Motor Accident Compensation – Reliance on Income Tax Returns – Tribunal Award Restored – Supreme Court held that exclusion of Income Tax Return for Assessment Year 2008-2009 by High Court was erroneous – Return reflected income for the period prior to the date of accident and was valid for computing compensation – High Court’s logic that return was filed after accident was held untenable – Tribunal’s original award of ₹31,41,000 restored [Paras 11–16].

Assessment of Income – Legal Validity of Income Tax Returns – Return Date Irrelevant if Filing Pertains to Period Preceding Accident – Court reiterated that returns are binding statutory records for assessing deceased's income and filing date does not affect relevance – Cited precedents in Malarvizhi, K. Ramya, and S. Vishnu Ganga supporting reliance on IT returns [Paras 12–14].

Social Welfare Legislation – Beneficial Interpretation – High Court Criticized for Superficial Reasoning – Court reaffirmed that the Motor Vehicles Act must be interpreted as a social welfare legislation, requiring a forward-looking and claimant-friendly approach – Cited Shivaleela and K. Ramya to affirm pro-claimant interpretation [Paras 15–16].

Final Decision – Compensation of ₹31,41,000 Restored with 9% Interest – Additional Interest for Delay Ordered – Respondent directed to pay within two months or face additional 9% interest for delay – Appeal allowed and High Court’s modified award set aside [Paras 16–17].

Criminal Law – Discharge - Sanction for Prosecution – Applicability of Section 197 CrPC – Respondent Entitled to Protection – Supreme Court upheld High Court's view that the respondent, though on deputation to the Municipal Corporation, remained a public servant of the Government of Punjab – Discharge for IPC offences upheld due to absence of prior sanction under Section 197 CrPC – Deputation did not sever his relationship with the parent department [Paras 7, 22–28].

Definition of Public Servant – Deputation Does Not Nullify Public Servant Status – Court affirmed that the respondent continued to be in the "service or pay" of the Government within the meaning of Section 21, IPC – Emphasized that deputation must be seen as temporary service, not employment severance – Disciplinary control remained with parent State [Paras 20–27].

Object of Section 197 CrPC – Judicial Endorsement of Protective Intent – Reaffirmed that Section 197 exists to protect officials from vexatious litigation for acts done in official capacity – Relied on Matajog Dobey v. H.C. Bhari and recent jurisprudence including A. Sreenivasa Reddy [Paras 22–26].

Final Decision – Appeals Dismissed – High Court Order Affirmed – No Retrospective Application of PC Act Amendments – Respondent protected by law as it stood pre-amendment – Liberty granted to CBI to seek fresh sanction under CrPC, if advised [Paras 28–31].

Suo Motu Writ - Motor Accident Compensation – Unclaimed Compensation – Systemic Shortcomings Identified – Court took cognizance of vast unclaimed amounts in MAC Tribunals and Labour Courts across States (e.g., ₹459 crores in Bombay, ₹282 crores in Gujarat) – Directed formulation of procedural safeguards to ensure disbursal to rightful claimants – Suo motu action based on email from retired judge highlighting the issue [Paras 1–5].

Directions to High Courts and Tribunals – Mandatory Procedural Protocols – Comprehensive guidelines issued to all High Courts for framing practice directions or procedural rules under Section 176 of the MV Act – Directions include collection of Aadhaar, PAN, email, and bank details at filing and disbursement stages – Direct bank transfers mandated for released amounts [Paras 6–10].

Judicial Monitoring and IT Integration – Compliance Reporting Ordered – High Courts to involve Legal Services Authorities and District Administration for tracing claimants – Dashboards to be developed with eCourts IT teams to monitor compensation statuses – Compliance to be reported by 30 July 2025 for further review [Paras 9–13].

Final Directions – Implementation Until Statutory Rules Framed – Guidelines to remain binding until rules under Section 176 are formally enacted by State Governments – Flexibility granted to High Courts to adopt additional measures beyond this order [Paras 10–12].

Matrimonial Law - Divorce – Irretrievable Breakdown of Marriage – Article 142 Invoked – Divorce Granted – Supreme Court held that parties had lived separately for over eleven years with no possibility of reconciliation – Repeated attempts at mediation failed and parties remained emotionally and practically estranged – Marriage dissolved in exercise of powers under Article 142 of the Constitution [Paras 4, 9, 12].

Custody and Visitation – Mother Granted Monthly Visitation – Despite no formal custody proceedings or visitation applications, the Court granted respondent-mother the right to meet daughter twice a month – Held that continued contact with mother was necessary for the emotional well-being of the child – Arrangement to be coordinated in good faith by both parties [Paras 10–11].

Facts Considered – Special Needs of Second Child – Court noted that the mother was preoccupied with the care of the second child with cerebral palsy (now deceased) and was also in government service – Accepted explanation for not initiating custody/visitation proceedings earlier [Paras 6–8].

Final Decision – Divorce Decree Passed – Visitation Rights Granted – Marriage dissolved under Article 142 – Respondent granted visitation with daughter at appellant’s residence twice monthly – Parties may still seek custody adjudication before competent forum [Paras 11–12].

Criminal Law - Juvenile Justice Act – Quashing - Applicability of Section 75 – Actual Charge or Control Requirement – Charge Quashed – The appellant, Chairman of the Managing Committee of a school, was summoned under Section 75 of the JJ Act for failure to install CCTV cameras as per Guidelines issued by the Directorate of Education following an incident of sexual assault of a 4-year-old student by another minor – Held: For Section 75 to apply, it must be shown that the person had "actual charge" or "control" over the child – Mere administrative control over the institution does not amount to control over every student – Summoning order and High Court’s confirmation thereof quashed [Paras 7–9].

Criminal Liability – Role of Moral vs. Legal Responsibility – No Presumption of Criminal Control – It was argued that the appellant was morally responsible as Chairman – Court held moral responsibility is irrelevant unless legal control or actual charge over the child is established under the statutory framework – Moral responsibility cannot substitute for the statutory requirement under criminal law [Para 8].

Criminal Procedure – Summoning of Accused – Legal Prerequisite – Summons Not Sustainable – Where foundational requirements of the statute are not met, issuance of process against an individual is not justified – Summons issued by Special Court and affirmed by High Court found to be unsustainable and liable to be set aside [Para 9].

Decision – Appeal Allowed – Summons and High Court order quashed – Clarified that findings are limited to the appellant and shall not affect proceedings against other accused before Special Court [Paras 9–10].

Criminal Law - Rash and Negligent Driving – Conviction under Section 304A IPC – Sentence Modified – The appellant was convicted for causing death by rash and negligent driving – Trial Court sentenced him to six months’ imprisonment – Conviction affirmed by the First Appellate Court and High Court – Supreme Court upheld conviction but modified sentence by applying the Probation of Offenders Act – In lieu of imprisonment, the appellant was directed to pay Rs. 10 lakhs to the legal heirs of the deceased [Paras 2-6, 11].

Probation of Offenders Act – Applicability to Accidental Offences – Custodial Sentence Replaced with Compensation – The Court found that custodial punishment in a case of unintentional vehicular accident served no constructive purpose – Directed release of the appellant under the Probation of Offenders Act – Ordered equitable compensation as a better alternative to imprisonment [Paras 8, 11].

Compensation to Deceased's Family – Rs. 10 Lakh Directed – Welfare-Oriented Remedy – Court directed the appellant to pay Rs. 1 lakh each to the ten legal heirs of the deceased who were economically dependent – Directed the District Legal Services Authority, Ramanagara to ensure opening of bank accounts and oversee disbursement – Status report of compliance to be filed within three months [Paras 10-14].

Arbitration Law - IBC vs Arbitration – Jurisdiction of MSME Council Post-Resolution Plan – Award Held Non-Executable – Appeal Allowed - MSME Facilitation Council passed an arbitral award in favour of the respondent after approval of a resolution plan under IBC that extinguished operational creditor claims – Held: Once a resolution plan is approved under Section 31 IBC, all pre-existing claims not part of the plan stand extinguished – Facilitation Council lacked jurisdiction – Award is nullity and non-executable [Paras 50-52].

Section 47 CPC – Plea of Nullity in Execution Proceedings – Maintainable Even Without Section 34 Challenge – Allowed - Appellant’s objection under Section 47 CPC to execution of arbitral award as a nullity was wrongly rejected by High Court – Held: Award passed without jurisdiction may be challenged in execution proceedings even if not set aside under Section 34 of Arbitration Act – High Court erred in narrowing the scope of Section 47 [Paras 47-49].

Resolution Plan – Binding Nature – Operational Creditor Claims at Nil – Respondent Bound - The respondent’s claim, though pending arbitral adjudication, was settled at nil value in the resolution plan – Non-inclusion in top 30 operational creditors does not confer higher rights – Award rendered in respect of extinguished claim is invalid [Paras 40-41, 50.1].

Moratorium – Lifting Does Not Revive Extinguished Claims – Facilitation Council Lost Jurisdiction - High Court’s view that arbitral proceedings revived post-moratorium is erroneous – Held: Revival cannot override extinguishment of claim under approved resolution plan – Object of IBC is to ensure clean slate to resolution applicant [Paras 50.1, 51].

Final Decision – High Court and Executing Court Orders Set Aside – Execution Proceedings Quashed - The arbitral award dated 06.07.2018 is non-est in law – Orders of Executing Court dated 03.03.2023 and High Court dated 17.07.2023 set aside – Execution case quashed – Appeal allowed [Paras 52-53].

Criminal Law - Suspension of Sentence – Section 389 CrPC – Scope and Judicial Discipline – High Court Order Set Aside - The High Court suspended the sentence of the convict under POCSO on the ground of doubtful age of victim without conclusively reversing the trial court's finding – Held: Suspension of sentence under Section 389 requires judicial restraint and cannot pre-empt trial court findings unless clearly unsustainable – High Court acted beyond its remit [Paras 6–9].

Victim’s Age – Trial Court Finding Final Till Overturned – Suspension Unjustified - Trial Court had convicted the accused based on established minor status of victim – Held: Until overturned in appeal, the trial court’s finding must be respected – Grant of suspension based on speculative doubt over age cannot be sustained [Para 9].

Societal Interests and Sentence – Balancing Test – Supreme Court Caution - The Court reaffirmed the balance between rights of the convict and societal interests, especially in serious offences against children – Held: Suspension of a 20-year sentence in such a case does not serve public interest or the cause of justice [Paras 9–10].

Final Decision – Appeal Allowed – Suspension Revoked – Surrender Ordered - Supreme Court set aside the High Court's order of sentence suspension – Directed the convict to surrender forthwith – Liberty granted to approach High Court for bail if appeal not heard within 18 months [Paras 10–11].

Civil Law - Deemed Conveyance – Jurisdiction of Competent Authority under MOFA – Scope Limited – Upheld - Competent Authority under Section 11(3) of MOFA granted deemed conveyance over entire plot including area allotted to appellant – Held: Authority can issue certificate of deemed conveyance but cannot conclusively adjudicate title – Parties may seek civil remedy for title disputes [Paras 20-22, 37(ii)].

Leasehold Rights – Protection under Deemed Conveyance – Condition Imposed - Although deemed conveyance granted in favour of co-operative society, the certificate mandated execution of perpetual lease in favour of appellant in respect of distinct sub-plot – Held: Such condition valid and binding in light of deed of dissolution and lease agreement – Appellant's rights as perpetual lessee upheld [Paras 34-36].

Competent Authority – Summary Nature of Proceedings – No Cross-examination Permitted – Limited Adjudicatory Role - Proceedings under MOFA are quasi-judicial but summary in nature – Authority is not to conclusively decide complex title disputes – Writ interference discouraged unless order is manifestly illegal [Paras 19-21, 37(i)-(iii)].

Registering Officer – No Power to Revisit Certificate – Limited Role - Registrar under Section 11(5) of MOFA cannot review merits of deemed conveyance certificate – May refuse registration only if procedural or statutory preconditions unmet (e.g., consent, stamp duty, injunction) – Role confined to registration compliance [Paras 22-23, 37(iv)].

Final Decision – Appeal Dismissed – Appellant’s Rights Preserved - Supreme Court upheld High Court and Competent Authority’s orders – Appellant’s leasehold rights in “Arun plot” protected and remain unaffected – Civil suit remedy preserved for title adjudication [Paras 36, 38].