Civil Law - Relocation & Rehabilitation Policy – Eligibility for alternate shop – Scope restricted to licensees, lessees, or Tehbazari holders – The appellant, not being a licensee, lessee, or Tehbazari holder, was not eligible for relocation benefits under the Delhi MRTS Project Policy – Held: Scheme was only applicable to shopkeepers having valid legal rights conferred by MCD/NDMC, not to encroachers [Paras 8-15].

 Promissory Estoppel – Applicability – Absence of unequivocal promise or representation – DMRC's proposal for rehabilitation was restricted to license holders – Appellant, lacking any license or recognized right, cannot invoke promissory estoppel against DMRC – Mere participation in the draw of lots and deposit of money did not create an enforceable right – Held: Appellant cannot claim benefit under promissory estoppel [Paras 15-33].  

Administrative File Notings – Value in judicial proceedings – DMRC's internal note of 20.04.2011 suggesting appellant's eligibility is merely an opinion – Held: Eligibility must be determined strictly under the policy and applicable law, not based on internal office notings – Such notings do not bind the corporation or confer any legal right [Para 37].  

Decision – Appeal dismissed – Appellant held ineligible under Relocation and Rehabilitation Policy – Principles of promissory estoppel and legitimate expectation held inapplicable – Findings of the learned Single Judge upheld – No interference warranted [Paras 38-40].

Criminal Law - Quashing of Proceedings – Protest Leadership Alone Not Sufficient – No Specific Allegations – Proceedings Quashed - Petitioner, then President of Telangana Political JAC, was accused of calling for a rail roko during agitation in 2011—Held: No evidence of direct participation or instigation—Witnesses only referred to political call, not physical involvement—Continuation of trial would amount to abuse of legal process [Paras 6–8, 13–14].

Section 188 IPC – Prosecution Barred Without Proper Complaint – Violation of Section 195(1)(a) CrPC - Cognizance for disobedience to public servant’s order requires complaint by competent authority—Charge sheet filed by police officer without requisite authority—Prosecution unsustainable in law [Paras 9–10].

Public Protest and Mens Rea – No Material Showing Intent or Threat – Criminal Liability Not Attracted - Presence of slogans or crowd gathering on railway tracks not attributable directly to petitioner—Statements failed to prove intent to incite violence or disrupt services—No mens rea for offences under IPC or Railways Act [Paras 7, 11].

Bhajan Lal Guidelines – Guideline No. 6 Invoked – Legal Bar and Lack of Allegations - Citing State of Haryana v. Bhajan Lal, Court found express legal bar to prosecution and absence of prima facie case—Quashing under Section 482 CrPC justified [Paras 11–13].

Decision – Criminal Petition Allowed – Proceedings in C.C. No. 393 of 2023 Quashed Against Petitioner – Miscellaneous Applications Closed [Paras 14–15].

Compounding of Offence – Section 138 NI Act – Consent of Complainant Mandatory – Application Dismissed - The petitioner sought compounding of the offence on the basis of partial deposit of compensation – The complainant opposed the request and refused to consent – Held: Compounding under Section 138 read with Section 147 NI Act requires consent of complainant; Courts cannot override this requirement – Petition dismissed [Paras 1-9, 15].

Inherent Powers of High Court – Section 482 CrPC – Not Substitutable for Consent – Court Cannot Compel Compromise - Citing JIK Industries v. Amar Lal V. Jumani and Raj Reddy Kallem v. State of Haryana, the Court held it cannot invoke Section 482 CrPC or Section 147 NI Act to compound an offence in absence of complainant’s consent – Compounding without consent not permissible even if compensation is paid [Paras 6-8, 17-19].

Quantum of Compensation – Inadequate Payment – No Basis for Quashing - The Court found that the cheque amount was ₹1,65,525 dated 17.03.2004 and calculated interest at 9% per annum over 21 years to ₹3,12,842 – Against this, only ₹50,000 had been deposited by the accused – Held: Compensation inadequate, and petitioner's plea for quashing based on partial payment cannot be entertained [Paras 11-13].

Litigation Abuse – Delay and Forum Shopping – Premium on Dishonesty Not Permitted - The Court cautioned against the misuse of judicial process where accused protracts litigation and later seeks quashing based on partial compliance – Held: Law cannot allow litigants to harass complainants and then claim relief under guise of justice [Para 14].

Decision – Application for Compounding Dismissed – Final Hearing Directed - The compounding application was rejected – Court scheduled the main criminal revision for final hearing in due course [Paras 15-16].
 

Criminal Revision – Appeal against Conviction - Food Adulteration – Synthetic Colour in Dal Masur – Conviction Justified – Dal Masur found adulterated with synthetic colour 'sunset yellow', a prohibited additive not permitted under Rule 29 of the PFA Rules – Court held that even if colour is permitted for other foods, its use in Dal Masur is strictly prohibited – Held: Offence under Section 7/16(1)(a)(i) of the PFA Act is made out [Paras 15–17].

Service of Public Analyst Report – Presumption of Delivery – Compliance with Section 13(2) of PFA Act Established – Accused claimed non-receipt of analyst’s report – Court held that the registered letter was not returned, raising presumption of due service – Further, accused did not deny receipt in his Section 313 statement – Held: No violation of Section 13(2); argument raised for the first time during arguments not sustainable [Paras 6–9].

Rules 17 & 18 of PFA Rules – Manner of Dispatch and Seal – No Prejudice Caused – Procedural Compliance Presumed – Though Food Inspector did not expressly mention sending seal specimen, the analyst’s report confirmed seal matched – Held: Substantial compliance shown, no prejudice to accused, conviction valid [Paras 12–13].

Right to Speedy Trial – Delay in Final Hearing – Sentence Reduced – Though benefit of probation denied due to Section 20AA of PFA Act, Court acknowledged prolonged pendency of over 26 years since offence and 15 years since suspension of sentence – Held: Conviction upheld, but sentence reduced to period already undergone (7 days) considering Article 21 of Constitution and mental agony faced [Paras 30–40].

Final Decision – Conviction Upheld – Sentence Modified – Court affirmed conviction under Section 7/16(1)(a)(i) of PFA Act – Original sentence of 3 months RI and ₹500 fine modified – Sentence reduced to period already undergone – Fine enhanced to ₹10,000 with four weeks to deposit, failing which original sentence will revive [Para 40].

Criminal Law - Dowry Death – Acquittal Upheld – Failure to Prove Demand or Cruelty – Appeal Dismissed – The appellant challenged acquittal in a case involving death of his daughter allegedly due to dowry-related cruelty – Trial court found no evidence of dowry demand or proof of homicidal or suicidal death – Prosecution witnesses failed to support allegations during cross-examination – Held: No perversity in trial court findings, hence acquittal sustained [Paras 6–9, 24–25]. 
Presumption under Section 106 Evidence Act – No Automatic Shift in Burden – Section 106 not applicable in absence of foundational facts – Accused present in house at time of incident does not by itself justify drawing adverse inference under Section 106 – Held: Burden of proving guilt remains on prosecution throughout [Para 23]. 
 
Medical Evidence – No Proof of Strangulation – Cause of Death Uncertain – As per PW-4 (doctor), no fresh injury marks or signs of strangulation were found – Postmortem inconclusive and viscera report not produced – Held: Medical evidence contradicts prosecution case, supports trial court’s view [Paras 20–21]. 
 
Illicit Relationship Allegation – Not Substantiated – Alleged affair of accused not proved – No specific details or corroborating evidence produced – Held: Mere allegation without evidence cannot establish motive or cruelty [Para 22]. 
Standard for Interference with Acquittal – No Perversity in Trial Court’s Findings – Supreme Court precedents reiterated that appellate courts must not interfere with acquittals unless findings are palpably wrong or manifestly erroneous – Held: Trial court’s findings sustainable, appeal dismissed [Paras 10–16, 25–26]. 
 

Civil Law – Eviction - Public Premises – Allotment Without Auction – Long-Standing Possession Not a Ground for Extension – The appellant challenged the Single Judge’s order denying extension of fair price shop allotment without auction – Held: Appellant’s initial allotment was made without auction in 1997 and extensions were granted irregularly – Government Order No. 492-HME of 2008 mandates public auction for such allotments – Mere payment of rent and long possession cannot override the statutory auction requirement [Paras 7-11]. 
 
Government Policy – Mandatory Auction for Hospital Premises – Applicability Affirmed – The Court held that the 2008 Government Order applies to all hospital structures including fair price shops – Authorities were unjustifiably allowing the appellant to continue without following the mandatory auction procedure – The appellant cannot claim vested rights against clear public policy [Paras 9-11]. 
 
Equity – No Equitable Consideration Against Express Statute – The appellant’s plea for equity based on past payment of rent and long occupation was rejected – Court emphasized that public property cannot be continued on private arrangements without compliance with government orders – Holding government property for 28 years without following auction violates public interest [Paras 10-11]. 
 
Final Decision – Appeal Dismissed – The Court upheld the Single Judge’s judgment – Dismissed the Letters Patent Appeal holding that there was no infirmity in the impugned judgment and no right to extension without auction – Directions issued to authorities to follow Government Order No. 492-HME of 2008 [Paras 11-12]. 
 

IBC Disciplinary Proceedings – Scope of Judicial Review – Limited Interference – In exercise of writ jurisdiction, the Court does not sit as an appellate authority over findings of disciplinary bodies and restricts itself to assessing procedural propriety, adherence to principles of natural justice and proportionality – Held: The disciplinary process was not vitiated on jurisdictional grounds but committed errors affecting proportionality of punishment [Paras 31, 35]. 
 
Recovery of Security Deposit – Erroneous Calculation – Disciplinary 
Committee considered erroneous figures not accepted even by Investigating Authority – Held: Such a factual error contributed to disproportionate punishment [Para 32]. 
 
Work-in-Progress (WIP) Realization – Auditor’s Report Ignored – Disciplinary Committee rejected the auditor's report without adequate justification – The report showed that realization was higher than assessed value – Held: Findings suffer from procedural irregularity affecting the proportionality of penalty [Para 33]. 
 
CoC Authorization – Operation of Bank Account – Appellant’s actions in relation to Corporate Debtor’s account were duly approved by Committee of Creditors through formal resolutions – No case of financial mismanagement or personal gain made out – Held: Appellant acted within the framework of the IBC [Para 34]. 
 
Principle of Proportionality – Suspension Period Reduced – Considering the errors in appreciating evidence and proportionality of penalty, the Court reduced the suspension from two years to the period already undergone i.e., about 1 year and 4 months – Held: Appellant is entitled to restoration of registration as Insolvency Professional [Paras 36-37]. 
 
Decision – Appeal Partly Allowed – The impugned judgment and order of the learned Single Judge is modified to the extent that the suspension period imposed upon the appellant stands reduced to the period already undergone – Appellant’s registration to be restored forthwith with liberty to IBBI to proceed against him afresh if warranted on any subsequent violation – Costs made easy [Para 37]. 
 

Writ - Maintainability – Second Writ Petition After Withdrawal of First Without Liberty – Barred by Constructive Res Judicata - The appellant had earlier withdrawn CWJC No.19237 of 2015 without reserving liberty to refile – The second writ petition CWJC No.19359 of 2016 challenging the same cause was rightly held not maintainable by the Single Judge – Doctrine of election and principles laid down in Joint Action Committee vs. DGCA (2011) 5 SCC 435 and M.J. Exporters (2021) 13 SCC 543 applied [Paras 3-5]. 
 
Government Accommodation – No Vested Right Post-Resignation – Penal Rent Justified - Appellant, after resigning as MLA on 14.03.2014, continued to occupy Quarter No.3, Taylor Road till 12.05.2016 without valid allotment – Court held that the notification relied by appellant (dated 21.08.2008) did not entitle him to continue occupying the specific quarter meant for ministers – The continued occupation was illegal – Penal rent of Rs.20,98,757 imposed was lawful [Paras 16-17]. 
 
Public Premises – Unauthorized Occupation – Liability to Pay Penal Rent with Interest - Court relied upon Lok Prahari vs. State of U.P. (2016) 8 SCC 389, S.D. 
Bandi vs. Karnataka SRTC (2013) 12 SCC 631, and other binding precedents – Unauthorized occupation by former legislators is impermissible – Appellant directed to pay Rs.20,98,757 along with 6% interest from 24.08.2016 till actual payment [Paras 17-19]. 
 
Doctrine of Equality – Distribution of Public Property - Court reiterated that public property like government accommodation is not a private right – Allotment is coterminus with official status – Retention beyond entitlement infringes others’ rights – Appellant acted contrary to legal and ethical expectations [Paras 18-19]. 
 
Final Decision – Appeal Dismissed - The appeal was found devoid of merit both on maintainability and merits – The appellant was directed to deposit the penal rent with interest within one month [Paras 20-22]. 
 

Civil Writ - Education Law - Sports Quota – Horizontal vs Vertical Reservation – Compartmentalization Upheld - Petitioner contended that sports quota should be a standalone reservation and sub-division of seats based on community within sports quota amounts to reservation within reservation which is impermissible – Held: Sports quota is a horizontal reservation, and G.O.Ms.No.231 validly provides for distribution of sports seats among OC, BC, SC, ST categories – High Court upheld the compartmentalized horizontal reservation system following P. Srividya vs. State of AP and Indra Sawhney case [Paras 7-14]. 
 
Allotment of Seat – Comparative Merit – Petitioner’s Claim Rejected - Petitioner belonging to OC category could not claim the seat allotted to respondent No.18 belonging to BC-A category under sports quota – No seat was available for OC candidates under sports quota in respondent No.21-college – Further, petitioner failed to show that any less meritorious OC candidate was allotted a sports quota seat – Writ petition dismissed [Paras 15-17].