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].
 

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].

Criminal Law - Death Penalty – Inadequate Legal Representation – Violation of Article 21 of Constitution – De novo Trial Ordered - The Court found that the convict was deprived of adequate legal assistance throughout the trial due to frequent change of legal aid counsel, perfunctory cross-examinations, and failure to provide proper defence – This amounted to a violation of the convict’s right to a fair trial under Article 21, necessitating a retrial from the stage of charge framing [Paras 10-16].

Section 313 CrPC – Improper Examination of Accused – Prejudice Caused – Trial Vitiated - The Court observed that the accused's statement under Section 313 CrPC was lengthy, vague, and failed to put specific material circumstances individually to the convict – This denial of opportunity to effectively explain the evidence against him constituted a serious procedural irregularity causing prejudice and vitiating the trial [Paras 17-20].

Sentencing in Death Penalty Cases – Failure to Consider Mitigating Circumstances – Separate Sentencing Hearing Mandatory - The Court criticized the trial court for not conducting a separate sentencing hearing or considering mitigating factors before awarding the death penalty, in violation of constitutional norms established under Bachan Singh and Machhi Singh – Hence, the death sentence could not be sustained without a fair sentencing procedure [Paras 21-22].

Denial of Fair Trial – Fundamental Lapses by Trial Court – Need for De Novo Trial - Cumulative procedural irregularities including ineffective legal aid, improper Section 313 CrPC examination, absence of a genuine sentencing hearing, and the failure to protect the convict’s rights led the Court to conclude that the trial was fundamentally unfair and unconstitutional – Consequently, the conviction and sentence were set aside, and the matter was remanded for a de novo trial [Paras 23-28].

Decision – Conviction and sentence set aside – Case remanded to Trial Court for a fresh trial – Directions issued for competent legal aid, proper conduct of trial, and compliance with constitutional standards [Paras 28-32].
 

Criminal Law – Quashing 0f FIR - Muslim Divorce – Talaq-e-Ahsan – Distinction from Talaq-e-bidat – Quashment of FIR - Applicants demonstrated that the pronouncement of divorce was through Talaq-e-Ahsan and not Talaq-e-bidat which alone is banned – Held: Talaq-e-Ahsan is a recognized mode of divorce under Muslim Personal Law and not punishable under Section 4 of the Muslim Women (Protection of Rights on Marriage) Act, 2019 [Paras 3-7].

Scope of Section 4 of the Muslim Women (Protection of Rights on Marriage) Act – Offence applies only to husband – No vicarious liability for relatives – Proceedings against parents-in-law quashed - Held: Section 4 applies solely to Muslim husbands; involvement of in-laws is legally untenable, and their prosecution constitutes an abuse of process [Para 6].

Requirement of Immediate or Irrevocable Divorce – Definition under the Act – Instantaneous Divorce Only Punishable - Held: Only Talaq forms having instantaneous and irrevocable effect such as Talaq-e-bidat are punishable; Talaq-e-Ahsan not prohibited as per Supreme Court and Kerala High Court precedents [Paras 7-8].

Abuse of Process – Quashing of Proceedings – Preventing Misuse of Criminal Process - Held: When allegations do not satisfy ingredients of offence and proceedings are manifestly attended with mala fide intention, it amounts to abuse of process and deserves quashment [Paras 7-8].

Decision – FIR and criminal proceedings quashed - The Court allowed the application and quashed the FIR registered at Bhusawal Bazar Peth Police Station and Regular Criminal Case No. 1156/2024 pending before the Judicial Magistrate First Class, Bhusawal, against all applicants [Final Order].
 

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].
 

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].
 

Writ - Maintainability of Writ Petition – Private Entities and Public Law Element – Writ Petition Not Maintainable - Petitioners contended maintainability of writ petition against private trusts performing public duties and receiving State regulation and funds – Held: Mere regulation by statute without financial, administrative or functional State control does not bring private entities within the ambit of "State" under Article 12 – No public law element established; writ not maintainable [Paras 9-17].

Alternative Statutory Remedy – Availability under Bombay Public Trusts Act – Writ Dismissed - Reliefs sought against trustees removable under specific statutory procedure in Bombay Public Trusts Act, 1950 – Existence of effective statutory remedy barred invocation of writ jurisdiction under Article 226 – Writ Court rightly declined interference [Paras 22-25].

Res Judicata and Constructive Res Judicata – Challenge Before NCLT and Labour Tribunal – Writ Petition Barred - Petitioners previously agitated similar grievances before NCLT and Labour Tribunal – Failure to appeal NCLT’s dismissal and re-litigation of same issues attracted res judicata and constructive res judicata – Writ Petition not maintainable [Paras 26-32].

Foreign Entities and Non-Statutory Bodies – Writ Against Foreign Entity Not Maintainable - Relief sought against UK-based entity and non-statutory body (Bishops Council) outside India's jurisdiction and legal recognition – Writ jurisdiction could not be invoked against them [Paras 33-35].

Requirement of Public Law Element – Enforcement of Private Rights – Writ Not Entertained - Allegations involved private disputes of ex-employees terminated by private institutions without sufficient public duty or fundamental rights breach – Absence of public law element barred writ jurisdiction [Paras 36-41].

Decision – Writ Appeal Dismissed – Held that the learned Single Judge had taken a plausible and correct view in declining to entertain the writ petition for want of maintainability – Appeal dismissed with no order as to costs [Paras 27-32].
 

Railway Accident Claims – Burden to Prove Bona Fide Travel – Claim Rejected – Appeal Dismissed - The appellant claimed compensation for death of his son allegedly caused by falling from Train No. 12506 (North East Express) near Banhai Station – Tribunal found no eyewitnesses or evidence of ticket purchase or boarding – Held: Without proof of bona fide travel or untoward incident as defined under Section 123(c) read with 124-A of Railways Act, no liability of compensation arises – Appeal dismissed [Paras 1–3, 7–12].

Railway Accidents – Death on Track Not Presumed to Be Fall From Train – Mutilated Body Found in Middle of Track – Presumption of Being Run Over - Body found severely mutilated in middle of track 6 hours after train passed – Tribunal and Court relied on physical evidence and precedent to infer that such condition unlikely from accidental fall from moving train – Held: Death more consistent with run-over or suicide attempt; not covered under ‘untoward incident’ [Paras 7, 11].

Evidence – Hearsay and Non-Eyewitness Testimony – No Presumption in Absence of Ticket or Witnesses - Testimony by deceased’s father was based on hearsay and contradicted by police record – No journey ticket recovered – Held: Mere averment of travel insufficient to establish right to compensation under Railway Claims framework [Paras 9–12].

*Decision – Appeal Dismissed – Tribunal’s Findings Upheld – No Compensation Payable - Court upheld the Tribunal’s decision finding no credible evidence of bona fide travel or untoward incident – Accordingly, appellant not entitled to any compensation – Appeal dismissed in entirety [Para 12].
 

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].