Issues: Whether the High Court erred in remitting the limited question of valuation and fixation of reserve price of Schedule A to E properties to the Debts Recovery Tribunal (DRT) after the auction sale had been conducted, confirmed and a sale certificate registered; and whether such remand unlawfully disturbed the rights of the bona fide auction purchaser.

Analysis: The Court examined the factual matrix showing that the DRT conducted the auction after obtaining a valuation report dated 08.09.2010, that sixteen bidders participated, that the appellant was declared the highest bidder, deposited the sale consideration and obtained a registered sale certificate in 2011, and that the DRT and DRAT had earlier upheld the auction's legality. The Court recognised the settled principle protecting bona fide auction purchasers and the need for finality in court-confirmed sales, citing authorities that confirmed auction sales should not be lightly disturbed except in cases of fraud or material irregularity. The Court balanced that principle against the supervisory jurisdiction of the High Court to examine the adequacy of valuation and the lawfulness of reserve price fixation where credible issues are raised, noting that the objective of recovery proceedings is to realise the maximum value of secured assets. The Court observed that the High Court's direction was narrowly confined to remanding the valuation issue to the DRT for fresh consideration on relevant materials and did not set aside the auction, disturb the sale confirmation, or negate the rights of the auction purchaser. The remand was held to be a limited exercise to permit the Tribunal to reassess whether valuation and reserve price fixation accorded with law so as to protect the interests of all parties.

Conclusion: The High Court did not err in remitting the limited issue of valuation and fixation of the reserve price to the DRT for fresh consideration; the remand is a lawful, confined exercise of supervisory jurisdiction and does not unjustifiably disturb the confirmed auction. The Civil Appeal is dismissed (decision in favour of the respondents).

Issues: (i) Whether the charge of criminal conspiracy and the alleged demand of bribe on behalf of the assessing officer were proved. (ii) Whether the demand and acceptance of illegal gratification by the inspector were proved so as to sustain conviction under the anti-corruption law.

Issue (i): Whether the charge of criminal conspiracy and the alleged demand of bribe on behalf of the assessing officer were proved.

Analysis: The evidence did not establish any meeting of minds between the two public servants. There was no reliable proof that the assessing officer demanded any bribe, and no convincing material showed that the inspector made the demand in the presence of the assessing officer. The prosecution case, so far as it linked the assessing officer to a conspiracy, remained unsupported by proof of direct demand or participation.

Conclusion: The charge of criminal conspiracy was not proved and the assessing officer's acquittal stood confirmed.

Issue (ii): Whether the demand and acceptance of illegal gratification by the inspector were proved so as to sustain conviction under the anti-corruption law.

Analysis: The complainant's testimony as to the demand made by the inspector on the relevant date was supported by the trap laying officer and substantial parts of the independent witnesses' evidence. The pre-trap formalities, recovery of the marked notes from the inspector, and the positive sodium carbonate test on his hands and clothing corroborated acceptance. The absence of reliable evidence against the assessing officer did not dilute the separate case against the inspector, and the recoveries and conduct of the inspector provided sufficient proof of the offence.

Conclusion: The inspector's conviction for the offence of accepting illegal gratification was restored, while the conspiracy charge remained unproved.

Final Conclusion: The judgment preserves the acquittal of the assessing officer, but reinstates the inspector's conviction for corrupt acceptance of gratification, with a reduced sentence.

Ratio Decidendi: A public servant can be convicted for acceptance of illegal gratification on independent proof of demand, acceptance, recovery, and corroborative trap evidence even when the alleged conspiracy with another accused is not established.

Issues: (i) Whether the impugned High Court order could disturb the benefit already conferred on the appellants by the earlier judgment of the Supreme Court and affect their career prospects. (ii) Whether persons who were not parties to the earlier proceedings could pursue an independent remedy against a judgment or order that allegedly prejudiced their rights.

Issue (i): Whether the impugned High Court order could disturb the benefit already conferred on the appellants by the earlier judgment of the Supreme Court and affect their career prospects.

Analysis: The earlier decision had already granted the appellants relief and their promotions had been implemented. Once that position had attained finality, the High Court could not, in substance, reopen or undermine the consequence of the Supreme Court's earlier order in proceedings to which the appellants were not parties. The impugned observations, insofar as they could prejudice the appellants, were therefore not to operate against them in view of the special facts noticed.

Conclusion: The issue was answered in favour of the appellants, and the impugned order was not to affect their career prospects.

Issue (ii): Whether persons who were not parties to the earlier proceedings could pursue an independent remedy against a judgment or order that allegedly prejudiced their rights.

Analysis: The governing principle is that a decision may sometimes have broader consequences beyond the immediate parties, but a non-party who is aggrieved is not remediless. The available course is to approach the appropriate forum in accordance with law, including the remedies recognised for persons affected by a judgment but not impleaded in the earlier proceedings.

Conclusion: The issue was answered by holding that the intervenors and the petitioner in the connected matter were at liberty to pursue an appropriate remedy before the appropriate forum.

Final Conclusion: The appeal was allowed to the extent of protecting the appellants from prejudice under the impugned order, while the connected matters were left to be pursued through independent remedies in accordance with law.

Ratio Decidendi: A judgment affecting service rights cannot be allowed to prejudice non-parties without affording them the remedy recognised by law, and an earlier final order in favour of parties cannot be indirectly unsettled in later proceedings so as to impair their accrued benefits.

Issues: Whether the guarantors/sureties are discharged under Section 139 of the Indian Contract Act, 1872 by reason of the creditor's acts or omissions, or remain liable to the extent of the original sanctioned amount under Section 133 of the Indian Contract Act, 1872 where the principal debtor overdrew funds in excess of the sanctioned cash-credit facility.

Analysis: Chapter VIII of the Indian Contract Act, 1872 governs guarantee and discharge of surety. Section 133 provides that any variance in the terms of the contract between principal-debtor and creditor made without the surety's consent discharges the surety as to transactions subsequent to the variance. Section 139 provides that a surety is discharged where the creditor does an act inconsistent with the surety's rights or omits a duty which results in impairment of the surety's eventual remedy against the principal-debtor. Applying these provisions to the facts, the principal-debtor was originally sanctioned a cash-credit facility of Rs. 4,00,000; amounts in excess were subsequently withdrawn without the sureties' consent. That overdraw constituted a variance in the original contract permitting discharge only as to transactions after the variance under Section 133. For Section 139 to apply, there must be not only an act inconsistent with the surety's rights but also impairment of the surety's eventual remedy against the principal-debtor; no such impairment is shown on these facts. Authorities establish that the creditor may proceed against sureties and need not first exhaust remedies against the principal-debtor, and that discharge under Section 133 operates only for transactions subsequent to unauthorized variation.

Conclusion: The sureties are liable to the extent of the original sanctioned amount of Rs. 4,00,000 with applicable interest and are not liable for amounts overdrawn without their consent; this conclusion is in favour of the Appellant.

Issues: (i) Whether pre-award or pendente lite interest, described as compensation, could be granted in the face of the contractual bar under the GCC and the Arbitration and Conciliation Act, 1996; (ii) Whether post-award interest could be granted and, if so, whether the rate fixed by the arbitral tribunal was sustainable; (iii) Whether the Commercial Court and the High Court erred in refusing to interfere under Sections 34 and 37 of the Arbitration and Conciliation Act, 1996.

Issue (i): Whether pre-award or pendente lite interest, described as compensation, could be granted in the face of the contractual bar under the GCC and the Arbitration and Conciliation Act, 1996.

Analysis: Clause 16(3) of the GCC expressly barred interest on amounts payable to the contractor under the contract. Section 31(7)(a) of the Arbitration and Conciliation Act, 1996 makes the award of pre-award interest subject to party agreement, and Section 28(3) requires the tribunal to act in accordance with the contract. The contractual bar was held to be wide and independent, and the tribunal could not avoid it by labelling the award as compensation.

Conclusion: Pre-award or pendente lite interest was not permissible and the award of such interest was liable to be set aside.

Issue (ii): Whether post-award interest could be granted and, if so, whether the rate fixed by the arbitral tribunal was sustainable.

Analysis: Clause 64(5) of the GCC barred interest only up to the date of the award and did not exclude interest thereafter. Section 31(7)(b) operates independently of contractual exclusion unless the award itself directs otherwise. The entitlement to post-award interest was therefore upheld, but the tribunal had given no reasons for fixing it at 12% per annum and the rate was considered excessive in the circumstances.

Conclusion: Post-award interest was justified, but the rate was reduced from 12% per annum to 8% per annum from the date of award till realization.

Issue (iii): Whether the Commercial Court and the High Court erred in refusing to interfere under Sections 34 and 37 of the Arbitration and Conciliation Act, 1996.

Analysis: The courts below failed to notice that the tribunal had awarded pre-award interest in breach of an express contractual prohibition. That error went to the legality of the award and justified interference even within the limited supervisory scope under Sections 34 and 37. At the same time, the grant of post-award interest was not barred, though its rate required modification.

Conclusion: The Commercial Court and the High Court erred in law in so far as they upheld the pre-award interest component and the unmodified post-award rate.

Final Conclusion: The award was sustained only to the extent of post-award interest as modified, while the component granting pre-award or pendente lite interest was set aside, resulting in a partial allowance of the appeal.

Ratio Decidendi: Under the 1996 Act, an arbitrator cannot grant pre-award interest where the contract expressly bars it, but post-award interest under Section 31(7)(b) is not excluded by such bar unless the contract clearly so provides; the rate of post-award interest remains subject to judicial modification where unjustified.

Issues: (i) Whether the complaint and cognizance were barred by limitation under the Code of Criminal Procedure, 1973. (ii) Whether non-compliance with Section 202 of the Code vitiated the summoning process when the complaint was made by a public servant. (iii) Whether the High Court could quash the prosecution for alleged deficiency in pleading the role of company directors under the Drugs and Cosmetics Act, 1940.

Issue (i): Whether the complaint and cognizance were barred by limitation under the Code of Criminal Procedure, 1973.

Analysis: The limitation period for the offence punishable under the Drugs and Cosmetics Act, 1940 was three years. The Court held that, on the facts, the relevant starting point was the date on which the identity of the accused became known during the investigation, not the initial complaint by the private informant. The complaint before the court was filed within three years from that point, and the delay was therefore within the permissible period.

Conclusion: The limitation objection failed and the finding was in favour of the Appellants.

Issue (ii): Whether non-compliance with Section 202 of the Code vitiated the summoning process when the complaint was made by a public servant.

Analysis: The Court read Sections 200 and 202 of the Code harmoniously and treated a complaint by a public servant acting in discharge of official duty on a different footing. Reliance was placed on the earlier view that the object of an inquiry under Section 202 is to prevent unnecessary harassment, but that the statutory setting does not justify quashing where the complaint is by a public servant and the case is otherwise supported by official action. The Court rejected the distinction sought to be drawn on facts and held that the mandatory inquiry point did not justify interference in the present case.

Conclusion: The challenge based on Section 202 failed and was decided in favour of the Appellants.

Issue (iii): Whether the High Court could quash the prosecution for alleged deficiency in pleading the role of company directors under the Drugs and Cosmetics Act, 1940.

Analysis: The Court held that questions whether the directors were in charge of, and responsible for, the conduct of the company's business were matters of fact that should ordinarily be tested at trial. The High Court's conclusion that the complaint was insufficient on that aspect was found to be premature.

Conclusion: The quashing on the ground of Section 34 was unsustainable and the issue was decided in favour of the Appellants.

Final Conclusion: The prosecution was restored in the appeals where the quashing order was set aside, while the separate accused appeal was dismissed. The Court clarified that its observations were confined to the present appeals and would not prejudice the trial on merits.

Ratio Decidendi: In a prosecution initiated by a public servant under the Drugs and Cosmetics Act, the limitation period may commence when the identity of the accused is ascertained during investigation, and the requirement of inquiry under Section 202 of the Code does not warrant quashing where the complaint is by a public servant acting in discharge of official duty and the challenge is otherwise premature.

Issues: (i) Whether the legal representatives of the judgment-debtor could challenge the validity of the equitable mortgage after the award had attained finality; (ii) whether the revision under Section 154 of the Maharashtra Co-operative Societies Act, 1960 was maintainable despite the earlier liberty to pursue the remedy under Rule 107(13) and (14) of the Maharashtra Co-operative Societies Rules, 1961; (iii) whether non-deposit of the balance purchase money within the period prescribed under Rule 107(11)(h) rendered the auction sale void and whether that requirement could be waived by the creditor bank; (iv) what consequential order should follow once the auction sale was found void.

Issue (i): Whether the legal representatives of the judgment-debtor could challenge the validity of the equitable mortgage after the award had attained finality.

Analysis: The award passed by the Co-operative Court had become final. The judgment-debtor was liable jointly and severally under the award, and the property in dispute formed part of his assets available for execution. Once the award attained finality and the recovery certificate stood as a decree for execution, the property could be proceeded against for realization of the decretal amount. In that setting, the objection based on want of prior governmental permission for mortgage did not affect the recoverability of the property in execution.

Conclusion: The challenge to the auction on the ground of invalid mortgage was rejected.

Issue (ii): Whether the revision under Section 154 of the Maharashtra Co-operative Societies Act, 1960 was maintainable despite the earlier liberty to pursue the remedy under Rule 107(13) and (14) of the Maharashtra Co-operative Societies Rules, 1961.

Analysis: Section 154 confers wide revisional power on the State Government or the Registrar to examine legality, propriety, and regularity of a decision or proceeding of a subordinate officer. The remedies under Rule 107(13) and (14) are applications to set aside a sale on specified grounds and do not curtail the statutory revisional power. The pre-deposit requirement in Section 154(2A) applies to revisions against recovery certificates, not to a revision challenging confirmation of sale. Accordingly, the revision could be entertained notwithstanding non-availment of the rule-based remedy.

Conclusion: The revision was held maintainable under Section 154.

Issue (iii): Whether non-deposit of the balance purchase money within the period prescribed under Rule 107(11)(h) rendered the auction sale void and whether that requirement could be waived by the creditor bank.

Analysis: Rule 107(11)(g) and (h) require deposit of 15 per cent at the time of purchase and payment of the balance within the stipulated period. The rule does not confer discretion to extend time for the balance purchase money. Non-compliance attracts forfeiture and resale, and the provision serves not only the creditor's interest but also the integrity of public auctions. The record did not show any waiver by the judgment-debtor or his legal representatives, and the principle applied in the SARFAESI context was held inapplicable because the cooperative rules did not contain a comparable enabling provision for extension.

Conclusion: The auction sale and its confirmation were held void and null.

Issue (iv): What consequential order should follow once the auction sale was found void.

Analysis: Since the sale was void, the appropriate consequence was restoration of the parties to the extent possible through a fresh auction in accordance with Rule 107(11)(j). The auction purchaser could not be penalized for the procedural fault in the recovery process, and refund with interest was necessary to balance equities. The Court therefore modified the High Court's operative directions and substituted them with an order setting aside the sale, annulling the confirmation, directing a fresh auction, and requiring refund of the deposit with interest.

Conclusion: The High Court's order was modified, and a fresh auction with refund of the purchaser's money was directed.

Final Conclusion: The appeals were disposed of by upholding the finding that the auction sale was void, while altering the consequential relief so that the property would be re-auctioned and the auction purchaser would receive refund with interest.

Ratio Decidendi: Mandatory conditions governing deposit of auction purchase money under the cooperative recovery rules, when not complied with, render the sale a nullity and may be enforced through revisional jurisdiction even if the statutory rule-based sale challenge was not invoked.

Issues: (i) Whether the search and raid under Section 30 of the Pre-Conception and Pre-Natal Diagnostic Techniques (Prohibition of Sex Selection) Act, 1994 was vitiated because the decision was taken by the Chairperson alone and not by the District Appropriate Authority collectively; (ii) Whether the complaint and summoning order were liable to be quashed because the appellant had earlier been discharged in the police case arising from the same incident; and (iii) Whether the alleged irregularity regarding the advisory committee and the record-keeping requirements under the PCPNDT Act and Rules barred continuation of the complaint proceedings.

Issue (i): Whether the search and raid under Section 30 of the Pre-Conception and Pre-Natal Diagnostic Techniques (Prohibition of Sex Selection) Act, 1994 was vitiated because the decision was taken by the Chairperson alone and not by the District Appropriate Authority collectively.

Analysis: The statutory scheme treats the appropriate authority as a collective body for purposes of authorising search under Section 30. The communication directing the raid showed action by the Civil Surgeon acting alone and did not disclose any collective decision of the authority. On that footing, the search was contrary to Section 30. At the same time, the illegality of the search did not require the seized material to be discarded altogether. The evidence gathered in the course of the search could still be considered subject to relevancy and admissibility.

Conclusion: The search was illegal for want of collective authorisation, but the seized material was not rendered wholly unusable and the challenge to the proceedings did not succeed on that ground.

Issue (ii): Whether the complaint and summoning order were liable to be quashed because the appellant had earlier been discharged in the police case arising from the same incident.

Analysis: A discharge in the police case did not affect the independent complaint jurisdiction under Section 28 of the PCPNDT Act, which permits cognizance only on a complaint by the appropriate authority or an authorised officer. The earlier police discharge was based on investigation in the FIR case and did not conclude the statutory complaint proceedings. The complaint was also supported by the statutory scheme requiring proper records, including Form F, and by the limitation framework under Section 468(2)(c) of the Code of Criminal Procedure, 1973 as applied to the offence alleged. The alleged contraventions of Sections 4, 5, 6 and 29 of the PCPNDT Act and Rules 9 and 10 of the PCPNDT Rules were matters for trial and not for quashing at the threshold.

Conclusion: The prior discharge in the police case did not bar the complaint or the summoning order, and quashing was not warranted.

Issue (iii): Whether the alleged irregularity regarding the advisory committee and the record-keeping requirements under the PCPNDT Act and Rules barred continuation of the complaint proceedings.

Analysis: Rule 18A of the PCPNDT Rules operates as a code of conduct for appropriate authorities. The objection that a person connected with the raid was later associated with the advisory committee did not, on the facts, vitiate the complaint. The rule against including a person who is part of the investigating machinery did not apply on the materials accepted by the Court. Separately, the Act and Rules require strict maintenance of records, and deficiency in such records may amount to contravention of the Act. The allegations of non-maintenance or deficient maintenance of mandatory records were therefore not matters to be short-circuited in proceedings under Section 482 of the Code of Criminal Procedure, 1973.

Conclusion: The alleged advisory committee irregularity did not invalidate the prosecution, and the record-keeping allegations had to be tested in trial.

Final Conclusion: The complaint proceedings were held to be maintainable, the challenge to quashing failed, and the prosecution was allowed to continue, with the Court leaving questions relating to reliability and admissibility of evidence open.

Ratio Decidendi: A search under Section 30 of the PCPNDT Act must be authorised by the appropriate authority as a collective decision, but even if the search is illegal, material seized during that search is not automatically excluded and may still be relied upon subject to the rules of relevancy and admissibility; a prior discharge in an FIR-based police case does not bar an independent complaint under Section 28 of the Act.

Issues: (i) Whether the Court could issue nationwide directions to strengthen implementation of the Solid Waste Management Rules, 2026 and related compliance mechanisms. (ii) Whether the right to a clean and healthy environment under Article 21, read with the Environment (Protection) Act, 1986, justified proactive monitoring, segregation, and remediation measures for solid waste management.

Issue (i): Whether the Court could issue nationwide directions to strengthen implementation of the Solid Waste Management Rules, 2026 and related compliance mechanisms.

Analysis: The order records that the new waste-management regime is comprehensive and is intended to address persistent non-compliance and implementation gaps under the earlier regime. It proceeds on the basis that the Rules are framed under the Environment (Protection) Act, 1986, and that the Central Government may issue directions for their effective enforcement. On that foundation, the Court formulates a multi-tier compliance architecture involving State and district authorities, local bodies, pollution control boards, bulk waste generators, and educational institutions, together with timelines, reporting obligations, and monitoring mechanisms.

Conclusion: The Court issued nationwide implementation directions to facilitate compliance with the Solid Waste Management Rules, 2026.

Issue (ii): Whether the right to a clean and healthy environment under Article 21, read with the Environment (Protection) Act, 1986, justified proactive monitoring, segregation, and remediation measures for solid waste management.

Analysis: The order treats the right to a clean and healthy environment as part of the right to life under Article 21 and emphasises the State's duty to protect the environment. It links the constitutional mandate with statutory powers under the Environment (Protection) Act, 1986, and with the new Rules' emphasis on source segregation, four-stream waste handling, bulk-waste-generator responsibility, public awareness, and remediation of legacy dumpsites. The reasoning also stresses that compliance gaps require immediate administrative and institutional action rather than delayed implementation.

Conclusion: The Court held that constitutional environmental protection justified immediate and structured enforcement measures for solid waste management.

Final Conclusion: The order lays down an expanded compliance framework for solid waste management, with nation-wide preparatory directions aimed at ensuring effective implementation of the new regime while the connected matters remain under continued monitoring.

Ratio Decidendi: The constitutional right to a clean and healthy environment, read with the statutory power to enforce environmental rules, permits proactive directions and monitoring measures to secure effective compliance with solid-waste management obligations.

Issues: (i) Whether the purchaser's claim that the sale was without notice of the existing liability could displace the attachment in execution; (ii) Whether a post-award transferee could resist execution of the money award under Order XXI Rule 102 of the Code of Civil Procedure, 1908.

Issue (i): Whether the purchaser's claim that the sale was without notice of the existing liability could displace the attachment in execution.

Analysis: The sale deed was executed after the arbitral proceedings had been instituted and after the award had been made. The Court noted that the non-production of the tripartite agreement, which explained the earlier debt-related arrangement, weakened the plea of absence of notice. The independent recovery steps under the SARFAESI proceedings did not shield the judgment-debtor's property from execution of the award. On the record, the purchaser failed to establish that the transfer was free from notice of the existing claim.

Conclusion: The plea of purchase without notice was rejected.

Issue (ii): Whether a post-award transferee could resist execution of the money award under Order XXI Rule 102 of the Code of Civil Procedure, 1908.

Analysis: An arbitral award enforceable under Section 36 of the Arbitration and Conciliation Act, 1996 stands in the position of a decree. Order XXI Rule 102 bars a transferee pendente lite from resisting execution through the protections otherwise available to third-party claimants. The Court held that pendency for this purpose is linked to the institution of the proceeding that culminated in the award, and not merely to the later challenge under Section 34. A transferee after institution of the arbitral proceedings and after the award cannot defeat execution by setting up a later purchase, even in a money claim, because that would frustrate realization of the decree-holder's fruits of the decree.

Conclusion: The purchaser was treated as a transferee pendente lite and her claim petition was not maintainable against execution.

Final Conclusion: The attachment and the dismissal of the claim petition were upheld, and the execution of the arbitral award was allowed to proceed against the property.

Ratio Decidendi: A transferee of the judgment-debtor's property after institution of the proceeding that culminates in a decree or enforceable award is a transferee pendente lite and cannot resist execution under Order XXI Rule 102, including where the decree is for money and the award remains unsatisfied.

Issues: (i) Whether the High Court's order granting bail was legally sustainable; (ii) Whether the completed investigation warranted transfer to a special agency; (iii) Whether bail applicants must make full disclosure of material particulars and criminal antecedents.

Issue (i): Whether the High Court's order granting bail was legally sustainable.

Analysis: An appellate challenge to grant of bail is distinct from cancellation based on post-bail misconduct. A bail order may be annulled where it is perverse, legally untenable, based on irrelevant material, or overlooks material considerations including the gravity of accusations, criminal antecedents and societal impact. The bail order relied upon documents whose genuineness formed the subject of the prosecution, despite prima facie material that the purported institution lacked affiliation to conduct a law course and that the marksheet had not been issued by the University. The respondent's suppression of multiple criminal antecedents materially vitiated the exercise of bail discretion.

Conclusion: The bail order was legally unsustainable and was set aside; bail was cancelled in favour of the appellant.

Issue (ii): Whether the completed investigation warranted transfer to a special agency.

Analysis: Transfer of an investigation to an independent or special agency after filing of the chargesheet is an exceptional measure, requiring cogent material showing bias, mala fides, improper investigation, extraneous influence, or a credible need to restore public confidence. The investigation had concluded, cognizance had been taken, and no substantiated material established that the State investigation was tainted or influenced.

Conclusion: Transfer of the investigation to a special agency was declined.

Issue (iii): Whether bail applicants must make full disclosure of material particulars and criminal antecedents.

Analysis: Suppression or selective disclosure of material facts in bail proceedings amounts to abuse of process and undermines informed judicial discretion. Bail applicants must disclose criminal antecedents, earlier and pending bail applications, coercive processes, custody details, procedural status and other material particulars, supported by affidavit. An illustrative, recommendatory disclosure framework was issued to promote transparency and uniformity, with circulation to High Courts and the district judiciary for appropriate consideration.

Conclusion: Full and candid disclosure of material particulars by bail applicants was reaffirmed, and a recommendatory disclosure framework was issued.

Final Conclusion: The invalid grant of bail was annulled, while the request to transfer the concluded investigation was rejected; institutional measures for transparent bail disclosures were directed.

Ratio Decidendi: A superior court may annul a bail order without proof of supervening circumstances where the order is perverse, relies on suspect or irrelevant material, or ignores material considerations such as criminal antecedents and the gravity of the accusations.

Issues: (i) Whether successive registration of FIRs (FIR No.20/2025 and FIR No.458/2025) constituted a mala fide abuse of the criminal process to keep petitioner No.1 in custody and whether petitioner No.1 is entitled to be released on bail in those FIRs; (ii) Whether coercive action should be restrained against petitioner No.2 during the pendency of the petition.

Issue (i): Whether successive FIRs were mala fide and whether petitioner No.1 is entitled to bail in FIR No.20/2025 and FIR No.458/2025.

Analysis: The petition record shows that petitioner No.1 had been called for inquiry in an earlier FIR and that two subsequent FIRs were registered after this Court had granted interim bail; the timing and sequence of registrations and remands indicate a pattern aimed at prolonging custody. Applicable constitutional provisions invoked include Article 32 read with Article 142 and the petition raised alleged violations of Articles 14, 19 and 21. Criminal law framework includes offences alleged under specified sections of the Indian Penal Code, 1860 and provisions of the Prevention of Corruption Act, 1988. The registrational chronology, remand orders following grant of bail by this Court, and the absence of prior prosecution activity over many years were treated as material in assessing whether the process was being abused to frustrate the effect of bail.

Conclusion: Petitioner No.1 is entitled to be released on bail in FIR No.20/2025 and FIR No.458/2025. This conclusion is in favour of the appellant.

Issue (ii): Whether coercive action should be restrained against petitioner No.2 during the pendency of the petition.

Analysis: Petitioner No.2 had not been arrested at the time of decision. Given the findings on the pattern of successive FIRs and the need to protect personal liberty while investigation proceeds, a protective restraint on coercive steps was considered appropriate, subject to cooperation with the investigation.

Conclusion: No coercive steps shall be taken against petitioner No.2 subject to her cooperation with the investigation. This conclusion is in favour of the appellant.

Final Conclusion: The writ petition is allowed; petitioner No.1 is directed to be released on bail in the specified FIRs and coercive action against petitioner No.2 is restrained on the stated condition, thereby providing protective relief to the petitioners while preserving investigative rights of the State.

Ratio Decidendi: Where successive criminal proceedings are instituted in sequence after judicial bail to defeat the effect of that bail and to perpetuate custody without independent supporting circumstances, such registrations constitute abuse of process and justify grant of bail and protective restraint on coercive action.

Issues: (i) Whether the High Court order directing listing of the contempt petition for framing of charges can be sustained without a clear and categorical direction as to existence of a right and mode of compliance, and whether the respondents should be permitted to challenge the Government order dated 09.05.2025 by filing a writ petition to be taken up along with the contempt proceedings.

Analysis: The Court examined the sequence of writ orders, executive orders and repeated remands/reconsideration directed by the High Court, noting the absence of a clear, categorical finding by the High Court establishing a right and specifying the manner of compliance such that the executive would have no discretion. The Court also considered the propriety of invoking contempt jurisdiction when an appealable or challengeable executive order (09.05.2025) existed and remained unchallenged. Applying principles that courts must issue clear directions when seeking compliance and that contempt should not be used as a substitute for available challenges to executive action, the Court directed that the respondents be permitted to file a writ petition against the 09.05.2025 order and required the High Court to first decide that writ petition (hearing petitioners and State) and to refrain from remanding the matter back to the authorities; if the High Court finds merit it must issue clear and categorical directions for compliance, otherwise it may dismiss the writ petition with reasons.

Conclusion: Permission is granted to respondents to file a writ petition against the order dated 09.05.2025; the High Court shall take up that writ petition along with the contempt proceedings, decide the writ petition on merits without remanding the matter to the authorities, and either issue clear directions for compliance or dismiss the writ petition with reasoned findings.

Ratio Decidendi: Where a court's order lacks a clear, categorical identification of a legally enforceable right and a specified mode of compliance, contempt proceedings are inappropriate; instead, parties must be permitted to challenge the executive order by ordinary writ remedy and courts should issue explicit directions or dismiss the challenge after reasoned consideration.

Issues: (i) Whether land acquisition proceedings initiated under the Land Acquisition Act, 1894, but culminating in an award after commencement of the 2013 Act, are governed by Section 24(1)(a) of the 2013 Act. (ii) Whether an appeal under Section 74 of the 2013 Act is subject to Section 5 of the Limitation Act, 1963. (iii) Whether the delay in filing the first appeals deserved condonation.

Issue (i): Whether land acquisition proceedings initiated under the Land Acquisition Act, 1894, but culminating in an award after commencement of the 2013 Act, are governed by Section 24(1)(a) of the 2013 Act.

Analysis: Section 24(1)(a) applies where acquisition proceedings under the 1894 Act had commenced but no award had been made before commencement of the 2013 Act. In such cases, the acquisition continues, but the award-making stage is governed by the 2013 Act, save that rehabilitation and resettlement entitlements are not retrospectively imported into proceedings initiated under the earlier Act. The provision is a savings clause designed to extend the beneficial regime of the 2013 Act to pending matters at the stage of compensation determination.

Conclusion: The proceedings were correctly treated as governed by Section 24(1)(a) of the 2013 Act, and the awards had to be made under the 2013 Act, apart from rehabilitation and resettlement entitlements.

Issue (ii): Whether an appeal under Section 74 of the 2013 Act is subject to Section 5 of the Limitation Act, 1963.

Analysis: Section 74 prescribes a limitation period for appeals to the High Court, and its proviso only permits a further period within which the delayed appeal may still be entertained. The 2013 Act does not expressly exclude the Limitation Act, and Section 103 states that the Act is in addition to and not in derogation of other laws in force. Read with Section 29(2) of the Limitation Act, 1963, the absence of express exclusion means that Section 5 remains available. The statutory scheme does not justify reading an implied exclusion into Section 74.

Conclusion: Section 5 of the Limitation Act, 1963 applies to appeals under Section 74 of the 2013 Act.

Issue (iii): Whether the delay in filing the first appeals deserved condonation.

Analysis: Since Section 5 of the Limitation Act, 1963 applied, and the matters involved appeals against awards under the 2013 Act, the delay applications were liable to be considered on the liberal standard of sufficient cause. The Court found no reason to remit the matters for further delay adjudication and preferred to avoid prolonging the litigation.

Conclusion: The delay in filing the first appeals was condoned and the applications were allowed.

Final Conclusion: The impugned High Court orders were set aside to the extent they had rejected condonation, and the first appeals were permitted to proceed on merits under the 2013 Act regime.

Ratio Decidendi: Where a special statute prescribing a limitation period does not expressly exclude the Limitation Act, 1963, Section 5 remains applicable by virtue of Section 29(2); and for pending land acquisition proceedings culminating in an award after commencement of the 2013 Act, Section 24(1)(a) requires application of the 2013 Act at the award stage.

Issues: Whether the delay in filing and re-filing the special leave petition could be condoned on the facts pleaded by the State.

Analysis: The application for condonation of delay disclosed no sufficient cause. The explanation was treated as a mere excuse rather than a legally acceptable justification. While a liberal approach to delay is sometimes adopted in matters involving the State, condonation remains discretionary and cannot be claimed as of right. The prolonged and unexplained lapse, including the failure to act with promptitude even after the earlier dismissal in the High Court, showed utter lethargy and indolence. The governing principle under Section 5 of the Limitation Act, 1963 requires a real and satisfactory explanation, and the Court found none.

Conclusion: The delay was not condonable and the special leave petition was liable to be dismissed as time-barred.

Ratio Decidendi: Condonation of delay under Section 5 of the Limitation Act, 1963 is a matter of judicial discretion requiring sufficient cause, and governmental litigants are not exempt from showing a real, acceptable explanation for prolonged delay.

Issues: (i) Whether the Revenue Officer had jurisdiction to review the concluded vesting order dated 07.10.1971 under the West Bengal Estates Acquisition Act, 1953; (ii) Whether the respondent-company satisfied the requirements of Section 6(1)(j) of the West Bengal Estates Acquisition Act, 1953 to retain the land on the footing that it was exclusively engaged in agricultural farming on 01.01.1952.

Issue (i): Whether the Revenue Officer had jurisdiction to review the concluded vesting order dated 07.10.1971 under the West Bengal Estates Acquisition Act, 1953.

Analysis: The power of review is not inherent and can be exercised only when the statute expressly or by necessary implication confers it. The authorities under the West Bengal Estates Acquisition Act, 1953 are statutory, quasi-judicial authorities and the omnibus investment of Civil Court powers under Section 57A of that Act does not, by itself, include a substantive power of review. Section 57B further shows a legislative intent against reopening matters already enquired into, determined or decided under the Act. A concluded vesting order, which had attained finality, could not be reopened by an executive authority in the absence of an express review provision. Such an exercise would also be inconsistent with the finality of adjudication and the separation of powers.

Conclusion: The Revenue Officer had no jurisdiction to review the vesting order, and the fresh order dated 07.05.2008 was void ab initio.

Issue (ii): Whether the respondent-company satisfied the requirements of Section 6(1)(j) of the West Bengal Estates Acquisition Act, 1953 to retain the land on the footing that it was exclusively engaged in agricultural farming on 01.01.1952.

Analysis: To claim retention under Section 6(1)(j), the company had to establish that it was engaged exclusively in farming, and that such engagement existed on 01.01.1952. The materials relied upon by the respondent-company did not satisfactorily prove that statutory condition. The earlier vesting proceedings had given it opportunities to produce supporting evidence, but it failed to do so. The memoranda and later documents did not establish exclusive farming as the sole business of the company, and belated reliance on old documents could not justify reopening a concluded determination.

Conclusion: The respondent-company failed to satisfy Section 6(1)(j) and was not entitled to retain the lands in question.

Final Conclusion: The statutory framework did not permit the revival of a final vesting determination by review, and the respondent-company's claim to retention failed on merits as well. The Tribunal's restoration of the 1971 vesting order was upheld and the High Court's contrary view was rejected.

Ratio Decidendi: A quasi-judicial authority cannot review a concluded order unless the statute expressly or by necessary implication confers that power, and a claim for retention under Section 6(1)(j) of the West Bengal Estates Acquisition Act, 1953 must be proved by strict compliance with the statutory precondition of exclusive engagement in farming on the relevant date.

Issues: (i) Whether the High Court exceeded its jurisdiction in second appeal by reversing the first appellate court's factual findings; (ii) Whether the notarised photocopy of the power of attorney was admissible and sufficient to establish authority to alienate the properties.

Issue (i): Whether the High Court exceeded its jurisdiction in second appeal by reversing the first appellate court's factual findings.

Analysis: Section 100 confines second-appellate jurisdiction to substantial questions of law and ordinarily preserves findings of fact. Interference remains permissible where findings rest on inadmissible material, ignore material evidence, misconstrue documents, or are vitiated by perversity. Reliance by the first appellate court on an unproved photocopy to infer authority to alienate constituted reliance on no legally admissible evidence, raising a question of law.

Conclusion: The High Court's interference was within the permissible scope of second-appellate jurisdiction. The issue is decided in favour of the plaintiff.

Issue (ii): Whether the notarised photocopy of the power of attorney was admissible and sufficient to establish authority to alienate the properties.

Analysis: Documentary facts must ordinarily be proved by primary evidence. Secondary evidence is admissible only after establishing the existence and execution of the original, a legally recognised reason for its non-production, and the authenticity of the copy. The photocopy was produced without the required factual foundation or compliance with the procedure governing secondary evidence. Statutory presumptions concerning authentication could not be invoked before the document was lawfully admitted and proved.

Conclusion: The photocopy was no evidence of authority to sell, and the alleged power of attorney could not validate the conveyances. The issue is decided in favour of the plaintiff.

Final Conclusion: The alleged authority to alienate having remained unproved, the conveyances executed on its basis did not bind the plaintiff.

Ratio Decidendi: A photocopy of a document cannot establish its contents or attract presumptions of due execution unless the statutory conditions for admission and proof of secondary evidence are first satisfied.

Issues: (i) whether, after approval of a resolution plan and change of management in corporate insolvency resolution process, the company could still be proceeded against for dishonour of cheques issued before the takeover; (ii) whether the complainant could continue proceedings only against the erstwhile directors-in-charge and cheque-signatories.

Issue (i): whether, after approval of a resolution plan and change of management in corporate insolvency resolution process, the company could still be proceeded against for dishonour of cheques issued before the takeover;

Analysis: Once the corporate insolvency resolution process culminated in approval of the resolution plan, the erstwhile management stood replaced by the successful resolution applicant. The liability for dishonour of cheques issued prior to the change in management could not be fastened on the company under the new management, as the legal effect of the approved resolution plan and the consequent takeover had to be given full effect. The company, therefore, could not be treated as responsible for the alleged offence in relation to acts committed before the new management assumed charge.

Conclusion: The company could not be held liable for the dishonour of the cheques after the resolution process and change of management.

Issue (ii): whether the complainant could continue proceedings only against the erstwhile directors-in-charge and cheque-signatories.

Analysis: The complaint could survive against those persons who were in charge of the company and were responsible for the issuance and dishonour of the cheques at the relevant time. The later impleadment of the company, after the change in management, could not affect the position of the new management, and the prosecution could proceed against the persons allegedly responsible in the erstwhile regime.

Conclusion: The complainant could proceed only against the erstwhile directors-in-charge and cheque-signatories.

Final Conclusion: The impugned remand and subsequent impleadment of the company were set aside to the extent they exposed the company under the new management, while the prosecution was left to continue against the persons responsible at the time of the cheque transactions.

Ratio Decidendi: On approval of a resolution plan and substitution of management in corporate insolvency resolution process, the company under the new management cannot be made liable for dishonour of cheques issued before the takeover; proceedings may continue only against those who were in charge at the relevant time.

Issues: (i) Whether, in proceedings under Section 15(2) of the Arbitration and Conciliation Act, 1996, the High Court could declare prior arbitral proceedings as a nullity on the ground that they were conducted during a moratorium under Section 14 of the Insolvency and Bankruptcy Code, 2016; (ii) Whether transactions undertaken pursuant to the arbitral orders during the relevant period should be protected.

Issue (i): Whether, in proceedings under Section 15(2) of the Arbitration and Conciliation Act, 1996, the High Court could declare prior arbitral proceedings as a nullity on the ground that they were conducted during a moratorium under Section 14 of the Insolvency and Bankruptcy Code, 2016.

Analysis: Section 15(2) contemplates only substitution of the arbitrator according to the rules applicable to the original appointment. Section 15(3) and Section 15(4) preserve the continuity of the arbitration and protect prior hearings and orders, unless the parties agree otherwise. The Court held that the High Court, while exercising jurisdiction under Section 15(2), could not travel beyond the limited statutory remit and could not set aside or nullify arbitral orders which the Arbitration and Conciliation Act, 1996 does not permit to be challenged in that manner. The Arbitration and Conciliation Act, 1996 is a self-contained code and the course prescribed by statute cannot be displaced by an alternate procedure.

Conclusion: The High Court lacked jurisdiction to declare the proceedings held between 17.03.2022 and 25.08.2022 a nullity, and that part of the impugned order was set aside.

Issue (ii): Whether transactions undertaken pursuant to the arbitral orders during the relevant period should be protected.

Analysis: The Court took note of the long lapse of time and the creation of third-party rights, including home buyers' interests, and exercised its constitutional power to avoid undoing completed commercial arrangements that had proceeded on the strength of the arbitral orders.

Conclusion: The transactions entered into pursuant to the arbitral orders were declared legally valid.

Final Conclusion: The appeal was partly allowed by removing the declaration of nullity, while preserving the transactions carried out in the interregnum and substituting the arbitrator for continuation of the arbitration from the existing stage.

Ratio Decidendi: In proceedings for substitution of an arbitrator, the court must confine itself to the limited power of appointing a substitute under the Arbitration and Conciliation Act, 1996, and cannot nullify prior arbitral proceedings or orders, which remain protected by the statutory scheme of continuity.

Issues: Whether an application under Section 29A(5) of the Arbitration and Conciliation Act, 1996 for extension of the mandate of the arbitrator is maintainable after expiry of the time prescribed under Section 29A(1) and the extended period under Section 29A(3), and even after an award has been rendered.

Analysis: Section 29A is designed to secure timely completion of arbitral proceedings while preserving the court's supervisory power to extend time before or after expiry of the statutory period. The structure of Section 29A, including the proviso to sub-section (4), sub-sections (5) to (9), and the deeming continuity of the reconstituted tribunal, shows that the mandate is not treated as finally extinguished in a manner that disables judicial intervention. The absence of an express bar on a post-award application, together with the legislative purpose of ensuring that arbitration reaches an effective conclusion, supports the view that the court's power under Section 29A(5) is not lost merely because the arbitrator has rendered an award after the mandate expired. Such an award is ineffective and unenforceable, but that circumstance does not denude the court of jurisdiction to consider extension on sufficient cause and on appropriate terms.

Conclusion: The application under Section 29A(5) is maintainable even after expiry of the statutory and consensual extension periods and even after an award has been rendered; the award passed after expiry of mandate is unenforceable, and the court may still consider extension, substitution, costs, and other conditions as warranted.

Final Conclusion: The challenge to the High Court's refusal was accepted, and the matter was sent back for decision on the Section 29A application in accordance with the declared principles, thereby preserving the arbitral process rather than treating the late award as an absolute bar to relief.

Ratio Decidendi: Section 29A of the Arbitration and Conciliation Act, 1996 does not create a threshold prohibition against seeking extension of an arbitrator's mandate after expiry of the prescribed period or after a late award has been made; the court retains jurisdiction to extend time on sufficient cause, with incidental powers to impose conditions, substitute arbitrators, and secure effective continuation of the arbitration.