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Issues:
- Challenge to direction for payment of maturity value for lost Indira Vikas Patras (IVPs). - Interpretation of Indira Vikas Patra Rules, 1986 regarding replacement of lost certificates. - Applicability of Rule 7(2) in cases of lost, stolen, mutilated, or destroyed IVPs. - Comparison of IVPs to ordinary currency notes for replacement purposes. - Consideration of legal principles in issuing directions contrary to law. Analysis: The Supreme Court judgment dealt with two appeals involving the payment of maturity value for lost Indira Vikas Patras (IVPs). The respondents in both cases had lost their IVPs and sought replacement or payment of maturity value. The Court analyzed the relevant provisions of the Indira Vikas Patra Rules, 1986, particularly Rule 7(2), which states that lost, stolen, or destroyed certificates will not be replaced by any post office. The Court compared IVPs to currency notes, emphasizing that like currency notes, lost IVPs cannot be replaced. The Court noted that the legality of Rule 7(2) was not challenged, making any direction for replacement contrary to law. The Court considered the previous decision in J. Kemparayappa v. Union of India, highlighting that IVPs are freely transferable bearer bonds, and replacements are not issued in case of loss. The Court also referred to a Delhi High Court decision supporting the non-replacement of lost IVPs. In light of these legal principles, the Court concluded that the directions for payment of maturity value were unsustainable and contrary to law. Regarding the specific cases, the Court noted that one respondent had already been paid the amount following the direction, and in that case, no refund was required. For the other appeal, if payment had not been made, the appellants were not liable to make the payment. However, if payment had already been made, no recovery would be pursued. The Court emphasized the need to clarify the legal position to address numerous similar claims, despite the small amounts involved. In conclusion, the Court allowed the appeals to the extent of setting aside the directions for payment of maturity value for lost IVPs, without imposing any costs. The judgment underscored the importance of upholding legal principles and rules governing the replacement of lost certificates, such as IVPs, to prevent directions contrary to established law.
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