Criminal Law - Challenge Rejection of Sanction for Prosecution – Scope of Section 197 CrPC – Requirement of Sanction – Dismissal Upheld - Petitioner, a police officer, sought protection under Section 197 CrPC contending that criminal prosecution without prior sanction was impermissible – Court held that sanction protection is available only for acts reasonably connected with discharge of official duties – Alleged actions of unlawful entry, assault and caste-based abuses by the petitioner were held unconnected with official duties – Therefore, no prior sanction was necessary [Paras 5-6, 12, 14-15, 20].

Nature of Official Duty – Test for Reasonable Connection – Judicial Interpretation – No Protection - Court reiterated that the act must have a direct and reasonable nexus with official duties and not be a mere cloak for wrongful actions – Held: Merely being a public servant does not shield one from prosecution for private or unlawful acts unrelated to official functions [Paras 6, 11, 14, 16].

Stage for Considering Sanction – During or After Trial – Opportunity to Defense - It was clarified that question of sanction can arise at various stages of trial, but in the present case, the facts did not warrant such protection even at the initial stage – Hence, the trial court’s dismissal of application under Section 197 CrPC was proper [Paras 15, 20].

Decision – Revision Petition Dismissed – No Illegality Found - Held: Trial court rightly rejected the application under Section 197(2) CrPC – No merit in the revision petition – Dismissed along with stay application [Para 21].
 

Civil Law - Specific Performance – Oral and Written Agreement – Burden of Proof – Dismissal of Suit – The appellant sought specific performance based on an oral agreement and a subsequent written agreement dated 30.08.2000 – The Trial Court found that the oral agreement was not proved due to lack of corroborative evidence and the diary produced (Ex.P/1) lacked evidentiary value – Held: Oral agreement could not be established solely by entries without supporting testimony or documents [Paras 22-25].

Execution of Written Agreement – Authority to Execute – Invalidity of Power of Attorney – The written agreement was executed by one Trilok Singh purportedly on behalf of others under a power of attorney, two of the executors having predeceased the agreement – Held: Agreement executed on behalf of deceased persons invalid – No enforceable contract established [Paras 26-28].

Readiness and Willingness – Financial Incapacity – Specific Performance Denied – The appellant failed to demonstrate continuous readiness and willingness, critical for specific performance – Admissions regarding financial incapacity and inability to pay court fees were decisive – Held: Plaintiff failed to establish readiness and willingness as required under Section 16(c) of the Specific Relief Act, 1963 [Paras 29-31].

Possession and Adverse Possession Claim – Documentary Evidence – Claim Rejected – The appellant’s possession was not proved through revenue records – Orders of the Tehsildar and SDO dismissed the claim of possession – Held: Mere physical occupation without legal right or acknowledgment by authorities does not confer ownership or protect possession [Paras 32-34].

Application for Additional Evidence – Order 41 Rule 27 CPC – Dismissal – Documents produced at appellate stage (electricity bills, Nagar Palika receipts, etc.) were rejected for not being newly discovered evidence and irrelevant to pronouncement of judgment – Held: No grounds made for admitting additional evidence under Order 41 Rule 27 CPC [Paras 18-21].

Decision – Appeal Dismissed – Trial Court’s findings affirmed – The appellant failed to prove oral or written agreement, possession, readiness and willingness; thus, no interference warranted with Trial Court judgment [Paras 37-38].
 

Criminal Law – Murder – Appeal Against Acquittal - Last Seen Evidence – Incomplete Chain – Circumstantial Weakness – Acquittal Upheld - The appellant-State challenged the acquittal of the accused on the basis of last seen evidence supported by PW-3 and PW-5 – Held: The last seen circumstance did not conclusively establish the presence of the accused with the deceased at the relevant time – The testimony lacked consistency and proximity – It could not form a complete chain to infer guilt [Paras 7-8].

Extra Judicial Confession – Testimony of PW-15 Unreliable – Confession Disbelieved - PW-15 Hariram’s account of the accused's confession was found unconvincing due to lack of relationship with the accused, delay in reporting, and absence of corroborating official evidence – Held: Such a confession, introduced late without investigation under Section 161 Cr.P.C., could not be relied upon to reverse the acquittal [Paras 8-9].

Disclosure Under Section 27 Evidence Act – Site Already Known – Confession Ineffectual – The site of the alleged offence was already inspected by police prior to accused's disclosure – Held: The alleged recovery based on accused’s statement under Section 27 had no evidentiary value, weakening the prosecution’s narrative [Para 7(ii)].

Motive and Recovery – Absence of Mens Rea and Material Evidence – Conviction Unsustainable - The prosecution failed to establish motive, recover the weapon, or present bloodstained clothes – Held: In a case relying solely on circumstantial evidence, the absence of these elements was fatal – Benefit of doubt rightly granted [Paras 9-10].

Circumstantial Evidence – Incomplete Chain – Acquittal Justified - The court reiterated that the chain of evidence must be conclusive and rule out every other hypothesis – Held: Incomplete chain and absence of direct evidence justified acquittal in light of precedents including Sharad Birdhichand Sarda and Jabir v. State of Uttarakhand [Paras 11-14].

Appeal Against Acquittal – Interference Limited – Alternate View Plausible – Acquittal Maintained - Following H.D. Sundara case, the High Court held that where an alternate view is plausible and the trial court's view is reasonable, appellate interference is unwarranted – Held: No perversity in the trial court judgment – Appeal dismissed [Paras 15-17].
 

Criminal Law - Sanction for Prosecution – Cognizance under Section 120-B IPC in Absence of PC Act Sanction – Cognizance Set Aside – Petitioner, a public servant, was summoned for conspiracy to commit offence under Section 7 of the PC Act despite competent authority declining sanction under Section 19 – Court held that where the object of the alleged conspiracy is an offence under the PC Act, and no other IPC offence is alleged, prosecution under Section 120-B IPC alone is legally impermissible – Held: Prosecution for conspiracy cannot survive independently where the underlying act is barred from trial due to denial of sanction under the PC Act – Summoning order quashed [Paras 13-31].

Bail – Rape – POCSO Act - DNA Report – Admissibility at Bail Stage – Interim Assessment - DNA evidence considered as opinion evidence which requires proof in trial – Delay in analysis and questions regarding sample collection and testing procedures raised doubt – Held: DNA report cannot be treated as conclusive proof at bail stage and bail granted considering long incarceration [Paras 7.1, 7.3, 18-25].

Presumption under POCSO Act – Section 29 – Scope and Limitation – Presumption under Section 29 not absolute and comes into play only upon foundational facts being established – Prima facie inconsistencies in prosecutrix’s version noted, undermining foundation for presumption – Held: Bail granted, presumption under Section 29 not mechanically applicable [Paras 15-17].

Delay in Lodging FIR – Effect – FIR lodged after significant delay – Court recognized that delay alone not fatal in sexual assault cases involving minors – However, discrepancy in facts and circumstances undermined credibility of prosecution’s case at bail stage [Paras 10-11, 14].

Long Incarceration – Pending Trial – Relevance – Applicant incarcerated for over 2 years and 8 months with no certainty of trial commencement – Held: Prolonged pre-trial detention considered a valid ground for grant of bail [Paras 12-13, 25].

Decision – Bail Granted – Court directed release of Applicant on bail with conditions to ensure non-tampering of evidence and non-contact with victim – Observations made limited to bail and shall not affect trial merits [Paras 26-29].

Civil Writ - Judicial Review – Answer Keys in Competitive Exams – Limited Interference Permissible – The Court reaffirmed the settled legal principles from Ran Vijay Singh and Shubham Pal cases, holding that Courts should exercise restraint and interfere only when answer keys are palpably and demonstrably wrong – Judicial review is not excluded entirely, but limited to rare and exceptional cases where injustice is apparent without inferential reasoning [Paras 5, 10-13].

Out of Syllabus Questions – Legal Reasoning Section – Question Declared Invalid – The Court held that Question No.77 referencing a minor's competence to contract was out of syllabus for requiring prior legal knowledge, contrary to CLAT's declared policy – Question was directed to be treated as withdrawn and excluded from evaluation [Paras 21-23].

Incorrect Answer Key – Admission of Error by Consortium – Benefit Granted – For Questions 115 and 116, the Consortium admitted error in the final key and cross-referencing between sets – The Court directed full marks to be awarded to candidates across all affected sets (B, C, D) regardless of whether the question was attempted or answered correctly [Paras 44-46].

Belated Objections – Not Entertained – Objections raised after the prescribed window without prior challenge were rejected, citing Salil Maheshwari – Held: Litigants cannot raise objections post-result declaration if they failed to utilize the official objection window [Paras 9-10, 27, 29].

Question with Multiple Plausible Answers – Court Deference to Oversight Committee – Where split expert opinion existed (e.g., Questions 91 & 93), the Court upheld the Oversight Committee's resolution favoring the view most supported by the passage – Held: Courts should not substitute their views for those of subject matter experts in ambiguous academic questions [Paras 33-39].

Decision – Answer Key Partially Modified – Revaluation Directed – Final direction to revise marksheets and republish the list of selected candidates within four weeks – Candidates who attempted the affected questions to be evaluated per modified answers or granted full marks where applicable – All connected petitions and appeals disposed of accordingly [Paras 48-49].
 

Criminal Law – Murder - Circumstantial Evidence – Standards for Conviction – Chain of Circumstances Incomplete – Conviction Set Aside - In a case resting on circumstantial evidence, the prosecution must establish all circumstances conclusively and exclude any hypothesis consistent with the innocence of the accused – The prosecution failed to establish the identity of the deceased and failed to prove that the accused was last seen with the deceased – Therefore, benefit of doubt granted and conviction set aside [Paras 3-5, 8-14].

Burden of Proof – Section 106 of Evidence Act – Applicability – Prosecution Must First Establish Complete Chain - The prosecution cannot rely on the failure of the accused to explain facts within his special knowledge unless it first establishes a prima facie case beyond reasonable doubt – Here, failure to prove the basic facts rendered Section 106 inapplicable – Failure of accused to explain absence from the flat not fatal [Paras 17-19].

Motive – Absence of Proof of Pending Cases – Failure of Prosecution - Alleged motive that accused wanted to fake death to escape trial was not established by producing evidence of pending cases – No investigation against others possibly involved – Weak prosecution conduct noted [Paras 21-22].

Role of Prosecutor – Duty to Conduct Prosecution Diligently – Criticism of Casual Approach - The Court criticized the prosecution for failure to bring crucial evidence on record and for casual conduct during trial – Directions issued to Director of Prosecution for taking note against erring prosecutor [Paras 22-25].

Decision – Appeal Allowed – Conviction and Sentence Quashed – Appellant Acquitted - The Court acquitted the appellant giving him benefit of doubt as prosecution failed to prove guilt beyond reasonable doubt and directed his immediate release if not required in any other case [Paras 23-24].

Criminal Law - Rape – Mentally Retarded Victim – Conviction Confirmed – Appellant convicted under Section 376(2)(j)(i) IPC for rape of mentally challenged girl aged around 18–20 years, who had the mental capacity of a 4-year-old – Conviction based on direct eyewitness account (P.W.1 – aunt), corroborated by medical evidence and testimony of special educators and doctors – Held: Victim was incapable of consenting, and prosecution proved penetrative sexual assault beyond doubt [Paras 3–7].

Minimum Sentence – Amendment Not Retrospective – Sentence Modified – Trial Court sentenced appellant to 10 years based on amended minimum punishment under Act 22 of 2018 – Held: Offence occurred on 26.05.2015, amendment effective only from 21.04.2018 – Court modifies sentence to 7 years rigorous imprisonment and reduces fine from ₹50,000 to ₹5,000 [Paras 8–9].

Medical and Expert Evidence – Victim’s Mental Condition Proven – Doctor (P.W.7), Special School Teacher (P.W.5), and expert witnesses (C.W.1 & C.W.2 from Institute of Mental Health) confirmed victim had low IQ and mental maturity of 4-year-old – Forensic and medical reports corroborated prosecution case – Appellant’s sexual potency was also confirmed (P.W.6) [Paras 3, 7].

Defence Version – False Implication Plea Rejected – Appellant alleged animosity due to prior refusal to offer food on credit – Held: No evidence to support false implication – P.W.1 witnessed the act, appellant fled the scene, and was seen by hotel owner (P.W.2) – Allegation of prejudice by trial court unfounded [Paras 4–5, 7].

Final Decision – Conviction Upheld, Sentence Modified – Criminal Appeal partly allowed – Sentence reduced from 10 years to 7 years R.I. and fine reduced to ₹5,000 [Para 10].

Patent Law – Challenge to Section 53 Patents Act – Appeal Dismissed – Petitioners sought to declare Section 53 unconstitutional for counting patent term from application date despite delays in grant – High Court upheld that Section 53 and Section 11A(7) operate in distinct domains – Section 53 governs term and cessation; Section 11A(7) confers provisional rights without full enforceability until patent is granted [Paras 12–24].

Delay in Grant – No Violation of Constitutional Rights – No Ground for Striking Down Provision – The delay of 7 years in granting the patent, though regrettable, was held not to invalidate the statutory scheme – Representation seeking legislative amendment or compensation was found beyond judicial remit under Article 226 [Paras 6–11, 23–27].

Pre-grant Rights and Enforcement – Limited Scope – Interim Protection Only – Section 11A(7) provides limited privileges but bars infringement proceedings before patent grant – Court reaffirmed statutory rights in patent law are distinct from common law and are enforceable only post-grant [Paras 13–16, 24].

Judicial Review of Legislative Policy – Separation of Powers – Rejected – Court held it cannot direct Parliament to amend legislation or restructure statutory timelines – Reliance on comparative models like the US Patent Term Adjustment (PTA) was held inapplicable in Indian context, as affirmed by expert committee in Nittoo Denko case [Paras 25–26].

Final Decision – Appeal Dismissed – Writ Dismissal Affirmed – No conflict found between Sections 53 and 11A(7) – Appellants directed to bear their own costs – Request for certified copy allowed [Paras 27–30].