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Constitution of India, 1950 — Art. 16 and 226 — Public Employment — Direct Recruitment — Eligibility Criteria — Workshop Experience — Pendency of workshop renewal applications — Effect on candidates — Where a recruitment notification mandates a minimum of one year of experience in a Government-approved workshop, candidates cannot be prejudiced or disqualified merely because the workshop’s application for renewal of approval was pending with the State authorities during the period they gained experience — Depriving an otherwise eligible candidate of employment due to an administrative “period of eclipse” or delay on the part of state machinery is arbitrary and discriminatory–Ashok Kumar Yadav v. State of Haryana, 1985 INSC 137, relied on; State of Uttar Pradesh v. Atul Kumar Dwivedi, 2022 INSC 24, Distinguished. Right to Information Act, 2005 — S. 24(4) — Madhya Pradesh Special Police Establishment Act, 1947 — S. 2(1), S. 3 — “Intelligence and Security Organisation” — Scope and Applicability of Exemption — Jurisdiction of Special Police Establishment (SPE) — The expression “intelligence and security organisations” under Section 24 of the RTI Act implies that the concerned entity must be statutory or institutionally empowered to handle matters of intelligence and national/state security — The Special Police Establishment (SPE) of Madhya Pradesh, established under Section 2(1) of the Act of 1947, is clothed with a limited jurisdiction restricted strictly to investigating offences punishable under the Prevention of Corruption Act, 1988, and select economic/fraud offenses under Sections 409, 420, and Chapter XVIII of the Indian Penal Code — Because neither the Lokayukt nor the SPE handles matters connected to general ‘intelligence’ and ‘security’, the SPE cannot be deemed an “intelligence and security organisation” under Section 24(4) of the RTI Act — Principle of institutional parity cannot be invoked to grant blanket exemptions to a anti-corruption investigation agency. Civil Procedure Code, 1908 (CPC) — Section 11, Explanation IV — Constructive Res Judicata — Application of the principle depends on the facts and circumstances of each case, considering the ambit of earlier proceedings and the nexus of the matter to the controversy — It is founded on public policy to prevent multiplicity of proceedings and avoid parties being vexed twice over for the same litigation — Parties are expected to exercise reasonable diligence and bring forward every point that properly belonged to the subject of litigation and which they might and ought to have brought forward — Negligence, inadvertence, or accident in omitting a part of the case does not exempt from its application. Motor Vehicles Act, 1988 — Section 165 and 166 — Liability for injuries sustained due to falling tree branch — Injuries caused by falling tree branch while vehicle was stationary under the tree during rain — Held, not an accident “arising out of the use of a motor vehicle” as the motor vehicle did not play an active role. [ Protection of Children from Sexual Offences Act, 2012 (POCSO Act) — Sections 24, 33(5), 36, 39 — Child-sensitive judicial processes — Mandatory safeguards for child victims — Courts must ensure child-friendly procedures, minimum intrusion, and psychological safety, avoiding re-traumatisation and secondary victimisation in all proceedings concerning children, especially those involving allegations of sexual abuse.

Constitution of India, 1950 — Art. 16 and 226 — Public Employment — Direct Recruitment — Eligibility Criteria — Workshop Experience — Pendency of workshop renewal applications — Effect on candidates — Where a recruitment notification mandates a minimum of one year of experience in a Government-approved workshop, candidates cannot be prejudiced or disqualified merely because the workshop’s application for renewal of approval was pending with the State authorities during the period they gained experience — Depriving an otherwise eligible candidate of employment due to an administrative “period of eclipse” or delay on the part of state machinery is arbitrary and discriminatory–Ashok Kumar Yadav v. State of Haryana, 1985 INSC 137, relied on; State of Uttar Pradesh v. Atul Kumar Dwivedi, 2022 INSC 24, Distinguished.

Right to Information Act, 2005 — S. 24(4) — Madhya Pradesh Special Police Establishment Act, 1947 — S. 2(1), S. 3 — “Intelligence and Security Organisation” — Scope and Applicability of Exemption — Jurisdiction of Special Police Establishment (SPE) — The expression “intelligence and security organisations” under Section 24 of the RTI Act implies that the concerned entity must be statutory or institutionally empowered to handle matters of intelligence and national/state security — The Special Police Establishment (SPE) of Madhya Pradesh, established under Section 2(1) of the Act of 1947, is clothed with a limited jurisdiction restricted strictly to investigating offences punishable under the Prevention of Corruption Act, 1988, and select economic/fraud offenses under Sections 409, 420, and Chapter XVIII of the Indian Penal Code — Because neither the Lokayukt nor the SPE handles matters connected to general ‘intelligence’ and ‘security’, the SPE cannot be deemed an “intelligence and security organisation” under Section 24(4) of the RTI Act — Principle of institutional parity cannot be invoked to grant blanket exemptions to a anti-corruption investigation agency.

Contract Law — Termination and Blacklisting — Principles of Judicial Review — Courts must apply distinct standards of legality, rationality, and proportionality when reviewing administrative actions related to contract termination and blacklisting, considering the differing gravity of these measures and their consequences.

2026 INSC 312 SUPREME COURT OF INDIA DIVISION BENCH M/S A.K.G. CONSTRUCTION AND DEVELOPERS PVT. LTD Vs. STATE OF JHARKHAND AND OTHERS ( Before : Pamidighantam Sri Narasimha and Alok…

Service Matters

Service Law — Disciplinary proceedings — Punishment — Judicial review — The court’s power to review punishment is limited and generally does not allow substitution of its own judgment for that of the disciplinary authority unless the punishment is illogical, suffers from procedural impropriety, or shocks the conscience of the court

2026 INSC 313 SUPREME COURT OF INDIA DIVISION BENCH PUNJAB AND SIND BANK Vs. SH. RAJ KUMAR ( Before : Dipankar Datta and Satish Chandra Sharma, JJ. ) Civil Appeal…

Waqf Act, 1995 — Section 3(i) and Section 32(2)(g) — Jurisdiction of Civil Court versus Waqf Board — Distinction between Sajjadanashin and Mutawalli — Sajjadanashin is a spiritual head with religious duties, while Mutawalli is a secular manager of Waqf property — Waqf Board has jurisdiction over appointment and removal of Mutawallis but not Sajjadanashins — Civil Court retains jurisdiction over disputes concerning the office of Sajjadanashin — High Court wrongly held Civil Court lacked jurisdiction.

2026 INSC 314 SUPREME COURT OF INDIA DIVISION BENCH SYED MOHAMMED GHOUSE PASHA KHADRI Vs. SYED MOHAMMED ADIL PASHA KHADRI AND OTHERS ( Before : M.M. Sundresh and Vipul M.…

National Highways Act, 1956 — Amendments and compensation provisions — Section 3-J introduced in 1997 removed applicability of Land Acquisition Act, 1894 (1894 Act) provisions for solatium and interest — Overturned by various High Courts, including reading down Sections 3-G and 3-J to grant solatium and interest — Subsequently, Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (2013 Act) and its amended provisions extended to NH Act — Court clarified that landowners acquired lands under NH Act between 1997 and 2015 are entitled to solatium and interest — Review Petition filed by NHAI arguing financial burden was underestimated rejected, but clarification on delayed claims issued.

2026 INSC 291 SUPREME COURT OF INDIA DIVISION BENCH NATIONAL HIGHWAYS AUTHORITY OF INDIA Vs. TARSEM SINGH AND OTHERS ( Before : Surya Kant, CJI and Ujjal Bhuyan, J. )…

Civil Procedure Code, 1908 (CPC) — Order 21 Rule 102 — Applicability — Provision contemplates a situation where a judgment debtor transfers property after institution of suit to a person who then obstructs execution — Not applicable where respondents derived title from independent registered sale deeds, not from the judgment debtor.

2026 INSC 292 SUPREME COURT OF INDIA DIVISION BENCH SHARADA SANGHI AND OTHERS Vs. ASHA AGARWAL AND OTHERS ( Before : Dipankar Datta and Augustine George Masih, JJ. ) Civil…

Land Acquisition Act, 1894 — Section 28-A — Re-determination of compensation — Second application for re-determination based on High Court award maintainable even after accepting compensation based on Reference Court award — Principle of merger means appellate court’s award supersedes earlier award, entitling landowners to benefit from higher compensation — Object of Section 28-A is to ensure equality in compensation among similarly placed landowners.

2026 INSC 293 SUPREME COURT OF INDIA DIVISION BENCH ANDANAYYA AND OTHERS Vs. DEPUTY CHIEF ENGINEER AND OTHERS ( Before : M. M. Sundresh and Nongmeikapam Kotiswar Singh, JJ. )…

Electricity Act, 2003 — Section 61, 86 — Tariff determination and Generation Based Incentive (GBI) — State Electricity Regulatory Commission (SERC) has exclusive power to determine tariff — Ministry of New and Renewable Energy (MNRE) introduced GBI to incentivise renewable energy generation — GBI is intended to be over and above the tariff fixed by SERC — SERC must consider GBI while determining tariff, but not necessarily deduct it — SERC’s power to determine tariff includes considering incentives — Parliament’s allocation of funds for GBI does not prevent SERC from considering it in tariff — SERC must exercise its power harmoniously with other stakeholders to achieve policy objectives.

2026 INSC 294 SUPREME COURT OF INDIA DIVISION BENCH SOUTHERN POWER DISTRIBUTION COMPANY OF ANDHRA PRADESH LIMITED AND ANOTHER Vs. GREEN INFRA WIND SOLUTIONS LIMITED AND ANOTHER ( Before :…

Contract Law — Award of Tender — Judicial Review — High Court should exercise restraint when reviewing tender evaluation processes, especially in technical matters, unless there is clear evidence of mala fide, arbitrariness, or irrationality — A marginal difference in scores, as seen in this case, does not automatically warrant interference, especially when the owner has the right to accept or reject bids and the contract is already underway.

2026 INSC 295 SUPREME COURT OF INDIA DIVISION BENCH M/S. STEAG ENERGY SERVICES (INDIA) PVT. LTD. Vs. GSPC PIPAVAV POWER COMPANY LTD. (GPPC) AND OTHERS ( Before : Pamidighantam Sri…

[Bombay Electricity Duty Act, 1958, S. 5A] – State Government can withdraw electricity duty exemptions, provided it’s reasonable, fair, and not arbitrary or discriminatory. [Bombay Electricity Duty Act, 1958, S. 5A] – Withdrawal of electricity duty exemption requires reasonable notice to industries structured around the concession.

2026 INSC 296 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF MAHARASHTRA AND OTHERS Vs. RELIANCE INDUSTRIES LTD. AND OTHERS ( Before : Pamidighantam Sri Narasimha and Alok Aradhe,…

Criminal Procedure Code, 1973 (CrPC) — Sections 482 and 226 — Quashing of FIR and criminal proceedings — Allegations of dowry demand, cruelty, and assault resulting in miscarriage — Delay in lodging FIR — Vague and omnibus allegations without corroborating evidence — Inherent improbability of allegations — Abuse of process of law — The Supreme Court quashed the FIR and criminal proceedings against the appellants (sister-in-law and parents-in-law) leading to a miscarriage — The Court noted significant delay in lodging the FIR, vague and omnibus allegations without concrete evidence, and the inherent improbability of the accusations — The Court emphasized that general and sweeping accusations unsupported by evidence cannot form the basis for criminal prosecution and that the legal provisions should not be misused for personal vendetta or arm-twisting tactics — The Court relied on the principles laid down in State of Haryana vs Bhajan Lal, including cases where allegations are absurd or inherently improbable, or where the proceeding is maliciously instituted with ulterior motive — The Court also considered the age and career prospects of the accused, deeming it inexpedient and not in the interest of justice to allow the prosecution to continue against them.

2026 INSC 297 SUPREME COURT OF INDIA DIVISION BENCH CHARUL SHUKLA Vs. STATE OF U.P. AND OTHERS ( Before : B.V. Nagarathna and Ujjal Bhuyan, JJ. ) Criminal Appeal No…..of…

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