Issue and Background – Data Entry Operators, previously appointed under various designations within Electronic Data Processing, sought reclassification and pay scale upgrades based on the recommendations of the Fourth Central Pay Commission and subsequent organizational restructure by Government of India Office Memorandums in 1989 and rules framed under the Constitution - The contention centered on whether such employees are entitled to higher pay scales retroactively based on their qualifications and roles.

Tribunal and High Court Decisions – Various Central Administrative Tribunal benches and High Courts provided contradictory rulings on the entitlement to upgraded pay scales, with some granting higher scales retroactively and others denying such claims - Appeals were made to the Supreme Court against these decisions.

Supreme Court Judgment – The Court reviewed the classifications, qualifications, pay scales, and recruitment rules involved, ultimately ruling that reclassification does not entitle an automatic upgrade to higher pay scales unless specified by government orders - The Court emphasized that differences in pay scales based on educational qualifications and responsibilities do not violate Articles 14 or 16 of the Constitution - The Supreme Court set aside the orders that granted pay scale upgrades not aligned with government stipulations. [Paras 22-33]

Principle of Equal Pay – The Court reiterated the principle that 'equal pay for equal work' is not mechanically applicable and must consider qualifications, responsibilities, and recruitment rules - Reliance on cases such as Mew Ram Kanojia vs. All India Institute of Medical Sciences and Shyam Babu Verma vs. Union of India was highlighted to support the decision. [Paras 29-31]

Criminal Law - Sanction for Prosecution - Public Servant's Protection - Appeals against High Court's decision to quash prosecution orders for lack of valid sanction under the Prevention of Corruption Act, 1988, and CrPC - High Court upheld that without valid sanction, cognizance of offenses could not be taken against the respondent who was a public servant both during and post-service - Supreme Court affirms that once sanction is refused while the public servant is in service, prosecution post-retirement is also untenable unless new facts emerge after retirement - Held, no merit in appeals, dismissed - Upholds the principle that lack of sanction precludes prosecution, stressing the importance of timely and reasoned decision-making in sanctioning processes to uphold public confidence and rule of law. [Paras 1-27]

In conclusion, the Supreme Court's decision highlights the critical role of proper sanction in the prosecution of public servants and underscores the judiciary's stance on protecting the rights of the accused against unwarranted prosecution, particularly in corruption cases. The case reinforces legal precedents concerning the necessity of sanction and the implications of its absence, ensuring adherence to the rule of law and due process.

Regulatory Compliance with Cigarettes Act and Rules – Various appeals from Mumbai, Chennai, and Ahmedabad contesting circulars/notices issued by Municipal Corporations regulating smoking areas in public places like hotels and restaurants - High Courts upheld these regulations, but appellants argued these exceed the scope of the Cigarettes Act and Rules [Paras 1-4]

Legal Interpretation of Smoking Regulations – Supreme Court scrutinized whether the impugned circular dated 4th July, 2011, and similar regulations from other cities merely implement or exceed the Cigarettes Act and Rules - Conditions like prohibiting sale of tobacco products within licensed premises, restrictions on hookah usage, and specifications on dimensions of smoking areas were challenged [Paras 6-7, 13-20]

Decision – Supreme Court found specific provisions of the circulars ultra vires to the Cigarettes Act - Provisions prohibiting the sale of tobacco in licensed premises and the usage of hookahs were struck down - Dimension requirements for smoking areas upheld - All appeals allowed partially [Paras 22-27]

Jurisdiction and Precedent – Revisiting the Supreme Court's decision – Appeal arising due to High Court's allowance of writ petition challenging reversion orders based on reservation in promotions – High Court's decision found contrary to Supreme Court's earlier decision which ruled no reservation in promotions – Supreme Court reasserts that lower courts must follow its decisions unless overruled or distinguished – High Court found to err by setting aside reversion orders which were in compliance with Supreme Court's precedent – Original judgment and subsequent reversion orders upheld. [Paras 1-20]

Employment and Cooperative Societies – Application of reservation policies – South Central Railway Employees Co-Op. Credit Society had initially applied reservation in promotions, leading to legal challenges and reversion orders – Supreme Court maintains its stance that reservation policies were not applicable to promotions within the Society, as decided in earlier judgment, thus upholding reversion of employees promoted through reservation. [Paras 3-6, 19]

Judicial Overreach – High Court's decision to allow promotions despite Supreme Court's clear ruling considered an overreach and misinterpretation of the principle of stare decisis and Article 141 of the Constitution – Supreme Court criticizes the High Court for its judgment that disregarded Supreme Court's binding decision. [Paras 16-18]

Decision: The Supreme Court sets aside the judgment of the High Court, reinstating the original judgment and reversion orders – Appeal allowed with no order as to costs.

Jurisdiction of Arbitral Tribunal - Challenge raised after submission of statement of defence - Whether permissible under Arbitration and Conciliation Act, 1996 - The Tribunal constituted under the Act held fully competent to adjudicate the dispute as per the contractual agreement - High Court’s decision allowing amendment to challenge jurisdiction after initial submission overturned - Emphasis on preventing delay and misuse of procedural rights in arbitration - [Paras 2, 10-18].

Jurisdictional Objections - Requirement to raise before or at submission of statement of defence under Section 16(2) of the Arbitration Act, 1996 - High Court's allowance of amendment to include jurisdictional objections years after the award considered contrary to statutory mandates - Supreme Court clarifies limitations on raising jurisdictional objections beyond the specified stage to ensure procedural efficiency and fairness in arbitration - [Paras 12-16].

Public Policy and Jurisdiction - Argument that jurisdictional challenge relates to public policy rejected - Public policy under Section 34 related to the broader national context, not specific state legislation conflicts - Clarification of the scope of public policy in arbitral disputes - [Paras 17-18].

Decision: Amendment application allowing jurisdictional challenge set aside - High Court's judgment and order reversed - No order as to costs.

Dowry and Harassment – Conviction under IPC Sections 304B, 498A and Sections 3, 4 of the Dowry Prohibition Act - Kanchanben Bhanderi, mother-in-law, convicted for dowry harassment leading to daughter-in-law Hina’s suicide by consuming poison seven months post-marriage - Conviction sustained by the Supreme Court despite acquittal of husband due to specific evidence against her - Allegations of cruelty connected with dowry demands proven – High Court's acquittal of husband on account of his lack of involvement in harassment, and general allegations made against him found reasonable - No parity in cases between mother-in-law and husband due to specific evidence against the former - Sentence reduced from eight to seven years RI for offences under IPC Section 304B and 498A [Paras 1-16]

Demand of Dowry - Clear and specific evidence of demands for dowry and harassment by the appellant led to mental and physical cruelty towards the deceased, contributing to her suicidal decision - Testimonies of family members and friends supported the prosecution’s claim, overcoming defense arguments related to general household dissatisfaction and possible accidental poisoning - Evidence from PW8 (mother), PW10 (cousin), and PW18 (friend) crucial in establishing the continuous demand for dowry and resultant harassment [Paras 5-14]

Legal Principle - Importance of specific and cogent evidence in dowry death cases highlighted - Convictions under Section 304B IPC require demonstrated linkage between cruelty and dowry demands, upheld by cited precedents including Satvir Singh and Others Vs. State of Punjab and Another, and Durga Prasad and Another Vs. State of M.P. - General principles of parity among accused considered, emphasizing individual roles and evidence [Paras 9-13, 16]

Insurance Claim and Settlement – Respondent's factory damaged by fire – Claimed insurance amount under a fire insurance policy – Dispute arises over the settlement amount and the conditions under which the discharge voucher was signed - Appellant contested the claims of duress and undue influence, asserting that the settlement was agreed upon without coercion and was in line with the surveyor's assessment - Respondent alleges duress due to financial strain and coercive conditions imposed by the appellant. [Paras 2-4]

Arbitration Clause Invocation – Respondent sought arbitration under Section 11 of the Arbitration and Conciliation Act, 1996, claiming duress in settlement – High Court deemed disputes arbitrable and appointed an arbitrator - Appellant challenges the High Court's decision, arguing full and final settlement had been reached with the voluntary signing of discharge voucher and subrogation letter. [Paras 5-6]

Judicial Review – Supreme Court examined whether the discharge agreement was signed under duress or undue influence – Consideration of the financial status of the respondent and circumstances of signing the agreement - Held, no evidence supporting claims of non-voluntary agreement - Full and final settlement deemed valid and no arbitrable dispute existed. [Paras 7-10]

Decision – Appeal allowed – High Court's order appointing an arbitrator set aside, as no arbitrable dispute exists after voluntary full and final settlement of the insurance claim. [Para 10]

Property Law - Intestate Succession - Suit for possession and declaration of ownership over residential property filed by the deceased’s brother challenged by a woman claiming to be the deceased’s wife - Trial court favored the brother based on familial relations under Hindu Succession Act, 1956, but High Court reversed finding her to be the lawful wife and thus class-I heir.

Legal Representative - Inquiry required to determine the appropriate legal representative for deceased Respondent in appellate proceedings - High Court failed to properly ascertain legal representative status under Order XXII Rule 5 of the CPC, leading to remand by Supreme Court.

Evidence and Presumptions - High Court found extensive cohabitation and recognition as husband and wife over a long period sufficient to establish marital status under common law presumptions of marriage, contrary to the trial court's findings based strictly on documentary evidence and legal submissions.

Conviction Review - Allegations of forming unlawful assembly with intent to commit murder; weapons used; multiple assailants; confirmation of lower court's findings by High Court despite questionable witness credibility - [Para 2-4].

Witness Credibility - Inconsistencies in testimonies, identification of assailants without proper foundation; reliance on chance witnesses and hostile testimonies questioned - [Para 4, 6-8, 10-11].

Evidence Evaluation - Analysis by Supreme Court highlights discrepancies and contradictions in prosecution witnesses' testimonies, leading to doubts about their reliability in corroborating the occurrence of crime as alleged - [Para 9-22].

Legal Reasoning - High Court's affirmation of conviction criticized for lack of substantial evidence; reliance on discredited witness testimonies and failure to consider full scope of trial court's critical findings - [Para 23-37].

Decision - Supreme Court allows appeal; sets aside convictions of appellants, emphasizing need for credible, reliable evidence for conviction - [Para 38].