Outcome: The special leave petitions were dismissed and the order granting default bail was not interfered with.

Issues: Whether an order under Section 319 of the Code of Criminal Procedure, 1973 could validly be passed after the trial court had already pronounced conviction and sentence.

Analysis: The controlling principle applied was that once the trial court pronounces the order of sentence, it becomes functus officio and cannot thereafter exercise jurisdiction to summon additional accused under Section 319. Since the impugned order had been passed only after conviction and sentence, it was outside jurisdiction.

Conclusion: The order under Section 319 was without jurisdiction and could not be sustained.

Issues: Whether the petitioner, facing allegations under the Narcotic Drugs and Psychotropic Substances Act, 1985 involving commercial quantity, was entitled to regular bail by dispensing with the requirements of Section 37 of the Act.

Analysis: The allegations involved recovery of commercial quantity, so the restrictions under Section 37 ordinarily applied. However, the Court noted the absence of criminal antecedents, the prolonged custody of about two and a half years, and that the trial had not commenced though charges had been framed. On those considerations, the Court found it appropriate to relax the statutory bail conditions at that stage.

Conclusion: The petitioner was granted regular bail, and the conditions of Section 37 of the Narcotic Drugs and Psychotropic Substances Act, 1985 were dispensed with for the purpose of release on bail.

Issues: Whether the mere filing of an appeal, without any interim stay, could justify refusal of the No Objection Certificate and sustain the High Court's refusal to interfere.

Analysis: Under Order XLI Rule 5 of the Code of Civil Procedure, 1908, the filing of an appeal by itself does not operate as a stay of the decree. In the absence of any interim order staying the decree, the decree continues to operate and the authorities cannot refuse relief merely because an appeal has been lodged and is pending for listing.

Conclusion: The rejection of the No Objection Certificate on the ground of a filed but unstayed appeal was unjustified, and interference with the High Court's order was warranted.

Final Conclusion: The High Court's order was set aside and the District Magistrate was directed to issue the No Objection Certificate within two weeks, subject to the result of the pending appeal.

Ratio Decidendi: Mere filing of an appeal does not suspend the operation of the decree unless there is an order of stay; until then, the decree remains enforceable and relief cannot be denied on that basis alone.

Issues: Whether, where an arbitral tribunal makes suo motu corrections to an award under Section 33(3) of the Arbitration and Conciliation Act, 1996, the period of limitation under Section 34(3) runs from the date of the original award or from the date of the corrected award received by the party.

Analysis: The limitation under Section 34(3) is intended to give the party an effective opportunity to study and challenge the award. Where the tribunal itself corrects the award under Section 33(3), the original award stands modified and it is the corrected award that has to be challenged. The corrected award, therefore, constitutes the operative award for the purpose of computing limitation, and the period begins when the corrected award is made and received. The filing in the case was within ninety days from the corrected award, and in any event the court retains power to consider condonation within the permissible additional period while proceedings remain pending.

Conclusion: The limitation period for filing objections ran from the date of the corrected award, and the objections were within time.

Outcome: The matter was adjourned for two weeks on the request of the petitioner.

Issues: Whether the petitioner was entitled to bail in a prosecution under the narcotics law despite the allegation of commercial quantity and the seriousness of the ations, having regard to the period already spent in custody and the likely delay in conclusion of trial.

Analysis: The petition sought release on bail in a case under the narcotics statute involving serious allegations and commercial quantity. The Court took note of the petitioner's custody for about two years and the fact that the trial was likely to take time. On that assessment, the balance tilted in favour of granting bail notwithstanding the nature of the ations.

Conclusion: Bail was granted to the petitioner.

Issues: Whether the High Court's observations and directions, being contrary to the law declared in Arnesh Kumar, could be treated as binding precedent and whether the impugned order required interference.

Analysis: The order reiterates that decisions of the Supreme Court are binding under Article 141 of the Constitution of India and that subordinate courts are expected to deal with such judgments with due respect. Observations made by the High Court which were inconsistent with the binding principles governing arrest and remand were found to be unwarranted and untenable. The Court also found that the reasoning adopted in allowing the revision was not sustainable in law, and that the subsequent directions issued by the Division Bench could not stand. The matter was left to be reconsidered on its own merits, without being influenced by the impugned observations.

Conclusion: The observations contrary to the binding law declared by the Supreme Court were held not to be a binding precedent, and the impugned judgment and order were set aside with a direction for fresh consideration in accordance with law.

Final Conclusion: The decision preserves the binding force of Supreme Court precedent and restores the matter for independent adjudication on merits.

Ratio Decidendi: Findings or observations of a court that are contrary to the law declared by the Supreme Court cannot operate as binding precedent and may be interfered with for want of legal sustainability.

Issues: Whether a sale certificate issued in a SARFAESI sale requires registration or further action beyond filing with the registering authority, and whether the authorities were justified in seeking interference with the impugned judgment.

Analysis: The Court noted that the question had long been settled and reiterated that a sale certificate is not a conveyance requiring stamp duty or compulsory registration. It further held that under the Registration Act, the authorised officer is required to issue the duly validated sale certificate to the auction purchaser and forward a copy to the registering authorities for filing in Book I, which has the same effect as registration and removes the need for any additional step.

Conclusion: The requirement of further registration was negatived, and the petitioners were not entitled to interference with the impugned judgment.