and Conciliation Act, 1996 – Section 5 of the Limitation Act – Appeal Dismissed – Appellant filed the present appeal with a delay of 85 days citing busy schedule and travel as reasons – Held: The expression "sufficient cause" under the Limitation Act is not elastic enough to cover long delays beyond the period prescribed for filing appeals under Section 37 – In commercial disputes governed by the Arbitration Act and the Commercial Courts Act, delay is to be condoned by way of exception and not by way of rule – Busy schedule and travel do not constitute sufficient cause – I.A. for condonation of delay dismissed [Paras 4, 5, 6, 7, 8].

Arbitration Law – Interpretation of Contract by Arbitral Tribunal – Scope of Interference under Section 34 – Share Purchase Agreement – Exit Option – Appellant invested Rs. 10 lakhs for 20% shareholding in the respondent company under an SPA dated 30.03.2020, with an option to exit at three and a half times the investment value at the end of five years – Appellant exercised the exit option on 01.08.2018, well beyond the stipulated period of 30.03.2015 – SPA was admittedly not renewed – Arbitral Tribunal held the exit option to be a qualified and not an absolute option, and that exercise of the option after expiry of five years and after expiry of the SPA was not valid – Held: Interpretation of the SPA by the Arbitral Tribunal is neither patently illegal nor perverse – Courts do not sit in appeal over arbitral awards – Merely because another interpretation is possible, it is not a ground to set aside the award [Paras 9, 12, 17, 18, 19, 20, 21].

Arbitration Law – Patent Illegality – Minimal Judicial Interference – Section 34(2-A) – Patent illegality must be illegality going to the root of the matter – Erroneous application of law or an interpretation which is merely less preferable does not constitute patent illegality – Courts cannot reappreciate evidence or substitute their view for that of the Arbitral Tribunal – Where a contractual provision is capable of more than one interpretation, the Court cannot interfere merely because another interpretation would have been better [Para 15].

Decision: Appeal dismissed both on the ground of being barred by limitation and on merits – I.A. No. 1/2023 for condonation of delay dismissed – All pending applications stand closed.

Railway Accident Compensation – Bona Fide Passenger – Burden of Proof – Section 124-A, Railways Act, 1989 – Appellant claimed compensation for amputation of both legs allegedly sustained when he fell from a passenger train near Red Fort on 20.06.2015 – Occurrence of untoward incident and nature of injuries established from contemporaneous MLC, DD entry No. 20A dated 20.06.2015 at Old Delhi and hospital record – Principal issue whether appellant was a bona fide passenger – Appellant relied on Monthly Season Ticket (MST) No. 11ZQB9P194 issued in the name of "Raju" – However, two other MSTs on record reflected the name "Raj Kumar" – Age recorded in MST (35 years) inconsistent with age in MLC, Aadhaar card, Election Commission identity card (age 38 years/25 years as on 01.01.2012), permanent disability certificate (28 years) and claim application (27 years) – Certificate of local MLA relied upon to establish same identity did not reconcile age discrepancy – Held: Inconsistency in name coupled with mismatch in age and absence of reliable explanation renders linkage between appellant and MST unreliable – Initial burden of establishing bona fide travel not discharged – Claim not sustainable – Appeal dismissed [Paras 7–10].

Railway Claims – Discrepancy in Documents – Evidentiary Value of Government Records – Government records prepared at first point of contact in the ordinary course carry significant evidentiary value – Where name recorded in MST differed across documents and age reflected therein was inconsistent with multiple official records, plea of incorrect recording at the time of MST issuance without any corroborative material or prior complaint of error cannot be accepted – Explanation of mistaken recording does not inspire confidence in absence of any request for correction to the issuing authority [Para 8].

Condonation of Delay – 922 Days – Beneficial Legislation – Railway Claims Tribunal Act – Liberal Approach – Delay of 922 days condoned taking into account appellant's economically weaker status, financial constraints preventing timely engagement of counsel, and prolonged medical treatment and rehabilitation on account of permanent disability – Railways Act, 1989 and Railway Claims Tribunal Act, 1987 arise out of beneficial and social welfare legislation – Liberal and justice-oriented approach required while considering condonation applications to prevent genuine claims from being defeated on technical grounds [Paras 1–7, CM Appl. 51620/2019].

Decision: Delay of 922 days condoned – Appeal on merits dismissed – Impugned judgment dated 17.02.2017 of the Railway Claims Tribunal, Principal Bench, Delhi in OA II(u) No. 195/2015 upheld [Paras 7–10, FAO].

Criminal Law – Murder – Circumstantial Evidence – Standard of Proof – Conviction under Section 302 read with Section 34 IPC challenged – Case resting entirely on circumstantial evidence with no independent eyewitness – For conviction based on circumstantial evidence, the circumstances must be fully established, consistent only with the hypothesis of guilt, of conclusive nature, and must exclude every hypothesis but the one proposed to be proved – Chain of evidence must be so complete as not to leave any reasonable ground for a conclusion consistent with the innocence of the accused – Trial Court convicted the appellant without enumerating the chain of circumstances – Held: Prosecution failed to prove guilt beyond reasonable doubt – Conviction set aside – Appellant acquitted [Paras 12–13, 30].

Last Seen Together – Singular Circumstance – Insufficient for Conviction – Appellant and co-accused last seen with deceased at 11.00 p.m. by PW 1 (mother) and PW 2 (brother) – Body found at 3.00–4.00 a.m. in injured condition – Wide time gap of approximately four hours between last seen and discovery of body – Possibility of third person intervening not ruled out – No evidence of events between 12 midnight and 3 a.m. connecting appellant to death – Last seen together is a singular piece of circumstantial evidence and does not by itself necessarily lead to inference that the accused committed the crime – Something more establishing connectivity between accused and crime is required – Mere non-explanation by accused cannot by itself lead to proof of guilt [Paras 19–23].

Eyewitness – Credibility – Got-up Witness – PW 3, watchman at Amrai and neighbour of deceased, claimed to have seen accused assaulting deceased with beer bottle at 12 midnight – Evidence of assault came by way of omission and not initial disclosure – PW 3 admitted he identified accused at the instance of police who told him these were the persons who assaulted – No TI Parade conducted – PW 3 went back to sleep after allegedly witnessing assault and made no attempt to inform the family or police – Conduct wholly unnatural – Witness found to be a got-up witness planted by prosecution – Evidence not inspiring confidence [Paras 20–21].

Motive – Not Conclusively Proved – Prosecution sought to establish motive through PW 1 and PW 2 deposing about quarrel between accused and deceased four to six months prior – No complaint was lodged about said quarrel – Investigating Officer admitted no evidence collected regarding prior quarrel – Deposition of PW 10 (police constable friend of deceased) about phone call at midnight at most shows quarrel ongoing but does not prove commission of murder – Motive in circumstantial evidence cases may create strong suspicion but suspicion however strong cannot be substitute for proof of guilt beyond reasonable doubt [Paras 24–25].

Recovery of Blood-Stained Clothes – Inconclusive – Chemical Analyser Report – PW 8 (panch witness) admitted in cross-examination that police did not show him the clothes and accused and had obtained signature on an already prepared panchnama – Chemical Analyser's report on blood grouping from clothes found inconclusive – No fingerprints found on beer bottles as per Fingerprint Expert report – Recovery of blood-stained stone also inconclusive – No forensic material connecting appellant to the crime [Paras 27, 21].

Call Detail Records – Corroborative Value Limited – CDRs proving three calls made by appellant to deceased after 10 p.m. on 26.05.2016 consistent with last seen theory – CDRs at most prove contact between appellant and deceased at around 11 p.m. – By themselves insufficient to connect appellant with the murder in the absence of other incriminating material [Para 26].

Decision: Appeal allowed – Conviction and sentence under Section 302 IPC recorded by Additional Sessions Judge, Pune vide judgment dated 18.12.2019 in Sessions Case No. 823/2016 quashed and set aside – Appellant acquitted – Appellant to be released forthwith if not required in any other case – Appellant directed to execute PR Bond of Rs. 25,000/- under Section 481 BNSS, 2023 for appearance in event of appeal against acquittal [Para 31].

Criminal Law – Murder – Culpable Homicide Not Amounting to Murder – Modification of Conviction – Appellants convicted by trial court under Section 302/34 IPC for killing deceased Jitaram Satnami with a plough yoke during a land dispute – High Court on reappraisal finding that the assault was not premeditated but arose suddenly upon seeing the deceased on disputed land intending to sow paddy seeds – Accused were not armed and used the yoke already tied to the plough – Held: Case falls under Exceptions (i) and (iv) to Section 299 IPC — conviction modified to Section 304 Part II IPC and sentence reduced to 7 years RI [Paras 14, 15, 16].

Eye-Witness Testimony – Credibility – P.W.1 (father-in-law of deceased and informant) and P.W.2 corroborated each other in material particulars regarding the assault — Cross-examination yielded nothing to discredit them — Minor contradictions between P.W.1 and P.W.2 (absence of reference to abuse in P.W.1's version) held to be immaterial and insufficient to demolish prosecution case — Held: Minor improvements and embellishments are not to be used to discredit other clinching evidence of occurrence [Paras 10, 11.3].

FIR – Validity – Scribe's Endorsement – FIR scribed in Odia though informant stated in Chhattisgarhi language — Scribe not examined — Held: Endorsement by scribe that contents were read over to informant who affixed LTI sufficient — No acceptable material to show scribe was not conversant with Chhattisgarhi — Doubt arising from presumption and speculation not tenable [Para 11.1].

Overt Act – Specific Attribution – Accused Lokanath – Argument that no witness specifically named Lokanath Satnami rejected — Both P.W.1 and P.W.2 first identified both accused in the dock and then described the assault — Specific overt act attributed to Lokanath including assault on right leg and subsequently on other parts of the deceased's body — Charge under Section 34 IPC also applicable [Para 11.6].

Abatement – Death of Co-Appellant – Appellant No. 1 Bhoka Satnami expired on 01.06.2015 during pendency of appeal — Appeal stood abated with regard to him by order dated 24.10.2025 — Remaining appeal proceeded against Appellant No. 2 Lokanath Satnami alone [Para 1].

Sentence – Reduction – Passage of Time – Occurrence took place 26 years prior to judgment — Ends of justice held to be best served by sentencing accused to 7 years RI with usual set-off in lieu of life imprisonment [Para 15].

Decision: Appeal allowed in part — Conviction under Section 302/34 IPC set aside — Conviction substituted with Section 304 Part II IPC — Sentence of life imprisonment modified to 7 years rigorous imprisonment with set-off — Bail bonds of appellant Lokanath Satnami cancelled — Appellant directed to be taken into custody forthwith to serve remaining sentence, if any.

Writ Jurisdiction – Clean Hands – Suppression of Material Facts – Petitioner sought mandamus directing demolition of constructions by Respondents 3 and 4 alleged to be encroachments on his property covered by sale deed – In course of proceedings, Thandaper account of petitioner's father in respect of the suit property stood cancelled by revenue authorities – Petitioner had not disclosed the cancellation of the Thandaper account and was found to be involved in other alleged land-grabbing activities in Devikulam Taluk – Held: Petitioner did not approach the Court with clean hands and had not disclosed full facts; equitable relief sought in writ petition not granted [Paras 15, 16].

Government Scheme – Constructions on Puramboke Land – Allotment under Life Mission and IAY PMRY Schemes – Respondents 3 and 4 constructed residential houses under the IAY PMRY Scheme and Life Mission Scheme on puramboke land to which no patta had been issued – Assignment applications of Respondent No. 3 pending with revenue authorities – Buildings below 1000 sq. ft. exempted from building permit requirement – Held: Whether houses can be allotted under Government schemes on puramboke lands is a matter requiring enquiry by the competent authorities; encroachments by petitioner as well as Respondents 3 and 4 on Government lands to be enquired into by District Collector [Paras 13, 14, 16].

District Collector – Duty to Enquire – Encroachment on Government Land – Court, upon finding that the encroachments committed by the petitioner as well as Respondents 3 and 4 on Government lands had not been adequately investigated, directed the District Collector, Idukki, to conduct a detailed enquiry regarding such encroachments and take appropriate decision in accordance with law after affording an opportunity of hearing, within three months from the date of receipt of the judgment [Para 16].

Decision: Writ petition disposed of – District Collector, Idukki, directed to conduct a detailed enquiry into encroachments, if any, committed by the petitioner as well as Respondents 3 and 4 on Government lands and take appropriate decision in accordance with law after hearing all parties, within three months from the date of receipt of the judgment [Para 16].

Motor Accident Claim — Negligence — Death of Pillion Rider — Appeal by Insurer Dismissed — The deceased, aged 38 years, working as Principal of Sri Chaitanya E-Techno School, Madhira, was travelling as pillion rider on a motorcycle when the offending lorry came from behind in a rash and negligent manner and hit the motorcycle, resulting in the instantaneous death of the deceased on 15.03.2012 — Crime No. 190 of 2012 was registered under Section 304-A IPC against the driver of the lorry — The Tribunal awarded a total compensation of Rs. 30,05,000/- with interest at 7.5% per annum, holding all respondents jointly and severally liable — Insurer challenged the award primarily contending that the accident occurred due to sole negligence of the deceased — Held: The insurer failed to examine the driver before the Tribunal and raised no challenge to the charge sheet before the competent Court — The absence of cross-examination of PW3 left the evidence of the deceased's salary of Rs. 30,000/- per month unrebutted — No illegality or infirmity found in the Tribunal's order [Paras 3, 10-11, 15-17].

Quantum of Compensation — Multiplier Method — Loss of Dependency — The Tribunal deducted 20% towards income tax and professional tax, arriving at net salary of Rs. 24,000/- per month, and further deducted 1/3rd towards personal expenses, computing net annual contribution to the family at Rs. 1,92,000/- — Applying multiplier of 15 as per Sarla Verma, loss of dependency was assessed at Rs. 28,80,000/- — Rs. 1,00,000/- awarded towards loss of consortium to the widow as per Rajesh v. Rajbir Singh — Rs. 25,000/- towards funeral and transportation expenses — Total compensation: Rs. 30,05,000/- — Held: The Tribunal was legally correct in its approach and the award calls for no interference [Paras 13-14, 17].

Cross Objection — Enhancement — Dismissed as Infructuous — The claimants filed Cross Objection No. 42 of 2024 seeking enhancement of compensation — Since the main appeal by the insurer was dismissed upholding the Tribunal's award, no further order was called for on the Cross Objection and the same was dismissed [Paras 19-20].

Decision: M.A.C.M.A. No. 2037 of 2016 dismissed — Award of the Tribunal dated 30.12.2015 in M.V.O.P. No. 241 of 2013 upheld — Cross Objection No. 42 of 2024 dismissed as infructuous — No order as to costs — Interlocutory Applications, if any, stand closed.

Matrimonial Law – Mental Cruelty – Divorce – Section 13(1)(ia), Hindu Marriage Act – Pre-suit and Post-suit Cruelty – Decree of Divorce Affirmed – Marriage solemnised on 27.04.2005; wife left matrimonial home on 02.11.2009; husband instituted divorce suit on 15.01.2010; wife lodged criminal complaint on 05.02.2010 (three months after the alleged incident and 21 days after filing of divorce suit) – Trial Court decreed divorce on grounds of cruelty and irretrievable breakdown of marriage – On appeal, Division Bench found pre-suit cruelty established through evidence of PW-1 (husband) corroborated by PW-2 (elder brother, residing in matrimonial home), whose evidence remained substantially unshaken in cross-examination – Admissions of DW-3 (wife's mother) in cross-examination corroborated plaint allegations as to wife's stubborn nature, imposition of will on matrimonial family, and baseless character assassination of husband – Post-suit cruelty established through two criminal complaints (Asansol P.S. Case No. 31/2010 under Section 498A IPC; Asansol P.S. Case No. 15/2017 under Sections 403, 406 and 120B IPC) both culminating in acquittal on ground of no evidence – Husband detained for nine hours at police station after arrest from outside workplace on basis of baseless complaint – Cumulative conduct of wife held to constitute mental cruelty – Held: Decree of divorce on ground of cruelty affirmed; appeal dismissed [Paras 27–51, 65–67].

Evidence – Interested Witness – Elder Brother of Husband – PW-2, elder brother of respondent-husband residing in matrimonial home, corroborated PW-1's evidence in entirety – Appellant contended PW-2 was an interested witness – Held: Mere relationship with a party does not automatically render a witness interested or unreliable; PW-2's direct knowledge of events by virtue of residing in matrimonial home made him a competent and reliable witness – Evidence-in-chief of PW-1 and PW-2 remained substantially unshaken in cross-examination [Para 31, 32].

Evidence – Apparent Contradiction – "Difference of Opinion" vs. "Marital Dispute" – Husband stated at one place that differences arose from inception of marriage and at another that marital dispute arose 1–1½ years after marriage – Held: Qualitative distinction exists between "difference of opinion" from the date of marriage and "marital dispute" that crystallised about 1–1½ years thereafter; the two statements are not contradictory or mutually exclusive [Para 33].

Criminal Acquittal – Effect on Civil Proceedings – Mental Cruelty – Acquittal of husband in both criminal cases not on technical grounds but on finding of no evidence by the criminal court – Ratio of Chiranjeevi v. Smt. Lavanya (where acquittal was for failure to prove beyond reasonable doubt, not for no evidence) held inapplicable – Rani Narasimha Sastry v. Rani Suneela Rani, (2020) 18 SCC 247 applied: husband undergoing trial on wife's complaint and being acquitted for lack of evidence itself constitutes cruelty perpetrated by the wife – Followed also in Poulomi Biswas v. Shamik Biswas (coordinate Bench of this Court) [Paras 41–46].

Irretrievable Breakdown of Marriage – Ground for Divorce – Section 13(1)(ia), Hindu Marriage Act – Article 141, Constitution of India – Parties separated since November 2009; no resumption of conjugal life; no animus revertendi on part of wife; son of parties attained majority – Held: Irretrievable breakdown of marriage, though not an independent statutory ground of divorce, falls within the ambit of cruelty under Section 13(1)(ia) of the Hindu Marriage Act [Paras 52–58].

Permanent Alimony – Section 25, Hindu Marriage Act – Suo Motu Award – Scope – Appellant contended Trial Court ought to have granted permanent alimony suo motu at the time of passing the divorce decree – Held: Section 25(1) requires an application to be filed; affidavits-of-assets of both parties are to be filed and considered; no such application was filed by the appellant-wife either before the Trial Court or before the High Court at any stage – No court can suo motu pass an order of permanent alimony without a prayer therefor and supporting materials – Judgments in Rakhi Sadhukhan v. Raja Sadhukhan, 2025 SCC OnLine SC 1259 and M.V. Leelavathi v. Dr. C.R. Swamy, 2025 SCC OnLine SC 1724 distinguished: in both cases the Supreme Court acted under Article 142 and there had been adjudication of permanent alimony by the Trial Court – Held: Appellant at liberty to file a fresh application for permanent alimony before the competent civil court at any time subsequent to the decree, as expressly contemplated by Section 25(1) [Paras 60–64, 68].

Decision: Appeal dismissed on contest – Impugned judgment and decree dated 09.12.2021 of the learned Additional District Judge, Fourth Court at Asansol, District Paschim Bardhaman in Matrimonial Suit No. 40 of 2011, decreeing divorce in favour of respondent-husband affirmed – Appellant-wife granted liberty to file application for permanent alimony under Section 25, Hindu Marriage Act before the competent civil court – No order as to costs.

Constitutional Law – Promissory Estoppel – Legitimate Expectation – COVID-19 Lockdown – Chief Minister's Press Conference Assurance – Enforceability – Division Bench held that the Chief Minister's statement of 29.03.2020, assuring that the State would pay rent of migrant tenants unable to pay due to poverty during lockdown, was not enforceable by mandamus as it was never reduced to writing in any Office Memorandum, Notification, Circular, Rule, Regulation or other instrument having the force of law – Two distinct assurances identified: (i) proscription on landlords compelling migrant tenants to vacate, backed by DDMA Order No. 122-A (enforceable); (ii) State undertaking to pay migrants' rent (not enforceable, unsupported by any legal instrument) – Statement of Chief Minister made "in the heat of the moment" without prior assessment of financial implications – Held: A mere oral statement by the Chief Minister in a press conference, however eminent the source, does not constitute an enforceable "promise" in law; no mandamus can issue to compel performance of a duty not grounded in law – Directions of Single Judge modified accordingly [Paras 42–48, 61–72, 81–82].

Promissory Estoppel – Government Statements – Speech vs. Policy Decision – Distinction between pre-election and post-election statements of a politician recognised – However, even a statement by an elected Chief Minister on a public platform cannot be enforced by mandamus unless translated into a formal written instrument of State – Statement made in a press conference without any executive instruction, Rule, Regulation or other document having the force of law cannot constitute a "promise" for the purpose of promissory estoppel – Principle that promissory estoppel does not operate at the level of Government policy reiterated – Union of India v. Ganesh Rice Mills and State of Karnataka v. K.K. Mohandas applied; State of Punjab v. Nestle India Ltd. distinguished – Held: Even if citizens believed the statement to be legally binding, such belief cannot authorise the Court to issue mandamus in the absence of a legal duty [Paras 35–38, 46–72].

Legitimate Expectation – Doctrine – Scope and Limitations – Doctrine of legitimate expectation does not create a legal right; it creates at best an expectation that the State will act consistently, transparently and predictably – Doctrine can be invoked to ensure compliance with natural justice before the authority resiles from an established promise or practice, but cannot independently found a claim for substantive relief – Sivananda C.T. v. High Court of Kerala (Constitution Bench) followed: claimant must establish (i) legitimacy of the expectation and (ii) that denial violated Article 14 – Since no legally enforceable promise was held out in the first instance, doctrine of legitimate expectation cannot be invoked to bind the State to the press conference statement – Followed in State of U.P. v. Bhawana Mishra, 2026 SCC OnLine SC 37 [Paras 73–76].

Mandamus – Writ – Conditions for Issuance – A writ of mandamus can issue only to compel performance of a legal duty; it cannot be issued to direct the State to frame a policy – Asif Hameed v. State of J & K applied – DDMA Order No. 122-A proscribed landlords from evicting or collecting rent from migrant tenants during lockdown and was never challenged; landlords accordingly held disentitled from recovering rent for the lockdown period – However, no mandamus could issue directing the State to bear or reimburse such rent in the absence of any official instrument to that effect – State at liberty to take a policy decision on the matter voluntarily [Paras 53, 62, 71, 78–81].

Issue Estoppel – Maintainability – Division Bench of this Court in Gaurav Jain v. Union of India, 2020 SCC OnLine Del 652, referred to; maintainability of writ not re-agitated by State before Division Bench – Single Judge's finding on maintainability affirmed [Paras 10, 20].

Decision: Appeal disposed of – Directions of Single Judge modified – Prayer for mandamus directing State to implement the Chief Minister's press conference assurance of 29.03.2020 rejected – DDMA Order No. 122-A upheld: landlords disentitled from recovering rent from migrant tenants for the lockdown period – State at liberty to take a voluntary policy decision regarding the Chief Minister's rent assurance if it so deems appropriate – No orders as to costs.

Criminal Law - Matrimonial Cruelty – Section 498A IPC – Dowry Demand – Conviction Upheld – Petitioner No. 1, who married PW1 on 09.01.2000, along with his parents (Petitioners 2 and 3), subjected PW1 to physical and mental cruelty demanding more dowry, assaulted her while pregnant on 26.06.2000, and expelled her from the matrimonial home – Trial Court convicted all three petitioners under Section 498A read with Section 34 IPC and sentenced them to imprisonment till the rising of the Court with fines; Appellate Court confirmed – In revision, High Court found no ground to interfere with the concurrent findings – Held: Concurrent findings of guilt under Section 498A read with Section 34 IPC affirmed; revision petition dismissed [Paras 2, 3, 8].

Evidence – Credibility of Prosecutrix – Embellishments and Contradictions – Amicus Curiae and petitioners' counsel contended that the Trial Court had acknowledged embellishments, omissions, and contradictions in PW1's testimony, and had decided the matter on probabilities – Held: A casual remark in para 14 of the Trial Court judgment referring to "probabilising" PW1's version did not mean the case was decided on probabilities; minor embellishments and contradictions usual in matrimonial cruelty cases do not by themselves vitiate the prosecution case – Evidence of PW1 corroborated by PW2, PW3 (eye-witnesses to expulsion), and PW4 (father of complainant) [Paras 6, 7].

Revisional Jurisdiction – Scope – Concurrent Findings – Sentence – High Court reiterated that in exercise of revisional powers it is not permissible to unsettle concurrent findings of the courts below unless there is a manifest illegality or grave injustice – Sentence of imprisonment till rising of Court and fine (Rs. 50,000/- on Petitioner 1; Rs. 10,000/- each on Petitioners 2 and 3, with fine directed to be paid as compensation to PW1) held to be extremely lenient given that Section 498A IPC provides for imprisonment up to three years – No modification warranted [Para 8].

Amicus Curiae – Third Petitioner Deceased – Notice to Petitioners 1 and 2 duly served but they remained unrepresented – Notice to Petitioner 3 returned with endorsement "addressee is no more" – Adv. Ms. Nanda Surendran appointed as Amicus Curiae; original counsel also heard – Court placed on record its appreciation for the assistance rendered by the Amicus Curiae [Para 4, 5].

Decision: Criminal revision petition dismissed – Concurrent verdicts of conviction and sentence under Section 498A read with Section 34 IPC confirmed.