Suo Motu - Government Litigation – Negligence of Officers-in-Charge – Judicial Censure – Court Observes Widespread Apathy – Court severely criticized OICs for failing to cooperate with government counsels by not furnishing case files, leading to repeated deferrals and systemic delays – Held: This constitutes a violation of litigants' right to timely justice and dereliction of duty [Paras 1-3].

Mandamus to Government – Strict Guidelines Imposed – Accountability Framework Ordered – Court directed Chief Secretary, Law Secretary, and Advocate General to enforce structured coordination and reporting protocols among departments and counsels – Directed strict disciplinary action, including personal cost recovery and adverse ACR entries for defaulting OICs [Paras 2, 9-10, 14].

Departmental Reform – Integration of LITES and Legal Oversight – Revival Ordered – Despite launch of Litigation Information Tracking and Evaluation System (LITES), no effective use was made – Held: Departments must hold fortnightly reviews, provide counsels with complete case lists, and submit compliance reports to Justice Department [Paras 4-5].

State Litigation Policy – Legal Cells and Legal Coordination – Revived and Strengthened – Reinforced need for district-level Legal Cells and appointment of Joint Legal Remembrancer-ranked officers in departments with high case volume – Legal Cells to function as hubs coordinating litigation across departments [Paras 6-7].

Digital and Structural Reforms – AI, Analytics, CLE Suggested – Court recommended structured performance evaluations, AI-driven case tracking, real-time dashboards, and reward mechanisms for efficient OICs – Directed use of tech solutions and cross-departmental legal training to modernize litigation handling [Paras 7-8].

Final Directions – Compliance Mandated – Default to Attract Personal Liability – All departments and District Magistrates ordered to ensure full compliance with these directives within a month – Non-compliance to attract personal consequences, including financial penalties and adverse remarks in ACRs [Paras 10-14].
 

 Criminal Law - Rape and Murder – Appeal against conviction – Circumstantial Evidence Based on CCTV Footage – Trial Court Conviction Set Aside – Accused charged with brutal rape and murder of a woman in a hotel courtyard, identified via CCTV – Trial court convicted based on secondary video evidence – High Court held that unverified DVDs used in trial lacked Section 65B certification and were inadmissible – Conviction set aside [Paras 2–6, 21–25, 34]. 
 Electronic Evidence – Section 65B Certification Mandatory – DVDs Without Certificate Inadmissible – Court reaffirmed principles from Anvar v. Basheer and Arjun Panditrao Khotkar – DVDs copied from CCTV DVR were not accompanied by 65B certificates – Court ruled FSL reports not substitutes for 65B compliance – Prosecution failed to produce primary electronic record (DVR) as evidence [Paras 22–25, 32–34]. 
 Retrial – Appellate Court Orders Remand for Fresh Trial – Interests of Justice – Court found grave procedural failure in adducing evidence – Ordered retrial limited to proper admission of electronic records – Directed trial court to recall witnesses if needed and permit accused to present defence afresh – Existing evidence not discarded [Paras 26–29, 38]. 
 Fair Trial – Omission to Adduce Primary Evidence – Prejudice to Both Prosecution and Defence – High Court observed trial failed fundamental fairness due to omission to properly admit critical digital evidence – Both victim and accused prejudiced – Retrial ordered to ensure justice is served [Paras 26, 35]. 
 Decision: Appeal allowed in part – Conviction and sentence under Sections 302, 376A, and 201 IPC set aside – Case remanded to Sessions Court, Ernakulam for retrial to properly admit electronic evidence – Directions issued for expeditious disposal – Accused may recall or re-examine witnesses and present new defence [Paras 38–39]. 
 

Criminal Contempt – Allegation against Sitting Judges – Scandalizing the Court – Contemnor accused Judges of accepting bribes for dismissal of his writ petition – Complaint addressed to the President of India – Held: Allegation scandalizes the Court and tends to lower its authority within meaning of Section 2(c)(i) of the Contempt of Courts Act – Contemnor's admission of authorship and contents of complaint noted – No justification found for demand of covering letter [Paras 1-4, 8-9].

Judicial Integrity – Maintenance of Public Confidence – High Court reiterated importance of preserving dignity and authority of the judiciary – Referred to judgments emphasizing that even unproven allegations that create disaffection against the judiciary constitute contempt – Court found contemnor’s conduct obstructive to the administration of justice [Paras 5-7].

Sentence – Leniency Due to Age – Considering that contemnor was of old age and had no prior contempt history, Court imposed only a fine of Rs. 2,000/- with default sentence of one week simple imprisonment – Directed compliance by Senior Registrar [Paras 9-11].

Criminal Law - Murder  – Eyewitness Testimony by Relative – Credibility Upheld – Conviction Confirmed - PW-10 Ram Pal, brother-in-law of the deceased, was an eyewitness – Court held that being a related witness does not by itself make him untrustworthy – His presence at the scene was natural, his testimony consistent and corroborated by medical and forensic evidence – Ocular version matched with post-mortem findings [Paras 20, 24].

FIR Delay – No Prejudice Caused – Explained and Justified - FIR was registered within a reasonable time after the occurrence between 8:15-8:45 a.m.; statement recorded by 11:00 a.m., and special report reached Magistrate by 4:00 p.m. – Court held that delay was not inordinate and did not weaken prosecution case [Para 21].

Defence Argument – Bloodstained Clothes Not Seized – Not Sufficient to Discredit Witness – Court held that non-seizure of bloodstained clothes of eyewitness Ram Pal was an investigative lapse – But it did not negate his presence or the credibility of his testimony – Eyewitness account supported by medical and ballistic evidence [Para 23].

Medical vs Ocular Evidence – No Contradiction Found – Court held that minor discrepancies in wound description were not fatal – Post-mortem report corroborated injuries caused by gunshot – No inconsistency between medical opinion and eyewitness account [Para 24].

Motive – Prior Enmity Well Established – Conviction Justified - Prosecution established motive of revenge as deceased had been a co-accused in the murder case of Amar Singh’s brother – FIR records confirmed Ram Partap (related to deceased) was convicted for murder of Om Parkash (brother of Amar Singh) – Motive further corroborated credibility of prosecution story [Para 25].

Ballistic Evidence – Pistol Recovery and Forensic Match – Weapon Linked to Crime - Recovered country-made pistol was found to be functional – FSL confirmed fired cartridge and lead slug matched the weapon – Forensic evidence conclusively connected Amar Singh with the firearm used in the murder [Para 26].

Decision – Conviction Upheld – Life Imprisonment and Arms Act Sentence Affirmed – High Court found evidence of guilt overwhelming – Appeal dismissed – Appellant directed to surrender and serve remaining sentence [Para 27].

Criminal Law - Section 482 CrPC/Section 528 BNSS – Seeking Direction for Fair Investigation – No Right of Accused to Dictate Manner or Agency – Petition Dismissed – Petitioner sought direction to conduct investigation in a free and fair manner and impliedly questioned investigating agency – Supreme Court precedents cited to hold that an accused has no right to dictate how an investigation should proceed or which agency should conduct it – Held: Accused cannot claim pre-audience nor request court to intervene in the manner of investigation [Paras 3–6].

Court-Monitored Investigation – Distinction Between Monitoring and Supervision – Not Permissible by Trial Court – Court relied on Manohar Lal Sharma v. Principal Secretary, (2014) 2 SCC 532 to emphasize that courts may only monitor, not supervise, investigations – Supervision amounts to influencing the process and undermines fair trial – Held: Courts may intervene only in rare, exceptional circumstances and not at behest of accused [Paras 7–8].

Supreme Court Precedents – Investigation Cannot Be Driven by Accused – Consistent Judicial View – Cited judgments including Romila Thapar v. Union of India, (2018) 10 SCC 753 and Dinubhai Boghabhai Solanki v. State of Gujarat, (2014) 4 SCC 626 affirm that the accused has no legal right to influence the investigation or seek its transfer – Held: Petition misconceived and against settled law [Paras 5–6].

Final Decision – Petition Dismissed – No Interference Warranted – Court found no grounds to interfere with the investigation or to issue directions for change of investigating agency – Petition dismissed as devoid of merit [Para 9].

Temple Management – Succession to Committee of Management – Not Permissible under 1904 Agreement – Registered Trust Nama/Ikrar Nama of 1904 Governs – The temple management was originally vested with a Seven Member Committee constituted from six Thoks of 145 Sevayat families – Held: The agreement excludes legal succession to committee members; successors cannot inherit committee membership – Appointment must be made afresh as per Thok representation [Paras 23–25, 30–32, 38–
41]. 
 
Receivership – Role of Receiver Subordinate to Committee of Management – Receiver Not to Substitute Elected Committee – The 1924 compromise decree appointed a Receiver during deadlock – Held: Receiver’s role is secondary and temporary, meant to safeguard temple in absence of a duly constituted Committee – Continued reliance on 1924 compromise contrary to 1904 agreement [Paras 31–34, 39–41]. 
 
Judicial Overreach – Litigation Driven by Select Families – Abuse of Process – The petitioners and some respondents, claiming to be legal heirs of 1923 parties, excluded larger Sevayat community – Held: Petitioners’ claim of trusteeship unsustainable – All 734 families are equally bound by 1904 agreement; court deprecates misuse of judicial process to monopolize temple management [Paras 35–37, 40–41]. 
 
Binding Nature of 1904 Agreement – Governing Document for Temple Management – The court reaffirmed that the 1904 agreement is binding on all Pandas/Sevayats – Any appointment or management process must adhere strictly to its terms – Compromise decree of 1924 cannot override foundational governance framework [Paras 23–25, 38–41]. 
 
Judgment – Writ Petition Dismissed – Parties Directed to Follow 1904 Agreement – Court held that present litigation cannot override the original agreement of 1904 – All parties including petitioners and respondents must abide by its terms – Fresh Committee to be formed as per provisions laid down therein [Paras 41–42]. 
 

Bail – Proviso to Section 45(1) PMLA – Old Age and Infirmity – Bail Granted – Petitioner aged 86 years with multiple age-related ailments including cognitive impairment, dementia, and history of falls – Held: Petitioner falls within the category of “infirm” under the proviso to Section 45(1) of the PMLA – Not required to satisfy twin conditions under main provision – Bail granted [Paras 22–30]. 
 
Medical Grounds – Jail Facility Inadequate for Constant Monitoring – AIIMS Medical Board Report Considered – Despite not being acutely sick, the petitioner required round-the-clock monitoring, which could not be assured in jail – Held: Medical condition and advanced age necessitate release from custody [Paras 19, 27–28]. 
 
Triple Test – No Flight Risk, Witness Tampering or Evidence Destruction – Petitioner Released on Interim Bail Earlier Without Misuse – Held: Petitioner satisfies triple test for bail; ED’s allegations of influencing witnesses not substantiated at bail stage – Statement under Section 50 PMLA to be tested at trial [Paras 32–41]. 
 
Delay in Trial – Case Registered in 2018, Trial Yet to Commence – Massive Volume of Evidence and Witnesses – Held: Prolonged incarceration in face of slow trial offends Article 21 rights – Constitutional courts must intervene where trial delay makes bail refusal unjustified [Paras 42–46]. 
 
Judgment – Bail Granted – Constitutional Safeguards Prevail – The Court held petitioner entitled to bail under proviso to Section 45(1) PMLA due to agerelated infirmities and undue delay in trial – Bail granted with standard conditions [Paras 47–50]. 
 

Regular Bail – Prolonged Custody – Clean Antecedents – Bail Granted – Petitioner in custody for 8 months, not involved in any other case – No specific injury attributed to him – Challan presented and charges framed; no prosecution witness examined so far – Held: Further incarceration without trial violates right to speedy justice under Article 21 – Bail granted [Paras 3–4].

Criminal Jurisprudence – Bail as Rule, Jail as Exception – Constitutional Protection Affirmed – Relying on Dataram Singh v. State of U.P., (2018) 2 R.C.R. (Criminal) 131 – Court reiterated that presumption of innocence is a foundational principle – Arrest during investigation must be justified; pretrial custody should not be punitive – Bail discretion to be exercised with a humane and just approach [Para 4].

Delay in Trial – No Witness Examined – Continued Custody Unwarranted – Despite 28 listed prosecution witnesses, none examined yet – Held: Keeping petitioner in jail for an uncertain period without trial infringes upon Article 21 – Emphasized need for timely disposal in line with Hussainara Khatoon v. State of Bihar, (1980) 1 SCC 98 [Paras 4–5].

Decision: Regular bail granted – Petitioner to be released on furnishing appropriate bail and surety bonds – Court clarified that observations are not to influence merits of trial [Para 5].
 

Criminal Law - Exemption from Personal Appearance – Routine Rejection of Section 317 CrPC Petitions – Held Arbitrary – Trial Court rejected exemption petition on grounds of repeated past defaults – High Court held that discretionary powers must be exercised judicially, especially when supported by justifiable medical reasons – Rejection without considering circumstances was arbitrary [Paras 1.4, 11–15]. 
 
Non-Bailable Warrant – Issuance Without Application of Mind – Set Aside – Appellant appeared same day after filing petition for exemption and sought recall of NBW – Trial Court declined by labeling conduct as dilatory – High Court cited Supreme Court precedents (Inder Mohan Goswami, Satender Kumar Antil, Sherif Ahmed) and quashed warrant for violating individual liberty under Article 21 [Paras 7–10, 22]. 
 
Discretion under CrPC – Must be Judicial, Not Mechanical – Courts Directed to Exercise Care – Reiterating Maneka Gandhi v. Rani Jethmalani, Court emphasized that absence due to illness must be considered liberally – Special Court’s repeated rejection of Section 317 and 70(2) petitions held contrary to binding principles [Paras 5–6, 11, 14, 21]. 
 
Recording of Evidence in Absence of Accused – Section 273 and Exceptions – Court Clarified Scope – Referencing Atma Ram v. State of Rajasthan, Court noted trial can proceed in absence of accused under Sections 299, 317 CrPC and Section 16(5) of NIA Act – Trial not automatically vitiated due to absence if alternate procedural safeguards exist [Paras 16–20]. 
 
 Decision: Appeal allowed – Impugned orders dated 30.01.2025 in Crl.M.P. Nos. 73 and 76 of 2025 set aside – Non-bailable warrant recalled – Appellant directed to strictly comply with bail conditions and cooperate with trial – Special Court cautioned against mechanical rejection of exemption petitions [Para 22].