Civil Law - Procedural Law - Code of Civil Procedure 1908 - Order 8 Rule 1-A(3) - Production of documents - Trial Court dismissed defendants' application seeking to lead additional evidence to prove a field inquiry report and appellate records on the ground of belated filing - High Court observed that Order 8 Rule 1-A(3) does not prescribe a specific stage for production but requires leave of the Court - Held - Procedural laws are designed for the advancement of justice and parties should be afforded reasonable opportunity to produce evidence to prove their case on merits - Trial Court's refusal on purely technical grounds set aside - [Paras 14-20].

Civil Law - Additional Evidence - Code of Civil Procedure 1908 - Section 151 - Inherent powers of Court - Defendants sought to produce revenue records to support their defense in a suit for possession - Plaintiff opposed citing delay - Held - Right of a litigant to prove their case should not be scuttled by technicalities unless they overshadow the merits of the dispute - Petitioners permitted to produce evidence subject to payment of costs - [Paras 16-20].

Decision: Petition allowed - Order dated 28.3.2026 of the trial court set aside - Defendants permitted to produce the documents - Cost of Rs 5000 imposed - Parties directed to appear before the trial court on 22.9.2026.

Criminal Law - Bail - Bharatiya Nagarik Suraksha Sanhita 2023 - Section 483 - Incitement to violence and rioting - Applicant acting as leader of an organization called for a public assembly leading to a riotous situation where police were assaulted and public property damaged - Despite applicant's claim of non-presence at the site the Court observed that the applicant was the mastermind who incited the masses and later applauded the acts of the mob - Bail rejected considering the gravity of the offence and impact on public tranquility - Held - Bail application rejected - [Paras 1-7].

Criminal Law - Public Order and Sloganeering - Bharatiya Nyaya Sanhita 2023 - Incitement - Raising of slogans such as Gushtakh-e-Nabi Ki Ek Hi Saza Sar Tan Se Juda constitutes a challenge to the authority of law and the sovereignty and integrity of India and amounts to inciting an armed rebellion which is not protected under the guise of religious expression - Held - Such slogans cannot be equated with traditional religious slogans and justify denial of bail - [Paras 6-7].

Criminal Law - Bail - Criminal Antecedents - The applicant possessed extensive criminal antecedents of 24 cases and the investigation revealed substantial evidence connecting the applicant to the mobilization of the mob despite administrative prohibitions under Section 163 BNSS - Held - No case for grant of bail made out - [Paras 5-7].

Decision: Bail application rejected - The Court found no merit in the contention that the applicant was merely a political figure and held that the gravity of the incitement and the resulting violence against the state necessitated custodial detention.

Criminal Law - Insecticides Act 1968 - Sections 22 and 24 - Misbranding of insecticide - Petitioners sought quashing of criminal complaint for alleged sub-standard insecticide sample - Sample was analysed after shelf life had expired due to departmental delays - Resultantly petitioners were deprived of their valuable statutory right to seek re-analysis by Central Insecticides Laboratory under Section 24(4) - Held - Deprivation of such a vital right renders the prosecution an abuse of process of law - Quashed - [Paras 9-17].

Criminal Law - Insecticides Act 1968 - Section 22(6) - Mandatory procedure - Failure to send sample to analyst forthwith - Sample sent after a delay of 14 days contrary to the requirement of sending it forthwith - Held - Violation of mandatory provisions of Section 22(6) is fatal to the prosecution and constitutes sufficient ground for quashing - [Paras 18-22].

Criminal Law - Insecticides Act 1968 - Section 30 - Liability of marketer - Petitioner merely a marketer of insecticide - Sample drawn from original sealed container - No evidence of improper storage or tampering - Held - Marketer cannot be held vicariously liable for misbranding when the product is sold in sealed condition and manufacturer is identifiable - [Paras 23-32].

Criminal Law - Insecticides Act 1968 - Section 33 - Vicarious liability of Directors - Complaint lacked specific averments regarding consent- connivance or neglect of Directors - Summoning order passed in a mechanical manner without application of mind - Held - Directors cannot be summoned absent specific pleadings of their involvement in day-to-day affairs or specific acts of omission/commission - [Paras 33-43].

Decision: Petitions allowed – Criminal Complaint No. 44/2023 and summoning order dated 24.08.2023 quashed qua the petitioners.

Criminal Law - Rash and Negligent Driving - Indian Penal Code 1860 - Sections 279, 337 and 338 - Petitioner-accused convicted by trial court and upheld by appellate court for driving a pickup in a zigzag manner and hitting multiple vehicles resulting in grievous injury to informant - Petitioner admitted in statement under Section 313 CrPC that he was driving the offending vehicle - High Court maintained conviction noting that breach of road safety regulations and failure to give way to vehicles on the main road constituted conclusive proof of negligence - Held - Concurrent findings are well-reasoned and suffer from no perversity - Petition dismissed - [Paras 1-46].

Criminal Law - Evidence - Code of Criminal Procedure 1973 - Section 313 - Admission of guilt - Accused admitted in his statement that he was driving the vehicle at the time of the accident - Held - Though not substantive evidence in the strict sense, the statement of the accused under Section 313 CrPC can be taken into consideration to lend credence to the prosecution case and corroborate other evidence - [Paras 15-18].

Criminal Law - Sentencing - Probation of Offenders Act 1958 - Section 4 - Rash driving - Petitioner sought benefit of probation - Held - In view of the alarming proliferation of road accidents and the need for deterrent punishment for professional drivers, benevolent provisions of the Probation of Offenders Act cannot be extended to offences involving rash and negligent driving - [Paras 38-42].

Criminal Law - Revisional Jurisdiction - Code of Criminal Procedure 1973 - Section 397 - Scope - High Court's power - Held - Revisional jurisdiction does not equate to appellate power and cannot be used to reappreciate evidence in the absence of perversity, gross error, or miscarriage of justice - [Paras 13-14].

Decision: Revision petition dismissed – Conviction and sentence affirmed – Records directed to be returned.

Criminal Law - Quashing of FIR - Code of Criminal Procedure 1973 - Section 482 - Petitioner challenged FIR alleging unauthorized colonization on grounds that land within municipal limits falls outside jurisdiction of Town and Country Planning Department and relying on previous High Court orders - Court observed that allegations of carving out colony and laying roads without licence prima facie disclose offence under Act 1975 - Held - High Court cannot conduct mini-trial to appreciate evidence or veracity of defence at this stage - FIR sustained - [Paras 1-20].

Criminal Law - Statutory Interpretation - Haryana Development and Regulation of Urban Areas Act 1975 - Section 2(o) - Definition of Urban Area - Petitioner contended that land falling within municipal limits excludes applicability of Act 1975 - Court held that definition under Section 2(o) explicitly includes land within municipal limits and previous judgments regarding different enactments like Punjab Scheduled Roads Act 1963 are inapplicable - Held - Municipal status does not oust jurisdiction of Town and Country Planning Department under Act 1975 - [Paras 15-17].

Criminal Law - Precedents - Supreme Court Jurisdiction - Petitioner relied on High Court order in Rimpy Kansal case - Supreme Court in State of Haryana versus Rimpy Kansal set aside said order holding that blanket restraint on lodging FIRs by District Town Planner is impermissible - Held - Petitioner cannot rely on a set-aside order to claim jurisdictional immunity - [Paras 17-19].

Decision: Petition dismissed – The Court directed that the trial proceedings shall continue in accordance with law – No opinion expressed on the merits of the case.

Administrative Law - Competent Authority - Cinematograph Act 1952 - Section 4 and 7B - Orders refusing film certification issued by Regional Officer without valid delegation of powers - Appellant challenged the orders citing lack of jurisdiction as the Board and not the Regional Officer is the competent authority to sanction or refuse exhibition of films - Court found that prior to the notification dated 29.08.2026 there was no valid delegation of powers under Section 7B to the Regional Officer to refuse certification - Held - Impugned orders passed by an authority lacking competence were void and subsequently withdrawn by the respondents - [Paras 1-7].

Administrative Law - Principles of Natural Justice - Cinematograph Act 1952 - Section 4 - Opportunity of hearing - Statutory mandate to provide applicant with an opportunity of hearing before refusing certification - Court directed that fresh consideration be afforded to the appellant along with the supply of reports and relevant records of the Committees except for the names of the members of the Committee - Held - Procedural fairness and transparency in the certification process are mandatory - [Paras 8-11].

Statutory Interpretation - Delegation of Powers - Cinematograph Act 1952 - Section 7B - Scope of delegation to Regional Officer - Held - Section 7B(2) authorizes Regional Officers only for the limited purpose of issuing provisional certificates and does not extend to the power of refusing to sanction a film for public exhibition under Section 4(2)(v) - [Para 4.1].

Decision: Appeal disposed of - Impugned orders dated 26.05.2026 and 14.07.2026 stand withdrawn - Competent authority directed to undertake fresh consideration of the application for certification in accordance with the Cinematograph Act, 1952 and the 2024 Rules after affording an opportunity of hearing to the appellant.

Civil Law - Landlord and Tenant - Provincial Small Cause Courts Act 1887 - Section 25 - Eviction - Defendants in possession as tenants executed an agreement to sell and claimed protection under Section 53-A of the Transfer of Property Act 1882 alleging part performance and change in the character of possession - Trial Court decreed eviction finding no evidence of surrender of tenancy - High Court upheld the decree holding that mere execution of an agreement to sell or payment of consideration does not automatically extinguish a pre-existing tenancy or convert possession into part performance unless a clear nexus and express surrender are established - Held - Revision dismissed - [Paras 29-56].

Civil Law - Tenancy - Transfer of Property Act 1882 - Section 111 - Determination of Lease - Doctrine of Part Performance - Whether possession of a tenant becomes referable to an agreement to sell - Held - A tenant continuing in possession after an agreement to sell does not automatically hold in part performance - The burden lies on the tenant to prove a change in the juridical basis of possession and an unequivocal intention of the parties to terminate the landlord-tenant relationship - [Paras 40-46].

Civil Law - Notice - Transfer of Property Act 1882 - Section 106 - Validity of notice - Inclusion of time-barred rent - Whether a notice determining tenancy is invalidated if it includes a demand for arrears partially barred by limitation - Held - The validity of a notice is to be judged by its substance and the clear intention to terminate the tenancy - Inclusion of time-barred arrears does not invalidate the notice or the determination of the lease - [Paras 64-73].

Evidence Law - Documentary Evidence - Indian Evidence Act 1872 - Section 92 - Proviso 4 - Variation of registered instruments - Held - Terms of a registered agreement cannot be displaced or varied by an subsequent unregistered or oral arrangement - Recitals in a registered agreement regarding delivery of possession prevail over a disputed unregistered possession letter - [Paras 58-60].

Decision: The revision is dismissed – The judgment and decree dated 14.05.2026 are affirmed – No order as to costs.

Civil Law - Compensation - Employees Compensation Act 1923 - Sections 3 and 4A - Deceased driver died during course of employment - Commissioner awarded compensation along with interest and 50% penalty against insurance company - Parties arrived at a consensus before High Court to fix income at Rs 8000 per month and reduce penalty to 20% - High Court held that insurance company is liable for compensation and interest but is not liable to pay penalty under Section 4-A(3)(b) of the Act - Liability for penalty rests solely upon the insured employer - Held - Award modified to fix total compensation at Rs 14,84,733 inclusive of reduced penalty payable by employer - [Paras 1-11].

Civil Law - Insurance Liability - Employees Compensation Act 1923 - Section 4-A(3)(b) - Penalty - Indemnity - Insurance company is liable to pay compensation and interest imposed on the employer but cannot be held liable for penalty imposed for delay under Section 4-A(3)(b) - Penalty is a personal liability of the insured employer - Held - Insurance company exonerated from penalty payment - [Paras 8-9].

Decision: Both appeals partly allowed – Award modified to Rs 14,84,733 – Insurance company to pay compensation and interest – Employer directed to pay 20% penalty amount of Rs 1,73,528 – Compensation apportioned between widow, son, and mother of the deceased.

Writ Law - Principles of Natural Justice - West Bengal Goods and Services Tax Act 2017 and Central Goods and Services Tax Act 2017 - Section 107 - Limitation and Procedural Fairness - Petitioner challenged adjudication order and appellate order dismissing appeal on limitation - Petitioner contended show cause notice and order were uploaded under Additional Notice and Orders tab without separate intimation - Court observed failure to intimate constitutes violation of natural justice as petitioner was unable to reply - Appellate authority dismissed appeal solely on limitation without considering merits - Held - Impugned appellate order quashed and set aside with directions to decide the appeal on merits after affording opportunity of hearing - [Paras 1-9].

Writ Law - Appellate Procedure - West Bengal Goods and Services Tax Act 2017 and Central Goods and Services Tax Act 2017 - Section 107 - Dismissal on limitation - Appellate authority failed to exercise discretion to consider merits where procedural deficiency regarding service of notice was evident - Court intervened to ensure justice - Held - Matter remanded to Appellate Authority for fresh adjudication on merits - [Paras 6-7].

Decision: Writ petition disposed of – Appellate order dated 28.01.2026 quashed – Respondent No. 3 directed to admit the appeal and decide the same on merits after providing a hearing within 12 weeks.