Criminal Law - Acquittal in Essential Commodities Act Violation – Prosecution’s Burden of Proof – The State challenged the trial court’s acquittal of the accused, arguing that the unlicensed possession of rapeseed oil contravened essential commodity regulations. The court noted that the prosecution failed to substantiate ownership and possession of the storage site, undermining their claim – Held: Prosecution evidence did not conclusively prove the accused’s possession of the godown, nor link them definitively to the contraband, justifying the acquittal [Paras 5-7].

Appellate Interference in Acquittal Orders – Double Presumption of Innocence – Citing Chandrappa v. State of Karnataka and State of U.P. v. Banne, the court emphasized the need for restraint in overturning acquittals, especially where evidence is inconclusive or lacks corroboration – Held: The presumption of innocence is reinforced post-acquittal, and appellate interference is warranted only if findings are perverse or ignore substantial evidence, which was not established here [Paras 10-14].

Analyst’s Report and Evidence Reliability – The prosecution relied on an analyst’s report that identified adulteration in a sample of rapeseed oil, though only one of the fifteen tins was tested. The court found this insufficient to prove uniform contamination, further noting irregularities in evidence handling – Held: Evidence lacked the reliability to support the State’s claims, underscoring the trial court’s decision [Para 12].

Judgment – Appeal dismissed; acquittal upheld. The court found no compelling reason to overturn the trial court’s well-reasoned judgment given the prosecution’s failure to prove guilt beyond a reasonable doubt.

Decision: Appeal G.A. 11 of 1986 dismissed. Trial court acquittal under Section 7(1)(a)(ii) of the Essential Commodities Act is upheld.

Matrimonial Law – D.V. Act - Interim Maintenance – Modification by Appellate Court – Quantum Justified Under Beneficial Legislation – The petitioner challenged the award of ₹5,000 per month as interim maintenance to his estranged spouse under Section 23 of the D.V. Act, arguing that the couple had been separated since 2003, and no recent domestic violence had occurred. The appellate court, however, modified the original order to include this maintenance amount, recognizing the relief as essential under the beneficial nature of the D.V. Act – Held: The award of interim maintenance is within the discretion of the appellate court to provide interim relief in alignment with the Act’s protective intent, warranting no interference [Paras 5-8].

Separation Period and Eligibility for Relief – Applicability of D.V. Act Provisions – Despite the prolonged separation, the appellate court’s provision of interim maintenance reflects the ongoing protective scope of the D.V. Act, ensuring minimal sustenance for the aggrieved party until final resolution. The court noted that the statute’s objective extends to providing interim relief for financial security, regardless of the period of separation [Paras 7-9].

Expedited Trial Directive – Conclusion Within 6 Months – In disposing of the revision, the court directed that the trial court expedite the conclusion of Misc. Case No. 65 of 2018 within six months from this order, thereby ensuring timely finality in line with the D.V. Act’s objective [Para 10].

Revision petition disposed of; interim maintenance upheld. Trial court instructed to expedite case resolution within six months, uninfluenced by appellate findings.

Decision: CRR 38 of 2022 dismissed, upholding interim maintenance of ₹5,000 as ordered by the appellate court.

Media Reporting and Freedom of Speech – Article 19(1)(a) Scope in Criminal Case Reporting - The court examined the balance between the media’s freedom under Article 19(1)(a) and the requirements of fair trial and privacy rights, emphasizing that while media plays a critical role in a democracy, reporting must align with principles of accuracy and constitutional morality. Held: Article 19(1)(a) rights are limited by public interest, dignity, and the individual’s right to a fair trial under Article 21. Reporting that misleads the public or prejudices trials can warrant judicial restraint [Paras 6-9, 18-23].

Proportionality and Restrictions on Media Freedom – Guidelines Not Issued, But Declared Limits of Media Rights - Addressing whether additional judicial guidelines were necessary, the court invoked the proportionality test, noting that freedom of expression must be exercised within limits respecting privacy and fair trial rights, without requiring new guidelines. Declaration: Media’s reporting rights do not include speculation on trial outcomes or factual distortions, aligning with precedents set in Sahara India Real Estate Corporation Ltd. v. SEBI [Paras 20-23, 26].

Right to Information vs. Right to Privacy – Public’s Right to Know and Limits on Media Reporting - Court held that the public’s right to information does not extend to sensationalizing or inaccurate reporting, especially in ongoing criminal investigations. Media must ensure factual accuracy and context in reporting, reinforcing democratic transparency and public trust in the judiciary [Paras 10-12, 19-20].

Final Decision - The petitions seeking mandatory guidelines for media reporting were dismissed. The court declared the boundaries of Article 19(1)(a) in cases impacting public interest, right to fair trial, and privacy, providing a framework for media to self-regulate in reporting judicial matters and criminal investigations.
 

Passport Application – Rejection on Grounds of Family’s Criminal Antecedents – Fundamental Rights Violated - The Court examined the rejection of passport applications on the ground of criminal records of the petitioner’s husband and father-in-law – Held: Criminal antecedents of family members cannot influence assessment of the petitioner’s character or eligibility for issuance of a passport. Respondents directed to reassess the applications based solely on the petitioner’s character [Paras 13-14].

Non-Compliance with Judicial Directions – Fresh Application Ordered in W.P. No. 10154/2021 – Repeated Rejection on Same Grounds - Respondents were previously directed to disregard grounds of earlier rejection in fresh assessments. Non-compliance with this direction led to rejection on identical grounds – Held: Such non-compliance amounts to a cavalier approach, warranting quashing of the impugned orders [Paras 12-13].

Article 21 – Right to Travel Abroad – Fundamental Rights – The petitioner enjoys the same fundamental rights as other citizens, and extraneous considerations based on family connections infringe upon her constitutional rights – Held: Reassessment ordered, and if eligible, the passport must be issued without delay [Para 14].

Decision: The petitions are allowed. The impugned orders rejecting the passport applications are quashed. Respondents are directed to reassess the applications within four weeks, solely on the petitioner’s character, and issue the passport within six weeks if found eligible.

Criminal Law - Sexual Assault - Appeal Against Acquittal - The appellant contended that the trial court disregarded key evidence and failed to apply the statutory presumption under Section 29 of the POCSO Act in acquitting the accused of charges under Sections 354 and 323 IPC and Section 10 of POCSO - Held: On examination, the trial court’s reliance on inconsistencies in the complainant’s statements, coupled with the significant delay of 52 days in filing the complaint, was deemed reasonable. No sufficient grounds were found to overturn the acquittal [Paras 7-10].

Evidentiary Presumption - Section 29 POCSO - The Court affirmed that while the presumption under Section 29 places an onus on the accused, the burden is satisfied when the evidence shows credible contradictions or delay without sufficient explanation - In this case, the trial court’s findings, including the lack of corroborative medical evidence, justified the acquittal [Para 5].

Scope of Appellate Review in Acquittals - Presumption of Innocence - The appellate court noted that an acquittal strengthens the presumption of innocence, and intervention is warranted only if the lower court’s findings are demonstrably perverse or contrary to the weight of evidence. The acquittal was thus upheld [Paras 9-10].

Decision: The appeal is dismissed, upholding the acquittal of the accused.
 

Labour Law - Scope of the BOCW Act – Statutory Welfare Measures – Model Code of Conduct Implications – The Petition impugned a Circular dated 17 October 2023 issued by the Maharashtra Building and Other Construction Workers Welfare Board, which suspended registrations, renewals, and other welfare measures for construction workers based on the Model Code of Conduct for elections – Held: The Model Code of Conduct does not impede pre-existing statutory welfare measures – Suspension of registration and renewals was not justified as these are ongoing statutory activities under the BOCW Act, unrelated to election influence [Paras 5-12, 17-21].

Implementation of Welfare Schemes – Continuation of Statutory Benefits – The Court held that the suspended welfare activities such as registrations, renewals, and disbursal of benefits under pre-existing schemes should continue without interference from the Model Code of Conduct – The Model Code is intended to prevent election-influencing activities but does not cover statutory entitlements – Suspension quashed; welfare activities directed to resume immediately [Paras 23-27, 29-33].

Decision – Quashing of Circular – The Circular dated 17 October 2023 was declared void and ultra vires the BOCW Act – The Court directed the Respondents to restore the registration process and resume disbursal of benefits under the existing welfare schemes without political influence or promotional events, while prohibiting any introduction of new schemes or benefits during the election period [Paras 35-39].
 

Competence of Central Government to Impose Additional Fees – Validity of the Central Motor Vehicles (Twenty Third Amendment) Rules, 2021 – The petitioners challenged the imposition of additional fees for delayed renewal of Certificates of Registration and Fitness Certificates under the amended Rule 81 of the CMV Rules. The Court, citing the Bombay High Court’s decision in K' Savakash Auto Rickshaw Sangha v. Union of India, upheld the validity of the amended provisions. It reasoned that Section 211 of the Motor Vehicles Act provides the Central Government with sufficient power to levy additional fees for delayed applications, and such fees do not constitute a penalty. Therefore, the amendment was within the legislative competence of the Central Government – Held: Amendment upheld [Paras 18-20].

Judicial Comity and Divergent Decisions – Balancing Interpretations – The Court emphasized the principle of judicial comity, choosing to align with the Bombay High Court’s view, which validated the amendment, over the earlier Madras High Court decision in Chennai City Auto Ootunargal Sangam v. Union of India. Judicial discipline and respect for precedents from other jurisdictions were highlighted as essential to maintaining judicial integrity – Held: Followed Bombay High Court’s precedent [Paras 19-20].

Harmonization with State Rules – Coexistence of Central and State Regulations – The Court dismissed the argument that the Odisha Motor Vehicles Rules, 1993, which prescribe penalties for delayed renewals, nullify the Central amendment. It held that the Central Government retains the authority to amend the CMV Rules without requiring a parallel amendment in State Rules – Held: State Rules do not override Central Rules [Para 10].

Decision:  The writ petitions challenging the validity of the Central Motor Vehicles (Twenty Third Amendment) Rules, 2021, were dismissed. The Court upheld the imposition of additional fees for delayed applications as a lawful exercise of the Central Government's powers under the Motor Vehicles Act, 1988.
 

Electricity Law – Privatization of U.T. Chandigarh Electricity Wing – Validity of Bidding Process – The petitioners challenged the privatization process of the U.T. Chandigarh Electricity Wing, alleging that the transfer scheme under Section 131 of the Electricity Act, 2003, was neither finalized nor approved before the issuance of bids, and that no company was incorporated to undertake the functions prior to bidding – Held: The Court found that Section 131 does not necessitate a finalized transfer scheme before bids are issued; the transfer scheme is only required after identifying the transferee – The Court emphasized statutory interpretation should avoid assumptions absent express language [Paras 1.1, 1.3, 3.1].

Employee Rights – Continuity of Employment Terms Post-Privatization – Petitioners contended that privatization could adversely affect employment conditions of the U.T. Electricity Department employees – Held: Section 133 of the Electricity Act, 2003, protects employees by ensuring no change in service terms post-transfer – The Court confirmed employees’ conditions would not be negatively affected under the transfer scheme [Paras 2.2, 3.6].

Policy Decision – Scope of Judicial Review in Economic Matters – The petitioners argued for judicial intervention on policy grounds, claiming that privatization was unnecessary and contrary to the public interest – The Court, citing Supreme Court precedent, ruled that judicial review of economic policy decisions is limited unless there is clear violation of statutory or constitutional limits – Policy decisions, especially in economic reforms, involve complex considerations beyond judicial purview [Paras 3.7, 4].

Final Decision – Petitions Dismissed – The Court dismissed the petitions, finding that the process followed was legally compliant, and that policy decisions regarding privatization were within the executive's domain, thus beyond judicial interference unless shown to be arbitrary or illegal [Para 4].
 

Service Law – Financial and Pensionary Benefits – Work Charge Employee – Entitlement to Pension and ACP – Petitioner sought financial and pensionary benefits, claiming that her deceased husband’s services should be regularized from 2003, making her eligible for benefits like ACP, medical allowance, leave encashment, LTC, etc. – The Court held that as a work charge employee, the deceased was not entitled to benefits available to regular employees, as neither the ACP nor LTC applied to work charge employees without regular service status – Held: Family pension not permissible as per policy; the request for benefits dismissed due to non-applicability of cited benefits to work charge cadre [Paras 6-16].

Administrative Law – Scope of Judicial Review – Delay and Procedural Non-Compliance – The petitioner’s claim, made several years post her husband's demise, was dismissed as it failed to establish valid grounds for delayed claim; delay and procedural grounds further barred entitlement – Held: Writ relief unavailable due to excessive delay and failure to meet eligibility requirements [Paras 7, 10].

Decision: Petition dismissed. Court upheld the Tribunal's findings that the petitioner was ineligible for the claimed benefits under applicable rules for work charge employees and due to procedural deficiencies.