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].

Criminal Law – Dowry Death vs. Abetment of Suicide – Respondent convicted under Section 304B IPC for the death of his wife within seven years of marriage – High Court modified the conviction to Section 306 IPC and reduced the sentence to five years – Supreme Court upheld High Court’s decision, noting insufficient evidence of dowry harassment soon before the death [Paras 1, 3-4, 10-12].

Evidence – Presumption under Sections 113A and 113B – Court examined whether presumption of dowry death or abetment of suicide applied – Evidence showed harassment but did not clearly link to dowry demands – Presumption under Section 113B not applicable; Section 113A presumption of abetment upheld [Paras 8-9, 12-13].

Sentencing – Reduced Sentence Justified – Respondent’s sentence reduced from life imprisonment under Section 304B to five years under Section 306 due to lack of evidence for dowry death – Supreme Court found no reason to interfere with High Court’s judgment [Paras 13-14].

Decision: Appeal dismissed – High Court’s judgment convicting the respondent under Section 306 IPC and sentencing him to five years’ rigorous imprisonment with a fine upheld [Para 14].

Land Reforms – Tenant's Right to Occupancy – Appellant challenged the claim of Bhagirathi Bai (Respondent No. 2) to be registered as an occupant of the land under Section 45 of the Karnataka Land Reforms Act – Tribunal and High Court ruled in favor of the respondent, finding the land was used for agricultural purposes [Paras 1-4].

Assessment of Agricultural Use – Supreme Court noted that neither the Tribunal nor the High Court adequately addressed whether the land was agricultural on the "appointed day" as required – Spot inspection by the Tribunal in 1987 was irrelevant to the status of the land in 1974 – Directed re-examination of the issue [Paras 7-9].

Definition and Requirements – Court reiterated that to qualify under Section 45, a tenant must be an agriculturist personally cultivating the land on the appointed day – Definitions under Sections 2(11), 2(18), and 2(34) of the Act were emphasized in determining eligibility [Paras 7-8].

Decision: Appeal allowed – High Court and Tribunal's orders set aside – Matter remitted to the Tribunal for reconsideration in accordance with the observations on the requirements and status of the land on the appointed day [Paras 9-10].

Criminal Law – Conspiracy and Murder – Appellants convicted under Sections 302 and 120B IPC for conspiring and committing the murder of Sant Kumar Sinha – Prosecution established that appellants were part of the conspiracy with main accused Binod Kumar due to rivalry and illicit relationship issues – Supreme Court upheld conviction based on eyewitness and corroborative evidence [Paras 2-8, 16-17].

Evidence – Witness Credibility and Corroboration – Key witness Dr. Gopal Prasad Sinha identified appellants at the crime scene – Prosecution's case supported by medical evidence and seizure of vehicles used in the crime – Defence’s failure to discredit witness testimony or provide satisfactory explanation in Section 313 statements [Paras 9-13, 16-17].

Arrest and Recovery – Prosecution established appellants’ involvement through arrests and recoveries of vehicles used in the crime – Non-examination of arrest memo and panch witnesses deemed non-critical as defence did not raise the issue effectively during trial [Paras 10-12].

Decision: Appeals dismissed – Supreme Court affirmed the life imprisonment sentences imposed by lower courts, finding the evidence sufficient to prove conspiracy and involvement in the murder beyond reasonable doubt [Paras 19-20].

Civil Procedure – Return of Plaint – ONGC challenged the award of interest from the date of institution at Mehsana Court – Supreme Court held that when a plaint is returned under Order VII Rule 10 CPC, and refiled in a competent court, it is considered a fresh suit – Interest should accrue from the date of refiling, not from the original filing date [Paras 6-13].

Limitation – Section 14 of Limitation Act – Protection under Section 14 allows exclusion of the time spent prosecuting in a court without jurisdiction, but does not make the refiled suit a continuation of the original – Only court fees paid may be adjusted, but trial must proceed de novo [Para 12].

Execution – Limits of Executing Court – Court reiterated that executing courts cannot go behind the decree unless it is legally challenged – High Court's interpretation of "date of the suit" to include the period before refiling was incorrect [Para 14].

Decision: Appeals allowed – High Court's judgment set aside – Trial and appellate court's orders restored, affirming that interest is to be calculated from the date of refiling in the competent court at Surat [Paras 19-20].

Criminal Law – Abuse of Appeal Process – Supreme Court addressed the misuse of statutory appeal rights by convicts who, after obtaining bail, fail to surrender and evade justice – Emphasized that such appeals should be dismissed to prevent abuse of judicial process and ensure justice [Paras 1-2].

Criminal Procedure – Inherent Powers of High Court – Court highlighted the importance of Section 482 CrPC, empowering High Courts to take necessary actions to prevent abuse of process and secure the ends of justice – Confirmed that dismissal of appeals for non-prosecution is justified where appellants deliberately avoid court proceedings after securing bail [Paras 6, 11].

Legal Principles – Presence of Appellant – Court discussed previous judgments and clarified that High Courts have the authority to dismiss appeals if the appellant and counsel are absent and no efforts are made to prosecute the appeal – Emphasized the need for diligent prosecution of appeals to maintain justice [Paras 9-10].

Decision: Appeal dismissed – Supreme Court upheld the High Court’s approach of dismissing appeals for non-prosecution in cases where the appellant absconds after being granted bail – Confirmed the necessity of dismissing such appeals to uphold justice and prevent misuse of the appellate system [Paras 14-16].

Constitutional Law – Remuneration of Constitutional Appointee – Appellant, Chairman of Haryana Public Service Commission, contested State Government's reduction of his remuneration – Government initially relaxed regulation and fixed remuneration, later withdrew benefit – Court held State's withdrawal of benefit discriminatory and violative of Article 14 – State cannot vary remuneration to appointee's disadvantage post-appointment, especially without established master-servant relationship [Paras 1-17].

Judicial Discipline – Coordinate Bench Rulings – High Court committed error by overruling Single Judge judgment affirmed by coordinate bench – Proper procedure would be referral to larger bench if disagreement existed – Emphasizes importance of judicial propriety and consistency [Paras 13-16].

Regulation Relaxation – Applicability of Relaxed Regulations – Government relaxed Regulation 6 for appellant's remuneration – Subsequent withdrawal without justification or change in circumstances not permissible – High Court overlooked precedent and judicial propriety [Paras 10-12].

Decision: Appeal allowed – Impugned judgment set aside – Orders dated 29.11.1996 and 15.04.1997 quashed – Appellant entitled to consequential benefits within three months – State of Haryana directed to pay Rs. 50,000 as costs [Paras 17].

Negotiable Instruments – Dishonour of Cheque – Appellant convicted for issuing a cheque that was dishonoured for insufficient funds – Magistrate sentenced six months imprisonment and compensation of Rs. 80,000 – High Court substituted imprisonment with additional compensation – Supreme Court clarifies total compensation payable should not exceed twice the cheque amount – Further payment to be seen as fine, not additional compensation [Paras 1-13].

Compensation – Calculation and Limits – Cheque amount Rs. 69,500 – Compensation Rs. 80,000 already paid – Additional fine imposed by High Court causing confusion – Supreme Court sets final compensation at Rs. 80,000 plus fine of Rs. 20,000 – Emphasizes statutory limit on compensation under Section 138 [Paras 3-13].

Judicial Interpretation – Section 138 of Negotiable Instruments Act – Statutory interpretation to avoid exceeding fine limits – Compensation intended to cover dishonoured amount plus interest – Additional fines must align with statutory provisions [Paras 8-12].

Decision: Appeal allowed in part – Total compensation set at Rs. 80,000 with additional fine of Rs. 20,000 – Failure to pay additional fine results in six months imprisonment – Order of High Court modified accordingly [Paras 4, 13].

Administrative Law – Blacklisting – Appellant permanently blacklisted by BSNL for alleged fraud in receiving excess payments – High Court upheld blacklisting without fair hearing – Supreme Court held blacklisting must be fair, reasonable, and proportionate – Permanent blacklisting considered too harsh – Remanded to BSNL to determine appropriate period of debarment based on guidelines [Paras 1-27].

Fair Hearing – Principles of Natural Justice – Blacklisting affects civil rights – Requirement for fair hearing before blacklisting – Supreme Court emphasized need for objective and transparent guidelines for determining debarment periods – Ensures non-discrimination and fairness in administrative decisions [Paras 17-19, 26].

Proportionality – Review of Punishment – Permanent blacklisting deemed excessive given the circumstances – Supreme Court directed BSNL to reassess period of blacklisting – Highlighted importance of proportionality in penalties imposed by State or its instrumentalities [Paras 25-27].

Decision: Appeal allowed in part – High Court order set aside – Blacklisting order affirmed but period of debarment to be reassessed by BSNL with new guidelines – Process to be completed within six months [Paras 27].