Environmental Law – Development Project – Appellant involved in the Jal Mahal Tourism Infrastructure Project, focusing on the restoration and development of Mansagar Lake and its surrounding areas – High Court canceled the project citing violations of environmental norms and public trust doctrine – Supreme Court scrutinized the procedure and evidence presented by the appellant and government authorities, emphasizing the need for adherence to environmental regulations while balancing developmental objectives [Paras 1-118].

Public Interest Litigation – Delay and Malafides – Respondent's PIL filed years after project commencement, leading to substantial investments by the appellant – Supreme Court criticized the delay and questioned the bona fides of the PIL, noting suppression of facts and lack of prompt action – Court highlighted the importance of timely and genuine PILs to prevent undue prejudice to involved parties [Paras 39-50, 105].

Policy and Governance – Judicial Review – Supreme Court stressed the limits of judicial intervention in administrative decisions unless clear evidence of arbitrariness or illegality – Reaffirmed the importance of mutual respect among state organs and the need for courts to exercise restraint in matters involving complex policy decisions supported by expert assessments [Paras 117-118].

Decision: Appeals partly allowed – High Court’s order canceling the project set aside – Supreme Court mandated a balanced approach, allowing development while ensuring strict compliance with environmental and legal norms – Specific directions issued to ensure transparency and accountability in ongoing and future phases of the project [Para 118].

Criminal Law – Murder vs. Culpable Homicide – Private Defence – Appeal against conviction under Section 302 IPC – Examination of right of private defence as claimed by the accused – High Court's dismissal of appeal and affirmation of conviction by Trial Court for offences under Sections 302, 324 IPC and Section 27 of the Arms Act. Supreme Court re-evaluates evidence regarding the right of private defence – Finds no evidence supporting the claim of the accused acting in private defence – Held that the accused's actions did not meet the requirements for private defence and constituted culpable homicide not amounting to murder under Section 304 IPC instead of murder under Section 302 IPC – Conviction under Section 302 IPC set aside and replaced with conviction under Section 304 IPC. Sentence reduced to seven years rigorous imprisonment and fine of Rs. 5,000/-. [Paras 1-27]

Private Defence – Applicability – Analysis – Held – Accused’s claim of private defence unsupported by evidence – No reasonable apprehension of danger to body established – Evidence indicated that the accused was the aggressor – Statement of independent witness supports prosecution's case – Right of private defence not applicable when the accused was the aggressor. [Para 18-26]

Decision – Reclassification of Offence – Conviction under Section 302 IPC replaced with Section 304 IPC – Sentence modified to seven years rigorous imprisonment and fine of Rs. 5,000/- with further imprisonment of six months in default of fine payment – Convictions under Sections 324 IPC and 27 Arms Act upheld – Sentences to run concurrently. [Para 27-30]

Motor Vehicles Act - Compensation - Enhancement - Appeal against High Court's judgment enhancing compensation from Rs. 6,46,000/- to Rs. 18,22,000/- with interest at 7.5% per annum - Appellant, a student, sustained grievous injuries resulting in permanent disability affecting her future prospects - High Court determined notional monthly income at Rs. 6,000/-, deemed meager by Supreme Court considering appellant's academic performance and potential future income - Held that notional income should be Rs. 10,000/- per month with a 50% increase for future prospects - Total compensation recalculated to Rs. 30,93,000/- with 9% interest from the date of application - Appeal allowed with directions for deposit and disbursement of awarded amount. [Paras 1-26]

Compensation Assessment - Factors Considered - Held - Court considered age, academic performance, potential future income, and nature of injuries - Applied principles from prior judgments (Raj Kumar, Govind Yadav, Santosh Devi) - Acknowledged inflation and future prospects - Enhanced compensation under heads of loss of earning, pain and suffering, loss of amenities, and loss of marital prospects - Award included cost of litigation. [Paras 10-24]

Decision - Enhanced Compensation - Directed Insurance Company to deposit 50% of awarded amount in a nationalized bank for 3 years with liberty to appellant for withdrawal as needed - Remaining 50% to be paid within four weeks - Compliance report to be submitted within five weeks - Appeal allowed with no costs. [Paras 24-26]

Consumer Protection – Vires of Regulations – Constitutionality of Regulation 15 – Review Application Procedure – Appeal against High Court’s dismissal of writ petition challenging Regulation 15 of Consumer Protection Regulations, 2005 – Appellant contends Regulation 15 is ultra vires the Consumer Protection Act, 1986 – Supreme Court examines power of National Commission to frame regulations under Section 30A – Held, Regulation 15 valid and within jurisdiction – Regulation 15(2) allows for review applications to be decided by circulation, not necessarily requiring oral arguments – No violation of natural justice principles found – Appeal dismissed. [Paras 1-12]

Right to be Heard – Natural Justice – Applicability to Quasi-Judicial Bodies – Appellant's assertion of denial of right to oral hearing in review proceedings – Court finds no inherent right to oral hearing – Regulation provides discretion to National Commission – No curtailment of consumer rights observed – Procedural fairness maintained – Review by circulation not inconsistent with principles of natural justice. [Paras 6-10]

Proxy Counsel – Legal Standing – Appellant challenges National Commission's restriction on proxy counsel – Court affirms restriction – Proxy counsel not defined in Advocates Act – National Commission’s direction upheld – Does not violate Article 19(1)(g) of Constitution – Ensures representation by authorized legal practitioners. [Para 11]

Decision: Appeal dismissed. Regulation 15 of Consumer Protection Regulations, 2005 upheld as valid. National Commission's procedure for review applications by circulation without oral arguments deemed lawful and consistent with principles of natural justice. Restrictions on proxy counsel affirmed.

Criminal Law – Further Investigation – Special Leave Petition challenging High Court order upholding Additional Sessions Judge's decision concerning further investigation – Petitioner sought direction for recovery of stridhan and a palmtop communicator – Supreme Court finds no infirmity in the lower court's orders – High Court's refusal to interfere with revisional court's direction for investigation by concerned police officer upheld – Petition dismissed at admission stage. [Paras 1-9]

Recovery of Stridhan – Directions for Further Investigation – Analysis – Held – Additional Sessions Judge partly allowed further investigation but set aside direction to investigate specific items (stridhan and palmtop) by a particular officer – High Court upheld this approach, finding it inclusive of all circumstances – Supreme Court concurs, noting no prejudice to Petitioner as investigation steps were already taken. [Para 9]

Decision – Dismissal of Special Leave Petition – Court finds the petition lacks bonafide intent, aimed more at vexing Respondent rather than genuine recovery of stridhan – Investigation conducted did not show lacunae – No further directions necessary – SLP dismissed. [Paras 8-9]

Land Reforms - Deemed Tenancy - Requirements - Civil Appeal against High Court order rejecting claim to be deemed tenant under Section 4A of the Kerala Land Reforms Act - High Court found no valid mortgage deed as basis for possession claim - Appellant’s mother a minor at time of mortgage execution - Possession under mortgage deed not established - Held, mortgage deed invalid as mother was not of majority age and not represented by a guardian - Possession not delivered under the deed as required for usufructuary mortgage - Concurrent findings by Land Tribunal and Appellate Authority erroneous - Appeal dismissed. [Paras 1-25]

Validity of Mortgage - Analysis - Held - Mortgage deed executed in favor of appellant’s mother found void ab initio - Mother a minor at time of execution - Competency to contract under Indian Contract Act not met - Even if valid, mortgage found to be a simple mortgage with no possession delivered under the deed. [Paras 9-12]

Concurrent Findings of Fact - Reversal - Held - High Court correctly reversed concurrent findings of lower authorities - Lower authorities failed to consider material facts and legal requirements - High Court’s exercise of revisional jurisdiction valid and justified. [Paras 13-14]

Decision - Dismissal of Appeal - Appellant’s claim as deemed tenant under Kerala Land Reforms Act rejected - Mortgage deed found invalid and no possession established under deed - High Court’s judgment upheld - Appellant advised to seek resolution of ownership rights in appropriate forum. [Paras 14-15]

Doctrine of Frustration – Lease Agreements – Contractual Disputes – Frustration of Contract – Breach of Contract – Civil Remedies: The Supreme Court dealt with the enforceability of lease agreements and BOT contracts where subsequent governmental decisions and the expiration of the lease term caused frustration of the contract. The court held that the doctrine of frustration applies where the lease ends by efflux of time and MPRTC's heavy indebtedness prevented continuation. The appeal for specific performance of contract under Article 226 was declined, directing the appellants to pursue civil remedies for breach of contract. [Paras 54-59]

Scope of Judicial Review – Contractual Matters – Public Interest: The court emphasized the limited scope of judicial review in contractual matters, especially where one party is a state or its instrumentality. It reiterated that judicial review should be confined to legality and fairness, and not to the merits of the contract. The court further noted the necessity of maintaining public interest over contractual obligations when state instrumentalities are involved. [Paras 51-52]

Privity of Contract – Lease Renewal – Contract Construction – Rights of Parties: The court found no privity of contract between Sri Ram Builders and IDA, thus denying specific performance claims. It was clarified that lease renewal requires express consent of the lessor and is not automatic. The court ruled that MPRTC's unauthorized creation of third-party rights for premium collection was invalid. [Paras 53-55]

Decision: The Supreme Court dismissed the appeals, upholding the High Court's decision that directed Sri Ram Builders to seek civil remedies for breach of contract. The court affirmed the principle that contractual disputes involving public entities and public interest should be cautiously handled under Article 226. [Para 61]

Criminal Law - Conviction and Sentencing - Criminal Appeal challenging the death sentence - High Court affirmed the death sentence and conviction for murder and attempted rape - Appellant's young age (21 years) and no past criminal antecedents considered - Supreme Court commuted death sentence to life imprisonment due to possibility of reformation - Other convictions and sentences affirmed. [Paras 1-48]

Evidence - Circumstantial Evidence - Held - Strong circumstantial evidence linked the appellant to the crime - Sniffer dog tracking, recovery of blood-stained clothes, and past misconduct with the victim established guilt - Statement under Section 27 of the Evidence Act corroborated by other evidence. [Para 30]

Sentencing - Mitigating Factors - Age of the appellant (21 years) and potential for reformation considered - Court held that the case did not fall under "rarest of rare" category warranting death penalty - Life imprisonment substituted for death sentence. [Paras 42-47]

Decision - Sentence Commuted - Supreme Court commuted the death sentence to life imprisonment considering the mitigating factors and affirmed other parts of the conviction and sentence. [Para 48]

Criminal Law - Dowry Death – Conviction under Section 304B IPC – Appeal against High Court’s dismissal of appellant’s challenge to conviction and sentence by Trial Court – Appellant convicted for persistent demands for dowry and cruelty leading to wife's suicide within four years of marriage – Appeal dismissed, confirming findings of lower courts. [Paras 1-25]

Provisions and Presumptions – Analysis of Sections 304B IPC and 113B Evidence Act – Held – Prosecution successfully established that death was caused by poison and occurred within seven years of marriage – Evidence showed cruelty and harassment soon before death, fulfilling requirements for presumption of dowry death. [Para 10-20]

Evidence – Weight and Admissibility – Testimonies of deceased’s mother and mediator – Corroborated by medical evidence indicating death by pesticide poisoning – Rejection of appellant’s defence of death due to pregnancy complications – Persistent demands for dowry and harassment proven. [Paras 18-20]

Decision – Appeal Dismissed – Conviction and sentence under Sections 304B and 498A IPC upheld – Appellant to be taken into custody to serve remaining sentence. [Paras 21-24]