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Land Acquisition and Development — Public Purpose De-reservation — Subject land originally earmarked for High School was de-reserved by competent authority due to insufficient area; subsequent sale to private individuals was upheld by civil courts and its finality was not challenged. Contempt of Courts Act, 1971 — Sections 2(c), 19 — Criminal Contempt — Scandalising the court — An advocate’s public allegations against a sitting judge, made via a press conference and repeated in court applications, can constitute criminal contempt by scandalising the court, lowering its authority, and interfering with judicial proceedings — Such conduct is unbecoming of a legal professional and undermines public confidence in the judiciary. Recruitment Rules and Advertisement — Essential Qualifications — Work Experience — In absence of a specific rule or advertisement provision, a recruiting agency cannot relax essential eligibility criteria by treating a higher qualification as a replacement for a mandatory essential qualification — A preference for a higher qualification operates only for eligible and meritorious candidates and does not override or supplant the primary requirement of essential eligibility. Industrial Disputes Act, 1947 — Section 10 — Relief of back wages and regularisation — Employee illegally terminated, ordered reinstatement with back wages by Labour Commissioner and Industrial Court — Employer challenged, but interim order for back wages deposit was made and employee reinstated as daily wager — Employee sought regularisation after completing 180 days of service, granted by Industrial Court from the date of 180 days completion as per settlement clause — Employer failed to comply timely, only regularising employee on a sanctioned post after many years, imposing new conditions contrary to prior orders — Supreme Court held that employer cannot impose new conditions limiting regularisation contrary to earlier unchallenged orders and settlement terms, and reversed High Court’s decision setting aside back wages order. Arbitration and Conciliation Act, 1996 — Section 34 — Challenge to Arbitral Award — Legal Representatives — The Arbitration Act is a complete code for dispute resolution — Legal representatives of a deceased party are entitled to challenge an arbitral award under Section 34 of the Act, as the Act envisions continuity of proceedings after a party’s death and makes awards enforceable by or against legal representatives — Denying this right would render legal representatives remediless while making them liable to fulfill the award, contradicting the Act’s purpose.

Transfer of Property Act, 1882 — Section 106 — Notice terminating tenancy — Service by registered post — Return with endorsement “ND” (Not Delivered) — General Clauses Act, 1897 — Section 27 — Deemed service — High Court set aside ejectment decree solely on ground of “ND” endorsement, misinterpreting deemed service provisions — Supreme Court held High Court erred in not considering Section 27 of GC Act regarding deemed service by registered post.

2025 INSC 859 SUPREME COURT OF INDIA DIVISION BENCH KRISHNA SWAROOP AGARWAL (DEAD) THR. LR. Vs. ARVIND KUMAR ( Before : Sanjay Karol and Joymalya Bagchi, JJ. ) Civil Appeal…

Service Matters

Pension Law — Family Pension — Eligibility of ‘Substitutes’ in Railways — deceased husband of the appellant was appointed as a ‘Substitute Waterman’ and died in harness after serving for 9 years, 8 months, and 26 days — Railways denied family pension on the grounds that his service was not regularized and did not meet the 10-year qualifying period for family pension — Appellant contended that as per Indian Railway Establishment Manual Vol-I, Rule 1515 and Railway Service (Pension) Rules, 1993, especially Rule 75(2)(a), substitutes with continuous service of one year are entitled to family pension. Held, deceased had acquired temporary status and completed more than one year of continuous service, thus eligible for family pension.

2025 INSC 855 SUPREME COURT OF INDIA DIVISION BENCH MALA DEVI Vs. UNION OF INDIA AND OTHERS ( Before : Sanjay Karol and Satish Chandra Sharma, JJ. ) Civil Appeal…

Micro, Small and Medium Enterprises Development Act, 2006 (MSMED Act) — Section 18(2) — Conciliation proceedings — Referring time-barred claims — Time-barred claims can be referred to conciliation as the expiry of the limitation period does not extinguish the right to recover the amount, and a settlement agreement reached through conciliation is akin to a contract for repayment of a time-barred debt, recognized under Section 25(3) of the Contract Act

2025 INSC 864 SUPREME COURT OF INDIA DIVISION BENCH M/S SONALI POWER EQUIPMENTS PVT. LTD. Vs. CHAIRMAN, MAHARASHTRA STATE ELECTRICITY BOARD, MUMBAI AND OTHERS ( Before : Pamidighantam Sri Narasimha…

Succession Act, 1925, Sections 63, 68 — Indian Evidence Act, 1872, Section 68 — Proof of Will — Propounder has to prove due execution and dispel suspicious circumstances — Suspicious circumstances include shaky signature, feeble mind, unfair disposition, propounder benefiting significantly — Absence of reasoned disinheritance of natural heir, especially wife, qualifies as a suspicious circumstance — Such omission raises doubt about free disposing mind of testator.

2025 INSC 866 SUPREME COURT OF INDIA DIVISION BENCH GURDIAL SINGH (DEAD) THROUGH LR Vs. JAGIR KAUR (DEAD) AND ANOTHER ETC ( Before : Sanjay Karol and Joymalya Bagchi, JJ.…

Motor Vehicles Act, 1988 — Section 10(2)(d) & 2(21) — Driving Licence for Light Motor Vehicle (LMV) — Validity for driving commercial vehicle with Gross Vehicle Weight not exceeding 7500 kg — Driver possessing LMV license can drive transport vehicle up to 7500 kg without additional endorsement — Constitutional Bench decision in Bajaj Alliance General Insurance Co. Ltd. v. Rambha Devi affirmed Mukund Dewangan v. Oriental Insurance Co. Ltd.

2025 INSC 867 SUPREME COURT OF INDIA DIVISION BENCH SUNITA AND OTHERS Vs. UNITED INDIA INSURANCE CO. LTD. AND OTHERS ( Before : Sanjay Karol and Joymalya Bagchi, JJ. )…

Prevention of Corruption Act, 1988 — Sections 7, 13(1)(d), 13(2) read with Section 120B of Indian Penal Code, 1860 — Demand and acceptance of bribe — Essential to prove demand and acceptance by public servant — Mere acceptance of illegal gratification without demand is not an offence — Prosecution must prove foundational facts through oral or documentary evidence — Presumption under Section 20 is mandatory and subject to rebuttal; presumption of fact is discretionary — High Court erred in reversing acquittal based on inferences and conjectures, ignoring glaring contradictions in prosecution evidence.

2025 INSC 868 SUPREME COURT OF INDIA DIVISION BENCH M SAMBASIVA RAO Vs. THE STATE OF ANDHRA PRADESH ( Before : Pankaj Mithal and Ahsanuddin Amanullah, JJ. ) Criminal Appeal…

Penal Code, 1860 — Sections 406 and 420 — Cheating and Criminal Breach of Trust — FIR registered based on a property dispute, with conflicting allegations between FIR and civil suit pleadings — Discrepancies in alleged sale consideration and property descriptions indicate manipulation to create a criminal case out of a civil transaction.

2025 INSC 870 SUPREME COURT OF INDIA DIVISION BENCH MALA CHOUDHARY AND ANOTHER Vs. STATE OF TELANGANA AND ANOTHER ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Criminal…

Constitution of India, 1950 — Article 227 — Penal Code, 1860 — Sections 147, 323, 341, 325, 307, 427, 149 — Criminal Procedure Code, 1973 — Sections 439, 439(2) — Supreme Court’s Role and Judicial Restraint — High Courts should generally refrain from passing strictures against judicial officers. Strictures should only be passed in exceptional circumstances and after providing an opportunity to the officer to explain — The proper procedure is to report such matters to the Chief Justice for administrative action — Supreme Court expunged strictures against a judicial officer due to lack of opportunity and reversal of a key judgment cited by the High Court.

2025 INSC 871 SUPREME COURT OF INDIA FULL BENCH KAUSHAL SINGH Vs. THE STATE OF RAJASHTAN ( Before : Vikram Nath, Sanjay Karol and Sandeep Mehta, JJ. ) Criminal Appeal…

Arbitration and Conciliation Act, 1996 — Section 11 — Appointment of Arbitrator — Existence of arbitration agreement — High Court dismissed appellant’s application under Section 11 on the ground that no arbitration agreement existed — Clause 13 of contract relied upon as arbitration agreement — Clause stated that for parties other than Govt. Agencies, redressal of disputes “may be sought” through arbitration — Supreme Court held that use of “may be sought” indicates no subsisting agreement to use arbitration — Clause was an enabling provision if parties agreed, not a binding agreement.

2025 INSC 874 SUPREME COURT OF INDIA DIVISION BENCH BGM AND M-RPL-JMCT (JV) Vs. EASTERN COALFIELDS LIMITED ( Before : Pamidighantam Sri Narasimha and Manoj Misra, JJ. ) Civil Appeal…

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