Criminal Law - Rape and Abduction – Appeal Against Conviction - Credibility of Victim – Conviction Upheld – The appellant was convicted under Sections 342, 366, and 376(1) IPC for unlawfully restraining, abducting, and raping an 18-year-old – The High Court found the victim’s testimony cogent, consistent, and supported by medical evidence and corroborative testimony – Delay in FIR filing was reasonably explained and held not fatal – Minor inconsistencies in the victim’s testimony did not affect overall credibility – Conviction and sentence upheld [Paras 2, 4–8].
Use of Section 161/164 CrPC Statements – Contradiction Procedures – Defence Argument Rejected – The Court emphasized that Section 161 and 164 CrPC statements are not substantive evidence unless properly confronted during cross-examination under Section 145 Evidence Act – Defence failed to comply with these procedural requirements – Hence, no valid contradiction established [Paras 5, 7(i)–(viii)].
Enhancement of Sentence – Section 376(2)(b) and (c) IPC – Government Servant Claim Unsubstantiated – Appeal Dismissed – State’s claim that the accused was a government servant and should be convicted under Section 376(2)(b)/(c) IPC rejected – No documentary evidence, ID, or official record produced to establish his employment – Custody element under Section 376(2)(b) not satisfied – Belated attempt to alter charges held impermissible – Appeal for enhancement dismissed [Paras 3, 9–13].
 

Tenancy Law - Tenancy Claim – Cultivation by Relative – Tenancy Denied – MRT Order Set Aside - Petitioner challenged the MRT’s order which upheld tenancy rights of Uttamrao Khot – Held: Mere cultivation by a relative or adopted family member does not establish tenancy – No rent receipts or tenancy agreement were produced – Respondent's claim fails under Section 4 of the Tenancy Act [Paras 13–33].
Presumption of Cultivation – Blank Cultivator Column – Not Sufficient to Prove Tenancy - MRT and Tahsildar relied on blank entries in cultivation columns and assumed tenancy – Court held that such blanks do not raise presumption of tenant cultivation, especially when name of landlord appears in later years – Burden to prove tenancy lies on claimant [Paras 19–20, 25].
Documentary Evidence – Sugarcane Receipts and Revenue Payments – Found Insufficient - Respondent relied on sugarcane factory receipts and land revenue payment documents – Court found no conclusive link to tenancy, especially since payments may have been made as a relative – Letter dated 3 August 1976 allegedly proving rent payment was interpolated and lacked authenticity [Paras 24–30].
Family Relationship – Deemed Tenant Status Barred – Section 4(1)(a) Attracted - Respondent was proved to be brother of the original landowner, adopted by her mother – Held: A family member cannot claim deemed tenancy under Section 4 – Claim fails on statutory bar alone [Para 33].
Final Decision – Writ Petition Allowed – MRT and Tahsildar Orders Quashed - High Court held that MRT’s conclusions were perverse, findings unsupported by credible evidence – Restored SDO's decision rejecting tenancy claim – Respondents’ tenancy over Gat No.836 (New Gat No.125) not upheld [Paras 16–33].
 

Civil Law - Procedure – Order XVIII Rule 1 CPC – Right to Begin – Plaintiff Entitled to Lead Evidence – Deviation Not Justified – The appellant challenged the direction of the learned Single Judge requiring him (defendant) to lead evidence first in a partition suit – The High Court held that as per Order XVIII Rule 1 CPC, it is the plaintiff who has the right to begin unless the defendant admits all material facts and raises only legal defences or additional facts – No such admission was made by the appellant – Held: The impugned order directing the defendant to begin was contrary to procedural law and thus set aside [Paras 15-23]. 
 
Burden of Proof – Direction to Defendant to Lead Evidence – Improper Allocation – No Admission by Defendant – The trial court placed initial burden on defendant based on disputed documents allegedly in his exclusive knowledge – The appellate court held that absence of admissions by the defendant made it incorrect to call him first to lead evidence – The responsibility lies with the plaintiffs to prove their case in the first instance [Paras 16-18, 21-22]. 
 
Decision – Appeal Allowed – Impugned Order Set Aside – The direction requiring the appellant to lead evidence first was quashed – The respondents/plaintiffs were directed to lead their evidence in accordance with law [Para 23]. 
 

Judicial Proceedings – Conduct During Video Conferencing – SOP Recommendation Upheld – Petitioner, a Senior Police Inspector and witness in a Sessions Trial, challenged a Trial Judge’s letter to the DGP recommending Standard Operating Procedures (SOPs) for remote testimony – The letter was based on his alleged disrespectful behavior while deposing from a police station via mobile phone – Supreme Court held that request for SOP was administrative and aimed at preserving court decorum; it did not amount to punitive or mala fide action – Petition dismissed [Paras 1-2, 6-10].

Contempt and Misconduct – Casual Demeanor During Evidence – Court Disapproved – Petitioner was found laughing, muting the microphone, answering calls, and speaking to others while testifying – His behavior was deemed insolent and disruptive to trial decorum – Held: Witnesses, especially Investigating Officers, must maintain solemnity and respect while deposing, regardless of remote access – No personal bias found in Trial Judge’s conduct [Paras 3-9].

Relief – No Interference Warranted – Impugned Letter Not Illegal – Court held that recommending procedural reform through internal communication to senior officials is within a judge’s discretion and does not warrant judicial interference under Article 226 or Section 482 CrPC – Petition devoid of merit – Liberty granted to petitioner to respond to departmental notice on its own merits [Paras 10-11].

Decision – Petition Dismissed – No infirmity found in Trial Judge’s actions – Recommendations for SOPs held valid and well-intentioned – Petitioner may respond to administrative proceedings independently [Para 10-12].

Service Law – Regularisation in Higher Post – Petitioner Appointed as Peon but Entrusted Duties of Cashier – LongTerm Functioning in Higher Post Without Formal Promotion – Regularisation Ordered as Peon Ignoring Court Direction and Favourable Performance Report – Held: Petitioner qualified for regularisation in post of Cashier under 1984 Rules – Board failed to consider performance report as directed by Court – Impugned order quashed – Direction issued to reconsider regularisation in post of Cashier [Paras 6–13]. 
 
Constitutional Mandate – Non-Compliance of Judicial Direction – Mandate of High Court to Consider Branch 
Manager’s Report Ignored – Resolution of Board Preceded Court’s Direction But Later Order Failed to Incorporate Directed Consideration – Held: Violation of judicial discipline and disregard of binding direction – Action unsustainable [Paras 8.3–8.5, 12.3–12.5]. 
 
Doctrine of Equal Pay for Equal Work – Long-Term Discharge of Duties of Cashier with Lower Pay – Petitioner Entrusted with Responsibilities of Higher Grade Without Regularisation or Pay Benefits – Held: Petitioner entitled to pay and post of Cashier – Reliance placed on Supreme Court judgment in State of Punjab v. Dharam Pal – Principle of equal pay for equal work invoked [Paras 10.1–10.6, 12.6]. 
 
Applicability of 1984 Rules vs. 2011 Rules – Resolution for Regularisation Predated 2011 Rules – Eligibility to Be Assessed Under 1984 Rules – Held: Respondent’s reliance on 2011 Rules misplaced – Petitioner’s case to be decided under 1984 Rules where she met eligibility criteria for post of Cashier [Paras 7.3, 8.8, 13.1–13.2]. 
 
Administrative Law – Requirement of Reasoned Orders – Order Regularising as Peon Lacked Reasons or 
Consideration of Pertinent Facts – Held: Decision without reasons contrary to settled principles – Quashed for nonapplication of mind – Reliance placed on Steel Authority of India Ltd. V. Sales Tax Officer [Paras 9–9.5]. 
 
Maintainability of Writ – Availability of Alternative Remedy Not a Bar – Long Delay and Two Rounds of Litigation Justified Invocation of Article 226 – Held: Writ maintainable despite alternative remedy under Section 68 of Odisha Cooperative Societies Act [Paras 11.1–11.5, 14]. 
  
Decision – Writ Petition Allowed – Impugned Order Quashed – Petitioner’s Case to Be Reconsidered for Regularisation as Cashier – Direction to Decide Within Three Months – Petitioner Entitled to Higher Pay Scale upon Favourable Decision [Paras 15–17]. 
 

Bail – Alleged Violation of Official Secrets Act – Applicant Honey-Trapped – Bail Granted – Accused, a 23-year-old apprentice, was alleged to have shared names and details of naval vessels with two absconding accused identified as suspected foreign agents – Prima facie it appeared he was seduced through social media chats and lured into giving limited information without criminal intent – Court noted his full cooperation, clean antecedents, and prolonged custody – Held: A case of honey-trap, information not conclusively established as classified, and incarceration likely to derail reform – Bail granted with conditions [Paras 1–27]. 
 
Youth Offender – Reformative Approach – Court Emphasizes Rehabilitation – Applicant’s young age, lack of antecedents, and academic potential weighed heavily – Court invoked principles from Probation of Offenders Act and global penological trends focusing on reform of young offenders – Held: Long incarceration poses risk of pushing young accused into hardened criminality – Reform, not retribution, should guide the approach [Paras 21–26]. 
 
Honey Trap – Intelligence Modus Operandi – Judicial Alarm Raised – Court found the modus operandi of Accused Nos.2 and 3 to be a clear case of honey-trapping through social media – Observed: Youth are vulnerable targets of such covert techniques – Cautioned society at large about cyber-enabled seduction-based espionage – Held: Circumstances indicated the applicant was manipulated into inadvertent disclosures, without understanding the implications [Para 21]. 
 
Official Secrets Act – Prima Facie Evidence – Nature of Shared Information – Court examined the chats and documents to find that most information shared was not evidently classified or sensitive – Drawing shared was part of applicant’s training, and no wilful breach was proven – Held: Classification of shared material and criminal conspiracy are triable issues, not conclusive at bail stage [Paras 13–15]. 
 
Cooperation with Investigation – Full Disclosure – No Tampering – The applicant did not delete chats or withhold access to devices – Prosecution retrieved all data with the applicant’s assistance – Held: Conduct reflects bona fides, meriting consideration for bail [Para 12]. 
 
Decision – Bail Granted with Conditions – Considering the long incarceration (16 months), lack of antecedents, and no flight risk, bail granted – Directed to report to police and court regularly, surrender passport, and refrain from tampering with evidence – Court clarified observations are only for bail and not on merits of the case [Paras 27–28]. 
 

Bail – Cheating and Forgery – Prima Facie Offence Established – Bail Denied – The petitioner, accused of inducing the complainant to invest Rs.1.73 crores in forged schemes by impersonating an employee of Yes Securities Ltd., failed to show any bona fide investment or return of funds – Investigation revealed the use of fake letters and documents to mislead the complainant – Coaccused declared a proclaimed offender – Held: Allegations are grave, fraudulent intent evident, and continued detention justified at this stage [Paras 5–9]. 
 
Nature of Dispute – Not Merely Civil – Serious Criminal Elements Involved – Court Rejected Argument of Civil Dispute – Despite presence of financial transactions and ledgers, the consistent use of false documentation, impersonation, and deceit elevated the matter beyond a commercial disagreement – Fraudulent inducement supported by forged documents indicative of premeditated criminal conspiracy [Paras 2–6]. 
 
Long Detention – Not a Ground for Bail – Judicial Custody Since June 2023 – Bail Refused – Though the petitioner has been in custody since 05.06.2023 and investigation is complete, the Court held that serious nature of the allegations outweighs the duration of detention – Ongoing trial and gravity of offence warranted continued custody [Para 9]. 
 
Decision – Bail Application Dismissed – Court found no ground to grant bail considering the serious nature of allegations and fraudulent conduct prima facie established during investigation [Para 9]. 
 

Maintainability of Gratuity Claim – Direct Approach to Controlling Authority – Section 7 of the Payment of Gratuity Act – Application Not Mandatory – Claim Allowed – The employer contended that the gratuity claim made directly before the Controlling Authority was not maintainable without first filing an application with the employer – Held: Section 7(2) & (3) impose an independent obligation on the employer to determine and pay gratuity upon exit of the employee, regardless of any formal application – A direct claim before the Controlling Authority is maintainable [Paras 14-15, 30].

Limitation – Rule 7 of MP Rules vs. Parent Act – Gratuity Claim Not Time-Barred – Rule Not Overriding the Statute – The appellant raised limitation under Rule 7 of MP Gratuity Rules – Held: The Act of 1972, being a welfare legislation, overrides the Rules – Rule 7(5) itself clarifies that delay alone does not invalidate the claim – No limitation applies for making a gratuity claim under the Act [Paras 12, 20-21, 23-24].

Interest on Delayed Payment – Section 7(3A) – Automatic Accrual – Interest Mandatory – It was argued that delayed claims should not accrue interest – Held: Interest accrues automatically from the date gratuity becomes payable if not paid within 30 days, unless delay is due to the employee’s fault and Controlling Authority permits such delay – No such circumstance was shown – Interest @10% upheld [Paras 3, 16, 24].

Definition of Employee – Inclusion of Teachers – Amendment of 2009 – Teachers Covered – Initially relying on the Ahmedabad Pvt. Primary Teachers’ Assn. case to exclude teachers – Held: Following 2009 amendment and SC judgment in Birla Institute of Technology v. State of Jharkhand, teachers are now covered as employees under the Act [Paras 5, 29].

Decision – Appeals Dismissed – Employer’s Argument of Maintainability and Limitation Rejected – No Error in Controlling Authority or Learned Single Judge’s Orders – Directed that gratuity with interest be paid within 30 days if not already paid [Para 31].

Criminal Law - Sections 498-A and 306 IPC - Suicide – Abetment Not Proved – Acquittal Upheld – No Instigation or Active Role by Accused - The deceased allegedly committed suicide by self-immolation after claimed harassment by in-laws and husband – Court found no proximate evidence of instigation or mental cruelty triggering the act – Accused had been residing separately from deceased – Held: No evidence of abetment or harassment sufficient to invoke Sections 306 or 498-A IPC [Paras 10–12, 19].

Hostile Witnesses – Prosecution Case Undermined – Evidence Inconclusive - Several key witnesses including panch and inquest witnesses turned hostile – Medical officer could not confirm whether burns were suicidal, homicidal, or accidental – Scientific evidence indicated open kerosene jar and stove; incident possibly accidental – Held: Inconclusive cause of death supports acquittal [Paras 10.1–10.8, 11].

Mens Rea – No Mens Rea Established – Mental Element for Abetment Missing - Citing Supreme Court precedent (Mohan, Amalendu Pal), Court reiterated that mere cruelty or quarrel without intent to incite suicide does not attract Section 306 – Held: No proof of sustained provocation, mens rea, or direct incitement by accused [Paras 9–10, 12].

Separate Residence – No Direct Link to In-laws – Charges under Section 114 IPC Fail - The deceased and her husband resided separately from accused Nos. 2 and 3 – Court found no acts of aiding or presence at the time of death – No vicarious liability under Section 114 IPC sustainable [Para 11].

Decision – Appeal Dismissed – Acquittal Confirmed – No Ground for Interference - High Court held Trial Court rightly extended benefit of doubt – No perverse finding or illegality shown – Appeal dismissed; Trial Court's acquittal judgment affirmed [Paras 12–14].