Criminal Law - Murder and Sexual Offence - Indian Penal Code 1860 - Sections 302, 201, 377 - Appellant convicted by Trial Court and High Court based on circumstantial evidence - Theory of last seen and extra-judicial confession - Supreme Court observed missing links in chain of circumstances - Discrepancies in testimony of witnesses regarding date of police encounter and alleged purchase of items - No DNA evidence linking accused to rectal swab - Disclosure statement held unreliable as it led to no new discovery - Held - Prosecution failed to prove guilt beyond reasonable doubt - Conviction set aside - [Paras 1-50].

Evidence Law - Circumstantial Evidence - Indian Evidence Act 1872 - Theory of last seen - Prosecution witnesses failed to establish consistent account of deceased being in company of accused - Suggestion during cross-examination cannot substitute for conclusive evidence - Held - Last seen theory not established by reliable testimony - [Paras 21-23, 33-36].

Evidence Law - Extra-Judicial Confession - Reliability - Extra-judicial confession made to Sarpanch held weak piece of evidence - Absence of independent corroboration - Discrepancy between date of alleged confession and testimony of witnesses stating police had already apprehended accused - Held - Confession does not inspire confidence - [Paras 18, 31-33, 43].

Evidence Law - Discovery - Indian Evidence Act 1872 - Section 27 - Recovery of incriminating articles - Accused allegedly identified spot after police had already prepared site plan - No new facts discovered pursuant to disclosure statement - Held - Section 27 not satisfied - [Paras 38-40, 44].

Evidence Law - Forensic Report - Expert opinion - Lack of DNA matching between semen on accused underwear and rectal swab of deceased - High Court erred in shifting onus of proof to accused to establish difference - Held - Prosecution failed to establish incriminating link - [Paras 45].

Decision: Appeal allowed - Judgment of conviction and order on sentence set aside - Appellant acquitted of all charges and directed to be released forthwith.

Criminal Law - Juvenile Justice - Juvenile Justice (Care and Protection of Children) Act 2000 - Section 7A - Claim of juvenility - Appellant convicted under Section 201 Part II IPC for causing disappearance of evidence - Plea of juvenility raised after conviction attained finality - High Court rejected plea citing bar of finality of litigation and limitation of inherent power under Section 482 CrPC - Supreme Court held that juvenility is a jurisdictional fact going to the root of the matter - High Court erred in over-relying on technical shackles when statutory benefit of juvenility was denied - Appellant proved minor on date of occurrence by school and panchayat records - Conviction and sentence set aside as illegal - [Paras 1-35].

Criminal Law - Procedural Law - Code of Criminal Procedure 1973 - Section 482 and 362 - Inherent powers of High Court - Recall of judgment - Court can exercise inherent power to prevent abuse of process or to secure ends of justice - Mistake of Court leading to denial of statutory right of a juvenile must be remedied - Ex debito justitiae mandate - High Court has power to recall order resulting in miscarriage of justice - [Paras 27-34].

Criminal Law - Juvenile Justice - Parens Patriae - Welfare of children - State duty to protect children from criminal stigma - Legislative intendment to extend benefit of JJA even if claim raised after final disposal - Courts obliged to adopt purposive interpretation - [Paras 10-24].

Decision: Appeal allowed – Judgment of conviction and sentence dated 21/12/2005 passed against the appellant set aside – Appellant discharged from bail bonds liability.

Criminal Law - Murder - Indian Penal Code 1860 - Sections 302 and 307 read with Section 149 - Six accused convicted for the murder of the deceased through indiscriminate firing- Prosecution case alleged an ambush on election day- High Court upheld convictions despite lack of cartridge recoveries and medical evidence contradicting eyewitness accounts regarding the posture of the victim during the attack- Supreme Court observed major gaps in investigation including the failure to seize blood-stained clothes or weapons- The Court noted the testimony was inconsistent and the motive projected was unsubstantiated- Held - Prosecution failed to establish guilt beyond reasonable doubt - Convictions set aside and appellants acquitted - [Paras 1-13].

Evidence Law - Eyewitness Testimony - Indian Evidence Act 1872 - Section 3 - Credibility of witnesses - Prosecution relied on testimonies of related witnesses- Eyewitness accounts provided conflicting chronologies of the ambush- Expert medical evidence indicated the deceased was shot from a close distance while sitting whereas witnesses claimed the deceased was walking- Held - Medical opinion contradicted eyewitness versions rendering the testimonies unreliable - [Paras 2-10].

Criminal Law - Investigation - Code of Criminal Procedure 1973 - Investigation integrity - Failure to collect forensic evidence such as cartridges or blood samples - Inquest carried out prior to registration of First Information Statement - I.O. failed to seize relevant incriminating items- The Court observed the investigation was not merely faulty but virtually non-existent - Held - Conviction cannot be based on suspicion or the perceived collusion of the I.O. without substantive evidence - [Paras 4-11].

Decision: Appeals allowed - Judgments of the courts below set aside - Appellants acquitted - Bail bonds cancelled - Appellants to be released forthwith if not required in other cases.

Civil Law - Execution of Foreign Decree - Code of Civil Procedure 1908 - Section 44A - Appellant sought execution of UAE court decree against Judgment Debtor NP and related entities - Alleged asset dissipation through complex corporate restructuring and merger - Respondents denied contempt and liability - High Court dismissed contempt plea holding statements were not binding undertakings - Supreme Court finding prime facie evidence of asset camouflage and potential for paper decree - Upheld refusal to initiate contempt but mandated additional security for decree satisfaction - Directed expeditious disposal of execution proceedings by Commercial Courts - Held - Status quo order modified subject to additional security of Rs 200 crores - [Paras 1-75].

Civil Law - Contempt of Court - Contempt of Courts Act 1971 - Section 2(b) - Undertaking - Whether statement in counter-affidavit constitutes an unconditional undertaking - High Court found no contempt - Supreme Court agreeing with finding that statement was merely clarificatory and not a firm, solemn, and express undertaking - Held - No contempt made out - [Paras 55-60].

Civil Law - Corporate Law - Companies Act 2013 - Section 230 - Merger and Amalgamation - Appellant objected to merger as an attempt to defeat execution - NCLAT reversed NCLT protective orders - Supreme Court observing that genuine apprehension of decree-holder warrants interim protection - Held - Protective measures concerning non-alienation of assets and notice to High Court restored - [Paras 68-69].

Civil Law - Execution - Code of Civil Procedure 1908 - Section 47 - Lifting of Corporate Veil - Whether family-controlled entities constitute a unified structure - Supreme Court leaving the issue of lifting the corporate veil open to be decided by the Commercial Courts on merits - Held - Commercial Courts not bound by prior observations of High Court or NCLAT in respect of the said contention - [Paras 74-75].

Decision: Appeals disposed of - Respondents directed to furnish additional security of Rs 200 crores within two weeks - Commercial Courts directed to decide main Execution Petition and all applications within four months.

Criminal Law - Banking Fraud - Indian Penal Code 1860 - Section 420 and 120B - Prevention of Corruption Act 1988 - Section 13(1)(d) and 13(2) - Appellant as Branch Manager sanctioned loans to third parties - Prosecution alleged criminal conspiracy and misappropriation by A2 using A4 and A5 as fronts - Trial Court and High Court convicted appellant - Supreme Court found that loans were sanctioned by Regional Office and not solely by appellant - Loan accounts were fully satisfied via auction of mortgaged property - Excess auction money remained with bank instead of being returned to heirs - Prosecution failed to prove any illegal act or personal gain by appellant - Held - Case is fully fabricated and lacks evidence - Conviction set aside - [Paras 1-20].

Criminal Law - Evidence and Proof - Indian Evidence Act 1872 - Section 3 - Burden of proof - Prosecution relied on assumptions regarding property valuation and loan nexus - No contemporaneous records produced to prove illegal overvaluation or conspiracy - Testimony of witnesses found to be irrelevant or hearsay - CBI failed to prove the basic premise of the case - Held - Prosecution failed miserably in both proving and framing the case - [Paras 15-19].

Decision: Appeal allowed - Conviction and sentence set aside - Appellant acquitted - Registry directed to hold records for monitoring the disbursal of excess auction funds to legal heirs - Case posted for further directions on 05/10/2026.

Writ Law - Judicial Service - Constitution of India - Articles 233 and 235 - Enhancement of superannuation age - Supreme Court addressed the persistent resistance by various State Governments to enhance the retirement age of District Judicial Officers from 60 to 62 years - Court reiterated that judicial officers exercise sovereign judicial power and are not mere employees - Held - Judicial service is a specialized cadre distinct from other State services and claims of parity by other government employees are legally untenable - States that have consented are directed to amend service rules within two months - Pending amendments judicial officers reaching 60 years shall not superannuate until 62 years subject to performance assessment by the High Court - Officers superannuated on or after 31/03/2026 granted option to rejoin - Non-consenting States directed to reconsider their stance within two weeks - [Paras 1-15].

Writ Law - Judicial Independence - Constitution of India - Article 235 - Suitability Assessment - Supreme Court approved the mechanism adopted by several High Courts to link the extension of service beyond 60 years with a rigorous performance assessment - Held - This process balances the retention of experienced judicial talent with the removal of deadwood to ensure only officers of proven integrity continue in service - [Paras 12-13].

Decision: Directions issued to States of Chhattisgarh, Karnataka, Madhya Pradesh, Maharashtra, Sikkim, Tamil Nadu, and West Bengal to amend rules within two months – Judicial officers reaching 60 years to continue until 62 years pending rule amendment subject to assessment – Option to rejoin for those superannuated after 31/03/2026 – Non-consenting States directed to file compliance reports within two weeks.

Taxation Law - Finance Act 1979 - Sections 35 35A and 38 - Foreign Travel Tax Rules 1979 - Rules 4 7 9 11 and 12 - Appellant airline penalized for delayed payment of FTT - Authorities imposed penalty for six instances of delay - On remand the adjudicating authority drastically increased the penalty from Rs 12000 to Rs 7129140 - High Court upheld the penalty as automatic upon breach - Supreme Court held that delayed payment is not equivalent to non-payment of tax - Section 38(3) applies to non-payment while Section 38(4) read with the Rules covers delay - Penalty is not automatic and adjudicating authorities must exercise discretion - The increase of penalty on remand violated the principle of reformatio in peius - Held - Penalties set aside - [Paras 1-56].

Civil Law - Statutory Interpretation - Finance Act 1979 - Section 38 - Penalty - Nature of penalty under fiscal statutes - Penalty is not automatic despite use of the word shall - Power to impose penalty includes power not to impose penalty - Mere breach of timeline does not render the imposition of penalty a foregone conclusion - Authorities must consider circumstances and bona fide conduct - Held - Order imposing penalty quashed - [Paras 40-41 46 53].

Civil Law - Appellate Procedure - Reformatio in Peius - Principle of equity - Appellant placed in a worse position after filing appeal due to enhancement of penalty by adjudicating authority on remand - Supreme Court affirmed that an appellant should not be worse off by reason of filing an appeal - Held - Penalty enhancement set aside - [Paras 51-54].

Decision: Appeal allowed - Impugned orders of the High Court and authorities below regarding the imposition and enhancement of penalty are set aside and quashed - Respondents directed to refund the penalty amount with 9 percent interest per annum within 3 months.

Writ Law - Right to Education - Right of Children to Free and Compulsory Education Act 2009 - Section 18 - Menstrual hygiene management in schools - Petitioner sought compliance with previous directions for menstrual hygiene facilities in schools - Union filed affidavit indicating varying degrees of compliance across States - Court found reporting deficient with instances of non-application of mind and mere formal statistical responses - Court mandated shift to biodegradable and compostable napkins complying with ISO 17088 and IS 5405 standards instead of oxo-biodegradable ones due to environmental concerns over microplastics - Held - States must report specific infrastructure gaps rather than aggregate achievements - [Paras 1-13].

Writ Law - Public Interest Litigation - Right of Children to Free and Compulsory Education Act 2009 - Section 18 - Rule 16(a) - Monitoring of school facilities - District Education Officers directed to conduct periodic inspections including anonymous student feedback to assess toilets, washing facilities, and menstrual hygiene support - Court noted discrepancies in State reports regarding saturation of facilities - States directed to identify specific gaps and timeframes for resolution - Held - Mandated surprise inspections by teacher teams to ensure genuine compliance - [Paras 14-23].

Environmental Law - Sanitary products - Standardization - Shift from oxo-biodegradable to biodegradable materials - Court recognized that oxo-biodegradable products degrade into microplastics exacerbating pollution - Direction issued to adopt biodegradable and compostable napkins made from sustainable materials like bamboo, jute, or corn - Held - States responsible for ensuring safety and effectiveness of products - [Paras 6-12].

Decision: Interim application disposed of with directions for States to report specific infrastructure gaps, identify causes of such gaps, and provide estimated timelines for completion. Future reports must include findings from surprise inspections conducted by teacher teams – Matter posted for 29.09.2026.

Criminal Law - Externment - Chhattisgarh Rajya Suraksha Adhiniyam 1990 - Section 5 and 8 - Violation of principles of natural justice - District Magistrate passed an ex parte order of externment upon reopening a closed case without issuing notice or affording an opportunity of hearing - Appellant was in judicial custody at the time of the order - High Court dismissed writ petition relegating appellant to statutory appeal - Supreme Court held that the order was void ab initio for breach of statutory mandate of Section 8 and lack of jurisdiction to review a closure order - Held - Externment order and High Court judgment quashed - [Paras 1-36].

Writ Law - Maintainability - Constitution of India - Article 226 - Alternative remedy - High Court declined to exercise writ jurisdiction on the ground of availability of appeal under Section 9 of the Adhiniyam - Supreme Court held that where an order is ex facie vitiated by breach of principles of natural justice and want of jurisdiction the High Court should not relegate the party to alternative remedy - Held - High Court committed an abject failure to exercise jurisdiction - [Paras 16-27].

Criminal Law - Jurisdiction - Chhattisgarh Rajya Suraksha Adhiniyam 1990 - Section 5 - Administrative Review - District Magistrate recalled a closure order and passed an externment order - No statutory power exists for an administrative authority to review or recall its own order once proceedings are closed - Held - Authority exercised jurisdiction not vested in it by law - [Paras 25-26].

Criminal Law - Externment - Chhattisgarh Rajya Suraksha Adhiniyam 1990 - Section 5(b) - Conditions precedent - Requirement of offences involving force or violence - Allegations of insulting a religious figure do not fall under Chapters XII, XVI or XVII of the IPC - Held - Invocation of Section 5(b) was wholly misconceived and the order is not sustainable on merits - [Paras 29-30].

Decision: Appeal allowed - Impugned judgment of the High Court and the externment order passed by the District Magistrate are quashed - Appellant is free to enter the districts from where his externment was ordered.