Civil Law - Competing Wills – Registered vs. Unregistered – Suspicious Circumstances – Registered Will Upheld – Plaintiffs relied on registered Will dated 09.06.2000, proved through attesting witness and scribe's record – Defendant relied on unregistered Will dated 07.08.2004 – High Court held that propounder failed to explain suspicious circumstances including testator’s prior litigation with beneficiary and absence of mention of earlier Will – Registered Will stood duly proved; unregistered Will discarded [Paras 4–34].

Proof of Will – Attestation and Execution – Legal Requirement Satisfied – Will of 2000 held valid as one attesting witness deposed to its execution, contents explained to testator, and execution done in presence of both witnesses – Registration further bolstered its authenticity – Court found that requirement under Sections 63 of Succession Act and 68 of Evidence Act was met [Paras 11–21].

Suspicious Circumstances – Unexplained Presence of Beneficiary – Lack of Known Scribe – History of Litigation – Will Disbelieved – Will of 2004 was held invalid due to serious doubts: scribe’s identity unknown, both attesting witnesses knew beneficiary but not testator, and long-standing adversarial litigation between testator and beneficiary – No explanation for not registering subsequent Will, weakening its credibility [Paras 22–34].

Mutation Orders – No Evidentiary Value – Revenue Authority Findings Not Binding – Appellate Court wrongly relied on mutation sanction based on disputed Will – Court reiterated that mutation proceedings are administrative and cannot determine validity of testamentary documents [Para 35].

Admissions and Burden of Proof – No Binding Admission by Plaintiff – Pleading Suspicion Not Mandatory Where Apparent – Respondent’s claim that plaintiff admitted 2004 Will rejected as misreading – Even absent specific pleading, court may evaluate suspicious circumstances if they are facially evident and serious [Paras 36–42].

Decision – Appeal Allowed – Trial Court’s decree restored – Appellate Court’s judgment set aside – Will dated 09.06.2000 accepted as genuine; suit decreed in favour of appellants – No costs awarded [Paras 43–44].
 

Taxation Law - Goods in Transit – Physical Verification Report – No Discrepancy Found – Detention Unsustainable - Goods moving from Assam to Delhi intercepted in Uttar Pradesh – Despite availability of all required documents (Invoice, E-invoice, E-waybill, Bilty), authorities issued detention and subsequent demand – MOV-04 physical verification report noted no discrepancies in goods – Later change of stand by authorities to allege discrepancy impermissible – Detention and tax/penalty order held unsustainable [Paras 3-4, 8-10, 13-14].

Change of Stand by Revenue – Not Permissible – Once Physical Verification Completed - Revenue authorities, having found no discrepancies during MOV-04 stage, cannot later allege differences to justify detention – Principles reaffirmed that Revenue cannot shift grounds or "change goalposts" after initial findings – Detention causes prejudice and must be based on specific and valid grounds at the first instance [Paras 5, 7, 15].

Refund of Deposited Amount – Ordered – Amount paid during the course of litigation to be refunded within three weeks from production of certified copy of the order [Para 18].

Decision – Writ Petition Allowed – Impugned detention order quashed – Refund directed - Detention and imposition of tax/penalty based on post-verification shift in stand held illegal and arbitrary [Paras 16-18].
 

Criminal Law – Framing of Charges – Standard at the Stage of Framing – Prima Facie Case Sufficient - The Court clarified that at the stage of framing charges, detailed evaluation of evidence is not warranted; a prima facie view suggesting the accused might have committed the offence is sufficient – Charges framed against petitioners upheld [Paras 42-45].

Prevention of Corruption Act – Demand and Acceptance – Essential Ingredients – Demand of Bribe Proven Prima Facie - Statements of material witnesses and money trail corroborated prima facie the demand and acceptance of illegal gratification by the accused Binod Giri and involvement of Asif Ibrahim Dadarkar – Held that demand and motive were sufficiently established for trial purposes [Paras 38-40].

Evidence Law – Admissibility of Intercepted Calls – Compliance with Telegraph Act – To be Determined During Trial - Though compliance with Rule 419A and Section 5(2) of the Indian Telegraph Act was questioned, the Court held that admissibility and procedural compliance would be determined during trial and does not affect the framing of charges [Paras 41-47].

Criminal Procedure – Money Trail and Recovery – Effect on Framing of Charges – The existence of a money trail and seizure of bribe articles such as the Lenovo Tablet substantiated the prosecution’s version, justifying framing of charges against both accused [Paras 36-39, 48-49].

Decision – Writ Petitions Dismissed – Charges Against Petitioners Upheld - The Court dismissed the petitions challenging the framing of charges, holding there was sufficient material for the trial to proceed against both petitioners [Paras 49-50].
 

Guardianship – Custody of Minor – Welfare of Child Paramount – Declaration of Guardian – The Court held that despite the natural guardianship rights of grandparents, the welfare of the minor remains paramount – The Court found that Master Yohan had developed a strong emotional bond with Respondent, his deceased father’s fiancée, who had cared for him since 2021 – Held: Respondent declared guardian subject to conditions ensuring continued contact with biological grandparents and counseling support [Paras 35-50].

Interim Custody – Guardianship Orders – Access Rights – Though guardianship was given to the Respondent, the Court ensured that Petitioners (grandparents and aunt) would have regular visitation rights, including spending vacation time with the minor, balancing emotional welfare and family bonds [Paras 50-52].

Financial Stability vs Welfare – Financial Means Not Sole Criterion – Despite Petitioners having better financial standing, the Court prioritized emotional well-being and the bond shared between the minor and the Respondent – Held: Financial affluence alone does not decide custody when the child's welfare is better served otherwise [Paras 43-45].

Counseling – Emotional Stability of Minor – Need for Therapy – The Court mandated ongoing counseling sessions for Master Yohan with family participation to ensure emotional stability and gradual bonding with biological family members [Paras 49-50].

Decision – Guardianship Petition No. 2 of 2024 allowed – Guardianship Petitions No. 1 and 13 of 2024 dismissed – Respondent declared Guardian of XXX with conditions relating to access and counseling [Para 52].

Civil Law - Permanent Injunction - Influencer Speech – Defamation, Disparagement and Trademark Infringement Allegations – Right to Reputation vs. Free Speech – Plaintiff, a nutritional supplements company, sought interim injunction against defendants (social media influencers) for publishing YouTube and Instagram videos critiquing its product ‘ISO PRO’ based on third-party lab reports – The Court held that the influencers’ conduct was supported by evidence, formed part of constructive criticism, and did not warrant gagging free speech [Paras 1-9, 60-116].

Limitation – Composite Suit Not Barred – Plaintiff’s action for defamation, trademark infringement, and disparagement held to be within limitation – Held that Article 75 of the Limitation Act does not apply to composite suits involving commercial and IP claims – Continuous cause of action applies due to ongoing publication on digital platforms – Suit governed by residuary Article 113 with a three-year limitation [Paras 22-27].

Commercial Nature – Jurisdiction of Commercial Court Upheld – Reliefs sought linked to commercial reputation, brand value, and IP violations – Suit falls within definition under Section 2(1)(c)(xvii) of the Commercial Courts Act – Merely because it includes defamation does not disqualify it as a commercial dispute [Paras 28-30].

Trademark Use – No Prima Facie Infringement – Fair Use – Use of plaintiff’s trademarks in critical videos held to be for informational purposes and not “in the course of trade” – Such usage did not amount to advertising or unfair advantage under Sections 29(4) or 29(8) of the Trade Marks Act – Satirical or referential usage, absent commercial exploitation, not infringing [Paras 110-111].

Defamation – Defence of Truth and Fair Comment – Bona Fide Reports – Defendants relied on reports from NABL-accredited labs showing discrepancies between labelled and actual nutritional content – Court held that lab results were credible and plaintiff failed to rebut them with contrary evidence – Defence of truth was upheld; opinion based on lab data qualified as fair comment [Paras 70-79, 89].

Disparagement – Elements of Malicious Falsehood Not Satisfied – Plaintiff failed to prove that impugned content was false or published with malice – Drop in sales not conclusively linked to influencer videos – No competitive business motive shown by defendants at the time of video publication – No prima facie case for disparagement made out [Paras 90-92].

ASCI Guidelines – Not Applicable to Genuine, Unpaid Commentary – Guidelines for influencer advertising inapplicable as impugned videos were not paid promotions – Defendant’s subsequent affiliation with ‘Trustified’ launched after video publication was irrelevant – Qualifications not necessary where statements are backed by verifiable evidence [Paras 84-88].

Satirical Expression and Consumer Awareness – Expression Like ‘Ghatiya’ Not Defamatory – Use of colloquial or exaggerated language (‘Doctor Has No Choice’, ‘ghatiya’) held not to defeat fair comment defence – Satirical tone permissible under free speech and does not establish malice in absence of misleading content [Paras 82-83].

Decision – Interim Relief Denied – Prima Facie Defence of Free Speech Made – Court refused to restrain influencers at interim stage – Held that content was based on credible reports, expressed in public interest, and not shown to be false or malicious – Defendants entitled to constitutional protection of speech – Plaintiff failed to establish prima facie infringement or irreparable harm [Paras 112-116].
 

Criminal Law - Murder  – Intentional Use of Tractor as Weapon – Conviction Upheld – The appellant Dheer Singh was convicted for murdering his uncle Mangat by deliberately running over him with a tractor after a prior altercation over a property passage – The incident occurred while the deceased and the complainant were en route to lodge an FIR about an earlier assault by the appellant’s relatives – The trial court’s finding of intentional murder was based on eye-witness testimonies, medical and expert evidence, and was upheld by the High Court – The argument that the incident was accidental was rejected in light of ocular evidence and consistent site inspection findings [Paras 2, 4-6, 14-16, 36-44].

Related and Injured Witness Testimony – Reliability – Accepted – The Court held that the testimony of the complainant (PW-1), though related to the deceased and injured in a prior incident, was reliable – His presence at the spot was natural and corroborated by independent eye-witness Pitambar Singh (PW-2) and prompt lodging of FIR – The Court reiterated settled principles that related or interested witness evidence is not to be discarded if found credible [Paras 34-36, 42-44].

Medical and Expert Evidence – Consistency with Ocular Testimony – Deemed Supportive – Despite absence of bone fractures, the nature and number of injuries including a fatal head injury were consistent with being run over on soft soil by a tractor – Expert CW-1 and PW-5 supported the prosecution's version – Minor contradictions in injury analysis were not sufficient to discredit the overall case [Paras 15, 19, 38-41].

Delay and Motive – Prompt FIR and Proven Animus – Accepted – FIR was lodged within an hour of the second incident at a police station 4 miles away – Prior enmity and a preceding assault over a passage dispute supplied strong motive – The High Court found no delay or fabrication and noted the strong causative link between the events [Paras 12, 18, 37, 45-46].

Appeal – No Merit Found – Conviction Confirmed – The High Court found no infirmity in the trial court’s appreciation of evidence and dismissed the appeal – Directed re-arrest of the appellant and execution of sentence as per trial court’s judgment [Paras 47-48].
 

Criminal Law – Murder – Appeal Against Conviction - Second FIR – Procedural Illegality – Invalid Re-Investigation – The second FIR was registered by Baguihati PS instead of continuing under Section 173(8) CrPC after a closure report on the first FIR – Held: Magistrate's order must be treated as further investigation on the original FIR – The second FIR and the entire re-investigation process were invalid [Paras 9, 38-41].

Identification of Deceased – Failure to Exhibit Photograph – Serious Doubt – Prosecution Collapsed – No photograph identifying the deceased was exhibited in court – Family members contradicted identification – Post-mortem records and inquest procedures were flawed – Held: Identity of deceased not proved beyond reasonable doubt [Paras 42-50].

Medical Evidence – Contradictions with Eyewitness Testimony – Unexplained Injuries – The post-mortem report showed serious internal injuries inconsistent with eyewitness accounts – Cause of death was ambiguous – Held: Prosecution failed to establish how the injuries occurred – Medical evidence did not support prosecution version [Paras 51-56].

Eyewitness Credibility – Delay in Statement Recording – Unnatural Conduct – Testimonies Suspect – Alleged eyewitnesses gave statements under Section 164 CrPC nearly two years post-incident – Witnesses remained silent despite allegedly witnessing a murder – Held: Conduct was unnatural and testimony untrustworthy [Paras 57-63, 73-78].

Anonymous Informant – Lack of Verification – Source Not Traced – Police acted upon anonymous call but failed to identify or prove the source – Held: Absence of disclosure on identity of caller rendered further investigation unsustainable – Adverse inference drawn under Section 114(g) Evidence Act [Paras 50, 65-72].

Statements Under Section 164 CrPC – Unexplained Delay – Evidence Unreliable – Statements of key eyewitnesses recorded long after police allegedly became aware of murder – Held: Delay casts doubt on genuineness of statements and reliability of prosecution narrative [Paras 79-84].

Stock Witnesses – Past Criminal Involvement – Tutored Testimonies – Witnesses were previously involved in cases and had appeared as prosecution witnesses in other matters – Depositions were parrot-like and uncorroborated – Held: Evidence of such witnesses cannot be relied upon without independent corroboration [Paras 90-94].

Decision: Criminal Appeals Allowed – Conviction and Sentences Set Aside – The High Court held that the prosecution failed to prove the identity of the deceased, relied on contradictory medical and parrot-like eyewitness evidence recorded after unexplained delay, and violated procedural norms in registering a second FIR – All appellants acquitted of offences under Sections 302/34 and 201/34 IPC and directed to be released if not required in any other proceedings [Paras 85-86, 98-99].
 

Criminal Law – Quashing - POCSO Act – Ingredients Not Attracted – FIR Quashed – Accusation Against Petitioners Held Malicious – The complainant alleged harassment and attempted sexual assault on her 17-year-old daughter by her brothers and their children – FIR registered under Sections 8 and 12 of the POCSO Act – Court held that no ingredients of “sexual intent” or “sexual assault” as defined under Sections 7, 11, or 12 were present – Held: Complaint was retaliatory in nature, filed in context of ongoing property disputes [Paras 5-8, 14-15].

Section 354 IPC – Outrage of Modesty – No Material to Support Allegation – Court found no indication of intent to outrage modesty as required under Section 354 IPC – Allegations were vague and unsupported by evidence or witness statements – Permitting investigation held to be an abuse of process [Paras 9-10].

Section 506 IPC – Criminal Intimidation – Ingredients Lacking – Mere allegations of threats insufficient – FIR failed to disclose any specific intimidation to person or property as required under Section 503 IPC – Held: No prima facie case made out for criminal intimidation [Paras 10-11].

Abuse of Process – Complaint Filed as Counterblast to Family Dispute – FIR Quashed – Court observed numerous civil and criminal proceedings already pending among the parties – Held: FIR filed to harass petitioners and settle scores – Quashing justified under Section 482 CrPC to prevent miscarriage of justice [Paras 11-13].

Final Decision – Petition Allowed – FIR in Crime No. 400 of 2024 Quashed – All proceedings arising therefrom terminated – Interim stay of investigation made absolute [Para 13].
 

Civil Law - Trademark Infringement Suit – Commercial Suit Classification – Section 12 of CC Act – Specific Value Sufficient – Suit for infringement of ‘KRANTI’ trademark valued at over Rs.95 lakhs – Court held that valuation as pleaded, based on market value under Section 12(1)(d) of the Commercial Courts Act, satisfies ‘specified value’ requirement [Paras 6-13, 16-18].

Framing of Additional Issues – Scope Under Order XIV Rule 5 CPC – No Additional Issue Required – Court emphasized that issues are framed based on material propositions in pleadings – Petitioners’ plea for framing additional issue on jurisdiction rejected as no material variance or necessity shown [Paras 15-17].

Pleadings Interpretation – Hyper-Technical Objection Rejected – Absence of express mention of ‘specified value’ wording not fatal where pleadings, market value, and relief valuation collectively satisfied statutory requirements – Substance over form adopted [Paras 18-19].

Relationship Between CC Act and Suits Valuation/Court Fees Act – Harmonious Reading – CC Act provisions do not override the Court Fees Act or Suits Valuation Act – Principles of valuation under Court Fees law prevail unless specifically altered – Confirmed by reliance on Pankaj Ravjibhai Patel case [Paras 19-20].

Limited Interference Under Article 227 – Scope Explained – High Court reiterated that supervisory jurisdiction is limited, not appellate, and interference warranted only in case of grave injustice or jurisdictional error, neither of which existed here [Para 21].

Decision – Petition Dismissed – Impugned order of Trial Court upheld – No interference called for – Suit to proceed before Commercial Court based on existing issues – Petitioners directed to bear their own costs [Paras 22-23].