Civil Law - Medical Education - Rights of Persons with Disabilities Act 2016 - Sections 56 and 57 - Jurisdiction of Medical Assessment Board - Petitioners holding valid Disability Certificates and UDID cards issued by Chief Medical Officers certifying disability above 40 percent were subjected to reassessment by NMC-constituted Boards for MBBS admission - Boards unilaterally reduced disability percentages to declare candidates ineligible for PwBD reservation despite acknowledging functional competency - High Court held that Medical Assessment Boards lack statutory authority to re-quantify or displace the percentage of disability certified by the competent authority under Sections 56 and 57 of the RPwD Act 2016 - Board jurisdiction is strictly confined to individualized functional competency assessment under NMC guidelines - Held - Impugned eligibility certificates and appellate medical opinions quashed - Respondents directed to consider petitioners under PwBD category - [Paras 1-37].

Writ Law - Judicial Review - Reasonable Accommodation - Constitution of India - Article 14 - Denial of reservation benefits based on mechanical percentage-based re-classification by administrative boards - Court emphasized that reasonable accommodation is a constitutionally-anchored obligation and not a matter of executive discretion - Any guideline authorizing boards to re-determine quantum of benchmark disability contrary to the plenary statutory scheme of the RPwD Act 2016 is ultra vires - Held - Action of the Boards constitutes an excess of jurisdiction - [Paras 27-31].

Decision: Writ petitions allowed – Impugned conclusions regarding ineligibility for PwBD reservation quashed – Respondents directed to treat petitioners as eligible candidates under PwBD category for NEET (U.G.)-2026 counselling – Interim orders made absolute.

Criminal Law - Bail - Bharatiya Nagarik Suraksha Sanhita 2023 - Section 528 - Pendency of bail application - Trial Court refused to decide petitioner's pre-arrest bail application solely on the ground that a transfer petition involving other co-accused was pending before the High Court - No stay order was passed by the High Court in the said transfer petition - Held - Trial Court is duty-bound to decide the bail application on merits in the absence of any stay order - Practice of adjourning bail matters to await outcomes of separate transfer petitions is deprecated - Order dated 14.09.2026 set aside with direction to decide the bail application within 5 working days - [Paras 1-9].

Criminal Law - Practice and Procedure - Trial Court - Duty to adjudicate - Trial Court declined to hear bail application despite multiple opportunities given to the parties - Held - Courts are obligated to exercise judicial discretion and decide bail matters expeditiously and not defer them indefinitely without specific legal impediment or stay order - [Paras 6-7].

Decision: Petition disposed of - Impugned order dated 14.09.2026 set aside - Trial Court directed to decide the bail application (Annexure P-9) within 5 working days after hearing both parties.

Criminal Law - Acquittal - Code of Criminal Procedure 1973 - Section 378 - Appeal against acquittal - Respondent was convicted by Trial Court for poaching lions based on conjecture and circumstantial evidence linking him via telephone chits - Appellate Court acquitted the respondent finding the prosecution failed to prove guilt beyond reasonable doubt and noting the Investigating Officer's failure to produce call records - High Court held that appellate court rightly exercised powers as double presumption of innocence exists in favour of accused after acquittal - Evidence of lie-detection test was discarded as the expert was not examined - Held - No perversity in Appellate Court's judgment - Appeal dismissed - [Paras 1-22].

Evidence Law - Circumstantial Evidence - Indian Evidence Act 1872 - Section 3 - Reliability - Prosecution relied on chit containing mobile numbers found in possession of other co-accused to link the respondent to an international poaching ring - Trial Court admitted this was insufficient for direct proof but convicted based on suspicion - Held - Suspicion or conjecture cannot substitute legal evidence - High Court upheld acquittal - [Paras 10-12].

Criminal Law - Appellate Power - Code of Criminal Procedure 1973 - Section 378 - Scope of interference - Principles reiterated that if two reasonable conclusions are possible on the basis of evidence the appellate court should not disturb the acquittal - Appellate court is only empowered to interfere if the acquittal is perverse or suffers from manifest illegality - Held - Prosecution failed to discharge the burden of proof - [Paras 16-21].

Decision: Appeal dismissed – Impugned judgment and order of acquittal confirmed – Bail bond cancelled – Record and proceedings directed to be sent back.

Criminal Law - Quashing/Clubbing of FIRs - Constitution of India - Article 226 and 227 - Multiple FIRs lodged against petitioner for alleged non-payment of deposits by a credit society - Allegations identical in nature and arising from a common transaction - Petitioner sought clubbing of all subsequent FIRs with the first registered FIR as the Principal FIR - High Court applied the test of sameness and unity of transaction - Held - Allowing multiple investigations on the same set of facts leads to abuse of process and conflicting findings - Court directed all subsequent FIRs to be clubbed with the first FIR - treated as statements under Section 161 CrPC/180 BNSS - Transferred to Kotwali Lalitpur for a unified investigation - [Paras 1-39].

Criminal Law - First Information Report - Code of Criminal Procedure 1973 - Section 154 - Successive FIRs - Principles regarding registration of multiple FIRs for the same incident - Court held that while second FIRs are permissible for distinct incidents, they cannot be registered for the same transaction or occurrence - The 'test of sameness' must be applied to determine whether the acts form part of a continuous transaction - Where multiple FIRs pertain to the same incident or same conspiracy to cheat the public, they must be consolidated - [Paras 18-24].

Criminal Law - Investigation - Code of Criminal Procedure 1973 - Section 173 - Power of further investigation - Investigating agency possesses statutory power for further investigation but not the right to register fresh FIRs for the same transaction - Multiple proceedings for the same offence create prejudice to the accused and result in avoidable multiplicity of litigation - [Paras 32-34].

Decision: Writ petition disposed of – All subsequent FIRs clubbed/merged with the first FIR (Case Crime No. 612 of 2024) – Direction issued for transfer of cases to the jurisdiction of the Principal FIR – [Paras 36-39].

Service Law - Probationer - Discharge - Principles of Natural Justice - Constitution of India - Article 311 - Where the order of discharge of a probationer is not a simple discharge but is based on specific allegations of misconduct rendering it punitive and stigmatic in nature - The competent authority is mandatorily required to hold a departmental inquiry or at the very least issue a show cause notice to the probationer - Failure to observe the principles of natural justice renders the discharge order illegal and void - Appellate Court correctly set aside the discharge order - Held - Appeal dismissed - [Paras 14-17].

Service Law - Judicial Review - Civil Court Jurisdiction - Code of Civil Procedure 1908 - Section 100 - Jurisdiction of Civil Court to entertain service disputes regarding police personnel - In the absence of a specific statutory tribunal created to adjudicate service grievances of police personnel - The Civil Court has the inherent jurisdiction to entertain a suit challenging the validity of a termination or discharge order - Held - Appellate court correctly held that Civil Court possessed jurisdiction - [Para 19].

Civil Law - Second Appeal - Substantial Question of Law - Code of Civil Procedure 1908 - Section 100 - High Court in second appeal cannot reappreciate evidence or disturb findings of fact unless they are perverse or contrary to settled law - Appellate Court's findings on the stigmatic nature of the discharge order were based on legal evidence and consistent with Apex Court precedents - Held - No ground for interference - [Paras 20-21].

Decision: Second Appeal dismissed - Judgment and decree of the Appellate Court confirming the illegality of the discharge order and directing reinstatement is upheld.

Civil Law - Landlord and Tenant - Code of Civil Procedure 1908 - Order XII Rule 6 - Judgment on admissions - Appellant admitted in the Written Statement its induction as a tenant and payment of monthly rent of Rs 9000 to the Respondent - Appellant contended that the tenancy was permanent based on oral agreement and payment of security - Trial Court and Appellate Court held that claim of perpetual tenancy required a registered instrument under Section 17 Registration Act 1908 and was legally untenable - Held - Trial Court correctly exercised jurisdiction to decree possession on the basis of clear admissions of tenancy despite the Appellant's attempt to obfuscate the issue with unfounded claims of permanent possession - [Paras 1-64].

Civil Law - Tenancy - Transfer of Property Act 1882 - Section 106 - Notice to quit - Service of legal notice denied by Appellant - Held - Following the principle in Nopany Investments (P) Ltd v Santokh Singh (HUF) (2008) 2 SCC 728 the institution of the suit itself serves as a valid notice to quit upon the tenant rendering the objection regarding prior notice inconsequential - [Para 62].

Civil Law - Estoppel - Indian Evidence Act 1872 - Section 116 - Tenant's challenge to title - Appellant challenged Respondent's ownership alleging Benami transaction and lack of authorization - Held - A tenant cannot challenge the title of the landlord under Section 116 of the Evidence Act and is estopped from disputing the ownership of the person who inducted them into the premises - [Paras 23-28].

Decision: Appeal dismissed - The decree of possession is affirmed as no substantial question of law was found.

Criminal Law - Money Laundering - Prevention of Money Laundering Act 2002 - Section 19 - Arrest safeguards - Petitioner challenged arrest alleging non-compliance with statutory conditions regarding material in possession and recorded reasons to believe - Court held that while judicial review of subjective satisfaction is limited-authorities demonstrated compliance with Section 19 by recording reasons based on material collected during independent investigation post-ECIR registration - Held - Procedural mandates of Section 19 were satisfied - [Paras 14-22].

Criminal Law - Bail - Prevention of Money Laundering Act 2002 - Section 45 - Right to speedy trial - Petitioner in custody for over a year with investigation complete and trial proceedings stayed by High Court in separate proceedings - Court balanced stringent twin conditions of Section 45 against the overarching right to life and liberty under Article 21 of the Constitution - Held - Prolonged pre-trial incarceration without immediate prospect of trial commencement entitles petitioner to bail - [Paras 27-30].

Evidence Law - Statement under Section 50 - Prevention of Money Laundering Act 2002 - Section 50 - Admissibility - Statement recorded while accused in custody - Court held that statements recorded under Section 50 of PMLA from an accused in custody cannot be treated as substantive evidence as they lack the element of free will and can at best only corroborate existing material - Held - [Para 25].

Criminal Law - Arrest necessity - Prevention of Money Laundering Act 2002 - Section 19 - Necessity to arrest - Court reiterated that mere registration of an ECIR cannot transmute old allegations into a new found necessity for arrest - Necessity must arise from fresh circumstances or conduct - Held - [Para 26].

Decision: Prayer for bail allowed - Petitioner released on bail upon furnishing bond of Rs 10,00,000/- with local sureties subject to specified conditions including surrender of passport and non-tampering of evidence - [Paras 31-33].

Civil Law - Motor Accident Compensation - Motor Vehicles Act 1988 - Section 168 - Determination of just compensation - Appellate Court powers - Appellant-Insurance Company challenged compensation claiming theft of vehicle and discrepancy in driver name - Tribunal awarded compensation - Insurance Company contended theft and incorrect name of driver - High Court rejected theft claim for lack of evidence and dismissed name discrepancy noting prefix usage as common - Court affirmed use of completed age to determine multiplier of 13 - Held - Appellate Court is duty-bound under Section 168 to award just compensation - Appeal dismissed - [Paras 23-31].

Civil Law - Appellate Powers - Code of Civil Procedure 1908 - Order XLI Rule 33 - Enhancement of compensation - Absence of cross-appeal - High Court held that appellate court has wide powers to ensure just compensation - Even without cross-appeal from claimants the court can enhance award if it finds the Tribunal's assessment inadequate - Principle of beneficial legislation overrides hyper-technical objections - Held - Compensation enhanced to Rs 11,43,565 based on minimum wage notification and revised conventional heads - [Paras 37-55].

Civil Law - Computation of Compensation - Motor Vehicles Act 1988 - Minimum Wage - Determination of income - Deceased engaged in extraction of tadi - Tribunal used Rs 5000 as notional income - High Court applied minimum wage notification dated 04.01.2018 for unskilled labour at Rs 7400.46 - Held - Minimum wage is a reliable yardstick for notional income in absence of proof - [Paras 57-59].

Civil Law - Conventional Heads - Motor Vehicles Act 1988 - Consortium and Funeral Expenses - Ratio of Pranay Sethi - High Court applied 10% enhancement every three years from 2017 - Determined funeral expenses and loss of estate at Rs 18150 each and loss of consortium at Rs 48400 each for three claimants - Held - Loss of love and affection is subsumed within consortium - [Paras 60-66].

Decision: Appeal dismissed – Impugned judgment modified – Total compensation enhanced to Rs 11,43,565 with 7% interest – Tribunal directed to adjust previously paid amounts.

Criminal Law - Inherent Powers of High Court - Bharatiya Nagarik Suraksha Sanhita 2026 - Section 528 - Maintainability of second revision - Petitioner challenged magisterial order dismissing application for FIR registration under Section 175(3) BNSS - Sessions Court dismissed revision petition - High Court examined interplay between Section 438(3) BNSS (bar on second revision) and Section 528 BNSS (inherent powers) - Held - Prohibitions under Section 438(3) cannot be circumvented by invoking inherent powers under Section 528 unless there is a case of gross injustice or miscarriage of justice - Since petitioner was not left remediless as his complaint under Section 200 CrPC remained pending before the Magistrate the court refused to invoke inherent powers - Petition dismissed as not maintainable - [Paras 1-12].

Criminal Law - Investigation - Bharatiya Nagarik Suraksha Sanhita 2026 - Section 175(3) - Direction for FIR - Magistrate refused to order police investigation noting petitioner possessed all necessary evidence and identity of accused - Held - Discretion exercised by Magistrate to proceed under Section 200 CrPC instead of 175(3) is sound as the court can still invoke powers under Section 225 BNSS at a later stage if required - No gross injustice caused - [Paras 6-11].

Decision: Petition dismissed as not maintainable – Impugned orders of Magistrate and Court of Sessions upheld.