Service Law - Disability Rights – Regularisation Under G.O. – Denial of Probation and Promotion – Held Discriminatory – Appellants, all persons with benchmark disabilities, were reappointed under G.O. dated 18/05/2013 to supernumerary posts after temporary service under Rule 9(a)(i) KS & SSR – Subsequently denied declaration of probation and promotional avenues by G.O. dated 03/02/2016 – Held: The later G.O. sought to withdraw vested service rights, causing discrimination in violation of Article 14 – Supreme Court set aside the impugned G.O. [Paras 1–3, 21–24].

Service Jurisprudence – Supernumerary Appointments – Nature and Legal Rights – Court held that reappointments under the 2013 G.O. amounted to regular appointments including probationary status – Denial of equal service treatment to disabled employees on that basis was impermissible – Held: Once appointed to posts with probation, denial of seniority and promotion by subsequent clarification is illegal [Paras 6, 20–23].

Article 14 – Equality in Public Employment – Disparate Treatment of Disabled Employees – Violation Found – Appellants resigned from other secure posts expecting regularization – Arbitrary denial of parity solely due to method of appointment struck down – Held: Appointments under G.O. 18/05/2013 gave rise to legitimate expectations, and Clause 3.5 of G.O. 03/02/2016 could not override them [Paras 11–13, 23].

Decision – Appeals Allowed – G.O. 03/02/2016 Quashed – Rights Restored – Supreme Court allowed all appeals – Set aside Kerala High Court Division Bench judgments – Restored orders of Single Judge and Kerala Administrative Tribunal that had granted full service benefits including probation and promotion to the appellants [Para 24].

Environmental Law – Classification of Zudpi Jungle as Forest – Historical Usage vs. Legal Interpretation – Forest Status Upheld – Despite historical non-forestry use and poor vegetative quality, Zudpi Jungle lands recorded as forest in revenue records must be treated as ‘forest’ for the purpose of Section 2 of the Forest (Conservation) Act, 1980 in view of the 12.12.1996 Godavarman order – Held: All such lands, unless de-notified in compliance with legal procedure, continue to attract forest conservation laws [Paras 29, 48, 55, 90].

Environmental Protection – CEC’s 2025 Report – Recommendations Accepted – Extensive data collection and district-wise analysis by CEC validated – Court accepted CEC’s findings and ordered conditional declassification of certain Zudpi lands, while maintaining protection over ecologically sensitive areas – Held: Recommendations in Paras 46(i)–(xii) of 2025 CEC Report accepted in full [Paras 47, 91, 93, 95].

Encroachments and Illegal Use – Regularisation of Post-1980 Allotments Denied – State directed to remove all commercial allotments and encroachments made after 25.10.1980 – Task Forces to be constituted in each district with mandate to act within two years – Held: Post-1980 encroachments and illegal commercial uses of Zudpi Jungle land to be treated as violations requiring eviction [Paras 91(viii)–(ix), 93(viii)–(ix)].

Revenue Records – Correction Allowed for Pre-1996 Allotments – Subject to Conditions – Court permitted reclassification of Zudpi Jungle lands used for non-forest purposes prior to 12.12.1996 via consolidated proposals under Section 2(i) of FC Act – No NPV or compensatory afforestation required – Held: Revenue entries may be updated for such lands, but future use must remain unchanged and hereditary only [Paras 43(A), 47(ii), 91(ii)].

Administrative Procedure – Simplified Framework for Proposal Processing – MoEF&CC and State to develop streamlined application format for diversion proposals in consultation with CEC – Held: Simplified process to be created within three months; CEC empowered to resolve any disputes [Paras 47(iii), 91(iii)].

Sustainable Development – Balancing Ecology and Local Needs – Zudpi Jungle lands provide crucial local community support – However, environmental conservation cannot be compromised – Held: Framework permits limited, justified deletions without precedent effect, balancing Article 48A and Article 21 [Paras 48, 55, 93].

Protected Forests – Unallotted Fragmented Parcels – Mandatory Protection – All unallotted Zudpi Jungle land under 3 hectares not adjoining any forest to be declared ‘Protected Forests’ under Section 29 of Indian Forest Act, 1927 – Held: Fragmented parcels protected from alienation; diversion only possible with Central Government approval under FC Act [Paras 91(v), 93(v)].

Forest Rights – Determination Using Satellite Data – Historical imagery permitted as supporting evidence in Forest Rights Act determinations – Held: Satellite data to assist in identifying traditional use and tenure [Para 91(vii)].

Compensatory Afforestation – Flexibility in Vidarbha Region – Court allowed double-area Zudpi Jungle lands to be used in lieu of non-forest land for compensatory afforestation in five districts – Held: Chief Secretary certificate of non-availability not required; afforestation must comply with MoEF guidelines [Para 91(xi)].

Judgment – Final Order – Applications Disposed – CEC directed to monitor progress of implementation, including forest transfers, eviction drives, and proposal approvals – Held: Applications disposed of in terms of accepted recommendations with liberty to CEC to submit reports and intervene in case of non-compliance [Paras 93–96].

Criminal Law – Discharge – Limits under Section 239 CrPC – Special Court and High Court Orders Set Aside – Special Court and High Court discharged accused in ₹21 crore MSP fraud based on CCI's internal letter stating no loss – Supreme Court held this reliance was impermissible under Section 239 CrPC – Held: At charge stage, court can only consider prosecution material under Section 173 CrPC, not defence documents—Discharge orders illegal [Paras 13–28].

Corruption and Criminal Conspiracy – Cotton Procurement Scam – Prima Facie Case Made Out – Accused allegedly purchased cotton below MSP, hoarded it, and resold it via benami farmers to CCI at MSP using forged documents—Involvement of CCI officer (A-1) and son (A-3) established—Forgery confirmed by forensic analysis—Held: Material in charge sheet sufficient to proceed to trial—Discharge not warranted [Paras 6–8, 17–20, 27].

Judicial Process – Mini Trial at Discharge Stage Impermissible – Special Court’s evaluation of CCI's exoneration letter akin to a trial verdict rather than a charge analysis—Held: Courts below erroneously assessed defence case and presumed acquittal—Judicial discretion under Section 239 must not extend to considering accused’s evidence [Paras 20–26].

Criminal Procedure – Precedents – Accused Cannot Rely on External Evidence at Charge Stage – Court relied on State of Orissa v. Debendra Nath Padhi and State of Rajasthan v. Swarn Singh—Reiterated: Only prosecution's material under Section 173 CrPC can be examined at discharge—Accused cannot invoke right to file or rely on documents at framing of charge [Paras 24–26].

Decision – Criminal appeals allowed – Orders of discharge passed by Special Court and affirmed by High Court quashed – Discharge applications dismissed – Trial Court directed to reconsider charges strictly as per Section 239 CrPC, uninfluenced by defence material or observations in this judgment [Paras 27–28].

Taxation Law - Customs – Duty Drawback – Circular No. 35/2010-Cus. – Clarificatory Nature – Retrospective Application – Dispute over denial of 1% AIR duty drawback to exporters of Soyabean Meal who availed Central Excise rebate – Supreme Court held that CBEC Circular No. 35/2010-Cus. was clarificatory in nature and must apply retrospectively – Circular did not introduce new benefit but clarified consistent practice under earlier notifications from 2006 to 2010 – Held: Circular operates retrospectively; appellant entitled to duty drawback for period before 20.09.2010 [Paras 1–5, 12–16, 20].

Fiscal Interpretation – Beneficial Circular – Presumption of Retrospectivity – Court applied the principle that beneficial or clarificatory circulars are to be construed as retrospective unless expressly stated otherwise – Notifications and circulars were consistent in treating the 1% rate as covering customs component regardless of CENVAT availed – Held: Doctrine of fairness and purposive construction warranted retrospective operation of Circular No. 35/2010 [Paras 9–18].

Statutory Construction – No Substantive Change – Circular Confirmed Existing Position – Language across all relevant notifications (2006 to 2010) consistent – Circular did not create new rights or burdens but clarified already available benefit – Held: Department’s denial of drawback prior to 20.09.2010 based on prospective interpretation was erroneous [Paras 13–15].

Judicial Review – Error by High Court – Improper Dismissal of Review Petition – High Court dismissed writ petition and review relying solely on effective date mentioned in Circular – Failed to assess its clarificatory nature and misapplied legal standards – Held: High Court's decision set aside for not appreciating fiscal legislative principles correctly [Paras 19–20].

Decision – Appeal allowed – Impugned orders of the Madhya Pradesh High Court dated 17.11.2014 and 01.04.2016 set aside – CBEC Circular No. 35/2010-Cus. dated 17.09.2010 held to be clarificatory and retrospective – Appellant entitled to 1% AIR duty drawback for exports of Soyabean Meal since 2008 [Para 20].

Crimnal Law - Section 138 & 141 NI Act - Negotiable Instruments – Quashing Set Aside - Vicarious Liability of Director – Complaint Must Disclose Responsibility for Company’s Affairs – High Court quashed criminal proceedings under Section 138 NI Act against a director on the ground of insufficient averments—Supreme Court reversed, holding that complaint sufficiently alleged that respondent was “responsible for day-to-day affairs, management and working” of the company—Held: Averment satisfies the requirement under Section 141(1) NI Act—Complaint need not reproduce statutory language verbatim if substance is clear [Paras 2–6, 17–21, 27–30].

Director Liability – No Need to Parrot Section 141 – Substantive Allegations Sufficient – Supreme Court reiterated that complainants are not required to reproduce Section 141 verbatim—Complaint as a whole must show the director was in charge of and responsible for company’s business—Detailed Board resolutions and loan documents attached supported director’s active role—Held: Complaint sustainable against respondent no. 2 [Paras 18–21, 29–31, 34–39].

Precedents – S.M.S. Pharmaceuticals, Sabitha Ramamurthy, K.K. Ahuja, S.P. Mani – Applied – Court analyzed evolution of NI Act jurisprudence—Held: Complaint met the standards set in S.M.S. Pharmaceuticals (2005), Sabitha Ramamurthy (2006), K.K. Ahuja (2009), and S.P. Mani (2023)—Averments adequate to infer vicarious liability; no hyper-technical interpretation required [Paras 22–38].

Criminal Procedure – Quashing of Complaint – High Court Order Set Aside – High Court erroneously quashed proceedings under Section 482 CrPC—Held: Trial should proceed where complaint discloses sufficient prima facie material—A complaint cannot be dismissed solely for not using statutory language in precise terms [Paras 15–16, 39–40].

Decision – Appeal allowed – High Court order dated 10.01.2024 in Criminal W.P. No. 275 of 2022 quashed – Complaint restored against respondent no. 2 – Trial to proceed before Magistrate in accordance with law [Para 40].

Service Law - Judicial Service – Probation Termination – Stigmatic Discharge Not Sustainable – The appellant, a probationer in Rajasthan Judicial Service, was discharged based on an inquiry alleging misconduct including non-disclosure of past employment and simultaneous academic degrees – The Court held that the allegations predated judicial service and were not grave enough to justify termination – Held: Discharge order stigmatic and violative of natural justice, termination set aside [Paras 17–18, 27, 31–32].

Natural Justice – Procedural Deficiency in Inquiry – Inquiry Conducted Without Full Participation – The appellant was not provided an effective hearing during the vigilance inquiry and the report was not supplied to her – Held: Violation of principles of natural justice and fair play warrants quashing of action based on such inquiry [Paras 7–8, 27].

Public Employment – Discharge on Probation – Applicability of Article 311 – The discharge was based on an inquiry concluding misconduct without formal proceedings – Held: Though on probation, the appellant was entitled to protection from stigmatic discharge under Article 311, requiring proper inquiry and opportunity of defence [Paras 24–26].

Women in Judiciary – Need for Diversity – Importance of Retaining Women Judges – The Court emphasized the systemic value of diversity and fair treatment in the judiciary – Held: Appellant, having succeeded despite systemic barriers, should not be excluded for minor procedural lapses [Paras 28–31].

Decision – Appeal Allowed – Discharge Order Quashed – Appellant Reinstated – The Supreme Court quashed the show cause notice and discharge order – Directed reinstatement with notional seniority and benefits except back wages – Probation deemed successfully completed [Paras 32–33].

Criminal Writ – PIL – Allegation of Fraudulent Cost Escalation – Prima Facie Rejected – Petitioner, a former MLA and PAC Chairman, alleged wrongful revision of estimates in PRRLIS causing Rs. 2,426.07 crores loss to public exchequer – Supreme Court upheld the High Court’s dismissal of the writ petition – Held: Allegations required factual adjudication not suitable for exercise of writ jurisdiction under Article 226 – Summary dismissal by High Court justified [Paras 1, 4, 10, 18].

CBI Investigation – Scope of Judicial Discretion – Writ Court’s Non-Interference Upheld – Petitioner sought CBI investigation into the alleged irregularities – Supreme Court held that the High Court was justified in refusing to refer the matter to CBI – Mere allegations unsupported by prima facie evidence or substantiated material do not mandate such referral – Discretion exercised by the High Court cannot be faulted in SLP proceedings [Paras 9, 19].

Res Judicata – Constructive Res Judicata – Repetitive Petitions by Same Petitioner – Earlier PILs by the same petitioner on related issues (Nos. 28/2016, 179/2016, 338/2017) were already disposed of – Present SLP found to be barred by principle of constructive res judicata – Also noted suppression of material facts by the petitioner – Held: Maintainability of repeated PILs on same subject matter is seriously questionable [Paras 13, 21].

Vigilance Report – CVC Finding Complaint Unsubstantiated – Evidentiary Value – Central Vigilance Commission had closed the complaint regarding PRRLIS packages 5 and 8 as unsubstantiated by order dated 12.09.2017 – Supreme Court noted this finding while rejecting prayer for further inquiry – Held: Findings of competent statutory body carry persuasive value in assessing prima facie case in PILs [Paras 14, 21].

Final Decision – No Interference Warranted – Supreme Court found no illegality in High Court’s decision – Held: No justification to reopen the matter or interfere with impugned judgment – Special Leave Petition dismissed [Paras 20, 22].

Consumer Law - Challenge To Constitutionality And Validity Of Specific Provisions Of The Consumer Protection Rules, 2020 - Consumerism and Constitutional Philosophy – Broad Interpretation of Consumer Rights – Socio-Economic Relevance Affirmed – The Court held that the concept of consumerism is constitutionally embedded within principles of equality, dignity, justice and participatory democracy – Consumer forums are instruments of social justice promoting public accountability and participative governance – Consumer rights cannot be narrowly construed but must be seen in the context of constitutional values under Articles 38 and 51-A(h) [Paras 2–20].

Selection Committee Composition – Rule 6(1) of 2020 Rules Struck Down – Executive Dominance Held Unconstitutional – The Court held that Rule 6(1), which allowed excessive control of executive in appointment process, violated doctrine of separation of powers – Held: Only one nominee from executive branch can be permitted – Impugned rule declared ultra vires and struck down [Paras 55–58, 83].

Tenure of Appointees – Rule 10(2) Held Invalid – Minimum Five-Year Tenure Mandated – The 4-year term under Rule 10(2) was found contrary to precedent and judicially established principles – A minimum five-year tenure is essential to ensure institutional independence and stability of consumer fora – Rule 10(2) struck down [Paras 84, 99].

Written Examination Requirement – Directions in Limaye–I Clarified – No Written Exam for Judicial Members or Presidents – Held: Requirement of written test introduced in Limaye–I applies only to non-judicial members – Judicial Members and Presidents are exempted – Review Petitions allowed to clarify this misinterpretation – Appointments made without written tests for judicial roles upheld [Paras 78–81, 100].

Appointments Made Under 2023 Advertisements – Appointments of 112 Candidates Valid – Non-Impleadment of Appointees Rendered HC Decision Invalid – Held: High Court’s failure to implead selected candidates violates natural justice – Also, written examination was substantially complied with – Hence, appointments made via notification dated 05.10.2023 upheld [Paras 86–89].

Reappointments – Not a Vested Right – Must Be Made Under New Rules – The Court held that repealed 2019 Rules cannot govern reappointments – Held: Any reappointment must comply with fresh set of rules to be framed – Rule 8(18) of 2019 Rules cannot be revived or relied upon – No automatic reappointment possible [Paras 90–98].

Appointments in Telangana – Prospective Application of Limaye–I – No Retrospective Invalidation – The Court set aside High Court's decision cancelling Telangana appointments made prior to Limaye–I – Held: Directions in Limaye–I do not operate retrospectively – Appointees to be reinstated [Para 101].

Final Relief and Constitutional Directions – Mandate to Frame New Rules – SC exercised powers under Article 142 to direct Union of India to frame fresh Rules governing appointment, tenure and conditions of service – Emphasis on permanent consumer fora with clear recruitment framework – Court underscored need for transparency and institutional efficiency [Paras 102–104].

Decision – Civil Appeals Partly Allowed, Review Petitions Allowed in Part – Appointments upheld in certain states and quashed in others depending on compliance with legal and constitutional standards – Rules 6(1) and 10(2) declared unconstitutional – Directions issued for new regulatory framework and future appointments [Paras 99–104].

Criminal Law - Sections 420, 406, 467, 468, 473, 474, and 120B of the Indian Penal Code, 1860 - Quashing of FIR – Forged Lease Deed Used – FIR Restored – Allegation that accused used a forged lease deed to sell land and obtained ₹10 lakh as advance – Held: High Court erred in quashing FIR by relying on defence plea that accused were unaware of forgery or were willing to return money – Such issues are matters for trial – FIR restored for continuation of investigation and trial [Paras 2–10].

Plea of Defence – Not a Ground for Quashing – Accused Claimed to Be Victims Themselves – Rejected – Supreme Court reiterated that defence pleas cannot be considered at FIR stage – Even willingness to refund money does not negate commission of cognizable offence – Quashing order set aside [Paras 8–10].

Multiple FIRs – Distinct Transactions – Not Barred – Separate Victims, Separate Offences – Held: Presence of other FIRs relating to similar modus operandi does not make the current FIR a second FIR for the same offence – Each transaction with separate victim constitutes a distinct offence [Para 10].

Final Relief – FIR Quashing Set Aside – Criminal Proceedings to Continue – Supreme Court held that allegations made out a prima facie case – Investigation having culminated in a charge sheet, FIR and proceedings restored for trial – Appeal allowed [Paras 10–11].