Civil Law - Limitation – Article 58 of Limitation Act – Order VII Rule 11(d) CPC - Cause of Action – Suit Barred – Suit Filed Beyond Prescribed Period – The plaintiff filed suit in 2017 seeking declaration that a Will (2014) and Codicil (2014) were null and void – The plaint itself admitted that the plaintiff acquired knowledge of the Will and Codicil in the first week of November 2014 – Held: Under Article 58, limitation begins from the date the right to sue first accrues – Since the suit was filed after the expiry of 3 years from that date, it was clearly barred by limitation – Rejection of plaint under Order VII Rule 11(d) CPC was proper [Paras 19-24, 26-27].

Scope of Order VII Rule 11(d) CPC – Maintainability of Suit – Where Limitation Is Apparent from the Plaint – No Need for Evidence – The Court reiterated that if the plaint discloses that the suit is barred by law, it must be rejected under Order VII Rule 11(d) CPC – There is no requirement for parties to lead evidence where limitation is ex-facie apparent from the plaint – High Court erred in reversing trial court’s decision – Trial court order restored [Paras 25, 27].

Consequential Relief – Main Relief Barred – Effect on Ancillary Prayers – Permanent Injunction and other Reliefs Not Maintainable – The Supreme Court held that all ancillary reliefs flow from the main declaratory relief – Once the declaratory relief is time-barred, other prayers cannot survive independently – Whole plaint liable to be rejected [Paras 16, 29].

Declaratory Relief – Distinction Between Knowledge and Full Knowledge – Not Recognised – The plea that full knowledge came later was held to be an afterthought – The Court found no distinction between “knowledge” and “full knowledge” in law for limitation purposes [Para 28].

Final Decision – Appeal Allowed – High Court Order Set Aside – Trial Court Order Reinstated – The suit is held barred by limitation and the plaint rejected under Order VII Rule 11(d) CPC [Paras 30-32].

Civil Law - Municipal Council Resolution – Use of Urdu on Signboard – Powers under Section 308 of the 1965 Act – Collector’s Jurisdiction – Application Invalid – Under the amended Section 308, only the Chief Officer of the Municipal Council can approach the Collector to suspend a resolution – Petition filed by an individual was not maintainable under the amended law – High Court rightly held that the Collector lacked jurisdiction [Paras 9-11, 12].

Official Language – Interpretation of the Maharashtra Local Authorities (Official Languages) Act, 2022 – No Express Bar on Additional Languages – Use of Urdu alongside Marathi on signage not prohibited – The Act mandates Marathi for official and public-facing purposes but does not prohibit additional languages such as Urdu [Paras 13-15, 49].

Constitutional Validity – Language and Diversity – Article 345 and Language Use – The Constitution permits States to adopt multiple official languages – There is no restriction against using more than one language for public communication – Use of Urdu recognized under the VIIIth Schedule, and its usage cannot be invalidated solely on that basis [Paras 24-25].

Cultural and Linguistic Harmony – Urdu as an Indian Language – The judgment discusses at length the cultural, historical, and constitutional relevance of Urdu – Court observes that language is not synonymous with religion – Emphasizes linguistic unity and diversity – Rejection of communal interpretations of language identity [Paras 17-23, 27-47].

Decision – No Bar on Use of Urdu – High Court's interpretation upheld – Appeal dismissed – There is no legal basis to prohibit the use of Urdu alongside Marathi on the Municipal Council’s signboard – Display of Urdu does not violate the 2022 Act or any provision of law [Paras 49-50].

Intellectual Property – Copyright vs Design – Overlap – Appeal against High Court judgment restoring Inox’s copyright infringement suit dismissed by Commercial Court under Order VII Rule 11 CPC – Appellants (Cryogas and LNG Express) contended drawings used to manufacture Semi-trailers qualified as ‘designs’ under Section 2(d) of the Designs Act, 2000 and exceeded 50 industrial reproductions, hence barred under Section 15(2) of the Copyright Act, 1957 – High Court rejected Commercial Court’s findings, restored the plaint and interim application – Supreme Court upheld High Court view – Held: Determination of whether such drawings qualify as ‘artistic works’ under Copyright Act or as ‘designs’ under Designs Act involves mixed questions of law and fact, cannot be decided at threshold stage [Paras 63–68].

IP Law – Interpretation of Section 15(2), Copyright Act – Design vs Artistic Work – Supreme Court outlined a two-pronged test to assess such claims – (i) Whether the work is purely an artistic work entitled to copyright or a design derived from it subjected to industrial reproduction; (ii) If not purely artistic, whether it serves a functional utility and thus qualifies under the Designs Act – ‘Functional utility’ test recognized across Indian High Courts and aligned with U.S. doctrine of conceptual separability and international IP treaties – Clarified that mere industrial application of an artistic drawing does not negate copyright, unless criteria under Section 15(2) are met – Held: Legislative intent is to harmonize protection under both statutes and avoid encroachment [Paras 8–61].

Civil Procedure – Order VII Rule 11 CPC – Rejection of plaint – Scope – Held: Determination under Section 15(2) Copyright Act involves mixed legal-factual questions and cannot be summarily concluded at the stage of Order VII Rule 11 – As long as the plaint discloses some cause of action, however weak, it cannot be rejected – Suit contains claims for copyright in artistic drawings, literary works, and misappropriation of confidential information – Entire plaint must go to trial – Partial rejection not permissible [Paras 66–68].

Designs Act – Registrability – Visual appeal and industrial utility – Drawings must not be merely functional to qualify as designs – Court emphasized functional utility test to exclude purely mechanical works from design registration – ‘Design’ must result in finished article appealing to the eye – Original artistic drawings may enjoy copyright even if not registrable as design, unless reproduced more than 50 times industrially [Paras 30–39, 54–60].

Decision: Appeals dismissed – High Court judgment affirmed – Commercial Court directed to decide interim injunction application within two months – Full trial to be conducted within one year on all issues including copyright, design, literary work, and trade secrets based on newly laid test [Paras 70–71].

Civil Law - Oral Partition – Proof Through Boundaries – Not Sufficient – High Court Judgment Set Aside - High Court reversed concurrent findings of Trial and First Appellate Courts based solely on references to boundaries in unrelated sale and mortgage deeds (Ex.A3, A4, B3) – Supreme Court held that such documents relating to other properties cannot be conclusive proof of oral partition of suit property – Held: No reliable evidence of partition or exclusive title of plaintiffs – High Court acted beyond its jurisdiction under Section 100 CPC [Paras 10–14].

Execution of Will – Non-compliance with Statutory Requirements – Will Not Proved - Plaintiffs' claim of title relied upon will dated 16.07.2003 allegedly executed by Arunachalam – Both courts below found will unproved due to non-compliance with Sections 68 of the Evidence Act and 63 of the Succession Act – Supreme Court upheld this finding and held the High Court ignored crucial evidence while erroneously decreeing the suit [Paras 6, 12–13].

Non-Joinder of Necessary Parties – Co-owners Not Impleaded – Suit Bad in Law - Plaintiffs failed to implead co-owners of the suit survey number, despite admitting joint patta with eight others – Courts below rightly held the suit as defective – Supreme Court reaffirmed this conclusion and criticized High Court’s omission of this issue [Paras 6, 9, 13].

Scope of Second Appeal – Interference with Concurrent Findings – Reversal Unjustified - Supreme Court ruled that High Court exceeded its jurisdiction under Section 100 CPC by reappreciating evidence and overturning concurrent findings without substantial question of law – Held: Judgment was perverse and unsustainable [Paras 14–15].

Decision – Appeal Allowed – Trial Court and First Appellate Court Judgments Restored – Suit Dismissed - Judgment of Madras High Court dated 28.07.2022 in Second Appeal No. 351/2021 set aside – Findings of Trial Court and Sub-Judge restored – Plaintiff’s suit stands dismissed – No costs awarded [Paras 15–16].
 

Criminal Law – Bail - PMLA – Sanction under Section 197 CrPC – Cognizance Quashed – Bail Granted - The appellant, a retired civil servant, challenged his arrest under Section 3 of the PMLA citing that cognizance was wrongly taken without sanction as required under Section 197 CrPC – High Court quashed cognizance for lack of sanction – Supreme Court noted that no fresh cognizance has been taken, appellant had spent about a year in custody, and trial was unlikely to commence soon due to pendency and vacant Special Court – Held: Bail granted subject to stringent conditions [Paras 2–4, 7].

Delay in Trial – Prolonged Incarceration – Balancing of Rights - Considering over 20 accused, 30+ witnesses, and vacant Special Court under Section 43(1) of PMLA, the Court applied principles from V. Senthil Balaji vs Deputy Director, Directorate of Enforcement (2024 INSC 739) and emphasized that continued detention pending indefinite trial would violate liberty – Co-accused already granted bail in similar facts – Appellant entitled to bail [Paras 4–5].

Conditions of Bail – Potential to Influence Proceedings – Safeguards Imposed - Respondent argued the appellant is influential and may tamper with evidence – Court directed imposition of stringent conditions including surrender of passport, undertaking to attend trial, and right to seek bail cancellation on breach of conditions [Paras 5–8].

Administrative Directions – Vacant Special Court – Mandate to Designate Judge - Court noted Special Court under PMLA was lying vacant and directed the Central Government to immediately designate a Sessions Judge to hear the case under Section 43(1) PMLA – All issues regarding fresh cognizance kept open [Para 9].
 

Criminal Law - Bail Cancellation – Organized Child Trafficking – Improper Exercise of Discretion by High Court – Bail Cancelled - The High Court granted bail to multiple accused in a grave child trafficking case without proper application of judicial principles – Supreme Court held that the High Court's approach was casual, failed to consider the seriousness of offences, and bail orders required interference and cancellation [Paras 37, 67-70, 76-79].

Principles of Bail – Balance Between Liberty and Societal Interest – Discretion Must be Judicious - Reiterating jurisprudence from multiple landmark rulings, the Court emphasized that while liberty is essential, it must be balanced with public interest, especially in heinous offences like child trafficking – Bail orders devoid of reasoning or consideration of relevant factors are unsustainable [Paras 53-63, 74-75].

Absconding Accused – No Monitoring by State – Bail Misused – Bail Revoked - Several accused, once released on bail, absconded and evaded trial – Supreme Court observed that bail orders lacked essential safeguards like police station reporting – Held: Bail orders suffered from non-application of mind and were liable to be set aside [Paras 67-68].

Prima Facie Role of Accused – Direct Involvement in Trafficking – Sufficient Material on Record - Accused Santosh Sao was found to have purchased a trafficked male child for Rs. 4 lakhs; accused Jagveer Baranwal was caught with a trafficked child in his custody; Manish Jain was identified as one of the key operators in the trafficking network – Held: All three had substantial material against them and were not entitled to bail [Paras 69-71].

State Inaction – Failure to Challenge Bail Orders – Court Criticises Laxity - Court expressed deep concern at the State of Uttar Pradesh’s delay and inaction in appealing improper bail orders – Directed remedial action and issued warnings against lax conduct of state authorities [Para 68].

Trial Directions – Expedited Prosecution – Protection for Victims – Monitoring by High Courts - Supreme Court laid down a comprehensive action plan for lower courts, directing speedy committal, framing of charges, day-to-day trial, appointment of special public prosecutors, and police protection for victims – Also directed State and High Courts to take concrete steps for preventing trafficking and expediting related trials [Paras 80-81].

Public Awareness – Parental Vigilance – Institutional Accountability - Supreme Court issued a public message warning parents about the horrors of child trafficking, urging vigilance – Directed suspension of hospital licenses where infants are trafficked, reinforcing institutional accountability [Paras 90-91].

Final Decision – Bail Orders Set Aside – Accused to Surrender – Appeals Allowed - All impugned bail orders passed by the High Court were set aside – Accused directed to surrender and remain in judicial custody – Appeals allowed in their entirety [Paras 79-80].

Criminal Law – Quashing of Criminal Proceedings - Defamation – Builder-Buyer Protest – Peaceful Banner Display by Flat Owners – Complaint Quashed – The appellants protested against the developer by publicly displaying banners alleging non-performance and defects – The builder filed a defamation complaint – Held: The language used was temperate, grievances were genuine and publicly voiced in good faith for protection of residents' interests – Complaint and summons quashed [Paras 2–6, 14–16, 30–35].

Section 499 IPC – Ninth Exception – Good Faith Imputation in Public Interest – Applicable – Court held that peaceful expression of consumer grievances with no abusive or foul language fell under the ninth exception to Section 499 IPC – The protest aimed at safeguarding collective interests of homeowners and was thus protected [Paras 17–21].

Freedom of Speech – Peaceful Protest and Consumer Rights – Protest Upheld – Supreme Court reaffirmed right to protest under Article 19(1)(a), (b), and (c) – Noted that expressing dissatisfaction in a non-abusive, legitimate way is a protected form of dissent in a democratic setup – Attempt to criminalize such expression is misuse of process [Paras 26–30].

Scope of Magistrate’s Duty – Consideration of Exceptions at Summons Stage – Clarified – Referring to Iveco Magirus ruling, Court held that magistrates are not barred from considering applicability of exceptions to defamation at the time of issuing process – If a complete defense is evident, summons should not be issued [Paras 10, 13].

Decision – Criminal Complaint and Summons Quashed – High Court’s refusal to quash proceedings reversed – Appeal allowed – Complaint in CC No. 2042/SS/2016 and order issuing summons set aside [Paras 30–35].

Civil Law - Limitation – Suit Filed to Set Aside Decree after 17 Years – Bar under Article 59 of the Limitation Act – Suit Held Time-Barred – Respondents filed suit in 1982 to set aside a 1965 decree and claim partition – Trial Court and First Appellate Court dismissed the suit as barred by limitation – High Court remanded the matter for retrial on limitation issue – Held: Respondents were aware of earlier proceedings and were party to execution – Limitation is a question of law in this case, and Courts below rightly dismissed the suit as barred by law [Paras 13-16, 23-24].

Second Appeal – Jurisdiction under Section 100 CPC – Remand by High Court Without Deciding Substantial Questions of Law – Set Aside – High Court failed to decide substantial question of law framed at admission and remanded for retrial on limitation – Held: High Court's remand unsustainable as Section 100 empowers it to adjudicate substantial legal issues directly – Framing and non-framing of issues immaterial where parties had full opportunity to contest limitation [Paras 11-12, 18-22].

Procedural Law – Limitation and Framing of Issues – Courts’ Duty under Section 3 of Limitation Act – Even in Absence of Plea or Issue, Court Must Examine Limitation – Trial and Appellate Courts rightly adjudicated limitation based on pleadings, evidence, and statutory mandate – Procedural lapses do not override substantive justice where parties have had fair trial and no prejudice is caused [Paras 19-22].

Final Decision – Appeal Allowed – High Court’s judgment remanding case for fresh trial set aside – Judgments of Trial Court and First Appellate Court dismissing the suit restored – Respondents' claim barred by limitation and no relief warranted – Each party to bear own costs [Paras 23-24].

PIL - Food Labelling – Front-of-Pack Nutrition Labelling (FOPNL) – Mandamus Sought – Direction Issued - The petitioner sought implementation of Front-of-Package Warning Labels on packaged foods to enhance consumer awareness of high sugar, salt, and fat content – The Union of India submitted that the Food Safety and Standards Authority of India (FSSAI) had already notified a draft regulation in 2022 proposing the Indian Nutrition Rating (INR), a star-based FOPNL system, and received over 14,000 public comments – An Expert Committee was constituted to analyze the feedback and recommend changes – The Court acknowledged the steps taken and directed the Expert Committee to finalize and submit its report within three months to enable further regulatory action – Held: Petition disposed with directions for timely compliance and monitoring [Paras 1, 4–8].