental health deterioration – Cites Arnesh Kumar and Joginder Kumar to reinforce that arrest is not to be made mechanically – Held: Arrest powers must be exercised cautiously, keeping in view the consequences and the requirement to inform the arrested person meaningfully [Paras 28–31].

Decision:

– Criminal Appeal No. 2195 of 2025 disposed of, as issue of law has been settled – Appeal not entertained on merits [Para 59]

– Ad interim bail granted in Criminal Appeals No. 2189 & 2190 of 2025 to continue – Liberty to prosecution to seek remand after supply of written grounds [Para 60]

– Ad interim bail in SLP (Crl.) No. 8704 of 2025 to continue – Matter to be listed before appropriate bench [Para 63]

– Registry directed to circulate this judgment to Registrar Generals of all High Courts and Chief Secretaries of States/UTs [Para 65]

Motor Accident Claim - Motor Vehicles Act, 1988 – Section 166 – Compensation – Split Multiplier – Applicability – High Court reduced compensation by applying split multiplier on assumption of post-retirement income reduction – Held: There exists divergence among High Courts on applying split multiplier – Following Sarla Verma v. DTC (2009) 6 SCC 121 and Pranay Sethi (2017) 16 SCC 680, the multiplier must depend solely on age of the deceased – Retirement or superannuation cannot be treated as an “exceptional circumstance” to justify a split multiplier – Split multiplier is foreign to the Motor Vehicles Act and should not be used by Tribunals or Courts [Paras 14–19].

Judicial Discipline – Divergence of Views – Intra-Court Conflicts – Supreme Court expressed concern over inconsistent approaches by coordinate benches within same High Courts, leading to uncertainty for Motor Accident Claims Tribunals – Directed that where conflicting views exist, the matter should be referred to a larger bench to maintain judicial propriety [Para 14].

Motor Accident Compensation – Income Assessment – Future Prospects – Income at the time of death to be taken as base for computation – Future prospects of 15% correctly applied for deceased aged 51 years – High Court failed to comply with directive in Pranay Sethi regarding 10% enhancement under conventional heads every three years – Corrected computation yielded total compensation of ₹47,76,794/- [Paras 19–20].

Directions – Prospective Application – Circulation to High Courts and Tribunals – The ruling on non-applicability of split multiplier to operate prospectively – Registrar (Judicial) directed to circulate copy to Registrars General of all High Courts and to Motor Accident Tribunals for uniform application [Para 22].

Decision: Appeals allowed – High Court judgment dated 28.06.2024 and review orders dated 27.11.2024 set aside – Tribunal award dated 02.04.2014 restored with modification to ₹47,76,794/- compensation and interest @7.5% p.a. – Directions for remittance of compensation to appellants’ bank accounts before 30.11.2025 – Prospective effect clarified [Paras 20–23].

Municipal Law – Building Plan Sanction – Mixed-Use Regulations – Whether owner can be compelled to construct commercial ground floor in notified mixed-use streets – Held: No; mixed-use is only permissive, not mandatory – Authorities acted arbitrarily in denying sanction for purely residential construction – Deemed sanction upheld – Directions to approve fresh plans within four weeks – Costs of ₹10 lakhs imposed on SDMC for harassment [Paras 10–16, 19–20].

Building Plan Sanction – Mixed-Use Streets – MPD-2021 – Commercial Use Permissive, Not Mandatory - Mixed-use notification (15.09.2006) and Circular dated 27.05.2009 make it clear that commercial use on ground floor of mixed-use streets is optional – Owner may choose to develop property as (i) commercial, (ii) mixed-use, or (iii) purely residential – The circular expressly states that plans “can be sanctioned… as per the choice of the applicant” – High Court correctly held that owners cannot be forced to convert ground floor to commercial use [Paras 10–12].

Municipal Governance – Arbitrary Refusal of Sanction – Appellant’s Case Found Illogical and Contrary to Record - SDMC’s argument that respondents must compulsorily maintain a commercial ground floor is inconsistent with its own earlier case that the plans lacked stilt parking – No statutory instrument mandates compulsory commercial use – Court finds SDMC’s stand irrational, illogical, and contrary to MPD-2021 – Forcing citizens to set up shops when they desire only residential use held wholly unjustified [Paras 9, 13–14].

Dilapidated Structure – Fundamental Right to Rebuild – Municipality Cannot Prevent Reconstruction of Unsafe Home - Respondents’ 85-year-old residential house (constructed in 1940) was in a dangerously dilapidated condition – Court notes photographic evidence showing the premises at risk of collapse – Instead of ensuring safety, SDMC obstructed rebuilding for 15 years – Conduct held oppressive and amounting to harassment – Right to rebuild residential house recognised as a legitimate, vested entitlement [Paras 15–16].

Concurrent Findings – Tribunal, ADJ, and High Court All Upheld Deemed Sanction – Supreme Court Declines Interference - Three authorities concurrently held that respondents’ plans deserved sanction – Tribunal granted deemed sanction; ADJ affirmed; High Court affirmed and dismissed review – No perversity, no legal error, and no misinterpretation found – Interference under Article 136 unwarranted [Paras 5–9, 17].

Costs – Harassment by Public Authority – Exemplary Costs of ₹10 Lakhs Imposed on SDMC - Given prolonged litigation (15 years), arbitrary obstruction, and hardship caused to elderly residents, Court imposes ₹10,00,000 costs on SDMC to be paid to respondents on or before 17.12.2025 – Payment to be reported to Supreme Court [Para 20].

Directions – Fresh Plans – Mandatory Sanction Within Four Weeks - Respondents permitted to submit fresh building plans for residential construction – SDMC directed to grant sanction within four weeks from submission – Respondents may also rely on earlier plans approved by High Court [Paras 19–21].

Decision: Appeal dismissed – High Court order affirmed – Respondents entitled to rebuild residential house – Fresh plans to be sanctioned within four weeks – Costs of ₹10,00,000 imposed on SDMC – Connected appeal also disposed [Paras 18–22].

Arbitration and Conciliation – Validity of Arbitration Clause – Clause 8.28 not constituting arbitration agreement – Clause referred to dispute resolution through negotiation, mediation by Chairmen, and only used the term "arbitration" loosely – No binding intent or finality indicated – Chairmen of parties not neutral arbitrators – Court held that mere use of the word “arbitration” without intent to submit disputes to binding adjudication does not satisfy Section 7 of the Arbitration and Conciliation Act – Held: No valid arbitration agreement existed – Dismissal of Section 11(6) application upheld [Paras 4-6, 13-27]

Contract Law – Interpretation of Dispute Resolution Clauses – Three-tier clause in software agreement involved negotiation, mediation, and court access if unresolved – Clause failed to demonstrate intent to be bound by arbitral decision – Reliance on case law including K.K. Modi, Jagdish Chander, Mahanadi Coalfields to determine essential attributes of arbitration agreement – Held: Clause structured for internal settlement, not formal arbitration [Paras 14-25]

Post-Contractual Correspondence – Effect on Arbitration Agreement – No denial of arbitration clause in respondent’s replies – However, absence of foundational arbitration agreement renders post-notice correspondence irrelevant – Held: No estoppel can operate to create arbitration agreement where none exists – Distinguished Powertech and Visa International cases [Paras 28-31]

Decision: Appeal dismissed – No valid arbitration agreement existed – Appellant permitted to approach civil court for remedy – No costs awarded [Paras 32-34].

Criminal Law – Appeal Against Acquittal – Competency of Appeal – State of Chhattisgarh and de-facto complainant challenged acquittal of Amit Jogi in murder case originally investigated by State Police and later by CBI – High Court dismissed appeals as not maintainable based on three-Judge Bench decision in Lalu Prasad Yadav v. State of Bihar, (2010) 5 SCC 1 – Held: Where CBI conducts investigation under Section 378(2) CrPC, only Central Government is competent to file appeal – State’s appeal not maintainable – Ratio in Lalu Prasad Yadav upheld [Paras 18-24, 35].

Statutory Interpretation – Section 378 CrPC – Distinction Between Sub-sections (1) and (2) – Section 378(2) is an exception to 378(1) – Only Central Government can appeal in cases investigated by CBI or central agency under a Central Act – Words “save as otherwise provided in sub-section (2)” in 378(1) clearly limit State’s power to appeal in such cases – State's appeal rightly dismissed by High Court [Paras 18-21].

Investigation – Mixed Investigation by State Police and CBI – FIR initially registered and investigated by State Police – CBI took over after dissatisfaction by de-facto complainant – Chargesheet by CBI – Argument that State could still appeal due to initial involvement rejected – Supreme Court leaves open possibility that in suitable future case, where CBI is involved at State’s behest, State’s right to appeal may be examined – But not decided in this case [Paras 22-25].

Criminal Procedure – Delay in Appeal – Application for Leave to Appeal by CBI – High Court rejected CBI’s leave application on ground of 1373 days’ delay – Supreme Court condoned delay in view of gravity of charges – Directed High Court to consider CBI’s leave application on merits – CBI’s bona fide explanation noted – Appeal by CBI allowed [Paras 26, 30-33].

Victim’s Right of Appeal – Applicability of Proviso to Section 372 CrPC – De-facto complainant filed appeal under proviso to Section 372 CrPC – Trial court’s acquittal judgment dated 31.05.2007 – Proviso came into force on 31.12.2009 – Held: Victim’s right to appeal applies prospectively to acquittals post 31.12.2009 – Appeal rightly dismissed by High Court [Paras 27-29].

Hearing of Acquitted Accused – Exceptional Circumstance – Though ordinarily not required, Supreme Court directed that respondent-accused (Amit Jogi) be heard before High Court in CBI’s leave application due to long delay and exceptional facts – State and de-facto complainant also to be impleaded as parties [Para 34].

Criminal Appeal No. 1927 of 2014 (State of Chhattisgarh) – Dismissed

Criminal Appeal @ SLP(Crl.) No. 7331/2011 & 1438/2012 (de-facto complainant Satish Jaggi) – Dismissed

Criminal Appeal @ SLP(Crl.) No. 3037/2012 (CBI) – Allowed – Delay condoned – Matter remitted to High Court to decide on merits of CBI’s leave to appeal against acquittal [Paras 33, 35].

Execution of Decree – Abatement of Appeal – Decree Passed in Favour of Deceased Appellants – Nullity – Trial Court’s Decree Revived – Decree passed by First Appellate Court in favour of defendant Nos. 4 and 5 who had died prior to hearing and without substitution of legal heirs – Held: Decree a nullity as Order XXII Rule 6 CPC not attracted – Decree of Trial Court alone executable – Execution petition wrongly dismissed [Paras 5–14]

Civil Procedure – Abatement – Death of Appellants – Effect – Defendant Nos. 4 and 5 died before appeal hearing – No legal heirs brought on record – First appellate court’s judgment held to be void ab initio – Citing Rajendra Prasad v. Khirodhar Mahto and Amba Bai v. Gopal – High Court erred in treating appellate decree as operative – Restoration of execution proceedings ordered [Paras 8–13]

Execution Law – Null Decree – Executability – Principle – Where decree is a nullity, its invalidity can be raised even at execution stage – Citing Kiran Singh v. Chaman Paswan – Appellant entitled to enforce trial court decree dated 14.08.2006 – Rejection of execution by courts below unsustainable [Paras 14–16]

Decision: Appeal allowed – Orders of executing court and High Court set aside – Execution proceedings restored – Decree of trial court dated 14.08.2006 held valid and executable – No order as to costs [Para 16]