Constitutional Law – Article 14 – Equality before Law – Respondents challenged Clause (d) of Article 45 Schedule 1-A of the Indian Stamp Act, 1899 (as amended by the Madhya Pradesh Amendment Act, 2002) which prescribed stamp duty at 2% on the market value of property when the power of attorney was given without consideration to persons other than close relatives – High Court held the clause violative of Article 14 as arbitrary and unreasonable – Supreme Court reversed the High Court’s decision, upholding the provision as valid and not discriminatory – Legislative classification between close relatives and others was deemed rational and had a direct nexus to the object of the Act to prevent misuse of power of attorney for property transfers [Paras 1-31].

Taxation – Stamp Duty – Constitutional Challenge – Stamp duty provision challenged on grounds of unreasonableness – Supreme Court emphasized judicial restraint in striking down legislative enactments – Held that in fiscal matters, the Legislature enjoys greater latitude for classification – Provision aimed at curbing misuse of power of attorney for property transfers upheld [Paras 13-31].

Judicial Review – Scope – Constitutionality of legislative provisions – Courts must presume constitutionality and uphold statutes unless clear violation of constitutional principles – High Court’s reasoning found flawed due to failure to substantiate arbitrariness and irrationality claims [Paras 13-31].

Decision – Appeals allowed – High Court judgment set aside – Clause (d) Article 45 Schedule 1-A as amended by Madhya Pradesh Amendment Act, 2002, upheld – Writ petitions before the High Court dismissed [Para 31].

Environmental Law – Illegal Mining – Large-scale illegal mining and extraction of iron ore in Karnataka and Andhra Pradesh – Violations of environmental laws and forest degradation – Supreme Court directed Central Empowered Committee (CEC) to investigate and report on illegal activities – CEC identified serious irregularities, misuse of public office, and violations involving high-profile individuals, including the former Chief Minister of Karnataka [Paras 1-16].

Criminal Procedure – Investigation by CBI – Allegations of serious offences under IPC and Prevention of Corruption Act – Need for comprehensive investigation by specialized agency – Supreme Court directed CBI to investigate issues highlighted by CEC, including illegal land transactions and donations to educational societies linked to illegal mining profits – All pending proceedings related to these issues stayed [Paras 28-41].

Constitutional Law – Judicial Intervention – Supreme Court’s power to direct investigation by independent agency in matters of public interest – Importance of ensuring fair and unbiased investigation to uphold rule of law – Court emphasized its role in protecting environmental and national resources [Paras 42-44].

Decision – Directions issued to CBI – Investigation to be conducted by a special team headed by an officer not below the rank of Additional Director General of Police – CBI to submit report to the court within three months – Pending court proceedings stayed – All parties and state governments directed to cooperate with CBI investigation [Para 45].

Judicial Service – Disciplinary Proceedings – Appellant, Patna High Court, challenged the High Court’s decision that quashed the dismissal of Respondent, a judicial officer, for alleged misconduct – High Court set aside dismissal, reinstated Respondent with partial back wages – Supreme Court emphasized the importance of maintaining integrity and discipline within the judiciary – Upheld dismissal, stating the High Court on the administrative side had acted within its jurisdiction and the Division Bench exceeded its judicial review powers by interfering with the unanimous decision of the Full Court [Paras 2-17].

Scope of Judicial Review – Article 226 – Limited scope for interfering with disciplinary actions by High Courts against judicial officers – Supreme Court reiterated that interference is warranted only when there is a violation of principles of natural justice, statutory regulations, or if the decision is arbitrary or capricious – Emphasized the unique role of judicial officers in exercising sovereign judicial power and maintaining public trust [Paras 10-13].

Assessment of Judicial Officers – Annual Confidential Reports (ACRs) – Highlighted deficiencies in the current system of recording ACRs – Need for comprehensive and objective assessments to reflect true performance – Suggested reforms for uniformity and standardization in evaluating judicial officers [Paras 18-20].

Decision – Appeal allowed – High Court’s judgment set aside – Validity of dismissal notification upheld – No order as to costs [Para 20].

Criminal Law – Conviction Based on Circumstantial Evidence – Appellant Sandeep and co-accused Shashi Bhushan convicted for the murder of Jyoti, a pregnant woman – Case heavily reliant on circumstantial evidence, dying declarations, and forensic evidence – Trial Court and High Court found the evidence sufficient to convict both accused – Supreme Court upheld the conviction based on the chain of circumstances establishing guilt beyond reasonable doubt [Paras 1-35].

Dying Declaration – Admissibility and Reliability – Dying declaration made by the victim Jyoti shortly before her death was crucial to the prosecution’s case – Despite severe injuries, the victim’s statements were deemed reliable and were corroborated by other evidence – Supreme Court emphasized the importance of timely recording and corroboration of dying declarations in securing convictions [Paras 18-21].

Criminal Procedure – Delay in FIR and Forensic Evidence – Allegations of delay in altering the FIR and forwarding it to the Magistrate – Supreme Court held minor delays do not invalidate the FIR if the prosecution’s case is otherwise robust – Forensic evidence including DNA tests linking the accused to the crime was upheld as properly handled and reliable [Paras 31-34].

Sentencing – Rarest of Rare Doctrine – Death penalty imposed by the Trial Court and upheld by the High Court for Appellant Sandeep – Supreme Court modified the death sentence to life imprisonment with a minimum of 30 years without remission, citing the principles laid down in previous judgments on the 'rarest of rare' doctrine – Emphasized that while the crime was heinous, it did not meet the threshold for the death penalty [Paras 36-38].

Decision – Appeal partly allowed – Death sentence of Sandeep modified to life imprisonment with a minimum of 30 years without remission – Conviction and life sentence of co-accused Shashi Bhushan upheld [Para 39].

Military Law – Bias in Tribunal – Appellant challenged the composition of Court Martial on grounds of bias due to a pending complaint against the convening officer – Supreme Court held that mere suspicion or apprehension is not enough to establish bias – No reasonable grounds to believe the tribunal members were biased – Rejected the challenge to tribunal’s composition [Paras 13-23].

Natural Justice – Right to Defence – Appellant contended he was not provided with a defending officer of his choice – Supreme Court found no violation of principles of natural justice – Defending officer acted diligently and effectively – No prejudice caused to the appellant [Paras 24].

Evidence and Charges – Fraudulent Claims – Charges against Appellant for submitting false claims for transportation and Leave Travel Concession (LTC) – Supreme Court upheld the findings of guilt based on documentary and witness evidence – Rejected the contention of interpolation in bills and improper evidence handling [Paras 25-27].

Double Jeopardy – Recovery and Prosecution – Appellant argued recovery of excess amount from LTC claim precluded prosecution – Supreme Court held recovery does not bar prosecution under military law for misconduct and indiscipline – Rejected the plea of double jeopardy [Para 26].

Proportionality of Punishment – Sentence Review – Appellant argued the punishment was disproportionate – Supreme Court emphasized the need for strict discipline in the military – Upheld the sentence of cashiering and reduced imprisonment as proportionate to the seriousness of the misconduct – Doctrine of proportionality not applicable [Paras 28-32].

Decision – Appeal dismissed – Sentence of cashiering and reduced imprisonment upheld – Appellant’s contentions rejected [Para 33].

Human Rights – Enquiry into Allegations – Petitioner sought enquiry into allegations against the Chairman of the National Human Rights Commission (NHRC) under Section 5 of the Protection of Human Rights Act, 1993 – Allegations included owning benami properties, misuse of office, and false declarations – Supreme Court held that under Section 5(2), the President must first be satisfied based on the advice of the Council of Ministers before making a reference to the Supreme Court – Court directed the competent authority to take a decision on the petitioner's communication requesting an enquiry [Paras 1-7].

Constitutional Law – Writ of Mandamus – Petition for mandamus to compel the President of India to refer allegations to the Supreme Court for enquiry – Court held that the President’s satisfaction based on Council of Ministers' advice is a prerequisite for such a reference – Mandamus cannot be issued without this initial satisfaction [Para 6].

Administrative Law – President's Role in Enquiry – Role of the President of India in initiating an enquiry against NHRC Chairperson requires prima facie satisfaction and advice from the Council of Ministers – Detailed process ensures checks and balances before involving the Supreme Court [Paras 4-5].

Decision – Writ petition disposed of – Competent authority to decide on the communication requesting an enquiry into the allegations – President to act based on the advice of the Council of Ministers – Petitioner to be informed of the decision [Para 7-8].

Criminal Law – Murder Conviction – Appellant Abdul Nawaz convicted for the murder of a police officer during a scuffle while attempting to recover a dinghy used for illegal diesel extraction – Trial court and High Court upheld the conviction and life sentence – Supreme Court re-evaluated the evidence, particularly witness testimonies, and considered the application of Exception 4 to Section 300 IPC [Paras 1-8].

Witness Credibility – Statements of PWs 1 and 2 crucial – Minor discrepancies do not undermine overall reliability – Consistent evidence supports the sequence of events leading to the assault and drowning of the deceased [Paras 9-12].

Legal Doctrine – Exception 4 to Section 300 IPC – Sudden fight and lack of premeditation considered – Supreme Court found the incident occurred in a sudden fight in the heat of passion without cruel intent – Conviction altered from Section 302 IPC to Section 304 Part I IPC, recognizing culpable homicide not amounting to murder [Paras 13-16].

Sentencing – Proportionality – Sentence reduced to eight years of imprisonment under Section 304 Part I IPC, reflecting the nature of the act and the absence of premeditated intent to kill – Fine and default imprisonment sentence upheld [Para 17].

Decision – Appeal partly allowed – Conviction under Section 302 IPC set aside – Conviction under Section 304 Part I IPC imposed with an eight-year imprisonment sentence – Fine and default sentence affirmed [Para 17].

Dowry Death – Section 304B IPC – Conviction and life imprisonment for dowry death of appellant's wife – Prosecution established persistent dowry demands, cruelty, and unnatural death within seven years of marriage – Defence's claim of accidental death due to stove fire rejected as false and inconsistent – Conviction upheld [Paras 1-11].

Presumption under Section 113B Evidence Act – Presumption of dowry death applied as the death occurred under unnatural circumstances within seven years of marriage – Continuous harassment for dowry established through witness testimonies and letters from the deceased [Paras 7-10].

False Defence – Appellant's claim of accidental death contradicted by evidence – Absence of burn injuries on appellant and presence of injuries indicating a struggle supported prosecution's case – Conduct of absconding after the incident further incriminated the accused [Paras 12-16].

Sentencing – Life Imprisonment – No mitigating circumstances to reduce sentence – Heinous nature of the crime and the false defence presented by the appellant justified the life sentence – Appeal for lesser sentence rejected [Paras 17-18].

Decision – Appeal dismissed – Conviction and life sentence under Section 304B IPC upheld [Para 18].

Transfer of Criminal Case – Convenience of Parties and Witnesses – Petitioners, facing trial under the Prevention of Corruption Act, sought transfer of the case from Delhi to Thane – Majority of prosecution witnesses from Maharashtra – Petitioners based in Gujarat and Maharashtra – Supreme Court held that transfer would serve the ends of justice and convenience of parties and witnesses – Directed transfer to Thane [Paras 1-13].

Jurisdiction and Power of Transfer – Section 406 CrPC empowers the Supreme Court to transfer cases for the ends of justice – Convenience and expeditious trial considered – Transfer appropriate where majority of witnesses and parties are located in another jurisdiction [Paras 5-6, 8-11].

Precedent – Referenced cases on principles of fair trial and convenience – Established practice to consider location of witnesses and parties for transfer of cases – Cited cases: Abdul Nazar Madani v. State of Tamil Nadu, Capt. Amarinder Singh v. Prakash Singh Badal, Shree Baidyanath Ayurved Bhawan Pvt. Ltd. v. State of Punjab [Paras 8-11].

Decision – Petition allowed – Case transferred from Rohini Courts, New Delhi to the Court of Special Judge, CBI Cases, Thane, Maharashtra – Directions for expeditious trial [Para 13].