Criminal Law - Conviction for Murder - Direct Evidence vs. Motive – Appellant convicted for murdering his wife by inflicting injuries with a sharp-edged weapon – Appellant argued lack of motive – Court held motive insignificant in the presence of direct evidence – Conviction based on eyewitness testimony and forensic evidence upheld – Appellant’s contention regarding lack of motive dismissed as irrelevant. [Paras 44-45]

Evidence - Eyewitness Testimony and Forensic Corroboration – Prosecution's case supported by testimonies of eyewitnesses and the recovery of the weapon – Medical evidence confirmed the cause of death due to injuries inflicted by the appellant – Forensic examination of the weapon found human blood – Court found overwhelming evidence to establish guilt beyond reasonable doubt. [Paras 44-45]

Judicial Principles - Role of Motive in Presence of Direct Evidence – Court reiterated that motive is hidden in the heart and mind of the offender and is often difficult to ascertain – When direct evidence is available, the role of motive diminishes – Courts rely on direct and circumstantial evidence to establish guilt. [Paras 44]

Decision: Appeal dismissed – Conviction and life imprisonment under Section 302 IPC upheld – Overwhelming evidence and lack of credible defense led to dismissal of the appeal. [Paras 46]

Criminal Law - Conviction for Murder - Evidentiary Basis and Delay in Forensic Examination – Accused-appellants convicted under Sections 302/34 and 506 IPC for attacking the deceased with knives – Delay of 6 months in forensic examination of knives – Held, delay not beneficial to the accused given doctor's opinion that injuries matched knives – Inordinate delay potentially affecting blood detection on knives – Conviction upheld as intention inferred from weapon used, body parts targeted, and force applied. [Paras 26, 31]

Evidence - Medical and Forensic Testimonies – Blood not detected on knives due to delay in examination – Doctor’s opinion confirmed injuries on deceased matched recovered knives – Injuries declared sufficient to cause death in ordinary course of nature – Medical and forensic evidence corroborated prosecution’s case. [Paras 26, 31]

Judicial Principles - Inference of Intention from Circumstances – Intention inferred from weapon type, targeted body parts, applied force, and circumstantial factors – Injuries on vital body parts indicated deliberate intention to cause death – Supreme Court precedents affirming inference based on weapon and injury analysis followed. [Paras 26, 31]

Decision: Appeal dismissed – Conviction and sentence under Sections 302/34 and 506 IPC upheld – Accused-appellants’ arguments regarding forensic delay and lack of intention rejected. [Paras 32-33]

Constitutional Law - Eligibility for Public Service Appointments – Petitioners, employees of Punjab State Power Corporation Limited (PSPCL), claimed eligibility for PCS (Executive Branch) via Register C – Held, employees of statutory Boards/Corporations do not hold civil posts under the State or Union – Boards/Corporations are distinct entities, even if state-owned and controlled – Petitioners’ service not under the government, thus ineligible for PCS (Executive Branch) through Register C. [Paras 26-28]

Service Law - Civil Posts under the State - Distinction and Criteria – Detailed criteria for determining civil posts under the State – Corporations, though state-controlled, have independent existence – Service conditions not regulated by rules framed under Article 309 – Petitioners appointed by a Board and not a government department – Previous state department work transferred to Boards/Corporations does not affect current status. [Paras 26-28]

Judicial Precedents - Separate Entities and Service Rules – Employees of Punjab Vidhan Sabha and High Court treated differently due to constitutional creation and agreed applicability of Punjab Civil Services Rules – Petitioners’ reliance on past administrative functions of electricity supply department unavailing – Petitioners do not meet criteria for civil posts under Articles 309 or 311. [Paras 27-28]

Decision: Writ petition dismissed – Petitioners not eligible for appointment to PCS (Executive Branch) through Register C as they do not hold civil posts under the State. [Para 29]

Civil Procedure - Amendment of Pleadings - Bona Fide Intention – Petition for amendment of eviction petition and impleadment of Praveen Prakash Kanwal as petitioner No.2 claiming independent landlord status – Held, amendment permissible as long as material pleadings are not altered or substituted and the amendment is bona fide – No mala fide intention found, and amendment necessary for proper adjudication – Application allowed subject to costs. [Paras 17, 20]

Rent Law - Amendment of Eviction Petition - Impleadment of Trustee – Original petition filed by Trust through Managing Trustee, Chhajusing, with general power of attorney, Praveen Kanwal – Application for amendment filed after 7 years to implead Praveen Kanwal as independent landlord – Court allowed amendment considering it necessary to determine real questions in controversy – Delay not a bar for bona fide amendments – Costs imposed for delay. [Paras 6-8, 10-12, 20]

Judicial Precedents - Principles for Allowing Amendments – Apex Court’s principles in Revajeetu Builders & Developers v. Narayanaswamy & Sons and other cases followed – Courts should be liberal in allowing amendments necessary for justice – Amendments should not alter or substitute material pleadings or cause serious prejudice to the opposite party – Ensures adjudication of real issues. [Paras 17, 20]

Decision: Revision petitions allowed – Application for amendment and impleadment as petitioner No. 2 granted – Costs of Rs. 5000/- imposed for each case payable to the tenants. [Para 20]

Criminal Law - Parole - Temporary Release of Prisoners – Petitioner, a life convict for murder, denied parole on grounds of potential criminal activity – Held, likelihood of committing crime while on parole is not sufficient to decline parole – Parole can be denied only if release endangers state security or public order – Petitioner does not fall under 'hardcore prisoner' category, making him eligible for parole – Petition allowed, authorities directed to reconsider parole application. [Paras 11-13]

Statutory Interpretation - Definitions and Conditions – Section 2(aa) defines 'hardcore prisoner' excluding the petitioner – Sections 3 and 4 allow parole and furlough for good conduct, while Section 5A restricts release of certain prisoners – Section 6(2) specifies denial grounds related to state security and public order – Petitioner's parole denial on grounds of potential crime deemed unjustified – Authorities must provide valid reasons aligned with statutory provisions. [Paras 11-12]

Administrative Discretion - Judicial Review – District Magistrate’s recommendation based on general likelihood of crime insufficient – Statutory mandate requires specific threats to state security or public order for parole denial – Arbitrary exercise of administrative discretion rectified through judicial intervention – Authorities directed to reassess parole application with clear reasoning. [Paras 13, 16]

Decision: Petition allowed – District Magistrate's recommendation dated 1.2.2016 set aside – Authorities directed to reconsider parole application and pass appropriate orders in accordance with law – Parole granted subject to petitioner’s compliance with surety and behavioral conditions. [Paras 16-17]

Rent Law - Eviction for Bona Fide Requirement - Personal Necessity – Landlord filed ejectment petition for the bona fide requirement of setting up his son – Concurrent findings by lower courts ordering eviction – Petitioner contended that during pendency of the proceedings, landlord’s son had let out another property – Petitioner's application for amendment under Order 6 Rule 17 CPC to raise this point was rejected and never challenged – Held, eviction ordered based on bona fide requirement upheld – Revision petition dismissed. [Paras 1, 5, 8]

Civil Procedure - Amendment of Pleadings - Due Diligence Requirement – Tenant’s application for amendment of written statement under Order 6 Rule 17 CPC rejected by Rent Controller – Application sought to raise new issues about letting out property by landlord’s son – Rejected due to conclusion of evidence and lack of challenge to the rejection order – Amendment not permissible post-commencement of trial without due diligence. [Paras 5-6]

Judicial Review - Concurrent Findings - Revisional Jurisdiction – High Court noted that both lower courts had given concurrent findings regarding the landlord’s bona fide need – No specific grounds in tenant’s reply denying the requirement for personal necessity – Witnesses testified about landlord’s health and son’s need for premises – No new evidence justifying interference in lower courts’ well-reasoned orders – Revision petition dismissed in limine. [Paras 4, 6-9]

Decision: Revision petition dismissed – Eviction order upheld – Petitioner's application for amendment rightly rejected due to lack of challenge and late-stage filing – Landlord’s bona fide requirement for son’s use of premises affirmed. [Para 9]

Constitutional Law - Judicial Service - Inter-se Seniority - Quota System - Judicial Review – The petitioners challenged the seniority list dated 24.12.2015 of the Punjab Superior Judicial Service. The primary issue was the inter-se seniority among officers appointed through three sources: promotion from Civil Judges (Senior Division) based on merit-cum-seniority and passing a suitability test (50% quota); promotion through limited departmental competitive examination (25% quota); and direct recruitment (25% quota). The court held that any promotion made in excess of the quota prescribed in the rules must be treated as ad hoc and cannot be justified. Such officers are entitled to seniority only from the date when a vacancy in their quota becomes available. Violating or interchanging the quotas set in the rules would set a bad precedent and be violative of Article 14 of the Constitution. [Paras 1-201]​​

**Ad hoc Promotions - Seniority Benefits - Held, officers promoted beyond their prescribed quota are considered ad hoc and do not receive seniority benefits until a vacancy in their quota arises. The placement in seniority is effective only from the date when a post in their quota becomes available. [Paras 205-206]​​

No Estoppel Against Statute - Suitability Test - Held, the suitability test for promotion prescribed by the Supreme Court and included in the rules cannot be bypassed by administrative decisions or practices. Officers promoted without passing the required suitability test are not entitled to claim regular promotion status. [Paras 13, 46]​​

Decision - Petition Dismissed - The petition was dismissed, and the court upheld the seniority list dated 24.12.2015, with the direction that promotions exceeding the prescribed quota are to be considered ad hoc and seniority adjustments to be made accordingly. [Paras 200-201, 205-206]​​

Land Acquisition Law - Enhanced Compensation - Equitable Treatment of Landowners – Petitioner contended that respondent landowner, who did not appeal the compensation award, should not receive the enhanced compensation granted to other landowners in similar circumstances – Held, equitable treatment requires similarly situated landowners to receive similar compensation – Supreme Court precedent mandates pragmatic and non-pedantic approach in land acquisition matters – Enhanced compensation granted to the respondent landowner upheld. [Paras 7-8, 10-11, 15]

Principles of Natural Justice - Avoiding Multiplicity of Litigation – Emphasis on substantial justice and avoiding multiplicity of litigation – Respondent’s land acquired under same notification as other landowners who received higher compensation – Denial of similar compensation to respondent deemed discriminatory – Executing court's order upheld. [Paras 19-20]

Supreme Court Precedents - Pragmatic Approach in Land Acquisition – Reference to Supreme Court judgments emphasizing equitable compensation for similarly situated landowners – Courts must balance equities and ensure substantive rights are not defeated on technical grounds – Precedents in Samiyathal v. Special Tehsildar and Dhiraj Singh v. State of Haryana followed. [Paras 11-13, 15]

Decision: Revision petition dismissed – Enhanced compensation awarded to respondent landowner upheld – Execution court's order affirmed. [Para 23]

Land Law - Redetermination of Surplus Area - Suo Moto Powers – Financial Commissioner invoked suo moto powers after 11 years to redetermine surplus area – Held, such invocation not permissible once determination has attained finality up to the High Court – Surplus area vested and mutated in favor of the State, utilized, and not available for redetermination – Arbitrary and without jurisdiction – Orders set aside. [Paras 15, 17, 20]

Jurisdictional Limits - Finality of Orders - Non-Reopenable Cases – Once surplus area determination becomes final, it cannot be reopened arbitrarily – Financial Commissioner lacked jurisdiction as per notification delineating authority among benches – Final orders from High Court bind revisional authorities – Reopening based on assumptions about age verification of landowner’s son invalid. [Paras 15-17]

Public Administration - Legal Finality and Administrative Efficiency – Once land vested and allotted, re-determination of surplus area undermines administrative efficiency and legal certainty – State failed to provide evidence that allotments were paper transactions – Petitioners' possession and utilization of land legally recognized and unchallenged – Reopening surplus area after long lapse deemed misuse of suo moto powers. [Paras 20, 22]

Decision: Petition allowed – Impugned orders dated 28.08.2006, 31.10.2008, and 18.04.2009 set aside – Redetermination of surplus area held arbitrary and without jurisdiction. [Para 23]