Land Acquisition – Compensation – Exemplar Allotment by Beneficiary Body – Valid Basis – Enhanced – Supreme Court held that GIDC’s own allotment of nearby Plot No. 7/1 at ₹180/sq. mt. (1988) for commercial use is a valid exemplar for valuation of appellants’ acquired agricultural land – Allotment considered sufficiently proximate in time and location to use as base rate with adjustments [Paras 6–10, 14].

Market Value Determination – 5% Increment for One-Year Gap – 50% Deduction for Development and Size – Applied – Court granted 5% increase to ₹190/sq. mt. to account for time gap between exemplar allotment and acquisition notification (1989), and applied 40% deduction for development plus 10% for largeness – Final rate fixed at ₹95/sq. mt. [Paras 10–14].

Claim for Fruit Trees – No Evidence of Income – No Additional Award – Appellants claimed higher compensation for fruit-bearing trees (lemon, mango, guava) – Court found no proof of yield or sale income – APMC report only confirmed existence of trees – Compensation of ₹1,06,300/- as awarded by SLAO affirmed [Para 15].

Standard of Valuation – Judicial Guesswork Permissible – Precision Not Required – Court reiterated that market valuation involves judicial estimation and approximation – Not an algebraic exercise – Broad principles and prudence sufficient [Paras 11, 13].

Decision: Appeal allowed partly – High Court’s judgment dated 14.08.2015 and Reference Court’s award modified – Compensation for acquired land enhanced from ₹30 to ₹95 per sq. mt. – SLAO’s award revised accordingly – All statutory benefits and interest to be granted as per law – No additional compensation for trees [Paras 17–18].

Motor Accident Claim – Bilateral Amputation – Compensation Enhanced – Appeal Allowed – Appellant, a B.D.O., lost both legs in a road accident while riding pillion – Tribunal awarded ₹7.5 lakhs; High Court upheld the award after attributing contributory negligence to the scooter driver – Supreme Court held that the finding of contributory negligence was erroneous and unsupported by evidence – Full liability of ₹16 lakhs directed to be paid by insurer [Paras 2–14, 17–18].

Negligence – No Contributory Negligence Proven – Learner’s Licence Not Conclusive – Driver’s licence status alone cannot establish negligence – High Court’s finding that scooter driver had better visibility and B.D.O. abused his authority was held speculative and unsubstantiated – Supreme Court found evidence clearly established trailer driver's negligence as sole cause of accident [Paras 8–13].

Compensation – Prosthetics, Attendant, Medical Expenses – Future Cost Recognised – Court accepted that the cost of prosthetics, its wear and tear, medical expenses, and need for a personal attendant justified awarding full claim – ₹16 lakhs compensation granted under composite heads including ₹9 lakhs for medical/prosthetics and ₹5 lakhs for disability and loss of amenities [Paras 15–16].

Legal Principle – Standard of Proof – Preponderance of Probability in Tort – Court reiterated that motor accident claims are not adversarial and rely on preponderance of evidence – Surmises or speculative reasoning not sufficient to deny compensation [Paras 11–12].

Interest – 7% Simple Interest from Date of Award – ₹25,000 under Section 140 to be Adjusted – Insurance company directed to compute and deposit full amount within two months via RTGS/NEFT on receiving bank details from appellant [Paras 17–18].

Decision: Appeal allowed – Finding of contributory negligence set aside – Full compensation of ₹16,00,000 awarded with 7% simple interest from date of award – Amount under Section 140 to be deducted – Directions issued for timely disbursal by insurance company [Paras 17–18].

Civil Law - Gift vs. Will – Determination of Nature of 1985 Document – Settlement Deed Held Valid – Despite the document being titled as a Will by the father, the Supreme Court held that its content, structure, and operative clauses evidenced a gift/settlement in praesenti – The donor retained life interest and limited rights, but unequivocally conveyed ownership to the daughter – The High Court rightly reversed concurrent findings of the lower courts – Held: The deed conveyed vested rights in praesenti and cannot be treated as a Will [Paras 10-15.2].

Acceptance of Gift – Proof from Conduct – Gift Upheld – The donee had presented the gift for registration and was in possession of the original deed – These acts amounted to valid acceptance under Section 122 – Delivery of physical possession not essential for a valid gift – Conduct evidenced acceptance and made the gift irrevocable [Paras 6.1, 6.2, 6.4, 11.1, 14.1, 15.2, 18].

Unilateral Revocation of Gift – Not Permissible – Cancellation Deed Void – Defendant No.1 (father) could not unilaterally cancel the 1985 gift/settlement – The cancellation deed and the subsequent sale deed executed in 1993 were declared void and non-binding on the donee – Held: Once accepted, a gift cannot be revoked unilaterally unless specifically provided in the instrument [Paras 6.4, 11, 14.1, 18].

Possession and Mutation Entries – No Presumption of Ownership – Appellant’s Reliance on Possession Invalid – Possession and revenue record mutation post-sale deed in favour of appellant did not establish ownership – Such entries only indicate who pays revenue and carry no presumption of title [Paras 6.6, 18].

Composite Nature – Gift and Settlement Elements – Retention of Life Interest Not Fatal – A document may contain elements of both gift and settlement – Reservation of life interest does not negate the immediate transfer of ownership – Nomenclature is irrelevant; content determines character – Document must be read harmoniously to give effect to the transfer [Paras 11.3-11.5, 14,

15.2].

Final Decision – Appeal Dismissed – Gift/Settlement Confirmed – The Supreme Court affirmed the High Court’s judgment – Ext.A1 document declared a valid settlement deed – Cancellation and sale deeds held invalid – Appeal dismissed with no order as to costs [Paras 20-21].

Criminal Law – Registration of FIR - Inquest Proceedings under Section 174 CrPC – Limited Scope – Not a substitute for Investigation – Held: The purpose of an inquest under Section 174 CrPC is limited to determining the apparent cause of death and cannot substitute a criminal investigation when complaints disclose cognizable offences – Mere conclusion by police that deaths were due to depression does not justify non-registration of FIR – Inquiry under Section 174 does not extinguish the statutory duty under Section 154 CrPC [Paras 21-24].

Registration of FIR – Mandatory Duty under Section 154 CrPC – Held: When complaints disclose a cognizable offence, police is statutorily bound to register an FIR – Preliminary inquiry not permitted – Delhi Police’s failure to register FIRs in both cases despite serious allegations of caste-based discrimination and possible abetment of suicide was in violation of Lalita Kumari and Bhajan Lal principles [Paras 30-34, 39-40, 46].

SC/ST (Prevention of Atrocities) Act – Applicability of Section 18A – Held: The Act mandates registration of FIRs without any preliminary inquiry – Allegations of caste-based atrocities fell squarely within the framework of the Act – Police and institutional inaction violates statutory and constitutional duties [Paras 42-43, 46].

Hostel Deaths – Alleged Murders Mischaracterized as Suicides – Allegations ignored – Held: Written complaints by victims’ family members alleging murder, caste-based abuse, suspicious circumstances (e.g., signs of physical assault, bleeding, position of body) were dismissed without proper investigation – Police relied on postmortem and general statements to prematurely close the cases [Paras 3-6, 13-14].

Institutional Response – Failure of IIT Delhi to Investigate or Support – Held: IIT Delhi failed to initiate any impartial internal inquiry into allegations – No record of providing support or engaging with victim families – Delay in informing families, lack of transparency in crisis management highlighted systemic apathy [Paras 5-10, 15-17].

Educational Institutions – Duty of Care and Support – Held: Institutions are expected to act as ‘loco parentis’ and must proactively safeguard mental health of students – Failure to respond to early signs of distress or discrimination can lead to tragic consequences – Emphasized that IITs and similar institutions must establish systems to detect and prevent student suicides [Paras 47, 66].

Mental Health and Student Suicides – National Concern – Held: Rise in student suicides, especially among marginalized communities, is a systemic issue – Court recognized academic stress, discrimination, and lack of institutional empathy as root causes – Emphasized need for national reforms and accountability in higher education [Paras 53-58, 67-69].

Constitution of National Task Force – Held: Court directs setting up of an expert body to study causes of student suicides and recommend institutional reforms – Task Force to include psychiatrists, academics, and experts in education and equity – Interim report to be filed in four months; final in eight months – Supreme Court to monitor compliance [Paras 69-83].

Decision – FIRs Directed to be Registered – Appeal Allowed – Held: Complaints disclose cognizable offences under IPC and SC/ST Act – Police directed to register FIRs and commence investigation – Probe to be conducted by officer not below Assistant Commissioner of Police – Supreme Court retains seisin of the matter for monitoring investigation and implementation of institutional reforms [Paras 48, 84].
 

Criminal Law - Murder – Common Intention – Conviction Under Section 302/34 IPC – Conviction Upheld – The appellant along with two co-accused allegedly assaulted the deceased with a knife leading to his death – Courts below found consistent eyewitness accounts confirming the appellant’s presence and role – Minor discrepancies in witness statements were not found fatal – Held:

Conviction under Section 302 read with Section 34 IPC justified – Benefit of Section 304-I not applicable due to appellant being armed with knife indicating prior intent [Paras 3, 6, 20, 23].

Delay in Recording Statements – Explanation of Riot and Law-and-Order Issues – No Adverse Inference – Delay of 2/3 days in recording eyewitness statements under Section 161 CrPC explained due to communal tension and police’s focus on restoring law and order – Held: Delay not fatal to prosecution where satisfactorily explained [Paras 21].

Non-examination of Informant as Prosecution Witness – Informant Examined as

Defence Witness – No Prejudice – Trial Court had benefit of her testimony which aligned with FIR and other eyewitness accounts – Held: No adverse inference due to party examining her as defence witness instead of prosecution [Para 22].

Remission and Premature Release – Right to Consideration Under Applicable Policy – Liberty to Apply Afresh – Appellant had completed over 14 years of actual imprisonment and over 20 years with remission – Rejection based on incorrect interpretation of policy (requiring 24 years including remission) – Held: Appellant may file fresh representation which shall be considered in light of law and beneficial policy in force at time of eligibility [Paras 24-30].

Final Decision – Appeal Dismissed – Conviction and sentence under Section 302 IPC confirmed – Liberty granted to appellant to reapply for remission, to be considered expeditiously within three months [Paras 31].

Criminal Law - Rape Allegation – Promise of Marriage – Quashing of Proceedings – Appeal Allowed – The appellant sought quashing of criminal proceedings alleging rape and cheating on the ground that the relationship was consensual and the alleged promise of marriage, if any, came post facto – Supreme Court found that there was no inducement through false promise of marriage preceding the sexual relationship – The complainant’s own statements did not reveal coercion or inducement prior to intercourse – Held: Continuation of prosecution would amount to abuse of process – Proceedings quashed [Paras 7-13].

Consent and Coercion – Inconsistent Allegations – Statements of Victim Contradictory – The Court noted the victim’s repeated voluntary visits to the hotel and lack of immediate complaint despite alleged trauma – The allegations of coercion and forceful intercourse were held to be incompatible with the surrounding circumstances – Held: The narrative was inherently improbable and prosecution unsustainable [Paras 8-12].

Exercise of Inherent Powers – Section 482 CrPC – Justified in Exceptional Cases – Supreme Court emphasized that continuation of baseless prosecution would violate fairness and liberty – Held: This was a fit case for exercise of inherent powers under Section 482 to quash the trial pending before the Sessions Judge, Mahila Court, Erode [Para 13].

Final Decision – Appeal Allowed – Proceedings in S.C. No. 49 of 2022 quashed – Pending applications disposed of [Paras 14-15].

Civil Law – Title Suit – Declaration and Possession – Appellants' claim over suit land based on court auction in 1970 followed by sale deed and continuous possession – Trial Court decreed in appellants' favour but High Court reversed citing lack of documentary proof of original assignment to Govindu – Supreme Court held appellants established continuous possession and title through court auction and registered sale deed – State failed to prove legal resumption or title – Held: Appellants’ possession since 1970 and supporting evidence establish title – State’s claim of assigned land not supported by credible documents – Appellants entitled to compensation in lieu of land due to public construction [Paras 6–7, 16–18, 25–29, 85–86, 114–115]​.

Possession and Ownership – Presumption under Section 110 Evidence Act (now Section 113 of BSA, 2023) – Appellants in uninterrupted possession since 1970 – State unable to rebut presumption of ownership by proving its title – Court reiterated that possession raises prima facie presumption of ownership – State’s inability to show resumption order or patta documents undermines its claim – Held: Burden was on State to prove lawful resumption and ownership, which it failed to discharge [Paras 83–85]​.

Resumption Proceedings – Legality and Procedure – State claimed land was resumed in 1989 as assigned land under a conditional patta issued in 1943 – No resumption records or D-form patta were produced – DW1 (Mandal Revenue Officer) admitted issuance of patta passbook and revenue receipts to appellants – Held: Absence of resumption documentation renders takeover of land illegal – Constructed government building cannot defeat appellants’ right to compensation [Paras 18, 23, 114–116]​.

Limitation and Delay – Suit filed in 1996 for recovery of possession – State contended suit was barred due to 1989 resumption – Supreme Court observed appellants' uninterrupted possession until dispossession, and that State failed to prove due process of resumption – Held: Suit was maintainable and not barred by limitation as possession and cause of action were sufficiently proved [Paras 4, 114]​.

Government Land vs Private Title – Differentiation – Court emphasized difference between Land Patta Holders and Government Allottees – Highlighted that Pattadars have heritable, transferrable rights, whereas government assignees may not – In this case, appellants were recognized as Pattadars with legal standing under the 1971 Act – State could not produce assignment documents or invoke 1977 Act restrictions retroactively [Paras 40–44]​.

Compensation – Relief granted in lieu of land restoration – Court declined to order restoration of possession due to longstanding construction – Directed State to compensate appellants monetarily for wrongful dispossession of legally held land – Applied equitable principles where public purpose construction already completed [Paras 114–116]​.

Right to Property – Article 300-A of Constitution – Protection Against Deprivation Without Authority of Law – State Cannot Resume Land Without Due Process – Even if land is assigned, it is “property” under Article 300-A – Appellants held Pattadar Passbooks and paid land revenue – Held: The deprivation of property by the State without lawful authority violates Article 300-A – Compensation is constitutionally mandated [Paras 123-126].

Unconstitutional Conditions – No Compensation Clause in Assigned Land Patta – Clause Held Invalid – A clause in patta that deprives assignees of compensation on resumption was held unconstitutional – Violates fundamental rights under Articles 14, 21 and 31-A – State must not impose conditions requiring surrender of constitutional rights to receive government benefit – Held: State must compensate assignees at full market value even on resumption [Paras 115-122].

Section 80 CPC – Mandatory Statutory Notice – State Ignored Legal Notice – Adverse Inference Drawn – Appellants had issued valid notice under Section 80 CPC before filing suit – State failed to respond or act on it – Held: Statutory notice under Section 80 is not a mere formality; lack of response is against public policy and can attract adverse inference in trial [Paras 93-113].

Decision: Appeal allowed – High Court judgment set aside – Appellants held to have lawful title and possession – Entitled to compensation for deprivation of land due to illegal resumption by State.

CBI Investigation – Jurisdiction of High Court – Direction Set Aside – The High Court while granting bail directed CBI investigation based on a statement under Section 161

CrPC – Supreme Court held that such a direction in a bail proceeding exceeded jurisdiction under Section 439 CrPC – Held: No exceptional circumstance justified invoking extraordinary power – Direction to CBI quashed [Paras 2, 6-8].

Scope of Bail Jurisdiction – Improper Extension to Investigative Oversight – The High Court issued directives after bail was granted by relying on unverified statements and confronting the Investigating Officer in court – Held: The jurisdiction in bail ends with the decision on bail and cannot extend to supervising or altering the course of investigation [Paras 3, 6-7].

Precedents on Jurisdictional Limits – Reaffirmed – The Court relied on earlier decisions including State of West Bengal v. CPDR, M. Murugesan, Seemant Kumar Singh, and

Man Singh Verma – Held: Courts must refrain from overstepping their statutory jurisdiction in criminal proceedings [Paras 3, 6].

Final Decision – Appeal Allowed – Impugned order set aside to the extent of CBI direction – Bail not opposed by State and left undisturbed – No interference with investigation facts [Paras 8-9].

Criminal Law - Unlawful Assembly – Mere Presence at Scene – Reversal of Acquittal Set Aside – Accused Appellants Not Proven to Be Part of Mob – The appellants were named in the FIR and arrested at the spot during a riot involving over 1000 people – The High Court reversed their acquittal based solely on presence at the crime scene – Held: Mere presence, without overt act or incriminating material, does not establish membership of an unlawful assembly – Acquittal restored [Paras 11, 15, 16]. 
 
Standard of Proof – Reversal of Acquittal – Caution in Appeal Against Acquittal – No New Evidence or Infirmity in Trial Court’s View – The Trial Court found prosecution evidence perfunctory and acquitted all accused – High Court’s interference was unjustified as there was no compelling reason to overturn a plausible acquittal finding – Held: High Court erred in reversing acquittal without concrete evidence [Paras 11, 12, 17]. 
 
Evidentiary Value – Testimony of Prosecution Witnesses Discarded – PW-2 and PW-4 Found Unreliable – The High Court itself discarded the only eye-witnesses for lack of credibility – No identification parade was held – Accused named after 2 years – Held: Conviction cannot rest on such testimony [Paras 5, 6, 15]. 
 
Innocent Bystander Doctrine – No Evidence of Overt Act or Common Object – Appellants Were Residents of the Village – Without Prohibitory Orders, Presence Not Incriminating – Held: Accused cannot be convicted merely for being present at the riot scene unless active participation is proved [Paras 13-15]. 
 
Judgment – Appeals Allowed – High Court Judgment Reversed – Trial Court Acquittal Restored – Supreme Court held that the appellants were wrongfully convicted by the High Court and reinstated their acquittal as recorded by the Trial Court – Appeals allowed [Paras 17-18].