Criminal Law - Appeals against the conviction - Sections 498-A and 306 IPC  -Cruelty and Harassment – Demand for Dowry – No Specific Evidence – Acquittal – The prosecution alleged that the deceased was harassed and beaten by her husband and mother-in-law for bringing insufficient dowry – Witnesses made general and vague allegations without specific instances of cruelty – Contradictions in prosecution witnesses regarding the demand for dowry and payment of money – No independent evidence corroborating harassment – Held: Mere vague allegations without details of time, place, or nature of cruelty cannot sustain a conviction under Section 498-A IPC – Conviction set aside [Paras 13-17, 23-27].

Abetment of Suicide – Essential Ingredients – No Direct Instigation – No Mens Rea – Suicide Not Solely Attributable to Accused – The deceased consumed poison, but there was no evidence of direct or proximate instigation by the accused – No suicide note or specific act compelling the deceased to take the extreme step – Relationship between the deceased and her husband appeared cordial as per evidence – Held: A conviction under Section 306 IPC requires clear instigation or circumstances leaving no alternative but suicide – Mere allegations of discord in matrimonial life do not constitute abetment – Conviction set aside [Paras 18-22, 36-38].

Presumption Under Section 113A of the Evidence Act – Applicability – Requires Proof of Cruelty – No Automatic Presumption – The prosecution argued that since the suicide occurred within seven years of marriage, the presumption under Section 113A of the Evidence Act should apply – However, the presumption is discretionary and requires proof of cruelty – Inconsistent statements and lack of medical evidence for alleged injuries of the deceased create doubt – Held: The presumption under Section 113A cannot be invoked in the absence of clear evidence of cruelty – Acquittal granted [Paras 29-33, 39-40].

Judicial Approach in Matrimonial Disputes – General Allegations Against Husband’s Family – Risk of Misuse – Courts must scrutinize allegations carefully – Statements from prosecution witnesses were vague and lacked specific details – Conduct of deceased suggested no ongoing harassment – Witnesses admitted the deceased appeared happy and was willingly visiting her matrimonial home – Held: In matrimonial disputes, courts must guard against false implication by vague allegations – Benefit of doubt given to accused – Conviction set aside [Paras 34-35, 41-44].

Decision: The appeals are allowed. The conviction and sentence of the appellants under Sections 498-A and 306 IPC are set aside. The fine amount is to be refunded after the appeal period expires unless an appeal is filed before the Supreme Court. The accused shall furnish bail bonds as per Section 437-A Cr.P.C., ensuring their presence in case of further proceedings.

Criminal Law – Protection of Public Servants – Sanction under Section 197 CrPC – Proceedings Partially Quashed - Petitioners were police officers accused of misconduct during their official duty at a public event – A private complaint was filed against them after they registered an FIR against the complainant’s husband – Trial court took cognizance of multiple offences, rejecting the need for sanction under Section 197 CrPC – Held: Since the alleged acts were committed in the discharge of official duties, sanction was required for most offences – Decision: Cognizance set aside for all offences except under Sections 354 and 354B IPC [Paras 7-10, 24-28].

Scope of Official Duty – Acts Done in Excess – Test for Sanction under Section 197 CrPC - Court examined whether the alleged misconduct had a reasonable nexus with official duties – Held: Even if a public servant exceeds his duty, as long as there is a connection with official functions, sanction is required – Decision: Official actions taken by the petitioners warranted protection under Section 197 CrPC, barring exceptions for certain offences [Paras 9-17].

Public Order and State Notification – Kerala Police Officers Covered Under Section 197(2) & (3) CrPC - The trial court held that police officers were not entitled to protection under Section 197 – Court referred to a Kerala government notification extending such protection to police personnel maintaining public order – Held: The petitioners were covered under the notification and thus required prior sanction for prosecution – Decision: Trial court’s view on the non-applicability of Section 197 CrPC was incorrect [Paras 26-27].
 

Service Law – Project Affected Persons (PAP) – Delay and Laches – Claim Barred – Petitioner sought employment as a PAP based on land acquisition affecting his family – Initially employed on daily wages in 1993 and removed the same year – Request for reinstatement rejected in 1997 and reaffirmed in 2002 – Petitioner filed writ petition in 2024 – High Court held: The claim was inordinately delayed and barred by laches – Mere representations to authorities over the years do not revive a stale claim – Writ petition dismissed [Paras 10-14].

Limitation and Continuing Cause of Action – Mere Repeated Representations Do Not Extend Limitation – Petitioner argued that his cause of action was continuously accruing due to denial of employment – High Court relied on State of Tripura v. Arabinda Chakraborty (2014) and Union of India v. M.K. Sarkar (2010), holding that merely submitting repeated representations does not extend limitation – Cause of action arose in 1997, and the petition filed in 2024 was grossly time-barred [Paras 15-16].

Public Employment – No Vested Right to Appointment – Priority Does Not Mean Automatic Selection – Petitioner relied on Government Resolution dated 21.01.1980 to claim highest priority in employment – High Court held: PAP status grants priority in selection but does not create an absolute right to appointment – Rejection of appointment in 1997 and 2002 was valid and should have been challenged within a reasonable time [Paras 17-19].

Decision – Writ petition dismissed on grounds of delay and laches – No relief granted as the claim was stale and barred by limitation – No costs awarded [Paras 21-22].
 

Administrative Law – Judicial Review – Rejection of Fortified Rice Kernels (FRK) – Standard Operating Procedure (SOP) Compliance – Petitioners, rice millers supplying Fortified Rice under the Public Distribution System (PDS), challenged the rejection of their deliveries due to alleged failure in blending ratio – Government conducted surprise inspections and found stocks exceeding the permissible Fortified Rice Kernel (FRK) blending ratio of 0.9% to 1.2% – Petitioners argued that no prior notice was issued, and rejection violated principles of natural justice – Held: Surprise inspections are permitted under the SOP, and no prior notice is required – Rejection of BRL stocks upheld, and petitioners directed to replace the stocks [Paras 15-17].

Food Safety – Fortified Rice – Quality Control – Testing and Inspections – The Department of Food and Public Distribution (DFPD) conducted surprise inspections as per Bureau of Indian Standards (BIS) norms – Random sampling found FRK blending levels outside permissible limits – Petitioners argued that initial inspections cleared their stocks and subsequent rejection was arbitrary – Held: Testing process followed prescribed guidelines, and the petitioners' arguments were not tenable – Fortified Rice meant for PDS requires strict quality control, and stocks declared BRL must be replaced [Paras 16-20].

Procedural Fairness – Appeal Mechanism – Limited Scope for Challenge – Petitioners claimed that they were not given an opportunity to challenge the rejection – Respondents contended that the appeal mechanism under the SOP applies only at the initial acceptance stage and not for surprise inspections – Held: There is no provision for appeal against subsequent inspections, and the petitioners failed to establish any procedural violations – Judicial intervention not warranted [Paras 19-21].

Decision – Writ petitions dismissed – Rejection of BRL stocks upheld – Petitioners directed to replace rejected stocks with fresh supply as per SOP – No costs awarded [Paras 29-30].

Property Law – Usufructuary Mortgage – Automatic Redemption Under MPLRC – Dispute over agricultural land given as security for a loan—Appellant claimed continued possession based on mortgage deed—High Court held: Under Section 165(2)(b) of MPLRC, a usufructuary mortgage cannot exceed six years and is deemed redeemed by law upon expiry—Respondent (plaintiff) entitled to immediate possession [Paras 14-16].

Civil Procedure – Second Appeal – No Substantial Question of Law – Appellant contended that both Trial and Appellate Courts erred in interpreting mortgage terms—High Court held: Second appeal under Section 100 CPC is limited to cases involving substantial legal questions—Finding of automatic redemption under MPLRC is a settled legal principle, not warranting further interference [Paras 11-13].

Judicial Precedent – Appellate Court’s Findings Binding Unless Perverse – Appellant argued that mortgage deed Ex.P/3 should be treated as a shareholding agreement—High Court relied on Kondiba Dagadu Kadam v. Savitribai Sopan Gujar to hold that appellate findings, if based on proper evidence and reasoning, should not be disturbed in a second appeal [Para 13].

Decision – Second appeal dismissed—Trial Court’s conditional redemption order modified by First Appellate Court upheld—Appellant directed to vacate the suit land—No costs awarded [Paras 16-17].
 

Civil Law - Execution Proceedings – Application under Order XXI Rule 97 CPC – Transferee Pendente Lite – Not Maintainable – Petitioner purchased suit property during pendency of litigation – Held: Transfer hit by Section 52 of the Transfer of Property Act – Executing court should have dismissed the application under Rule 97 CPC at the threshold in view of bar under Rule 102 CPC – Revisional court erred in dismissing the application outright rather than remanding the matter for preliminary determination of res judicata [Paras 22–30, 35–36].

Doctrine of Lis Pendens – Applicability to Transferee During Suit – Rights Subordinate to Decree – Petitioner’s purchase in 2001 was during pendency of Original Suits No. 33/1991 and 151/1991 – Supreme Court precedents reaffirm that such transfers do not affect rights under decree – Transferee bound by outcome of litigation irrespective of notice – Held: Petitioner cannot resist execution of decree passed in 2003 [Paras 18–20].

Revisional Jurisdiction – Scope under Section 115 CPC – Revisional Court Cannot Assume Role of Executing Court – Revisional court should have remanded matter instead of rejecting the execution application – Observed: Supervisory jurisdiction to be exercised sparingly – Revisional court exceeded jurisdiction by adjudicating on merits where trial court had not decided the matter finally [Paras 31–34].

Execution Delay – Directions for Expeditious Disposal – Supreme Court Mandate for Timely Execution – Relying on Periyammal (2025) and Rahul S. Shah (2021), Court reminded executing courts to dispose of execution proceedings within six months – Expressed concern over 10-year pendency of application filed in 2014 – Direction issued to dispose matter within one month [Paras 30, 36–37].

Decision – Orders Set Aside – Matter Remanded to Executing Court – High Court set aside both revisional and trial court orders – Directed executing court to decide application under Order XXI Rule 97 CPC afresh in light of law on lis pendens and Order XXI Rule 102 CPC within one month [Para 37].

Criminal Law – Writ of Habeas Corpus - Illegal Detention – Violation of BNSS – Habeas Corpus Allowed – The detenue was arrested on 24.02.2025 and produced before the Magistrate on 25.02.2025 – Magistrate initially returned the remand report due to failure to provide arrest intimation under Section 47(1) of BNSS – Arrest intimation allegedly sent via WhatsApp to detenue’s relative, which was held to be improper – High Court held: Section 47(1) of BNSS mandates immediate communication of reasons for arrest – Failure to comply renders further detention illegal – Detenue ordered to be released [Paras 9-10, 15-16].

Fundamental Rights – Right to be Informed of Arrest – Constitutional Mandate – Article 22(1) of the Constitution guarantees that an arrested person must be informed of the grounds of arrest – High Court relied on Prabhir Purkayastha v. State (NCT of Delhi), (2024) 8 SCC 254, and held that violation of this right results in unlawful custody – Magistrate’s remand order found to be passed without due application of mind, making the detention invalid [Paras 10-13].

Procedural Irregularities – Failure to Comply with Statutory Requirements – No Rearrest Conducted – Respondents argued that detenue refused to receive arrest intimation and was later re-arrested – High Court held: No record of rearrest in remand report – Arrest remains non-compliant with legal requirements – Magistrate erred in returning the remand report for compliance instead of releasing detenue immediately [Paras 14-15].

Decision – Writ petition allowed – Remand order set aside – Detenue ordered to be released forthwith from District Jail, Nellore – State permitted to continue investigation as per law [Paras 16-18].

Criminal Writ - Habeas Corpus – Illegal Detention – Arrest without FIR or Grounds of Arrest – Detention Declared Illegal – The detenu was picked up without any FIR or communication of reasons for arrest – FIR was registered hours later, only after a Warrant Officer’s intervention – Held: Arrest violated Articles 21 and 22 and Section 47 of BNSS – Detention declared void ab initio [Paras 1–6, 16–17].

BNSS Compliance – Section 35 and 47 – No Notice or Written Grounds of Arrest – Procedural Safeguards Violated – No notice under Section 35(3) issued – Grounds of arrest not communicated forthwith – Arrest held contrary to statutory and constitutional safeguards – Mere post-facto FIR registration cannot cure illegality [Paras 4, 17].

Judicial Interpretation – Supreme Court in Vihaan Kumar – Written Communication of Grounds Mandatory – Court relied on Vihaan Kumar v. State of Haryana, 2025 SCC OnLine SC 269 – Held: Failure to inform arrestee of arrest grounds in writing vitiates custody – Procedural compliance essential to protect liberty under Articles 21 & 22 [Paras 14–15].

Custodial Dignity – Routine Arrest Without Justification Not Permissible – Citing Joginder Kumar v. State of U.P. and D.K. Basu, Court reiterated that power to arrest must be exercised with caution and justification – Custodial action impacts reputation and liberty and must conform to due process [Paras 7, 10–11].

Role of Warrant Officer – Ministerial Capacity Only – Overstepping Jurisdiction Deprecated – Court clarified that a Warrant Officer cannot adjudicate legality of arrest – Findings in Warrant Officer’s report regarding legality were beyond mandate and disapproved by the Court [Para 20].

Decision: Writ petition allowed – Detention declared illegal – Detenu ordered to be released forthwith unless required in any other case – Arrest and remand declared void due to non-compliance with constitutional and statutory safeguards [Paras 21–22].

Motor Accident Claims – Fraudulent Claims – Fabrication of Accident Story – Compensation Award Set Aside – Claimant sought compensation for the death of her husband, alleging he was a pillion rider on a motorcycle that met with an accident – Investigation revealed that the deceased had actually fallen from his own motorcycle due to dizziness – High Court held: Claim was fabricated with the involvement of the vehicle owner, driver, and lawyer – Award of ₹17,49,752/- quashed – Any compensation paid to be refunded to the insurance company with 9% interest [Paras 12-21].

False Evidence – Perjury in Motor Accident Claims – Criminal Prosecution Ordered – Special Investigation Team (SIT) found that claimant, vehicle owner, and driver colluded to create a false accident story – High Court relied on Dalip Singh v. State of U.P. and Dhananjay Sharma v. State of Haryana, emphasizing that perjury in judicial proceedings undermines the justice system – Directed prosecution under Sections 193, 196, 199, 209 IPC (corresponding to Sections 229, 233, 236, 246 of BNSS, 2023) [Paras 27-32].

Fraudulent Pleadings – Violation of CPC and BNSS – Action Against Lawyer – High Court noted that false pleadings and affidavits were filed to support the claim – Lawyer representing the claimant played a role in manufacturing the fraudulent case – Court directed disciplinary proceedings against the lawyer and prosecution for aiding perjury [Paras 28-30].

Decision – Appeal allowed – Compensation award set aside – Claimant, vehicle owner, driver, and lawyer to face criminal prosecution – Case referred to Chief Judicial Magistrate, Pakur, for cognizance – SIT report and evidence to be submitted for further action [Paras 32-33].