Dowry Death – Requirements Under Section 304B IPC – Conviction Reversed - The appellants contended that there was insufficient evidence of dowry-related harassment immediately before the deceased’s death, disputing claims of cruelty or dowry demand. The court examined evidence including witness testimony and circumstantial factors – Held: There was no concrete evidence proving sustained dowry-related cruelty or that dowry demands immediately preceded the deceased’s death. Statutory presumption under Section 113(B) of the Evidence Act could not apply due to lack of proximate evidence of harassment. The conviction was thus reversed, granting appellants the benefit of the doubt [Paras 12-16, 20].

Assessment of Evidence – Burden of Proof and Presumption of Innocence - The court underscored that the prosecution must prove dowry-related cruelty beyond reasonable doubt, with consistent testimonial support. Here, the primary witness did not establish dowry demand on the incident day, weakening the link between dowry harassment and the fatal outcome. Reinforced: The benefit of doubt is applied where evidence does not conclusively demonstrate a proximate link between alleged cruelty and the death [Paras 17-19].

Decision - The appeal was allowed, the conviction and sentence under Section 304B IPC were set aside, and the appellants were acquitted. Shashi Kala Devi’s bail bond was discharged [Para 21].
 

Defamation Law - Locus Standi of Complainant - "Person Aggrieved" Requirement under Section 199 of Cr.P.C. – The petitioner, the current Speaker of the Tamil Nadu Legislative Assembly, challenged a defamation complaint filed by a member of the AIADMK party. The Court emphasized that defamation complaints under Section 199 require that the complainant be the "person aggrieved" or explicitly authorized to act on behalf of an aggrieved party. Here, the Court held that the respondent lacked standing, as he neither suffered personal injury from the alleged defamatory statements nor acted with formal authorization from AIADMK [Paras 2, 8, 19, 24].

Interpretation of "Some Person Aggrieved" in Defamation Cases - AIADMK Membership Not Sufficient for Filing Complaint – Referring to Subramanian Swamy v. Union of India, the Court stated that "some person aggrieved" under Section 199(2) Cr.P.C. must directly connect to the defamatory remark or suffer tangible harm. Mere political affiliation with AIADMK did not confer the respondent with adequate standing to claim injury. Consequently, the complaint was quashed as the respondent failed to demonstrate any direct defamation against himself or hold authorization for representation [Paras 23, 25].

Impact of BNSS, 2023 on Proceedings Initiated Post-Enactment – The petitioner argued that the complaint was procedurally invalid under the repealed Cr.P.C., 1973. However, the Court clarified that, per Section 531(2)(a) of BNSS, 2023 and Section 4 of BNSS, actions for offenses occurring prior to 01/07/2024 are governed by the old Cr.P.C., ensuring continuity in legal remedies for rights or liabilities acquired under the previous code [Paras 14, 17].

Decision – Petition Allowed, Complaint Quashed – The Court quashed the defamation complaint, ruling that the respondent lacked standing, and reaffirmed the procedural validity of filing under the repealed Cr.P.C. for offenses committed before BNSS enactment. The Miscellaneous Petitions were also dismissed [Para 26].
 

Partition of Self-Acquired Property – Applicability of Rule Against Partial Partition – Partition Suit – Will of Late Smt. Abnash Kaur – Plaintiff sought partition based on the registered Will of late Smt. Abnash Kaur dated 06.02.1973, dividing her estate among six beneficiaries, each receiving a 1/6th share – Suit contested by Defendant No.1, who argued it constituted partial partition, contrary to law, citing Kenchegowda judgment – Held: Rule against partial partition applies primarily to joint family or coparcenary properties – As the suit property was self-acquired by Smt. Abnash Kaur and held by the parties as tenants-in-common, the rule of bar against partial partition was deemed inapplicable – Partition granted with conditions [Paras 69-82, 85-86, 161].

Will Execution – Validity and Proof Requirements – Plaintiff failed to prove the genuineness of Will of late Sh. Ajit Singh dated 21.07.1997 under Section 63 of the Indian Succession Act and Section 68 of the Evidence Act, as no issue was framed regarding the genuineness – No evidence led by the plaintiff despite the Court allowing defendants to dispute the will’s validity if evidence arose – Will deemed unproven in suit proceedings [Paras 89-92].

Necessary Parties – Non-impleadment Objections – Defendant Nos.1 and 2 raised objections concerning non-impleadment of other beneficiaries under the Will of late Sh. Ajit Singh – Supreme Court precedent in Shivshankara held that suits do not abate for non-impleadment if estate is substantially represented by other parties – Plaintiff adequately represented deceased Ajit Singh’s interest; objection of non-impleadment overruled [Paras 94-96].

Subrogation Rights – Mortgage Redemption – Defendant No.1 argued possession retention rights due to mortgage redemption as per Compromise Decree dated 20.02.1978 – Plaintiff countered this by claiming redemption was from the estate’s rental income – Held: Defendant No.1 entitled to retain possession until co-sharers pay contribution towards redemption amount; however, mortgage status does not entitle Defendant No.1 to exclusive ownership – Redemption deemed validly done by Defendant No.1 per compromise, with partition rights to plaintiff upon paying share of redemption [Paras 106-111, 121-122].

Termination of Lease – Sham Transaction Allegation – Plaintiff argued that the lease between late Smt. Abnash Kaur and Defendant No.1 was a sham, created to avoid tax liabilities and shield property from claims – Will and subsequent documents acknowledged lease as genuine, binding plaintiff – Plaintiff’s argument of termination based on lease amount was dismissed due to lack of supporting evidence and contradictory pleadings [Paras 144-155].

Limitation for Partition Suit – Plaintiff claimed partition of the suit property not barred by limitation – Citing Supreme Court precedents, Court reiterated that no limitation applies to partition suits, as partition is an incident attached to joint property rights – Plaintiff’s claim for partition sustained [Paras 135-140].

Declaratory and Injunctive Relief – Plaintiff sought declarations regarding ownership and an injunction against Defendant No.1 – Court held plaintiff entitled to permanent injunction as a co-sharer but denied declaratory reliefs, finding plaintiff’s claims unsubstantiated and contrary to pleadings on record [Paras 171, 173].

Decision: Partition granted with preliminary decree determining shares of parties in the suit property – Defendant No.1’s possession as subrogated mortgagee upheld pending payment by co-sharers of their redemption contributions – Declaratory reliefs denied; plaintiff entitled to injunctive relief as co-sharer – Suit disposed of accordingly [Paras 175-179].
 

Criminal Conspiracy – Standard of Proof – Acquittal of Accused – The prosecution’s case alleged a conspiracy to facilitate a jailbreak by smuggling explosive materials into Burail Jail. Witnesses turned hostile, key incriminatory evidence such as communication devices were unrecovered, and contradictions in arrest dates created doubt. Held: Prosecution failed to establish the conspiracy beyond a reasonable doubt, warranting acquittal for multiple co-accused [Paras 16-20, 47].

Burden of Proof – Applicability of Section 106, Evidence Act – Shifting Burden on Accused in Domestic Death Cases – Not Sustained - The trial court invoked Section 106 of the Evidence Act to shift the burden of proof onto the appellant, reasoning that he should explain the circumstances surrounding the death of his wife, who was in his custody. The High Court held this improper, noting that Section 106 cannot relieve the prosecution of its fundamental duty to establish guilt beyond a reasonable doubt. The prosecution must initially prove the appellant’s presence at the scene and last-seen circumstances to justify shifting any burden under Section 106. Here, lacking evidence of the appellant’s presence at the time of death, the High Court ruled Section 106 inapplicable, with no basis to impose a reverse burden on the appellant [Paras 1, 21-24, 29].

Alteration of Charges Post Examination – Section 302 IPC – Prejudicial Conduct – Right to Fair Defense - Initially charged under Sections 498-A, 304-B IPC, and Dowry Prohibition Act provisions, the trial court subsequently altered the charge to Section 302 IPC and convicted the appellant of murder without issuing proper notice. The High Court underscored that, while Section 216 CrPC permits charge alteration, it must be exercised without prejudicing the accused’s right to a fair defense. Failure to notify the appellant about the altered charge contravened fair trial principles and caused prejudice. Held: Conviction on an altered charge without due procedural notice was unsustainable and required reversal [Paras 27-31].

Wrongful Prosecution – Compensation for Unjust Incarceration – Lack of Statutory Framework - appellant endured 13 years of incarceration before being granted bail, highlighting the absence of compensatory mechanisms for wrongfully prosecuted individuals. The High Court lamented the lack of statutory provisions in India for compensation in wrongful prosecution cases, despite recommendations in the Law Commission’s 277th report advocating for reparation. While similar frameworks exist in other jurisdictions, India’s lack of such provisions conflicts with Article 21 protections. Observed: Legislative reform is urgently needed to provide statutory relief for victims of wrongful prosecution [Paras 45-51, 56-62].

Decision: The criminal appeal is allowed. The conviction under Sections 302 and 316 IPC is set aside, and the appellant is ordered to be released forthwith. The court emphasizes the urgent need for statutory frameworks to compensate victims of wrongful prosecution, consistent with constitutional safeguards under Articles 14 and 21.

Matrimonial Law – Divorce – Grounds of Cruelty – Long Separation – Held: Prolonged separation of 24 years with complete absence of reconciliation efforts constitutes mental cruelty under Section 13(1)(ia) of the Hindu Marriage Act, 1955 – The bitterness and irretrievable breakdown of the marriage fulfill the cruelty threshold – Divorce granted [Paras 26-29].

Desertion – Reasonable Cause – Burden of Proof – Held: The wife's claim of justified separation based on allegations of suspicion by the husband lacked corroborative evidence – Desertion by the wife without reasonable cause established – Judgment of trial court set aside [Paras 27-28].

Irretrievable Breakdown – De Facto Termination of Marriage – Held: While irretrievable breakdown is not a standalone ground for divorce under Indian law, it may be considered when coupled with long separation and cruelty – The Court dissolved the marriage recognizing its de facto termination [Paras 20-24].

Mental Cruelty – Evolution of Jurisprudence – Prolonged Separation as Cruelty – Held: Drawing from precedents, prolonged separation with absence of cohabitation and conjugal relations was held as an act of extreme mental cruelty, warranting dissolution of marriage [Paras 21-24].

Procedural Law – Burden of Proof – Preponderance of Probabilities – Held: The petitioner successfully established cruelty and desertion on a preponderance of probabilities – Trial court erred in requiring excessive corroboration [Para 15].

Decision: The appeal was allowed. The judgment of the Senior Civil Judge, Proddatur, dated 16.06.2010, dismissing the petition for divorce was set aside. The Court granted a decree of divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955, dissolving the marriage between the appellant and the respondent.
 

Banking Law - Fraud Classification - Principles of Natural Justice – The petitioner, Ratul Puri, sought quashing of the Bank of Baroda's decision to classify him as a "fraud" under the RBI's Master Directions on Frauds. The Court found that the classification without prior notice or opportunity for the petitioner to be heard was in violation of principles of natural justice. Held: Actions lacking in procedural fairness and natural justice are unsustainable [Paras 12-14, 20-22].

Legal Obligations of Banks under RBI Fraud Directions – Audi Alteram Partem – The Court reaffirmed that the doctrine of audi alteram partem applies even under RBI's Master Directions on Frauds. Serious consequences of fraud classification, such as credit denial and business restrictions, necessitate a fair hearing. Banks must provide borrowers with notice, an opportunity to respond to forensic audit findings, and reasoned decisions before classifying accounts as fraudulent [Paras 49, 62].

Reliance on Rajesh Aggarwal Case - Classification as Fraud and Civil Consequences – The Court referenced State Bank of India v. Rajesh Aggarwal and highlighted that the RBI’s Master Directions entail significant civil repercussions on individuals classified as "fraud," equating it to "civil death" in credit terms. Consequently, natural justice mandates procedural safeguards to prevent arbitrary exclusions from institutional finance [Paras 14, 49, 57, 62].

Decision – Petition Allowed – The impugned classification of the petitioner as “fraud” by Bank of Baroda was set aside due to procedural lapses in the application of natural justice. The Court directed Bank of Baroda to remove the petitioner’s “fraud” status from the Central Fraud Registry within 15 days, underscoring that no factual grounds warranted such classification [Para 14, 57, 62].
 

Service Law - Confidential Reports (CRs) – Standard for Judicial Review – Assessment Validity – The petitioner, an Army Brigadier, challenged adverse CRs that impacted his nomination for the National Defence College (NDC) and promotion to Major General – Held: Judicial review of CRs is permissible where objectivity or procedural fairness is compromised; the Tribunal's findings that assessments were consistent lacked scrutiny regarding evident subjectivity and procedural anomalies in the petitioner’s CRs [Paras 18-20, 34-40].

Confidential Reports – Expunction of Adverse Ratings – Objectivity and Consistency Standards – The petitioner alleged unjust downgrading in CRs from April–August 2009, July 2018–June 2019, and July 2020–February 2021 – Held: The expunction was warranted as the assessments by the Reviewing Officer (RO) in July 2018–June 2019 lacked correlation with recorded achievements, failing objective and consistent assessment standards; similarly, the expunction of the Initiating Officer's (IO) assessment in July 2020–February 2021 was arbitrary given alignment with prior positive assessments [Paras 41-45, 50-59].

Promotion and Nomination Eligibility – Impact of Confidential Report Assessments – Fair Consideration Ordered – Given that expunged adverse CRs had affected the petitioner’s ranking and eligibility for the NDC course and promotion, the Court directed reconsideration of his eligibility for these opportunities based on modified CRs [Paras 59-60].

Decision: The petition is partly allowed, expunging the adverse assessments in CRs for July 2018–June 2019 and July 2020–February 2021, and directing reconsideration of the petitioner’s eligibility for NDC and promotion to Major General.
 

Civil Law - Res Judicata – Applicability in Labour Disputes – Section 11, CPC – Second Reference Barred - The petitioner, terminated from employment through a contractor, filed a second reference with the Labour Court following the employer’s payment of differential wages under the Minimum Wages Act – The court held that the second reference was barred by res judicata as the issue of employment status was settled in an earlier reference in 2007, which went unchallenged by the petitioner – Held: Payment under Minimum Wages Act does not establish employment relationship with principal employer; the second reference is non-maintainable and dismissal of the petition was upheld [Paras 15-18].

Principle of Res Judicata – Labour Court’s Rulings Final When Unchallenged - The court reiterated that res judicata applies to Labour Court proceedings, as seen in the finality of the first reference decision on employment status – Allowing multiple references on the same cause of action would disrupt litigation finality and contradict the principle of res judicata, a doctrine that upholds litigation closure and judicial efficiency [Paras 16-18, 21].

Minimum Wages Act Payments – Limited Scope – Non-Implication for Employment Status - The petitioner argued that minimum wages payment inferred an employment relationship – The court clarified that differential wage payments do not alter employment status under the principal employer when work is performed through a contractor, nor do such payments imply regularization or nullify contractual limitations on employment [Para 19].

Decision – Petition Dismissed – The court upheld the Labour Court’s ruling, dismissing the second reference as barred by res judicata and affirming that payment of differential wages does not alter employment status with the principal employer.

Criminal Law - Interim Bail on Humanitarian Grounds - Medical Emergency of Family Member – The petitioner sought temporary bail, citing his wife’s critical need for spinal surgery requiring his assistance. The Court held that granting interim bail on such humanitarian grounds aligns with the fundamental rights under Article 21, which includes the right to family dignity and the marital duty of support. Bail was granted for 60 days to allow the petitioner to fulfill his role in her care [Paras 2, 8, 10, 11].

Risk Assessment - Non-flight Risk and Documentary Evidence – The Court found the petitioner to be a non-flight risk, with established family ties. Given that the evidence is mostly documentary and has been secured, there was minimal risk of tampering. These factors supported the decision to grant bail without compromising the prosecution's case [Paras 9, 10].

Article 21 - Right to Life and Dignity Extending to Marital Responsibilities – The Court emphasized that Article 21 extends to the right to live with dignity, which encompasses fulfilling marital vows and duties. The petitioner’s request for interim bail was thus acknowledged as part of his right to act as a supportive spouse in a time of medical need, which the Court deemed integral to human dignity [Para 10].

Decision – Petition Allowed with Conditions – The Court granted interim bail to the petitioner for a period of 60 days from the date of his release, with conditions that the petitioner is to surrender upon completion of the period. The order applies to all pending FIRs, and no insolvency certificate is required as part of the bail bond [Paras 11-14].