Suo Motu Jurisdiction – Temple Administration – Alleged Plunder of Sacred Assets – Court-Monitored Investigation – High Court initiated suo motu proceedings concerning alleged removal and substitution of gold-cladded plates from Dwarapalaka idols at Sabarimala – Special Investigation Team constituted pursuant to court directions – Continuous judicial supervision exercised to ensure transparency, accountability and thorough investigation [Paras 1–3].

Criminal Investigation – Arrests and Expansion of Probe – Organised Misappropriation – In Crime Nos. 3700/2025 and 3701/2025, majority of accused arrested – Investigation expanded beyond initial suspects with scrutiny of additional individuals based on witness statements and documentary evidence – Held: Prima facie indicators suggest organised and systematic misappropriation rather than isolated acts [Paras 4, 12–13].

Scientific Evidence – Gold Cladding Analysis – Vikram Sarabhai Space Centre Report – Samples of gold plates collected and analysed by VSSC pursuant to court orders – Chemical analysis revealed absence of nickel and acrylic polymer layers in original gold cladding (1998) and presence of such layers in later plating – Comparative thickness and composition indicated substitution and tampering – Held: Scientific report provides crucial evidentiary foundation to identify modus operandi, fix liability and trace conspiracy [Paras 5–7].

Investigation – Role of Experts – Decoding Technical Reports – Court directed SIT to record detailed statements of scientists and technical experts from VSSC and correlate scientific findings with seized material and documentary evidence – Held: Expert evidence essential for decoding technical data and linking it with criminal acts allegedly committed during 1998, 2019, 2024 and 2025 [Paras 6–8].

Temple Assets – Kodimaram Replacement – Seizure of ‘Vajivahanam’ – Investigation revealed replacement of Kodimaram in 2017 and subsequent handing over of ‘Vajivahanam’ to then Thantri – Article seized from residence of Thantri with assistance of certified goldsmith – Prima facie found to be Panchaloha with substantial gold content – Produced before jurisdictional court – Directed deeper probe into Ashtadikpalaka idols and related transactions [Paras 10–11].

Tracing Proceeds of Crime – Financial and Property Investigation – Statements of over 202 witnesses recorded – Bank accounts frozen and immovable properties of accused identified for tracing proceeds of crime – Recording of statements under Section 183 of Bharatiya Nagarik Suraksha Sanhita in progress [Para 9].

Judicial Oversight – Public Trust Doctrine – Temple Properties – Court observed that what appeared to be bona fide administrative actions disclosed serious institutional lapses and possible connivance – Held: Custodians of temple assets are trustees of public faith and any breach warrants stringent scrutiny – Investigation described as having opened a “Pandora’s box” and “hornet’s nest” revealing entrenched misconduct [Paras 12–13].

Further Directions – Sampling, Measurement and Logistical Support – SIT permitted to visit Sabarimala during temple closure to measure doors and collect further samples for quantifying gold misappropriated – State Police Chief directed to ensure full manpower and logistical support to SIT without delay [Paras 15–16].

Decision / Directions: Court recorded satisfaction with progress of investigation – Directed continuation of comprehensive, phased investigation with utmost diligence – Matter posted on 09.02.2026 for further status report.

Criminal Law – Murder Conviction – Circumstantial Evidence – Acquittal – Appellant convicted under Section 302 IPC for murder of his wife on allegation of assault with sickle – Conviction based on motive, recovery of weapon and clothes, FSL report and judicial confession under Section 164 Cr.P.C. – High Court held that prosecution failed to establish a complete and unbroken chain of circumstances pointing only to guilt of accused – Missing links and serious infirmities in prosecution case – Conviction set aside [Paras 19, 38–41].

Circumstantial Evidence – Principles Governing – Chain of Circumstances – Prosecution required to prove circumstances conclusively and consistent only with guilt of accused – Reliance placed on Sharad Birdhichand Sarda v. State of Maharashtra – Held: Evidence adduced fell short of mandatory standards required for conviction based purely on circumstantial evidence [Paras 19–20].

Motive – Proof of – Failure to Establish – Alleged motive of suspicion regarding wife’s alleged illicit relationship not proved – Testimony of PW-4 (labour contractor) found unreliable and based on hearsay – Witness admitted lack of personal knowledge of alleged quarrels or relationship – Failure to prove motive weighed in favour of accused [Paras 23–26].

Judicial Confession – Section 164 Cr.P.C. – Evidentiary Value – Confession not Substantive Evidence – Confession can only be used for corroboration and not as sole basis of conviction – Accused denied guilt and alleged coercion – Trial Court erred in treating confession as substantive proof of motive and guilt – Reliance on Vijaya Singh v. State of Uttarakhand reiterated [Paras 27–29].

Section 313 Cr.P.C. – Examination of Accused – Non-Confrontation of Inculpatory Material – Confessional statement under Section 164 Cr.P.C. not put to accused during Section 313 examination – Held: Failure amounts to serious irregularity causing prejudice – Trial vitiated for violation of principles of natural justice – Reliance on Samsul Haque v. State of Assam and Shivaji Sahabrao Bobade v. State of Maharashtra [Paras 30–32].

Recovery Evidence – Memorandum and Spot Panchanama – Inconsistencies – Recovery of clothes from open and accessible place – Discrepancies in timing of panchnamas – Held: Recovery evidence not trustworthy and insufficient to corroborate prosecution case [Paras 20–21].

Forensic Evidence – FSL Report – Chain of Custody – Blood Group Evidence – Failure to examine carrier and prove safe custody and transmission of samples – No blood detected on weapon – Blood on accused’s clothes alone insufficient to sustain conviction – Non-compliance with prescribed procedure fatal in circumstantial evidence cases – Reliance on Prakash Nishad v. State of Maharashtra and Putai v. State of U.P. [Paras 34–37].

Medical Evidence – Homicidal Death – Limited Role – Post-mortem report proved homicidal death and possible use of sickle – Held: Medical evidence alone cannot connect accused with crime in absence of reliable corroborative evidence [Para 33].

Decision: Appeal allowed – Conviction and sentence under Section 302 IPC quashed and set aside – Appellant acquitted – Appellant directed to be released forthwith if not required in any other case, subject to execution of P.R. Bond under Section 437A Cr.P.C. [Paras 41–42].

Motor Accident Claim – Rash and Negligent Driving – Determination of Liability – Deceased travelling as passenger in TATA Indigo car which collided with Swaraj Mazda goods vehicle that suddenly entered National Highway – Tribunal held accident occurred due to rash and negligent driving of Swaraj Mazda vehicle – FIR naming car driver as tortfeasor not relied upon as complainant disowned contents and no police witness examined – Finding of sole negligence on goods vehicle upheld [Paras 5–10].

Evidence – FIR – Evidentiary Value – FIR not substantive evidence – Complainant (PW-4) stated that he merely signed where police instructed – In absence of examination of police officials by insurer, Tribunal justified in discarding FIR contents – High Court affirmed approach [Paras 6, 8].

Contributory Negligence – Plea Rejected – Specific issue framed on rash and negligent driving of TATA Indigo vehicle – Tribunal held no negligence on part of car driver – High Court found no perversity in factual findings [Paras 9–10].

Compensation – Assessment of Income – Deceased aged 25 years, employed as software professional – Salary claimed at Rs.34,102/- per month – Tribunal restricted monthly income to Rs.17,000/- considering company was newly formed – Deduction of 50% towards personal expenses and addition of 40% towards future prospects upheld [Paras 7, 11].

Multiplier – Correct Application – Multiplier of 18 applied having regard to age of deceased – Compensation under conventional heads including loss of estate, funeral expenses and love and affection held to be just and reasonable [Paras 7, 11–12].

Appeal under Section 173 MV Act – Scope of Interference – High Court held that findings on negligence and quantum were well-reasoned and based on evidence – No ground made out for interference – Appeal dismissed [Paras 12–13].

Decision: Civil Miscellaneous Appeal dismissed – Award dated 29.06.2020 confirmed – Connected miscellaneous petition closed – No costs.

Insurance – Theft Claim – Burden of Proof – Complainant claimed loss of ₹25,49,120 due to theft of watches and stock – Surveyor assessed loss at ₹34,723 based on available records – Complainant failed to maintain stock register or produce authenticated list of stolen items – Calculation sheet merely reflected book entries without independent verification – Held, claim not substantiated by cogent evidence – Repudiation justified [Paras 14-17].

Surveyor’s Report – Evidentiary Value – Independent licensed surveyor appointed by insurer examined claim – Report recorded absence of stock register, absence of detailed list of stolen items and inability to verify stock statements – In absence of contrary reliable evidence, surveyor’s findings accepted – No arbitrariness shown [Paras 14-16].

Deficiency in Service – Meaning under Section 2(1)(g) – Deficiency requires fault, imperfection or inadequacy in performance of contractual obligation – Insurer repudiated claim based on surveyor’s report and non-submission of requisite documents – No illegality or mala fide established – No deficiency made out [Paras 11-12, 18].

Exaggerated / Unsupported Claim – Mere reminders and correspondence with insurer insufficient to prove quantum of loss – Claim amount not supported by authenticated inventory or contemporaneous stock records – Consumer complaint dismissed [Paras 16-18].

Decision: Complaint dismissed – No deficiency in service on part of Opposite Party No. 1 – No order as to costs – Pending applications disposed of.

The Negotiable Instruments Act – Dishonour of Cheque – Section 138 – Reversal of Acquittal – Trial Court acquitted accused on ground that complainant failed to prove financial capacity to advance loan of ₹10,00,000 – Lower appellate Court reversed acquittal and convicted accused – Held: Once issuance of cheque and signature are admitted, statutory presumptions under Sections 118 and 139 arise – Trial Court erred in insisting upon proof of source of funds without accused discharging initial burden [Paras 2, 5].

Presumption under Sections 118 & 139 NI Act – Burden of Proof – Accused did not dispute signature or issuance of cheque – Defence that cheque was misused not supported by any material evidence – Mere suggestion or denial insufficient to rebut statutory presumption – Accused failed to probabilise defence [Paras 4–5].

Financial Capacity of Complainant – Requirement of Proof – Complainant stated that loan amount was mobilised from known persons and agricultural income – Sale deed produced to show ownership of agricultural land – Held: At initial stage, complainant is not required to prove financial capacity unless accused lays foundation in reply notice or evidence – Failure to reply to statutory notice strengthens complainant’s case [Paras 3, 6].

Failure to Reply to Statutory Notice – Adverse Inference – Accused neither replied to demand notice nor paid cheque amount – Held: Failure to reply to statutory notice permits inference that defence is an afterthought – Reliance placed on Sanjabij Tari v. Kishore S. Borcar [Paras 2, 6].

Appellate Jurisdiction – Interference with Judgment of Conviction – Lower appellate Court gave cogent reasons for reversing acquittal – Judgment found to be well-reasoned and based on evidence – Held: No perversity or illegality warranting interference under Section 374(2) CrPC [Para 5].

Sentence – Non-compliance of Suspension Order – Accused failed to comply with condition of deposit while seeking suspension of sentence – Held: Trial Court directed to secure accused for undergoing sentence [Para 5].

Criminal Law  – Examination of Accused – Section 313 CrPC / Section 351 BNSS – Mandatory Duty of Court – Fair Trial – Convict sentenced to death for rape and murder of a five-year-old child – Trial Court failed to put vital incriminating circumstances, including DNA report, toxicology report and Section 164 CrPC statements, to the accused – Long omnibus questions reproducing entire prosecution case framed instead of specific material circumstances – Held: Such examination defeats the object of Section 313 and violates principles of audi alteram partem – Causes serious prejudice to the accused in a capital punishment case [Paras 22–29, 31–56].

Criminal Jurisprudence – Incriminating Evidence – DNA Evidence – Failure to Put to Accused – Ext PZ DNA report forming the backbone of prosecution case not put to accused under Section 313 CrPC – Held: Circumstances not put to the accused must ordinarily be excluded from consideration – In a case involving death sentence, omission is grave and non-negotiable – Fair opportunity to explain incriminating material is imperative [Paras 24–26, 40–43, 59].

Capital Punishment – Procedural Safeguards – Heightened Scrutiny – Death penalty imposed by Trial Court – Proceedings concluded with undue haste and without strict adherence to procedural safeguards – Held: In capital cases, every safeguard must be scrupulously followed – Any dilution of fair trial standards vitiates the conviction and sentence [Paras 59–60].

Appellate Powers – Remand – Section 386 CrPC – Curable Irregularity – Though defects under Section 313 CrPC are curable – Considering nature of omissions, defence rights, and need to balance justice to accused and victim – Held: Appropriate course is remand to Trial Court from the stage of recording statement of accused under Section 351 BNSS – Not a case of acquittal on merits nor mere exclusion of evidence [Paras 64–66, 69–70].

Criminal Appeal and Murder Reference – Result – Conviction and Sentence Set Aside – Death Reference Rendered Infructuous – Impugned judgment of conviction and order of sentence quashed – Matter remanded to Sessions Court to re-commence trial from stage of Section 351 BNSS (Section 313 CrPC) – Accused to be examined afresh on all incriminating circumstances and permitted to lead defence evidence – Murder Reference disposed of as infructuous [Paras 67–75].

Decision: CRA-D-750-2021 partly allowed to the extent of remand – Conviction and death sentence set aside – Murder Reference No. 3 of 2021 disposed of – Trial to recommence from the stage of examination of accused under Section 351 BNSS.

Industrial Law – Stay of Proceedings – Section 10 CPC – Rejected – Petitioner-Management sought to stay individual industrial disputes before Labour Court under Section 10 CPC, pending a collective reference on the legality of a strike under the Industrial Disputes Act, 1947 – Management argued that the outcome of the collective reference would directly impact individual dismissal orders, making individual trials redundant – Labour Court rejected the application, holding Section 10 CPC inapplicable to its proceedings – High Court upheld the Labour Court's decision, reiterating that Section 10 CPC applies exclusively to suits in Civil Courts and not to proceedings before Labour Courts or Industrial Tribunals, which are not courts of concurrent jurisdiction – The limited applicability of CPC provisions to Labour Courts, as outlined in Section 11(3) of the Industrial Disputes Act, does not extend to Section 10 CPC – Industrial disputes are not "suits" within the meaning of Section 10 CPC – The application was legally untenable and aimed at prolonging adjudication – High Court dismissed the writ petitions. [Paras 7, 8, 10, 11, 12, 16]

Industrial Law – Jurisdiction of Labour Court – Section 11 Industrial Disputes Act – Limited Applicability of CPC – The Industrial Disputes Act, 1947, specifically Section 11(3), grants Labour Courts and Tribunals certain powers of a Civil Court, limited to enforcing attendance, compelling document production, issuing commissions for witness examination, and other prescribed matters – This limited application does not extend to invoking Section 10 of the Code of Civil Procedure, 1908, to stay proceedings – The Apex Court has consistently held that Labour Courts are not Civil Courts of concurrent jurisdiction, and an industrial dispute cannot be equated with a civil suit – The invocation of Section 11 of the ID Act does not save an application seeking stay under Section 10 CPC – The Labour Court's rejection of such an application was justified. [Paras 11, 12, 13, 16]

Industrial Law – Speedy Adjudication – Interlocutory Orders – Discouraged – Industrial adjudication is founded on the objective of speedy and efficacious resolution of disputes – The Apex Court has repeatedly cautioned against entertaining challenges to interlocutory orders that stall proceedings and convert industrial adjudication into interminable contests – Allowing such petitions prolongs proceedings on unsustainable preliminary contentions, prejudicing workmen who have suffered dismissal and are pursuing statutory remedies for their livelihood and dignity – The writ jurisdiction of the High Court, though wide, is not meant for every procedural skirmish, especially when the statutory forum is competent to conclude proceedings – The High Court declined to interfere with the interlocutory order of the Labour Court. [Paras 14, 15, 16]

Industrial Law – Directions for Disposal – Time Limit – Considering the nature of the dispute and the hardship faced by workmen due to loss of livelihood, the Labour Court was directed to endeavor to decide the pending collective reference (Ref. No. 14 of 2024) along with the individual industrial disputes within an outer limit of six months from the date of receipt of the High Court's order – This direction aims to ensure that industrial justice is not rendered illusory by delay. [Para 17]

Decision: Appeal dismissed – Labour Court directed to decide pending reference and individual disputes within six months – [Paras 16, 17].

Patent Law – Deemed Abandonment – Section 21(1), Patents Act – Service of First Examination Report (FER) – Patent application rejected as abandoned due to non-filing of response to FER within prescribed and extended timelines – Petitioner contended that FER was not lawfully served as it was communicated only by e-mail and not by registered post under Section 149 – Held: Section 149 is permissive and not mandatory – Service by e-mail constitutes valid and lawful service under the Patents Act and Rules [Paras 7–10].

Statutory Interpretation – Use of Word ‘May’ – Service of Notices – Section 149 employs the word “may”, denoting discretion and not compulsion – No statutory mandate that service must only be by registered post – Legislative intent does not exclude electronic modes of service – Held: Postal service is not indispensable for triggering statutory timelines [Paras 7–8].

Patents Rules, 2003 – Validity of E-Service – Harmonious Construction – Rule-making power under Section 159(2)(vi) authorises prescription of modes of service – Rules 5 and 6 expressly recognise service by e-mail as lawful – Rules supplement and do not override the Act – Held: Act and Rules operate in harmony permitting exclusive service by e-mail [Paras 8–9].

Digitalisation of Patent Administration – Office Orders – Legal Effect – Patent Office Office Order No.23 of 2016 mandates issuance of FERs exclusively through e-mail – Applicants required to keep e-mail details updated – Consistent administrative practice reinforces validity of electronic service – Supported by Information Technology Act, 2000 [Paras 9–10].

Time-Bound Scheme under the Patents Act – Mandatory Compliance – Fixed timelines under Section 21(1) read with Rule 24-B are mandatory – Failure to respond to FER within statutory or extended period results in deemed abandonment – Courts cannot relax statutory deadlines in writ jurisdiction [Paras 11–12].

Belated Compliance – Effect – Attempt to file Form-4 long after expiry of prescribed period held impermissible – Once application deemed abandoned, it ceases to exist in law [Para 11].

Distinguishing Prior Precedents – Mandatory Manner Doctrine – Decisions cited on requirement of strict statutory compliance held inapplicable – No statutory prescription mandating postal service alone – Doctrine that an act must be done only in the prescribed manner does not apply where statute confers discretion [Para 13].

Decision: Writ Petition dismissed – Rejection of patent application on ground of abandonment upheld – Service of FER by e-mail held valid – No relief granted.

Tenancy Law  – Amendment of Pleadings – Subsequent Events – Article 227 – Interference Declined – Tenant challenged order permitting landlord to amend eviction petition after commencement of trial – Amendment sought to bring on record fact that tenant acquired another shop room in same locality suitable for business – Held: No illegality or perversity in order permitting amendment [Paras 1–4, 8–10].

Order VI Rule 17 CPC – Applicability to Rent Control Proceedings – Landlord sought amendment on ground of subsequent development which came to her knowledge only later – Amendment not claimed as matter of right but on showing due diligence – Rent Control Court justified in exercising discretion to allow amendment [Paras 2–3, 8–9].

Subsequent Events – Relevance in Rent Control Cases – Subsequent acquisition of another shop room by tenant in same municipality has direct bearing on eviction under Section 11(3) of the Act – Such events can be brought on record at any stage to enable court to mould relief and avoid multiplicity of proceedings [Paras 6, 9–10].

Due Diligence – Assessment – Objection of tenant that landlord had prior knowledge of subsequent event rejected – License issued by Municipality dated 01.09.2025 supported landlord’s plea that knowledge was acquired only recently – Plea of lack of due diligence not substantiated [Para 9].

Scope of Article 227 – Limited Supervisory Jurisdiction – High Court will not interfere with interlocutory orders of Rent Control Court unless there is patent illegality, jurisdictional error or perversity – Order permitting amendment found to be reasoned and bona fide [Paras 8–10].

Precedents – Subsequent Events – Reliance placed on Korah Abraham v. Varughis and Benjeena v. Pappachan – Subsequent events may be considered if they have fundamental impact on main issue and do not result in abuse of process – Principles applied to facts of present case [Paras 6, 9–10].

Decision – Original Petition dismissed – Order dated 26.11.2025 permitting amendment upheld – No merit found for exercise of supervisory jurisdiction under Article 227 [Paras 9–10].