Criminal Law – Rape Allegation – Acquittal – Appellant convicted by trial court under Section 376(2)(i) IPC and Section 3/4 POCSO Act, 2012 for allegedly committing rape on a 7-year-old girl – Trial court sentenced him to 14 years RI under IPC and 7 years RI under POCSO Act with fines under both provisions – On appeal, High Court finds that key prosecution witnesses including the victim (P.W.2), her mother (P.W.1), and father (P.W.3) did not support the prosecution case – No corroborative evidence from medical or forensic reports – Held: Prosecution failed to prove its case beyond reasonable doubt – Conviction unsustainable [Paras 24, 25, 30, 32, 33]

Witness Testimony – Credibility of Victim and Parents – Victim (P.W.2) denied any incident of rape or assault by appellant – Stated she fell while playing – Medical evidence also did not confirm penetrative assault – Mother (P.W.1) admitted she was not present at the scene and that FIR (Ex. Ka-1) was not read to her – Father (P.W.3) also denied witnessing any incident and stated that report was filed on hearsay – Both parents contradicted FIR version – Held: No credible witness to support prosecution case – Statements inconsistent and unreliable [Paras 16, 17, 18, 30]

Medical and Forensic Evidence – Lack of Corroboration – Medical report (Ex. Ka-3) noted hymen torn but no bleeding or external injury – Supplementary report (Ex. Ka-4) stated no penetrative sexual assault – FSL report (Ex. Ka-10) on 7 items including accused’s towel and victim’s clothing showed no spermatozoa or incriminating material – Held: Medical and forensic evidence do not support charge of rape – No corroboration of prosecution’s version [Paras 8, 9, 11, 19, 21, 30]

Investigating Officer – Procedural Flaws – I.O. (P.W.7) claimed site plan was prepared at informant’s instance – However, informant herself (P.W.1) denied presence during incident – Accused allegedly brought to police station by informant and her husband, but both denied apprehending him – Held: Prosecution version of accused being caught red-handed is unsubstantiated and unsupported by reliable evidence [Paras 16, 18, 22, 30]

Statutory Interpretation – Section 42 POCSO Act – Dual Sentencing Illegal – Trial court convicted and sentenced appellant under both Section 376(2)(i) IPC and Section 4 POCSO Act – High Court held that under Section 42 of POCSO Act, offender can only be sentenced under the law which provides for greater punishment – Reiterated that sentencing under both IPC and POCSO is impermissible – Relied on Krishnakant v. State of U.P. (2022) 10 ILRA 982 – Held: Trial court erred in awarding concurrent sentences under both statutes [Paras 26, 27, 31]

Decision: Appeal allowed – Conviction and sentence under Section 376(2)(i) IPC and Section 3/4 POCSO Act, 2012 set aside – Appellant acquitted of all charges – Appellant to be released from custody forthwith unless wanted in any other case [Paras 33, 34, 35]

Civil Law - Civil Procedure Code, 1908 - Reconstruction Of Record - Non-Availability Of Trial Court Record - Effect On Appeal - Held: The destruction of the Trial Court's record does not automatically warrant the dismissal of the appeal or affirmation of the Trial Court's decree. Where reconstruction is not fully possible due to non-cooperation of respondents, the Appellate Court can proceed based on available documents, pleadings, and the judgment under challenge. A party cannot take advantage of their own wrong in failing to cooperate with reconstruction.

Indian Contract Act, 1872 - Section 16 - Undue Influence - Fiduciary Relationship - Burden Of Proof - Held: A fiduciary relationship exists between an elder brother and a younger brother where the latter reposes confidence in the former. Where a transaction (Relinquishment Deed) appears unconscionable and is between parties in a fiduciary relationship, the burden of proof shifts to the beneficiary (dominant party) to prove the transaction was not induced by undue influence. Inducing a younger brother to execute a deed to "save family honor" against a sister's partition suit constitutes undue influence.

Indian Evidence Act, 1872 - Section 92 - Parol Evidence - Sham Documents - Held: The bar under Section 92 (excluding oral evidence to contradict written terms) does not apply when a party pleads that the document was a "sham" and was never intended to be acted upon. Oral evidence is admissible to prove that a transaction recorded in a document was a paper transaction meant to serve a collateral purpose (frustrating a third party's suit) and was not intended to be enforced between the signatories.

Muslim Law - Relinquishment Of Share - Spes Successionis - Transfer Of Property Act, 1882 - Section 6(A) - Held: A "Dastbardari" (Relinquishment Deed) cannot be valid if the beneficiary (transferee) denies the title/share of the transferor in the first place. One cannot relinquish a right that is not admitted to exist. Furthermore, under Section 6(a) of the Transfer of Property Act and Muslim Law, the transfer of spes successionis (chance of succession) is void ab initio. A renunciation of a chance of succession is not valid.

Estoppel - Validity Of Sham Document - Held: A document obtained through undue influence and proven to be a sham (executed solely to defeat a sister's claim in a separate suit) creates no estoppel against the executor. Such a document, which was never acted upon or produced in the relevant partition suit for decades, cannot be enforced.

Decision: Appeal allowed. Judgment and Decree dated 6-1-1973 set aside. The "Dastbardari" dated 23-2-1966 is declared null and void. Parties held entitled to shares as per the preliminary decree in the connected partition suit (2/5th share each to brothers).

Juvenile Justice Act, 2015 – Section 12 – Bail to Child in Conflict with Law (CCL) – Gravity of Offence vs. Statutory Mandate – Held: While the alleged offence (RPG attack on Police Station) is grave, Section 12 mandates bail as a rule for juveniles, irrespective of the nature of the offence (bailable or non-bailable) – Bail can only be denied if there are reasonable grounds to believe that release would bring the person into association with known criminals, expose them to moral/physical danger, or defeat the ends of justice – Mere apprehension by the State without material evidence on record regarding such association or danger is insufficient to deny bail. [Paras 8, 10]

Bail – Parity and Academic Career – Held: Co-accused (adults) facing similar charges were granted bail – Continued detention of juveniles would serve no purpose and adversely affect their academic career (one appellant being a B.A. student) – No criminal antecedents shown apart from the instant case – Appeals allowed; bail granted. [Paras 9-10]

Decision: Appeals allowed. Impugned orders set aside. Appellants ordered to be released on bail.

Constitutional Law – Right to Health – Medical Negligence – Public Law Remedy – Strict Liability – Context of patients losing eyesight after cataract surgeries at Govt. Civil Hospital under the National Programme for Control of Blindness – Held: The right to health and medical care is an integral part of the fundamental right to life under Article 21. An inquiry committee report revealed that the loss of vision suffered by the petitioners was caused by a severe post-operative infection (Endophthalmitis) due to the presence of 'Pseudomonas Aeruginosa' bacteria in the Operation Theatre fluids and saline. This established a gross deficiency in service and negligence in maintaining sterile conditions by the hospital authorities. The State is strictly liable to pay compensation under public law remedy for the deprivation of life and liberty caused by the negligence of its employees, distinct from any private law tort remedies available to the victims. [Paras 11-14]

Compensation – Quantum – Loss of Vision – Enhancement of Compensation – Context of 7 victims losing eyes after surgery – Held: While the State Government admitted liability and offered a standard ex-gratia payment of Rs. 3,00,000/- based on a policy decision, the Court found this amount inadequate given the severity of the injury (permanent loss of vision in one eye). Considering the irreversible nature of the loss, the trauma suffered, and the violation of fundamental rights, the Court enhanced the compensation. The State respondents were directed to pay Rs. 4,00,000/- (Rupees Four Lakhs) to each of the aggrieved persons. In cases where the original petitioners had died during the pendency of the writ, the compensation was directed to be paid to their legal heirs within a period of 6 weeks. [Para 15]

Decision: Writ Petitions disposed of with direction to pay compensation of Rs. 4,00,000/- to each victim. [Para 17]

Civil Law – Remand of Case – Order 41 Rule 23A CPC – Failure to Appreciate Evidence Independently – Context of Trial Court decreeing a suit for possession solely based on a previous judgment (Ex. PX) without independent findings on title – Held: The Trial Court committed a material procedural error by failing to record independent findings on the core issue of title (Issue No. 1). Instead of discussing the oral and documentary evidence adduced by the parties, the Trial Court relied exclusively on a previous judgment (Ex. PX) concerning the same land. Since Ex. PX was subsequently set aside by the Appellate Court, the entire foundation of the Trial Court's decree collapsed. The Lower Appellate Court correctly exercised its jurisdiction to set aside the decree and remand the matter for a fresh decision, as the Trial Court had effectively failed to apply its judicial mind to the pleadings and evidence on record. A wholesale remand is permissible and necessary when the Trial Court has not decided material issues on their own merits. [Paras 14-15]

Decision: Appeal dismissed. Case remanded to Trial Court. [Para 16]

Criminal Law – Section 406 IPC – Stridhan – Effect of Divorce by Mutual Consent – Complainant filed case for recovery of Stridhan after divorce – Held: Once the marriage is dissolved by a decree of divorce by mutual consent based on a settlement, and no liberty is reserved to continue criminal proceedings, the wife is estopped from continuing proceedings against the husband. No dispute survives. Acquittal upheld. [Paras 16-18]

Criminal Law – Appeal against Acquittal – Scope of Interference – Held: The High Court will interfere with an acquittal only if the judgment is patently perverse, based on misreading of evidence, or if the conclusion is one no reasonable person could reach. The Trial Court's view was reasonable and supported by Supreme Court precedents. [Paras 11-12]

Decision: Appeal dismissed. [Para 21]

Criminal Law – Quashing of Proceedings – Inordinate Delay – Article 21 Constitution of India – Context of the 19.02.2009 clash between lawyers and police in the Madras High Court campus – FIR registered in 2009, Charge Sheet filed in 2010, but Cognizance taken only in 2025 (16 years delay) – Held: Right to speedy trial is an inalienable fundamental right. The delay was administrative/procedural and not attributable to the accused. Continuation of proceedings after 16 years would be an abuse of process and an exercise in futility. [Paras 17, 22, 24].

Criminal Law – Vicarious Liability/Obedience to Orders – Police Action – Context where junior police personnel were charged for lathi-charging lawyers under orders of superiors – Held: The petitioners were in the lowest rank of the police force and acted under the orders of superiors to disperse an unruly mob. They had no personal animosity. Obedience to superior orders in a chaotic situation where the police station was set on fire cannot be the sole basis for prosecution after such a lapse of time. [Paras 6, 18].

Evidence – Identification of Accused – Absence of Test Identification Parade – Context where accused were identified solely based on blurred media photographs/videos without a TIP – Held: Identification based on subjective interpretation of blurred photographs, where police were wearing helmets with visors, and without a certificate under the IT Act or a proper Test Identification Parade, is insufficient to sustain a criminal prosecution. [Paras 14, 21].

Decision: Criminal Original Petitions allowed. Proceedings in C.C. Nos. 622, 623, 624, 625, and 626 of 2025 on the file of Additional Chief Metropolitan Magistrate, Egmore, are quashed. Petitioners acquitted.

Criminal Law – Quashing of FIR – Section 528 BNSS – Scope of Judicial Interference – Petition sought quashing of FIR alleging that the petitioner, as Channel Head of Zee Rajasthan, extorted money and threatened vendors with adverse news coverage – Held: Allegations in FIR prima facie disclose cognizable offences – Court cannot evaluate evidence or conduct a “mini-trial” at FIR stage – Investigation must proceed unhindered – Quashing power to be exercised sparingly and in rare cases [Paras 9–11, 13–18].

Media Ethics – Abuse of Position by Journalist – Extortion and Coercion – FIR alleged that petitioner misused company’s platform to solicit money through threats of defamatory broadcasts – Such acts, if proven, constitute gross abuse of media authority and harm to public trust – Allegations require full investigation and cannot be nullified as employer-employee dispute [Paras 7.1–7.2, 22–23].

Freedom of Press – Limits and Responsibility – Court reiterated that press freedom is integral to democracy but carries duty of fairness, accuracy, and integrity – “Freedom of Press is imperative for a functioning democracy; however, misuse of such freedom through coercion or blackmail cannot be tolerated” [Preface; Paras 7–9].

Bhajan Lal Principles – Applicability – Case does not fall within any of the exceptional categories enumerated in State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335 – Allegations not absurd, improbable, or mala fide on their face – Investigation must determine truth of allegations [Paras 2.1–2.4, 23].

Judicial Review – Stage of Investigation – Precedents Cited – Reaffirmed principles in Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, (2021) 19 SCC 407; Kaptan Singh v. State of U.P., (2021) 9 SCC 35; Dineshbhai Chandubhai Patel v. State of Gujarat, (2018) 3 SCC 104; Dr. Dhruvaram Murlidhar Sonar v. State of Maharashtra, (2019) 18 SCC 191 – High Court’s interference limited to cases where FIR does not disclose any cognizable offence [Paras 10–20].

Decision: FIR No. 257/2025 discloses cognizable offences – Investigation to continue uninhibited – Petition for quashing dismissed – Petitioner at liberty to approach Investigating Officer for fair-investigation concerns; IO to act as per law and issue notice under Section 35 BNSS if required [Paras 22–25].

Employees’ Compensation – Employer–Employee Relationship – Total Lack of Evidence – Commissioner relied solely on FIR/FIS without oral proof – Appellant specifically denied employment – Held: Existence of jurisdictional fact must be proved; matter remanded for fresh evidence; substantial question of law arises [Paras 7-10].

Employees’ Compensation – Jurisdictional Fact – Proof of Employment – Death of worker in quarry – Claimants produced only FIR/FIS and three other documents, no oral evidence – Commissioner accepted employer–employee relationship solely on basis of FIR/FIS – Held: Initial burden to prove relationship lies on claimants; lack of evidence on jurisdictional fact raises substantial question of law [Paras 2, 4, 7].

Evidence – FIR/FIS Not Substantive Proof – FIR/FIS marked without objection, but no witness examined to prove employment – Appellant denied relationship in written statement – Absence of oral evidence is fatal; mere marking of documents does not discharge burden – Commissioner’s reliance on FIR/FIS misplaced [Paras 4, 7].

Precedents – Distinction with Gangan v. Christin Raj – Division Bench decision relied upon by Commissioner held applicable only where adequate evidence is produced – Present case involves no such evidence; hence Commissioner’s reading incorrect [Para 7].

Substantial Question of Law – When Arises – Whether there is total lack of evidence regarding jurisdictional fact is a substantial question of law – Court follows earlier ruling in MFA(ECC) No. 18 of 2024 – Examination of total absence of evidence does not amount to re-appreciation of evidence [Paras 8-9].

Remand – Fresh Consideration Needed – As FIR/FIS and documents were marked without objection, claimants may have believed no further evidence required – Interest of justice and object of the Act require remand to give parties full opportunity to adduce evidence on employer–employee relationship [Paras 9-10].

Decision – Impugned award set aside – Matter remitted to Employees’ Compensation Commissioner – Parties to appear on 15.12.2025; evidence to be completed within four months; Commissioner to pass fresh order within six months – Deposited amount to remain intact till disposal [Para 10].