Criminal Law - Murder – Circumstantial Evidence – Sections 302, 498-A, 201 IPC – Acquittal – Appellant convicted for murdering wife by throttling and hanging her body to simulate suicide – High Court found prosecution failed to prove motive, failed to complete chain of circumstances, and relied on weak extra-judicial confession – Medical evidence ruled out manual throttling – Conduct of accused in shifting wife to hospitals consistent with innocence – Held: Prosecution case not proved beyond reasonable doubt – Conviction and sentence set aside; accused acquitted [Paras 23-42].

Motive – Crucial in Circumstantial Evidence – Prosecution failed to prove accused’s alleged extramarital affair or dowry demand – Non-disclosure of alleged woman’s identity fatal to case – Absence of clear motive weighs in favour of accused [Paras 12-15, 31-33].

Medical Evidence – Manual throttling ruled out – Post-mortem showed asphyxia due to pressure on neck but absent signs of throttling such as nail marks, finger impressions, petechial haemorrhage or cyanosis – Medical testimony inconsistent with prosecution theory [Paras 21, 40].

Extra-Judicial Confession – Weak type of evidence – PW-7’s testimony regarding confession improbable and unreliable – Supreme Court precedent in Sunny Kapoor v. State (UT Chandigarh), AIR 2006 SC 2242 applied – Confession discarded [Paras 38-40].

Presumption under Section 106, Evidence Act – Burden on accused arises only after prosecution establishes prima facie case – Here, prosecution failed to prove incriminating chain of circumstances; hence presumption under Section 106 not attracted [Paras 37-38].

Decision: Criminal Appeal allowed – Conviction and sentence imposed by IV Additional Sessions Judge, Kadapa, in S.C. No. 158 of 2016 set aside – Appellant acquitted of charges under Sections 302, 498-A, and 201 IPC – Fine, if paid, to be refunded – Appellant directed to complete formalities before prison authorities in terms of Batchu Ranga Rao v. State of A.P., 2016 (3) ALT (Crl.) 505 (DB) (AP) [Paras 41-42].

Contract Law - Recovery Suit under LoC – Rejection of Goods by Importer – Time Not Essence – Appeal Dismissed – In a dispute arising from the appellant’s refusal to accept goods under an irrevocable Letter of Credit, the Court upheld the Trial Court’s decree awarding Rs. 7,89,840/- with interest to the exporter (Respondent No. 1) – It held that the minor delay in shipment did not justify rejection, discrepancies raised by the issuing bank could not be relied upon by the buyer, and time was not the essence of the contract – Application to lead additional evidence was also dismissed – Held: No illegality or perversity in Trial Court’s judgment – Appeal and pending applications dismissed [Paras 1–2, 36–39, 53–59].

Letter of Credit – Separate Contract Doctrine – Buyer Cannot Refuse Delivery Based on Bank’s Objection – Appeal Dismissed – The Court reiterated that obligations under an LoC are independent from those under the sale contract – Appellant’s reliance on discrepancies raised by issuing bank to justify non-acceptance was misplaced – Held: Discrepancies did not impact buyer-seller contract; LoC rejection irrelevant to buyer’s liability [Paras 45–49].

Time of Shipment – Time Not Essence – Delay of Two Days Not Fatal – Conduct Shows Waiver – Appellant had accepted previous late shipments and failed to raise prompt objection upon receipt of goods – Held: Minor delay in shipment of third order did not justify cancellation – Contract did not treat time as essence – Performance deemed within reasonable time [Paras 27–44].

Additional Evidence – Negligence of Counsel Not a Ground – Application under Order XLI Rule 27 Rejected – Appellant’s plea that its previous counsel failed to conduct cross-examination or file affidavit was not accepted – Court found no exceptional circumstance warranting additional evidence at appellate stage – Corporate litigant expected to be vigilant [Paras 53–55].

Electronic Records – Section 65-B Certificate – Procedural Requirement Curable at Appellate Stage – Objection to admissibility of emails raised for first time in appeal – Respondent furnished Section 65-B certificate during hearing – Held: Certificate admissible; appeal being continuation of suit, defect was cured [Paras 50–52].

Standard of Review – No Interference Where Findings are Plausible – Appellate Court's Scope Limited – Trial Court’s findings based on evidence and consistent with legal principles – Held: No perversity or illegality warranting interference – Appeal dismissed [Paras 56–57].

Final Relief – Appeal and Applications Dismissed – Decretal Amount to Be Released – No merit found – Appellant’s deposit to be released to Respondent No. 1 with accrued interest – All pending applications also dismissed [Para 59].

Civil Law - Motor Accident Claim – Liability of Registered Owner – Vehicle Uninsured – Compensation Liability Affirmed – Offending scooter involved in accident was admittedly uninsured – Registered owner argued that vehicle was taken by respondent-driver without authority and that driver had agreed to bear compensation liability – Held: Registered owner cannot evade liability under Section 2(30) of Motor Vehicles Act – Absence of insurance and failure to prove forcible taking of vehicle makes registered owner liable – Dismissal of appeals upheld by relying on Supreme Court rulings in Naveen v. Vijay and Brij Bihari Gupta v. Manmet – Registered owner may pursue independent remedy against the driver but remains liable to injured parties [Paras 5, 9-12].

Uninsured Vehicle – No Relief Against Compensation Liability – Affidavit by Driver Not a Ground to Discharge Owner – Registered owner relied on driver’s affidavit stating he would pay compensation – Held: Such affidavit does not affect liability of registered owner under the Act – Owner must satisfy award and may seek recovery from driver separately – Tribunal rightly held both owner and driver jointly and severally liable [Paras 5, 11-12].

Appeals Against Compensation – No Enhancement Sought by Claimants – Finding Limited to Owner’s Liability – No appeal for enhancement was filed by claimants – Scope of appeal confined to contest of liability by registered owner – Tribunal award upheld to the extent of holding owner liable – Appeals dismissed [Paras 4, 12].

Service Law – Academic Arrangement Lecturers – Constitutional Validity of Exclusion from Regularization – Upheld – Petitioners appointed on academic arrangement basis sought regularization and struck down of Section 3(b), 10(2), and 10(2A) of the J&K Civil Services (Special Provisions) Act, 2010 – Held: Classification excluding academic arrangement appointees from regularization is not arbitrary – It has rational nexus with object of Act which is to regularize only those engaged against clear vacancies on ad hoc, contractual, or consolidated basis – Article 14 does not mandate equal treatment for unequals – Section 3(b) and related provisions held constitutionally valid [Paras 24–29].

Nature of Appointment – Academic Arrangement vs Ad hoc/Contractual – Distinction Determined – Appointments made against sanctioned posts and continued year after year either through limited selection or court intervention held to be contractual and consolidated in nature – Such appointments qualify for regularization under the Act of 2010 – Academic arrangement nomenclature not determinative – Substance of engagement considered over form [Paras 30–33].

Relief Granted – Directions for Regularization – High Court directs constitution of High-Level Committee to identify eligible appointees – Only those engaged prior to the commencement of the Act of 2010 against clear vacancies and completed 7 years of continuous service found eligible – Regularization to be prospective or retrospective based on date of eligibility – Future academic arrangements against clear vacancies prohibited – Committee to explore creation of additional teaching posts and refer vacancies to Public Service Commission [Paras 36–37].

Decision – Writ Petitions Allowed in Part – Tribunal’s judgment partially set aside – Section 3(b), 10(2), and 10(2A) upheld as valid – However, petitioners engaged prior to the Act on sanctioned posts held entitled to benefit of regularization – Matter remitted to committee for scrutiny and implementation of regularization exercise [Paras 29, 36–37].

Motor Accident Claim – Compensation – Enhancement – Section 168, Motor Vehicles Act – Compensation Enhanced – Claimant, a 29-year-old labourer, suffered multiple injuries and 30% permanent disability in a road accident – MACT awarded ₹66,000/- with 6% interest – High Court held Tribunal erred in ignoring Disability Certificate issued by Medical Board – Applying multiplier method, daily wages, and future prospects, Court reassessed compensation at ₹2,11,880/- with 6% interest – Held: Just compensation must be awarded even if it exceeds the claim amount; appeal allowed, compensation enhanced [Paras 12-21].

Assessment of Disability – Medical Board Certificate – Cannot be ignored – PW-2, Orthopedic Surgeon and Board member, certified 30% permanent disability – Tribunal wrongly reduced to ₹30,000/- – Court accepted disability assessment, computed loss of earning capacity accordingly [Paras 13-15, 17].

Just Compensation – Broad and Liberal Approach – Supreme Court precedents (Baby Sakshi Greola; Yadava Kumar; Rajkumar; Sidram) emphasize liberal and realistic computation – Compensation not confined to rigid formulas; Court must restore injured as far as possible to pre-accident status [Paras 12, 16].

Awarding More Than Claimed – No Restriction – In line with Nagappa, Kajal, and Ramla – Tribunal/Court bound to grant “just compensation” even beyond claim amount – Principle applied to grant enhanced award exceeding original claim [Para 20].

Decision: Appeal allowed – Compensation enhanced from ₹66,000/- to ₹2,11,880/- with 6% interest per annum from date of petition till realization – Liability fastened on owner and insurer jointly – Claimant entitled to withdraw enhanced amount; required to pay Court fee on enhanced portion – No order as to costs [Para 21].

Civil Law - Succession – Scheduled Tribe – Application of Indian Succession Act – Appeal Dismissed – The appellants challenged judgments declaring the plaintiff/respondent as the successor to agricultural land formerly owned by Tulsabai (widow of Gamna), asserting absence of adoption and claiming title based on ancestral gift and possession – Held: No exemption under Section 3 of Indian Succession Act, 1925 was proved to exclude Bhil tribe – Therefore, succession rightly governed by Sections 24, 28, and 32 of the Act – Plaintiff, as nephew of deceased, was closest kindred entitled to succeed – Second appeal dismissed as no substantial question of law arose [Paras 13-21, 26-30].

Adoption – Custom Not Proved – Succession Upheld on Basis of Kindred – Plaintiff's adoption was not accepted by the courts below for lack of evidence – However, concurrent findings held him to be the nearest surviving relative of the deceased couple – Courts rightly relied on statutory succession principles rather than unproven adoption or custom – Adoption plea immaterial to final outcome [Paras 12-15, 21].

Customary Law – Inapplicability Due to Lack of Exemption – Hindu and Indian Succession Acts Apply – Appellants contended that Bhil tribe is governed by custom and not general succession laws – Court held that without notification under Section 3 of Indian Succession Act, 1925, no exemption applies – Indian Succession Act validly governs devolution of property – Appellants' reliance on Madhu Kishwar distinguished [Paras 18-19].

Mutation and Compensation – No Independent Right Created – Sale by Defendants Invalid – Mutation in favour of defendants and subsequent sale to State under Mahi Canal Project did not create valid title – Original sale deed from 1966 in favour of Gamna remained unchallenged – Courts rightly declared mutation and sale-deed null and void – Compensation declared payable to rightful heir i.e. plaintiff [Paras 5-8, 22-23].

Substantial Question of Law – Not Made Out – Concurrent Findings Not Interfered With – Appellants failed to show any perverse findings or misapplication of law – Legal issues raised regarding adoption, mutation, and compensation did not satisfy threshold under Section 100 CPC – Appeal dismissed in limine [Paras 13, 26-30].

Final Decision – Second Appeal dismissed – No substantial question of law arose – Plaintiff/respondent declared rightful successor and owner – Defendants’ mutation and sale of land declared invalid – Compensation awarded to plaintiff – Costs not imposed [Paras 29-30].

Income Tax – Section 14A Disallowance – Mandatory Recording of Satisfaction – Disallowance Deleted – The Assessing Officer disallowed ₹5,07,04,000 under Section 14A read with Rule 8D – Held: AO failed to record any dissatisfaction with assessee’s claim of no expenditure incurred in earning exempt income – In absence of proper satisfaction as mandated under Section 14A(2), invocation of Rule 8D not justified – Disallowance liable to be deleted [Paras 9–12].

Rule 8D – Precondition of AO’s Satisfaction – Procedural Safeguard – Not Optional – The court reiterated that Rule 8D can be invoked only after AO records dissatisfaction with assessee’s computation of expenditure – Satisfaction must be based on objective analysis, not merely a ritual formality – Lack of such satisfaction renders the disallowance unsustainable in law [Paras 9–11].

Precedent – Reliance on Supreme Court Judgment – Decision Followed – The Court relied on Supreme Court judgment in Godrej & Boyce Mfg. Co. Ltd. v. DCIT, (2017) 394 ITR 449 (SC) – Held: AO’s mechanical application of Rule 8D without recording reasons violates settled law [Para 11].

Decision – Disallowance under Section 14A Deleted – Appeal Allowed – The impugned order confirming disallowance set aside – Appeal of assessee allowed with no order as to costs [Para 13].

Civil Law - Substitution of Legal Representative – Will Executed by Deceased Plaintiff – Order 22 Rule 3 CPC – Substitution Allowed – Original plaintiff Munni Devi filed suit for declaration and partition claiming 1/3rd share – After her death, petitioner (her son) filed substitution application based on a will executed by her in his favour – Trial Court rejected the application on the ground that other legal heirs named in the will were not impleaded – Held: A legatee under a will represents the estate of the deceased and is entitled to be substituted – No allegation of fraud or collusion was made by the respondents – Application wrongly rejected – Order of Trial Court set aside and petitioner directed to be impleaded as plaintiff [Paras 1–10].

Procedural Lapse by Trial Court – Failure to Declare Suit Abated – Judicial Criticism – Trial Court, while rejecting the substitution application, did not declare the suit abated despite no surviving plaintiff – Instead, the matter was posted for plaintiff’s evidence – Held: Such action reflects lack of basic procedural understanding – Presiding Officer requires training – Order to be forwarded to District Judge, Director of JOTRI, and Registrar General for appropriate action [Paras 12–13].

Final Decision – Misc. Petition allowed – Order dated 08/01/2025 in RCSA No. 233/2021 set aside – Petitioner to be substituted as plaintiff – Trial Court directed to proceed with the suit accordingly [Paras 10–11].

Criminal Law – Conviction Based on Extra-Judicial Confession and Circumstantial Evidence – Acquittal Ordered – The appellant was convicted under Sections 302 and 201 IPC for the alleged murder of his parents based on extra-judicial confessions and recoveries made at his instance – The High Court found that the alleged confessions were made in the presence of police and were not recorded under Section 164 CrPC, making them inadmissible under Section 25 of the Evidence Act – Further, the prosecution failed to prove a complete chain of circumstantial evidence, with no forensic report linking the accused to the crime – Held: The conviction was not legally sustainable and the benefit of doubt must go to the accused – The appeal was allowed and the appellant was acquitted [Paras 4, 16, 21–22, 26–33].

Extra-Judicial Confession – Presence of Police – Inadmissible and Unreliable – The conviction was based largely on extra-judicial confessions allegedly made by the appellant before local witnesses – Held: As confessions were made in presence of police personnel, voluntariness is doubtful and such statements cannot be relied upon – No confession was recorded under Section 164 CrPC – Confession inadmissible as per Section 25 of the Evidence Act [Paras 26–31].

Recovery of Weapons – Non-Compliance with Section 27 Evidence Act – Doubt Cast – Though weapons and blood-stained clothes were allegedly recovered at the instance of the accused, there was no recorded discovery statement – No FSL report to link recovered items with the crime – The prosecution failed to establish nexus between recovery and the alleged offence [Paras 21–22, 27].

Circumstantial Evidence – Chain Incomplete – Conviction Not Sustainable – The prosecution failed to prove motive, discovery statement, or forensic link – No eyewitness and no direct evidence – Medical opinion did not support weapon used – Held: Chain of circumstances not complete to exclude every hypothesis other than guilt – Conviction unsustainable in law [Paras 4, 16, 32].

Standard of Proof – Extra-Judicial Confession Requires Greater Scrutiny – Citing precedents including Sharad Birdhichand Sarda and Ramu Appa Mahapatar, court held that extra-judicial confession must be voluntary, reliable, and corroborated – These standards were not met in the present case – Confession not recorded in safe environment – No voluntary or corroborated statement [Paras 11–15, 30].

Decision – Appeal Allowed – Conviction Set Aside – Acquittal Ordered – The High Court found serious procedural lapses and gaps in evidence – Benefit of doubt extended to the accused – Conviction and sentence under Section 302/201 IPC set aside – Appellant directed to be released unless wanted in any other case [Para 33].