Criminal Procedure – Production of Documents – Petitioners, accused of double murder, sought scientific test reports of former suspects – Trial court and High Court rejected request, deeming it dilatory – Supreme Court upheld decisions, noting repeated delays by petitioners and procedural stage of trial [Paras 1-12].

Right to Fair Trial – Relevance of Scientific Evidence – Petitioners argued reports were essential for defense – Supreme Court referenced fair trial principles under Article 21, but found no breach as documents were deemed non-essential and requests intended to delay proceedings [Paras 10-11].

Section 91 CrPC – Summoning Documents – Court reiterated documents must be necessary and relevant – Petitioners failed to justify urgency and necessity for defense – Requests viewed as attempts to vex proceedings [Paras 5-9].

Decision: Special Leave Petition dismissed – Supreme Court emphasized the necessity of expeditious trials and disallowed further delay tactics by the petitioners.

Constitutional Law – Reservation for Disabled Persons – Section 33 of the Persons with Disabilities Act mandates 3% reservation in government establishments – High Court directed reservations to be computed based on total cadre strength, not just identified posts – Supreme Court affirmed, emphasizing legislative intent to ensure adequate representation of disabled persons [Paras 26-53].

Administrative Law – Implementation of Disability Reservations – Union of India contested High Court’s interpretation – Argued reservations should be on identified posts only – Supreme Court dismissed appeal, instructed modification of Office Memoranda to reflect correct computation method [Paras 51-53].

Horizontal Reservations – Relationship with Vertical Reservations – Court clarified distinction between horizontal reservations (for disabled persons) and vertical reservations (for SC/ST/OBC) – Affirmed that horizontal reservations cut across vertical reservations without breaching 50% cap on overall reservations [Paras 41-42].

Decision: Appeal dismissed – Supreme Court directed Union of India to modify Office Memoranda in line with the judgment and ensure compliance within three months – Emphasized non-compliance as an act of non-obedience [Para 54].

Criminal Law – Culpable Homicide – Appellant convicted under Section 304 IPC for causing death by firing a gun at a marriage ceremony – Prosecution's evidence mainly relied on FIR and witness testimonies – Supreme Court found insufficient evidence to attribute intent to kill, reduced conviction to Section 304 Part II IPC, highlighting that the act was done with knowledge likely to cause death [Paras 1-13].

Evidence – Witness Testimonies – Key witnesses did not clearly establish that the fatal shot came from the appellant's gun – Investigation was deemed slipshod, no ballistic report obtained – Court emphasized the need for concrete evidence to sustain conviction for culpable homicide [Paras 7-9].

Sentencing – Reduction of Sentence – Original sentence of life imprisonment under Section 304 Part I IPC found inappropriate – Supreme Court reduced sentence to seven years under Section 304 Part II IPC, maintaining the imposed fine [Paras 10-13].

Decision: Appeal allowed in part – Conviction modified to Section 304 Part II IPC – Sentence reduced to seven years' rigorous imprisonment – Fine of Rs. 1000 upheld, in default, further imprisonment for one year.

Contempt of Court – Erroneous Information – Appellants held in contempt for not providing required information regarding landowners who did not file objections under Section 5A of the Land Acquisition Act – Supreme Court found no deliberate intent to mislead, noting possible error of judgment – Apology tendered by appellants should have been accepted, emphasizing a broad and magnanimous view of the matter [Paras 11-13].

Contempt Jurisdiction – Principles of Exercise – Court reiterated that contempt power should be exercised with caution, restraint, and only when necessary – Emphasized that maintaining dignity and respect of the court is achieved through the quality of judgments and judicial conduct, not frequent use of contempt power [Paras 14-15].

Decision: Appeal allowed – High Court's order dated 31.01.2011 set aside – Apology of appellants accepted.

Election Law – Voter Verifiable Paper Audit Trail (VVPAT) – Appellant sought the introduction of VVPAT in EVMs to ensure accurate recording of votes – Supreme Court found that the introduction of VVPAT is necessary for free and fair elections, enhancing voter confidence in the electoral process – Directed phased implementation of VVPAT in forthcoming elections [Paras 28-31].

Constitutional Law – Right to Vote – Right to know that vote has been correctly recorded – Court emphasized that VVPAT system provides a means for voters to verify their vote, enhancing the transparency and trustworthiness of elections [Paras 29-30].

Administrative Directions – Financial Assistance – Directed Government of India to provide financial support for procuring VVPAT units – Allowed the Election Commission of India (ECI) to implement VVPAT in a phased manner, ensuring readiness for large-scale use [Para 31].

Decision: Appeal and writ petition disposed of – Supreme Court permitted ECI to implement VVPAT system in a phased manner for future elections – Government directed to provide necessary financial assistance.

Criminal Law – Murder – Appellant convicted for murder of his wife, Naina Sahni – Prosecution established that the appellant shot the deceased and attempted to dispose of the body by burning it in a tandoor – Appellant's presence at the scene and connection to the Bagia Restaurant confirmed by witnesses – Circumstantial evidence and forensic reports corroborated the prosecution's case [Paras 26-30].

Evidence – Forensic Analysis – Bullets recovered from the skull of the deceased matched appellant's licensed revolver – DNA tests confirmed the identity of the deceased – Blood samples and ballistic evidence substantiated the cause of death and the appellant’s involvement [Paras 13-16, 26-27].

Motive – Marital Discord – Prosecution proved motive by demonstrating that the appellant suspected his wife's fidelity and was reluctant to make their marriage public – Evidence of frequent quarrels and the appellant’s controlling behavior towards the deceased supported the motive [Paras 27-28].

Absconding – Conduct of Appellant – Appellant’s conduct post-crime, including absconding from Delhi and attempting to evade arrest, was considered as an incriminating circumstance – His arrest and the subsequent recovery of the weapon from his possession in Bangalore further implicated him [Paras 25, 29].

Decision: Appeal dismissed – Supreme Court confirmed the conviction and death sentence, emphasizing the completeness of the circumstantial evidence chain and the grave nature of the crime.

Excise Law – Grant of License – Appellant's application for liquor license filed in 1992, processed in 2004 – High Court ruled against renewal due to proximity to religious places and educational institutions within 1000 feet, as per amended Rule 8 of the 2003 Rules – Supreme Court upheld High Court's decision, emphasizing applicability of current rules at the time of license consideration [Paras 3-6, 12-13].

Retroactive Application of Rules – Pending Applications – Appellant argued that his 1992 application should be considered under 1993 Rules with a 300 feet restriction – Court noted circular dated 28.9.2005 applied to applications between 2003 and 2004, irrelevant to appellant's case – Rejected contention that 1992 application validly processed in 2006 under old rules [Paras 9-10].

Judicial Precedents – Application of Current Law – Court referred to established principle that rules in effect at the time of consideration apply, not at the time of application – Applied precedent from State of Kerala v. Kandath Distilleries [Para 12].

Decision: Appeal dismissed – Supreme Court confirmed High Court’s order prohibiting license renewal post-December 2013 – License found invalid under current rules due to proximity restrictions.

Property Law – Mortgage by Deposit of Title-Deeds – Appellants challenged the High Court's direction for mutation based on unregistered mortgage by deposit of title-deeds – Supreme Court held that such a mortgage does not require registration under Section 59 of the Transfer of Property Act and does not need payment of registration fee or stamp duty – Affirmed the High Court’s decision allowing mutation [Paras 12-17].

Registration and Stamp Duty – Applicability – The Court clarified that a memorandum of deposit merely recording the deposit does not require registration – However, a document detailing additional terms and conditions would require registration under Section 17(1)(c) of the Registration Act – No evidence was presented to show such an instrument existed in the present case [Paras 14-15].

Precedent – Cited Rachpal Mahraj v. Bhagwandas Daruka and United Bank of India Ltd. v. Lekharam Sonaram for the principle that the essence of mortgage by deposit of title-deeds is the delivery of documents to the creditor, and any accompanying memorandum not creating new rights does not necessitate registration [Paras 15-16].

Decision: Civil Appeal No. 9030 of 2013 dismissed – High Court judgment upheld, affirming that the mortgage by deposit of title-deeds does not require registration or payment of fees – Civil Appeal No. 9049 of 2013 allowed – Case remanded to High Court for fresh consideration regarding the applicability of the Transfer of Property Act, taking into account the locations specified in the notification [Paras 18-24].

Contract Law – Agreement to Sell – Plaintiffs filed a suit for specific performance based on an agreement to sell which included a recital that possession had been handed over – Defendants disputed the execution and possession transfer – Trial court found the agreement inadmissible for lack of proper stamping as a conveyance – High Court reversed, emphasizing defendants’ denial of possession [Paras 1-3].

Stamp Duty – Recital in Document – Supreme Court held that for admissibility, the recital in the document is decisive, not the adversary’s plea – Agreement with a possession transfer recital qualifies as "conveyance" under Section 2(10) of the Stamp Act and requires full stamp duty [Paras 9-10].

Admissibility of Evidence – Insufficiently Stamped Documents – Court upheld that an instrument not duly stamped cannot be admitted unless duty and penalty are paid as per Section 35 of the Stamp Act – Reversed High Court’s decision, reinstating trial court’s order on inadmissibility due to insufficient stamping [Paras 11-12].

Precedent – Cited Avinash Kumar Chauhan v. Vijay Krishna Mishra to affirm that instruments with possession transfer require appropriate stamp duty – High Court’s decision in Laxminarayan Porwal v. Omprakash Vairagi was overruled, confirming recitals in the document govern admissibility [Paras 12-13].

Decision: Appeal allowed – High Court's order set aside – Trial court’s order declaring the agreement to sell inadmissible for lack of proper stamp duty reinstated [Paras 15-16].