Criminal Law - SC/ST Act – Quashing - Caste-Based Assault Allegation – Conviction Set Aside on Compromise – Trial Court convicted appellants under multiple IPC and SC/ST Act provisions—Allegation of caste abuse and assault over a local altercation—Held: Appellants and de facto complainant now residing in same village peacefully—Court accepted voluntary compromise and invoked Section 482 CrPC to set aside conviction [Paras 1–3, 5–11, 14–15].

Criminal Procedure – Power Under Section 482 CrPC – Non-Heinous Private Offences – Reiterating Ramgopal and Ramawatar principles, Court held it can quash even post-conviction proceedings in non-heinous, private disputes to promote harmony—Held: Compromise was not the result of coercion—Discharge justified to maintain social peace [Paras 6–7, 13–14].

Evidentiary Assessment – Injury and Witness Reliability – Doubts Noted – Medical record showed shoulder dislocation without supporting x-ray—Key witnesses were family members—No public or independent witnesses examined despite alleged public assault—Held: Conviction based on weak and interested evidence; compromise is a just resolution [Paras 4–5, 10–11].

Community Harmony – SC/ST Act – Special Statute Not a Bar to Quash – Despite the SC/ST Act being a special statute, the Court held that it does not bar quashing under Section 482 CrPC when conditions of peaceful resolution and non-severity of offence are met—Held: Special law status no hindrance to compromise-based discharge [Para 14].

Decision – Conviction and sentence under Sections 147, 325 IPC r/w 149 and Sections 3(1)(s), 3(2)(va) of SC/ST Act set aside – Appellants discharged – Criminal appeal allowed – Connected petition closed [Paras 15–16].

Interest for Delayed Payment – Suit Maintainability – The appellant, a PWD contractor, filed a suit seeking interest for delayed payment of a bill amount for work completed. The trial court decreed interest at 18% per annum, which was reversed by the first appellate court. The High Court held that a suit for interest alone is maintainable under Section 3(1) of the Interest Act, 1978, and supported by the decision in Anirudhan v. Government of Kerala [1999 KHC 527] [Paras 1-7].

Accord and Satisfaction – Pleading Requirement – The respondents raised the plea of accord and satisfaction for the first time in the appellate stage. The court held that such a plea must be specifically pleaded in the written statement, and since it was not, it cannot be relied upon to deny the interest claim. The receipt of the final bill amount did not estop the appellant from claiming interest [Paras 12-20].

Decision: Appeal allowed. The judgment of the first appellate court was set aside, and the decree of the trial court granting interest at 18% per annum for the delayed payment was restored.

Criminal Law – Robbery – House Trespass – Threat – Conviction Sustained After 24 Years – Petitioners convicted under Sections 382, 454, and 506 IPC for armed robbery at commission agency office—Appeal dismissed in 2008 and revision pending since—Held: Conviction based on credible and corroborated eyewitness testimony; minor contradictions did not impair reliability—Conviction upheld [Paras 4–14].

Hostile Witness – Partial Support Valid – Evidentiary Value of PW-3 – Though PW-3 turned hostile regarding one co-accused, he corroborated the prosecution version against remaining petitioners—Held: Hostile status does not nullify admissible corroborative evidence supporting conviction [Paras 11, 14].

Delay in Trial – Sentence Modification – Long Pendency as Mitigating Factor – FIR registered in 2001, conviction in 2007, appeal dismissed in 2008, and revision disposed only in 2025—Petitioners already undergone substantial custody—Held: Sentence reduced to period undergone (approx. 9–10 months) with enhanced fine and compensation to complainant [Paras 15–16].

Section 506 IPC – Concurrent Sentencing – Enhancement of Fine – Petitioners directed to pay enhanced fines under all three charges—Out of total fine, ₹20,000 directed to be paid as compensation to complainant under CrPC—Sentences to run concurrently [Paras 15–16].

Decision – Criminal revision petition dismissed on merits – Conviction under Sections 382, 454, and 506 IPC upheld – Sentence reduced to period already undergone – Fine enhanced – Compensation awarded to victim – Petition qua Resham Singh abated due to death [Paras 3, 15–16].

Criminal Law - Anticipatory Bail – Conflicting Versions by Minor – FIR Under Section 376 IPC and Section 6 POCSO Act – Petitioner not named in initial FIR, which alleged rape by victim’s father—Later statement changed accusation to petitioner, a neighbourhood barber—Held: Considering conflicting versions of the victim and that petitioner joined investigation, custodial interrogation not required—Bail granted [Paras 1-4, 7-11, 13].

Forensic Evidence – DNA Inconclusive – No Corroboration of Allegation – FSL report found no male DNA on victim’s vaginal swab, smear or clothing—Medical and scientific evidence did not support prosecution’s case—Held: Lack of corroborative forensic evidence weighs in favour of granting anticipatory bail [Para 12].

Child Witness – Inconsistent Statements Under Section 164 CrPC – Impact on Bail – Victim initially accused father in FIR and medical narration—Subsequently implicated petitioner in new complaint—Contradiction in date of alleged incident (2022 winter vs. 02.09.2023)—Held: Discrepancies undermine credibility for pre-trial custody justification [Paras 5, 9-11].

Bail Principles – No Flight Risk – Cooperation with Investigation – Petitioner had already joined investigation—No likelihood of absconding or tampering with evidence—Held: Sufficient grounds for protection from arrest, subject to conditions [Para 13].

Decision – Bail application allowed – Petitioner granted anticipatory bail on furnishing personal bond of ₹30,000 with one surety—Directed not to contact or threaten victim or her family—To cooperate with IO as required [Paras 13-14].

Motor Accident Claim – Rash and Negligent Driving – Eyewitness Testimony Upheld – Appeal Partly Allowed – The deceased, a government employee, fell from a moving bus due to sudden braking – Insurance company challenged the finding of rash driving citing lack of independent witnesses – Court upheld the testimony of PW3, co-worker of the deceased, corroborated by FIR and Investigating Officer – No evidence rebutting the eyewitness's credibility – Onus duly discharged by claimants [Paras 3–7, 17].

Driving Licence Validity – Endorsement for Transport Vehicle – Plea Rejected – Insurance company argued that the driver held a 20-year licence in violation of statutory term – Court found from record (Ext.RW2/A) that endorsements were in place and licence validly renewed for transport vehicle – No objection taken during trial – Argument held misconceived and dismissed [Paras 11, 18–20].

Contributory Negligence – Not Pleaded or Proved – Claim Denied – Insurance company raised contributory negligence for first time on appeal – No such plea before MACT nor any evidence led – Court rejected the argument as unsustainable [Paras 9, 21].

Compensation Calculation – Age and Dependency Considered – Award Modified – MACT used age 50 based on postmortem; High Court corrected it to 55 as per Parivar Register (Ext.PW5/E) – Multiplier revised to 11 – Future prospects added @15% in terms of Pranay Sethi – Monthly income ₹12,829/-, with deductions and future prospects applied – Revised compensation: ₹13,28,220/- plus ₹40,000 loss of consortium each for 5 claimants [Paras 22–30].

Interest – Award Sustained – Interest @7.5% p.a. from date of petition upheld – No deduction for income tax applied due to income being below taxable limit [Paras 27, 32].

Decision – Award Modified – Reduced Total Compensation – Respondents No. 1 and 6 (wife and son) held entitled to ₹13,28,220/- plus ₹40,000 each for consortium – Other daughters entitled to consortium only – Oriental Insurance Company directed to pay entire amount by 31/07/2025 with interest – Appeal disposed of accordingly [Paras 30–33].

Civil Writ - Employment Law - Assistant Teacher Recruitment – Judicial Review of Answer Key – Limited Scope – Petitions Dismissed – Petitioners alleged erroneous evaluation and incorrect answers in ATRE-2018 and sought rectification – Held: Judicial review in academic matters is restricted to rare and exceptional cases with demonstrable, patent error – Courts must defer to the opinion of expert committees unless answers are clearly incorrect on the face of record – Majority of petitions dismissed for failure to meet qualifying marks even upon re-evaluation [Paras 2–6, 9–11, 12–13].

Evaluation Criteria – Minor Grammatical or Unit Errors – No Interference Where Substantive Answer is Incorrect – Petitioners contended that omission of units such as 'Rs.' or 'cm²' unfairly led to denial of marks – Held: Omission may be condonable in general language-based questions but not in scientific or mathematical subjects where units determine correctness – No relief where substantive answer failed evaluation standards [Paras 4, 5, 14–16].

Answer Key Disputes – Deference to Experts – Courts Not to Act as Academic Authorities – Petitioners questioned the correctness of several model answers – Held: As per law laid down by the Supreme Court, correctness of model answers certified by subject experts cannot be interfered with unless patently wrong – In absence of blatant error, Court declined to interfere [Paras 12–13].

Relief Limited to Potential Qualifiers – Cut-off Applied as Filter – Only those petitioners who, upon allowing their objections, could cross the qualifying marks (General: 67, SC: 60) were considered on merits – Rest of the petitions dismissed without detailed examination as academic exercise [Paras 9–11].

Re-evaluation Direction – Examination Authority to Verify Three Petitioners’ Claims – In three cases, petitioners potentially qualified upon rectification of answers – Held: Examination Regulatory Authority directed to re-examine answer scripts and update marks, subject to vacancy availability and verification [Para 16, Conclusion].

Civil Writ - Tender Process – Opening of Financial Bids – No Right to Pre-Award Disclosure – Petition Dismissed – Petitioner challenged opening of Cover-II (financial bids) without being informed of the outcome of its technical bid—Court held: Clauses 28.1 and 42.5 of ITB prohibit disclosure before award—Suppression of these clauses by Petitioner fatal—Held: No merit in claim; petition dismissed [Paras 1–3, 21–24].

Natural Justice – ITB Conditions Prevail – No Pre-Award Hearing Required – Though Petitioner invoked principles of fairness and transparency, Court held that having accepted ITB clauses, it cannot seek deviation—Right to reasons arises only post-award per clause 42.5—No violation of natural justice established [Paras 13, 22–23].

Procedural Suppression – Omission of ITB Clauses 28.1 and 42.5 – Petition Fails for Non-Disclosure – Petitioner relied on clauses 27.7 and 27.8 but omitted 28.1 and 42.5—Court found suppression deliberate and material—Cited K.D. Sharma v. SAIL to dismiss petition for lack of clean hands [Paras 16–18, 22].

Mega Infrastructure Projects – Judicial Interference Discouraged – Court emphasized significance of project and public impact of delays—Observed that evaluation time was reasonable given ₹8,000 crore scale—Held: Delay in bid opening unjustified where rights of Petitioner are protected post-award [Paras 19–20, 22(D)].

Post-Award Rights – Petitioner Free to Challenge Disqualification After Notification – Solicitor General assured Court that reasons for disqualification would be furnished—Court noted Petitioner can challenge both rejection and award subsequently—Preservation of electronic price bids directed [Paras 20, 25–26].

Decision – Writ Petition dismissed – Interim stay on bid opening lifted – MMRDA directed to preserve price bids for 2 weeks post award – No costs awarded [Paras 23–26].

Income Tax – Section 263 – Revisionary Jurisdiction – No Enquiry by AO – Appellant claimed 100% depreciation on leasehold improvements (interior works, partitions, etc.)—Assessing Officer allowed claim without examining nature or rate of depreciation—Held: As AO failed to conduct enquiry or apply mind to the issue, order was erroneous and prejudicial to revenue—CIT rightly invoked Section 263—Tribunal order upheld [Paras 1–6, 14–20].

Assessment Order – No Discussion on Depreciation Claim – Validity of 263 Action – Assessment order dated 29.10.2012 was silent on leasehold improvement depreciation—Authorized representative admitted during revision proceedings that no enquiry occurred—Held: Absence of reasoning or discussion in assessment implies non-application of mind—Sufficient ground for 263 revision [Paras 17–19].

Depreciation on Leasehold Improvements – Factual Inquiry Mandatory – Prior Tribunal Orders Not Binding – Appellant cited earlier favorable orders for AY 2000-01 & 2001-02—Held: Nature of expenditure differs yearly—Each AY must be independently examined—Past decisions not conclusive—100% depreciation not justified without scrutiny [Paras 10–11, 19–20].

Rectification under Section 154 – Not a Bar to 263 Revision – AO had initially issued rectification notice but accepted assessee’s reply and didn’t revise order—Held: Failure to revise under Section 154 does not imply enquiry was made—263 action remains valid where AO’s order is erroneous and prejudicial [Paras 5–6, 12–13].

Substantial Question of Law – No Arises – Concurrent Findings on Facts – High Court found no reason to interfere with concurrent findings of CIT and ITAT—Held: No substantial question of law arose—Appeal dismissed [Paras 21–22].

Decision – Appeal dismissed – Order of ITAT upholding Section 263 revision sustained – No costs awarded [Para 22].

Criminal Law - Bail – Murder - Section 302, 307, 120B, 109 of the IPC - Delay in Trial – Parity with Co-Accused – Bail Granted – The Petitioner, accused of shooting and killing one individual and attempting to murder another as part of a criminal conspiracy, had been in custody since 27.10.2018 – While a weapon allegedly used in the crime was recovered from the Petitioner and linked through ballistic examination, key evidence such as eyewitness identification failed in court, and forensic custody of the weapon was unaccounted for during the relevant period – Noting that all co-accused had been granted bail, the Court held that the Petitioner was entitled to parity – Held: The evidentiary worth of the weapon recovery and mobile CDR data required trial scrutiny and was insufficient to deny bail at the current stage – Pre-trial incarceration of over six years, with slow trial progress, violated Article 21 and justified release on bail [Paras 5–8].

Prolonged Detention – Speedy Trial – Constitutional Right – Bail Allowed – The Petitioner had undergone six years of pre-trial detention, with only 22 out of 39 prosecution witnesses examined – Further trial delay anticipated – Relying on Tapas Kumar Palit v. State of Chhattisgarh, the Court emphasized the fundamental right to speedy trial under Article 21 and granted bail accordingly [Para 8].

Recovery of Weapon – Delay in Seizure – Evidentiary Doubt – Recovery of the firearm occurred over ten days post-incident and was linked to the crime through a ballistic report issued after ten months – No credible explanation provided regarding the weapon’s custody – Held: The delayed recovery and unclear chain of custody diluted the conclusiveness of such evidence, and the recovery could not, on its own, justify denial of bail [Paras 6–7].

Prior Criminal Antecedents – Not Sole Ground to Deny Bail – The Petitioner’s involvement in other cases had either resulted in bail or were linked to the current case – The Court reiterated that mere pendency of FIRs does not bar grant of bail [Para 9].

Compliance During Interim Bail – No Misuse of Liberty – The Petitioner was earlier granted interim bail on three occasions and complied with all conditions – His conduct indicated no flight risk or threat of witness tampering [Para 10].

Decision – Bail Granted – The Petitioner was granted regular bail on furnishing a personal bond of ₹25,000 with one surety of like amount and subject to conditions including restriction on travel, regular court appearance, and cooperation with the investigating authorities [Paras 11–14].