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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.

U.P. Urban Premises Rent Control Ordinance, 2021 — Section 21(2) — Eviction proceedings — Landlord-tenant relationship established and affirmed up to Supreme Court — Tenant’s subsequent restoration application before Rent Authority, challenging sale deed validity, was an abuse of process and overreaching court orders — Rent Authority’s order setting aside eviction was void for lack of jurisdiction, as title dispute is purview of Civil Court, not Rent Authority — Judicial discipline and adherence to law require subordinate authorities to follow higher court orders

2026 INSC 299 SUPREME COURT OF INDIA DIVISION BENCH RAJESH GOYAL Vs. M/S LAXMI CONSTRUCTIONS AND OTHERS ( Before : Sanjay Karol and Nongmeikapam Kotiswar Singh, JJ. ) Civil Appeal…

Criminal Procedure, 1973 (CrPC) — Sections 215, 228, 464 and 465 — Charge framing — Substantial compliance — Purpose of charge framing is to give notice to accused of accusation and enable defence preparation — Defect in charge, including absence of signature, is curable if no prejudice or failure of justice is occasioned — Accused’s active participation and cross-examination indicate awareness of charges and no prejudice — Belated objection to charge defect, especially after demise of key witnesses, suggests lack of genuine prejudice.

2026 INSC 301 SUPREME COURT OF INDIA DIVISION BENCH SANDEEP YADAV Vs. SATISH AND OTHERS ( Before : Ahsanuddin Amanullah and R. Mahadevan, JJ. ) Criminal Appeal No.1617 of 2026…

Service Matters

Short Service Commission Women Officers (SSCWOs) — Eligibility for Permanent Commission (PC) and pensionary benefits — Applicability of Air Force Human Resource Policy — Refusal of benefits due to not meeting minimum average Annual Confidential Report (ACR) grading of 6.5 — Court’s refusal to grant benefits where minimum criteria not met and no demonstrated mitigating circumstances exist compared to other successful applicants.

SUPREME COURT OF INDIA FULL BENCH SQN. LDR. NITU THAPLIYAL AND OTHERS Vs. UNION OF INDIA AND OTHERS ( Before : Surya Kant, CJI, Ujjal Bhuyan and Nongmeikapam Kotiswar Singh,…

Service Matters

Air Force Act, 1950 — Short Service Commission Women Officers (SSCWOs) — Permanent Commission (PC) — Denial of PC — Assessment of performance and eligibility — HRP 01/2019 — Minimum Performance Criteria — ACR gradings — Mandatory In-Service Courses (MISCs) — Categorisation — Arbitrariness — Hurried implementation — Inadequate opportunity to meet criteria — Pregnancy — Deemed qualifying service for pension — One-time measure.

2026 INSC 280 SUPREME COURT OF INDIA FULL BENCH WG. CDR. SUCHETA EDN Vs. UNION OF INDIA AND OTHERS ( Before : Surya Kant, CJI, Ujjal Bhuyan and Nongmeikapam Kotiswar…

Service Matters

Army Act, 1950 — Short Service Commission Officers (SSCOs) — Permanent Commission (PC) — Annual Vacancy Cap — The Supreme Court examined the annual cap of 250 vacancies for PC, finding it not to be an immutable rule and that it had been breached historically for exigencies of service and policy changes, thus it should not act as an absolute bar to corrective relief, especially when the method of assessment was found to be unfair.

2026 INSC 281 SUPREME COURT OF INDIA FULL BENCH LT. COL. POOJA PAL AND OTHERS Vs. UNION OF INDIA AND OTHERS ( Before : Surya Kant, CJI, Ujjal Bhuyan and…

Service Matters

Service Law — Indian Navy — Short Service Commission Officers (SSCOs) — Grant of Permanent Commission (PC) — Assessment of suitability for PC — Whether casual grading of ACRs and “Not Recommended for PC” endorsements prejudiced officers’ chances of PC — Held yes, as officers were considered ineligible for PC at the time of their ACRs, leading to a distorted assessment of their inter se merit for PC — This circularity transformed past ineligibility into deemed unsuitability for career progression, creating an uneven playing field.

2026 INSC 282 SUPREME COURT OF INDIA FULL BENCH YOGENDRA KUMAR SINGH Vs. UNION OF INDIA AND OTHERS ( Before : Surya Kant, CJI, Ujjal Bhuyan and Nongmeikapam Kotiswar Singh,…

CONVERSION –Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — Section 3(1)(r), 3(1)(s), 3(2)(va) — Penal Code, 1860 — Sections 341, 323, 506 read with Section 34 — Quashing of criminal proceedings — Appellant converted to Christianity and worked as a Pastor for ten years — High Court quashed proceedings, holding appellant disentitled to protection under SC/ST Act due to conversion — Supreme Court upheld High Court’s decision — Conversion to a religion other than Hindu, Sikh, or Buddhist results in automatic and complete loss of Scheduled Caste status — Religious conversion bars claim to benefits under SC/ST Act, as it is predicated on Scheduled Caste membership.

2026 INSC 283 SUPREME COURT OF INDIA DIVISION BENCH CHINTHADA ANAND Vs. STATE OF ANDHRA PRADESH AND OTHERS ( Before : Prashant Kumar Mishra and Manmohan, JJ. ) Criminal Appeal…

Central Excise Act, 1944 — Section 11A(1) proviso — Extended period of limitation — Invocation of extended period of limitation for recovery of excise duty on Naphtha — Requires proof of fraud, collusion, wilful misstatement, or suppression of facts with intent to evade duty — Revenue failed to establish any deliberate act of suppression or evasion by the appellant, a public sector undertaking — Any duty evaded would be revenue neutral due to subsidy mechanism — Extended period of limitation held not applicable.

2026 INSC 285 SUPREME COURT OF INDIA DIVISION BENCH M/S. RASHTRIYA CHEMICALS AND FERTILIZERS LIMITED Vs. COMMISSIONER OF CENTRAL EXCISE AND SERVICE TAX (LTU) ( Before : Manoj Misra and…

Service Matters

Army Pension Regulations, 1961 — Condonation of shortfall in qualifying service for second pension for Defence Security Corps (DSC) personnel — The Union of India’s contention that condonation for shortfall in qualifying service for a second pension is not applicable to DSC personnel is rejected— The court finds that the Pension Regulations for the Army, specifically Paragraphs 125 (1961) and 44 (2008), which allow for condonation of service deficiency, are applicable to DSC personnel by incorporation by reference, unless there is an explicit inconsistency with DSC-specific provisions— The court finds no such inconsistency— Letters issued by the Ministry of Defence attempting to exclude DSC personnel from this condonation are ineffective as they cannot override statutory regulations.

2026 INSC 286 SUPREME COURT OF INDIA DIVISION BENCH UNION OF INDIA AND OTHERS Vs. BALAKRISHNAN MULLIKOTE (EX HAV 256812 M) ( Before : Manoj Misra and Manmohan, JJ. )…

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