Civil Law - Compromise Decree – Validity – Order 23 Rule 3 CPC – Estoppel – Compromise Decree Upheld - Appellants challenged a consent decree claiming their father was coerced into compromising without their knowledge – Held: Once the Court is satisfied about the lawfulness of a compromise, the resulting decree is valid and operates as estoppel – Such a decree cannot be challenged by a fresh suit, only by a recall application before the same Court [Paras 10-12].

Bar to Suit – Fresh Suit Challenging Compromise Decree – Order 23 Rule 3A CPC – Not Maintainable - The appellants’ 2003 suit sought to invalidate a 2000 compromise decree – Held: Order 23 Rule 3A bars any independent suit to set aside a decree on grounds that the underlying compromise was not lawful – Appellants’ remedy lay only before the Court that passed the compromise decree [Paras 11-12].

Res Judicata – Multiple Rounds of Litigation – Fresh Suit Barred - Appellants’ claims were previously settled in earlier proceedings and decrees – Held: The present suit is hit by principles of res judicata and constructive res judicata – Relief now claimed was either granted earlier or ought to have been claimed earlier [Paras 9, 14].

Joint Family Property – Burden of Proof – Appellants Failed to Prove Separate Property - Appellants claimed that 7 acres of land was personal property of their father purchased by grandmother – Held: Property was purchased using family funds and correctly deemed joint family property – Appellants failed to discharge burden to prove otherwise [Paras 7-8].

Decision – Dismissal of Appeal – No Merits in Appellants' Claim - The Supreme Court upheld concurrent findings of the Trial Court and High Court – Held: Appellants’ suit was devoid of merit, procedurally barred, and substantively unjustified – Appeal dismissed [Paras 14-15].

PIL - Organ Transplant Laws – Uniform Adoption Across States – Supreme Court directed Union of India to collect information from States regarding adoption of the Transplantation Act, Amendment Act, and Rules, and reasons for non-adoption where applicable – Emphasized necessity of uniform legal framework [Para 1(i)-(ii)].

Cadaveric vs. Live Donations – Data Sought – Court directed States to furnish data on proportion of cadaver transplants compared to live donor transplants – Also required steps taken to enhance cadaveric donations [Para 1(iv)].

Gender Disparity – Specific Directions Issued – Court called for data on gender-based disparity in organ donation and recipient statistics – States directed to report steps taken to reduce gender bias in access to organ transplantation [Para 1(v)].

Policy Compliance and Organ Allocation – Adherence to NOTTO Guidelines – States directed to report whether organ allocation policies follow the points system framed by the National Organ and Tissue Transplant Organization (NOTTO) – Deviations to be explained [Paras 1(vii)-(viii)].

Healthcare Infrastructure – Facilities and Awareness – Detailed information sought regarding availability of transplant-equipped hospitals, multi-organ transplant capabilities, and awareness programs – Financial assistance policies for donors and recipients to be disclosed [Paras 1(ix)-(xii)].

Decision – Union of India Directed to Convene Meeting – Union of India directed to convene meeting of Chief Secretaries and Health Secretaries of all States and UTs, collect comprehensive data as outlined, and submit a report before the Supreme Court by 18.07.2025 – Matter to be listed on 21.07.2025 [Paras 2-3].

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].

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].

Arbitration Law  – Partial Setting Aside of Arbitral Award – Impermissible – Matter Remitted - Supreme Court held that the High Court erred by modifying the arbitral award instead of either upholding or setting it aside in entirety – Partially affirming and partially reversing the award, while leaving parties to pursue further claims, was beyond the court’s powers under Section 34 – Held: Judgment of High Court unsustainable and matter remanded to Single Judge for fresh consideration of Section 34 petition [Paras 40-49, 56-57].

Coercion and Economic Duress – Supplementary and Tripartite Agreements – Findings Affirmed - Arbitral Tribunal’s conclusion that agreements were vitiated by coercion and were non-starters due to unmet conditions precedent was upheld – Tribunal rightly found that L&T abandoned the project and failed in its obligations under the Development Agreement – Findings not interfered with as they were based on evidence and plausible view of facts [Paras 35-36, 50-52].

Counterclaims and Indemnity – L&T’s Counterclaim Dismissed – Justified - Tribunal correctly dismissed L&T’s counterclaims for damages and performance, holding L&T had abandoned the contract and could not benefit from its breach – Claim for indemnity by PCL upheld in part, limited to obligations under Development Agreement [Paras 35-36].

Damages – Tribunal’s Quantification – Requires Reconsideration - Tribunal’s award of Rs. 35 crores damages to PCL and Rs. 75 crores in lieu of securing title deeds was interfered with by High Court – Supreme Court held such partial setting aside is impermissible but refrained from reinstating monetary components without complete review under Section 34 – Matter remanded [Paras 37-39, 56].

Decision – High Court Judgment Set Aside – Section 34 Petition Restored - Supreme Court held that High Court’s approach to modify award was impermissible in law – Remitted matter to Single Judge to decide Section 34 petition afresh in accordance with law – Appeals allowed [Paras 55-57].

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].

Land Acquisition – Compensation Determination Date – Section 26(1) Proviso RFCTLARR Act – Appeal Allowed - The High Court fixed market value as on 01.01.2014, the date of RFCTLARR Act’s commencement – Held: This is contrary to Section 26(1) proviso which mandates that compensation must be determined with reference to the date of Notification under Section 11 – Such notification not yet issued; hence fixing an earlier date is unlawful and prejudicial [Paras 2, 5, 9–14].

Utilization Without Acquisition – State’s Admission – Acquisition Pending - State admitted unauthorized use of 0-11-41 ha land without initiating acquisition or paying compensation – Held: Compensation must be based on lawful process commencing with a valid Section 11 Notification – Appellant entitled to compensation as per rates on the notification date when issued [Paras 4–6, 11].

Statutory Interpretation – Use of “Shall” in Section 26 – Legislative Mandate Binding - The Court reiterated that use of the word “shall” in the proviso reflects the mandatory nature of the requirement – Judicial discretion cannot override explicit statutory provision – No deviation permissible unless statute so allows [Para 9].

Final Decision – Appeal Allowed – High Court Judgment Set Aside – Direction to Follow Section 11 Notification Date - Supreme Court set aside the High Court order dated 21.08.2024 and directed that compensation be calculated as per the date of the future Notification under Section 11 of RFCTLARR Act, 2013 [Paras 13–14].

Public Premises Act – Applicability of Limitation – Section 18 of Limitation Act Held

Applicable – Recovery Proceedings Revived - The Estate Officer’s proceedings under

Section 7(1) of the PP Act were held barred by limitation by the District Judge and High Court – Held: Though limitation under Article 52 of Limitation Act applies, the acknowledgment in writing by the Licensees vide letters dated 04.02.2015,

07.09.2015, and 25.02.2016 extended limitation under Section 18 of the Limitation Act – Fresh period of limitation commenced from the date of acknowledgment – The recovery proceedings were within limitation [Paras 12-14].

Acknowledgment – Letters Seeking Deferment Amount to Acknowledgment - Even though the Licensees objected to payment pending decision in intra-court appeal, the correspondence acknowledging pending liability suffices for Section 18 of the Limitation Act – The contention that the liability was denied was rejected – Court clarified that acknowledgment is valid even if accompanied by a plea for deferment [Paras 12-14].

Doctrine of Consistent Conduct – Licensees Bound by Own Stand - Respondents consistently took the stand that the liability be deferred pending decision in intra-court appeal – No express denial of liability – Conduct amounts to acknowledgment – Plea of limitation taken for the first time at appellate stage cannot override admitted facts [Paras 14-17].

Retrospective Revision of Tariff – Not Decided in Present Case - Supreme Court left open the issue of legality of retrospective revision of license fee under TAMP notification dated 23.07.2010 – Ordered that pending intra-court appeals in Karnataka High Court will decide this issue – If Licensees succeed, demand would fail automatically – Else, recovery proceedings would continue [Para 18].

Final Decision – Appeals Allowed – Writ Petition Restored - Appeals allowed – Judgment of the High Court set aside – The recovery proceedings are not barred by limitation – The writ petitions are remanded to the High Court to be heard together with pending intra-court appeals regarding validity of retrospective tariff [Paras 18-19].

Anticipatory Bail – Criminal History and Threat Allegations – Bail Upheld – Respondent No. 2, a person with multiple past FIRs, was granted anticipatory bail by the High Court in a case involving threats and abuses to the complainant – Appellant contended risk of repeat offences – Held: Offences were not heinous and were triable by Judicial Magistrate – No legal error in the High Court's discretion – Appeal dismissed [Paras 2–4, 9–10].

Habitual Offender – Impact on Bail Decision – Not Absolute Bar – Though Respondent No. 2 had prior convictions and FIRs, the Court emphasized that bail should not be routinely denied on this ground alone – Each case must be assessed on current facts and merits – High Court had considered respondent’s background sufficiently [Paras 4–5, 10].

Cancellation of Bail – Applicable Legal Principles – Deepak Yadav Case Reaffirmed – Court reiterated that cancellation of bail requires cogent reasons and cannot be mechanical – Factors include abuse of liberty, tampering with evidence, or serious error in the initial bail grant – None found in present case [Paras 8–10].

Bail Conditions – Safeguard Imposed Despite Bail – Compliance Mandated – Supreme Court directed that respondent must report monthly to the police upon release in other cases – Non-compliance or involvement in further offences would justify moving for cancellation of bail [Para 10].

Decision – Anticipatory Bail Affirmed – Appeal Dismissed – No serious legal infirmity in the High Court’s decision – Order maintained with liberty to seek cancellation if future violations occur [Paras 10–11].