Criminal Law – Murder – Appeal Against Conviction  – Circumstantial Evidence – Last Seen Theory and Recovery of Bloodstained Articles – Conviction Set Aside - Appellant was convicted for murder of his foster daughter based solely on circumstantial evidence – Prosecution relied on last seen theory, recovery of bloodstained pant, and alleged improper motive – Court held last seen theory not proved due to lack of corroborative witnesses and uncertain timeline – Ownership of pant not established – No conclusive proof of motive or sexual assault – Chain of circumstances incomplete and failing the test in Sharad Birdhichand Sarda v. State of Maharashtra – Held: Prosecution failed to prove guilt beyond reasonable doubt, conviction unsustainable, appellant acquitted [Paras 14-24].

Bail – Jurisdiction of Magistrate – Offences under SC/ST Act and IPC Section 409 – Bail Order Set Aside - The learned Magistrate rejected remand of accused but also granted bail in offences triable by Sessions/Special Court including under SC/ST Act and Section 409 IPC – Held: Though rejection of remand was within discretion of Magistrate, granting bail was beyond jurisdiction – Victim not heard as required under Section 15A(3) SC/ST Act – High Court held Magistrate’s order granting bail without jurisdiction was legally unsustainable – Appeal partly allowed; remand rejection upheld, bail order set aside [Paras 6-13].

Quashing Proclamation Proceedings – Non-Compliance with Section 82 Cr.P.C. – Declaration of Proclaimed Person Quashed – The petitioner was declared proclaimed person in proceedings under Section 138 NI Act and consequent FIR under Section 174-A IPC was registered – Held: Trial Court erred in straightaway issuing proclamation without prior steps of summons or bailable warrants, and without recording satisfaction regarding absconding – Proclamation proceedings vitiated due to non-compliance with Section 82 Cr.P.C. – Impugned order and FIR quashed [Paras 1-3, 12].

Cognizance under Section 174-A IPC – Bar under Section 195 Cr.P.C. – Prosecution Unsustainable – The Court held that offences under Section 174-A IPC are governed by the bar under Section 195(1)(a)(i) Cr.P.C. – Cognizance requires a written complaint by the concerned public servant and cannot be initiated by police report – Registration of FIR without a complaint violates mandatory procedural law – Proceedings under Section 174-A IPC quashed [Paras 7-10].

Mandatory Procedure under Law – Adherence to Article 21 – Due Process Violated – The Court emphasized adherence to fair procedure as integral to personal liberty under Article 21 – When law prescribes a manner for action, deviation renders subsequent proceedings void – Directing initiation of criminal action without following the statutorily prescribed complaint procedure under Section 195 Cr.P.C. is illegal [Paras 11].

Decision – Petition Allowed – Order declaring petitioner proclaimed person, consequential FIR and all subsequent proceedings quashed – Trial Court directed to proceed in accordance with law, ensuring procedural compliance under Section 82 Cr.P.C. and Section 195 Cr.P.C. [Paras 14].

Criminal Law – Quashing of FIR – Allegations of Sexual Harassment and Intimidation – Petition Dismissed – Petitioner sought quashing of FIR under Sections 354, 354A, 506 IPC, alleging false implication by his niece-in-law – The Court noted that FIR disclosed specific acts of molestation and intimidation occurring over a sustained period – Held: Allegations, if taken at face value, prima facie disclosed commission of cognizable offences – Mere absence of such claims in parallel proceedings or assertions of malafide cannot justify quashing at preliminary stage – Petition dismissed [Paras 2–13].

Criminal Law - Motor Vehicle Accident – Rash and Negligent Driving – Sections 279 and 304(A) IPC – Conviction Set Aside – The accused was convicted by the Trial Court and the same was upheld by the First Appellate Court for allegedly causing death by rash and negligent driving – Held: Prosecution failed to establish rashness or negligence beyond reasonable doubt – Sole eyewitness PW-1 found to be unreliable, with contradictory testimony and no corroboration from other witnesses – Postmortem report indicated presence of alcohol in deceased’s body – Benefit of doubt extended to accused – Conviction and sentence quashed [Paras 12–20].

Eyewitness Testimony – Reliability – PW-1's Presence at Scene Disbelieved – PW-1 claimed to be eyewitness but admitted visiting hospital on call from accused and signing documents at police station – Held: Testimony found doubtful and inconsistent – No other eyewitness supported the prosecution version – Spot mahazar not supported by credible firsthand account – Conviction cannot rest solely on untrustworthy evidence [Paras 13–14].

Speed and Rashness – Mere High Speed Not Equivalent to Rash Driving – Reference to Supreme Court Judgment in State of Karnataka v. Satish (1998) 8 SCC 493 – Held: No material on record showing actual speed or driving behaviour of accused to infer rashness – High speed, without context, not enough to establish offence under Section 279 IPC [Paras 15–17].

Foreseeability and Contributory Negligence – Influence of Alcohol on Deceased – Postmortem showed strong traces of alcohol in deceased – Held: Prosecution failed to show foreseeability or breach of duty by accused – In absence of clear proximate cause linking accused’s conduct to the fatal accident, conviction unsustainable [Paras 18–19].

Final Decision – Acquittal Ordered – Revision allowed – Conviction and sentence by Trial and Appellate Courts set aside – Fine, if paid, to be refunded [Para 20].

Sports Law – Anti-Doping Violation – Suspension Quashed – Petitioner, a national-level basketball player, challenged orders of provisional suspension, notice of charge, and penalty of 4-year ineligibility for anti-doping violation under Articles 2.1 and 2.2 of the National Anti-Doping Rules, 2021 – Urine sample tested positive for 19-norandrosterone (19-NA), a non-specified anabolic steroid – Petitioner claimed substance entered his system via regular consumption of pork, especially meat from non-castrated male pigs – Evidence included purchase bills, affidavits from meat suppliers, and expert scientific opinions – Disciplinary and Appellate Panels failed to consider this evidence or allow Pharmacokinetics testing as suggested by Petitioner – Held: There was a clear breach of procedural fairness and statutory requirements under Sections 21 and 22 of the National Anti-Doping Act, 2022 – Orders were vitiated due to non-application of mind and failure to address cogent scientific defence – Writ Petition allowed [Paras 2, 4, 5, 6, 15.5, 15.6, 15.7, 16, 17, 18, 20, 21].

Procedural Fairness – Non-Consideration of Vital Defence Evidence – Petitioner submitted scientific studies, affidavits from experts, and biochemical rationale supporting the dietary origin of 19-NA – Disciplinary Panel ruled the violation as intentional without meaningful engagement with the evidence – Appellate Panel mechanically upheld the finding – Court held both Panels failed to discharge obligations under Section 22(8) of the Act which mandates fair hearing and reasoned orders – Ignored pharmacokinetic testing route despite indicating its relevance – Violation of principles of natural justice – Orders unsustainable [Paras 15.5, 15.6, 15.7, 16, 17, 18].

Sample Handling – Breach of Integrity and Testing Protocol – Sample opened, resealed, and transported to foreign lab without documented adherence to WADA Code and Section 21 of the Act – Petitioner not informed about initial test report from National Laboratory – Result Management obligations under Section 21 and Article 6.4 of WADA Code breached – Findings based on unverified processes cannot form basis of punitive action [Paras 15, 16].

Strict Liability Principle – Limits and Safeguards – Though anti-doping law operates on strict liability, Court emphasized that procedural safeguards and fairness remain indispensable – Ignominy suffered by athletes under presumption of guilt mandates punctilious adherence to rules and reasoned evaluation – Failure to do so can nullify strict liability outcomes [Paras 17, 18, 19].

Decision: Writ Petition allowed – Orders of Disciplinary Panel (11-10-2022) and Appellate Panel (16-04-2024) quashed – Petitioner reinstated – Held: Disciplinary proceedings lacked statutory and procedural compliance – No remand due to lapse of time and substantial period of penalty already elapsed [Paras 20, 21].

Civil Procedure – Caveat and Right to Hearing – Section 148-A CPC – Violation of Mandatory Notice Requirement – Ad interim injunction set aside - The Trial Court granted an ad interim injunction in favour of the plaintiffs without serving prior notice on the caveator (a trustee of the proforma defendant trust) – Held: The mandatory requirement of notice under Section 148-A(3) CPC was violated – A caveat, even if lodged by a trustee in personal capacity without specific authority, suffices for notice – The caveat squarely covered the subject matter of the suit, and urgency could not be invoked to bypass due process [Paras 23–34].

Trust Management – Section 92 CPC – Applicability Disputed – Dispute Concerns Academic Institute, Not Trust Per Se – Trial Court’s Jurisdiction Queried – The appellants argued that the core dispute was regarding the academic institution and not the trust’s administration – However, Court held it unnecessary to address this due to jurisdictional error from failure to serve caveat notice [Paras 8–9, 41].

Decision: Ad Interim Relief in Violation of Procedure – Order Without Jurisdiction – Appeal Allowed - Since ad interim relief was granted in breach of statutory caveat notice rights, the impugned order was held void for lack of jurisdiction – Appeal allowed without entering merits – Trial Court directed to reconsider the injunction application after hearing both sides [Paras 37–43].
 

Civil Law - Competing Wills – Registered vs. Unregistered – Suspicious Circumstances – Registered Will Upheld – Plaintiffs relied on registered Will dated 09.06.2000, proved through attesting witness and scribe's record – Defendant relied on unregistered Will dated 07.08.2004 – High Court held that propounder failed to explain suspicious circumstances including testator’s prior litigation with beneficiary and absence of mention of earlier Will – Registered Will stood duly proved; unregistered Will discarded [Paras 4–34].

Proof of Will – Attestation and Execution – Legal Requirement Satisfied – Will of 2000 held valid as one attesting witness deposed to its execution, contents explained to testator, and execution done in presence of both witnesses – Registration further bolstered its authenticity – Court found that requirement under Sections 63 of Succession Act and 68 of Evidence Act was met [Paras 11–21].

Suspicious Circumstances – Unexplained Presence of Beneficiary – Lack of Known Scribe – History of Litigation – Will Disbelieved – Will of 2004 was held invalid due to serious doubts: scribe’s identity unknown, both attesting witnesses knew beneficiary but not testator, and long-standing adversarial litigation between testator and beneficiary – No explanation for not registering subsequent Will, weakening its credibility [Paras 22–34].

Mutation Orders – No Evidentiary Value – Revenue Authority Findings Not Binding – Appellate Court wrongly relied on mutation sanction based on disputed Will – Court reiterated that mutation proceedings are administrative and cannot determine validity of testamentary documents [Para 35].

Admissions and Burden of Proof – No Binding Admission by Plaintiff – Pleading Suspicion Not Mandatory Where Apparent – Respondent’s claim that plaintiff admitted 2004 Will rejected as misreading – Even absent specific pleading, court may evaluate suspicious circumstances if they are facially evident and serious [Paras 36–42].

Decision – Appeal Allowed – Trial Court’s decree restored – Appellate Court’s judgment set aside – Will dated 09.06.2000 accepted as genuine; suit decreed in favour of appellants – No costs awarded [Paras 43–44].
 

Guardianship – Custody of Minor – Welfare of Child Paramount – Declaration of Guardian – The Court held that despite the natural guardianship rights of grandparents, the welfare of the minor remains paramount – The Court found that Master Yohan had developed a strong emotional bond with Respondent, his deceased father’s fiancée, who had cared for him since 2021 – Held: Respondent declared guardian subject to conditions ensuring continued contact with biological grandparents and counseling support [Paras 35-50].

Interim Custody – Guardianship Orders – Access Rights – Though guardianship was given to the Respondent, the Court ensured that Petitioners (grandparents and aunt) would have regular visitation rights, including spending vacation time with the minor, balancing emotional welfare and family bonds [Paras 50-52].

Financial Stability vs Welfare – Financial Means Not Sole Criterion – Despite Petitioners having better financial standing, the Court prioritized emotional well-being and the bond shared between the minor and the Respondent – Held: Financial affluence alone does not decide custody when the child's welfare is better served otherwise [Paras 43-45].

Counseling – Emotional Stability of Minor – Need for Therapy – The Court mandated ongoing counseling sessions for Master Yohan with family participation to ensure emotional stability and gradual bonding with biological family members [Paras 49-50].

Decision – Guardianship Petition No. 2 of 2024 allowed – Guardianship Petitions No. 1 and 13 of 2024 dismissed – Respondent declared Guardian of XXX with conditions relating to access and counseling [Para 52].