Reservation Policy – Applicability to Super-Specialty Posts – The appeals challenge whether reservation policies apply to super-specialty posts in AIIMS – Held that reservations should not apply to super-specialty posts as it compromises excellence – Affirmed observations from Indra Sawhney's case and other related judgments which emphasize the need for merit in super-specialty education and faculty appointments [Paras 1-20].

Interpretation of Articles 15, 16, and 335 – Emphasized that while reservations at the undergraduate and postgraduate levels are justifiable, the same does not apply to super-specialty levels where merit alone should be the criterion – Affirmed the views from earlier judgments including Indra Sawhney, Dr. Jagadish Saran, Dr. Pradeep Jain, and Dr. Preeti Srivastava cases [Paras 6-18].

Article 141 – Obiter Dicta as Binding Precedent – Discussed the binding nature of obiter dicta in landmark cases, affirming their application as precedents under Article 141 of the Constitution [Para 19].

Decision – Appeals allowed – Reservations in super-specialty posts at AIIMS are not permissible – Government advised to align with the views expressed in relevant Supreme Court judgments, upholding the principle of merit at the highest levels of medical education and faculty appointments [Paras 19-20].

Education Law – NEET and Minority Rights – Notifications by MCI and DCI introducing NEET challenged by various medical institutions, including minority institutions, as violative of their rights to administer and admit students independently. The challenge emphasized the infringement on religious and linguistic minorities' rights under Articles 19(1)(g), 25, 26, 29(1), and 30 of the Constitution [Paras 1-43].

Powers of MCI and DCI – Statutory Limits – Questioned the authority of MCI and DCI under their respective Acts to regulate admissions through NEET. Emphasized that their roles are recommendatory and pertain to maintaining standards of education, not direct control over admissions [Paras 6-7, 38-39].

Fundamental Rights – Article 30 and Admission Autonomy – Minority institutions argued that NEET undermines their constitutionally protected rights to establish and administer educational institutions of their choice, including the right to admit students per their regulations. Cited precedents affirming minimal interference in their admission processes as long as merit and fairness are maintained [Paras 25-37].

Regulations vs. Fundamental Rights – Asserted that subordinate legislation, such as the regulations under challenge, cannot override fundamental rights guaranteed under the Constitution. Cited precedents where similar attempts to regulate admissions in minority institutions were struck down [Paras 24, 30, 42].

Decision – Appeals allowed – Notifications introducing NEET for medical and dental admissions held unconstitutional as they infringe upon the fundamental rights of minority and unaided institutions to manage their admissions independently. The matter remitted to a Three-Judge Bench to address pending appeals in accordance with this judgment [Paras 43].

Civil Service Law – Refund of Salary and Allowances – Appellant-institute directed respondent to refund the amount of Rs. 12,32,126 paid towards salary and allowances during study leave granted for Ph.D. studies, as respondent failed to complete the Ph.D. program – High Court quashed demand notice and ordered refund of amount already recovered – Supreme Court held the bond executed by respondent was vague and did not clearly impose such a condition, but refused to order refund of the amount already recovered considering public interest [Paras 1-17].

Study Leave and Bond Conditions – Vague Terms – Bond executed on 05.05.1999 did not explicitly state the condition of refund if Ph.D. was not completed – Specific provision added later by the Board of Governors in 2002 – No clear reference to Rule 63 of the Central Civil Services (Leave) Rules in the bond executed by the respondent [Paras 9-13].

Application of Rule 63 – Rule 63 imposes a requirement for refund of salary and allowances if an employee fails to complete the course of study – High Court had no occasion to examine the applicability of Rule 63, as it was not specifically urged by the appellant-institute – Supreme Court emphasized the principle of "no work no pay" and public interest in ensuring that public money is spent effectively [Paras 13-15].

Decision – Appeal partly allowed – Judgment of the High Court modified – No further amount to be recovered from the respondent, but the amount already recovered (approximately Rs. 6,50,000) will not be refunded, considering public interest and the disservice caused by non-completion of the Ph.D. program [Paras 17-18].

Contempt of Court – Non-Compliance with Undertaking – State of Bihar committed to recruiting trained primary school teachers but failed to honor its undertaking, resulting in multiple contempt petitions – Supreme Court had directed the state to prioritize trained teachers for vacancies – Discrepancies in the number of vacancies and candidates led to appointing a Special Officer to finalize the list [Paras 1-7].

Appointment Process – Ensuring Fairness and Compliance – Justice V.A. Mohta and later Justice S.K. Chattopadhyay appointed to oversee and finalize the list of eligible candidates – 34,540 candidates appointed based on the finalized list – Further discrepancies and individual grievances led to modifications in the Court's earlier orders to address all legitimate claims [Paras 6-8].

Jurisdiction of High Court – Redressal of Grievances – Supreme Court allowed candidates to approach the High Court to address individual grievances regarding the final select list – Ensured that the appointments already made would not be disturbed – Directed the state to consider remaining vacancies while disposing of pending applications [Para 9].

Decision – Special Leave Petition and associated applications disposed of – Supreme Court modified its previous order, allowing applicants to seek relief from the High Court without affecting the appointments already made – Directed the state to consider filling the remaining 2,413 vacancies [Paras 9].

Juvenile Justice – Definition and Treatment of Juveniles – Petitions challenged the constitutionality of the Juvenile Justice Act, 2000, arguing for changes to handle juveniles committing heinous crimes under normal laws rather than juvenile justice provisions – Supreme Court upheld the current definition of juveniles under the Act, affirming it was in line with international standards and constitutional provisions – Emphasized the rehabilitative and reformative approach of the Juvenile Justice Act over punitive measures [Paras 1-50].

Constitutional Validity – Articles 14 and 21 – Upheld the Juvenile Justice Act as compliant with Articles 14 and 21 – Rejected the argument that the Act violated fundamental rights by allowing lenient treatment of juveniles involved in serious crimes – Emphasized the Act’s alignment with international conventions and the policy decision to treat individuals below 18 years as juveniles [Paras 27-31].

International Standards and National Policy – Referenced international instruments like the UN Convention on the Rights of the Child, Beijing Rules, and the Havana Rules – Confirmed that the age limit of 18 for juveniles is consistent with these standards – Recognized the legislative intent and policy considerations behind the Juvenile Justice Act, supporting the current age threshold for juvenile classification [Paras 41-45].

Role of Rehabilitation – Highlighted the Act’s focus on the rehabilitation and reintegration of juvenile offenders into society – Recognized that juveniles committing heinous crimes represent exceptions rather than the norm – Affirmed the necessity of a rehabilitative approach to prevent juveniles from becoming hardened criminals [Paras 48-49].

Decision – Writ Petitions and Transferred Case dismissed – Upheld the constitutionality of the Juvenile Justice (Care and Protection of Children) Act, 2000 – Emphasized the need for effective implementation of the Act rather than amending it based on isolated incidents [Para 50].

Criminal Law – Murder Conviction – Appellant convicted for the murder of Iqbal – Trial court and High Court found the appellant guilty under Section 302 read with Section 34 IPC – High Court acquitted co-accused Muzaffar and Shahjad based on their alibi, raising doubts about the prosecution's case against the appellant – Supreme Court found that the evidence against the appellant was insufficient and unreliable [Paras 1-20].

Right of Private Defense – Appellant argued the deceased was a known criminal who threatened his family – Although the claim of private defense was not accepted, the Court found the prosecution had failed to establish the circumstances of the incident convincingly – Evidence showed inconsistencies, particularly regarding the presence of co-accused and the recovery of the weapon [Paras 4-19].

Evidence and Prosecution Case – Inconsistencies and Doubts – FIR and witness testimonies indicated the involvement of co-accused who were later acquitted – Discrepancies in the recovery of the weapon and the ballistic evidence raised further doubts – Prosecution's failure to recover scooters allegedly present at the scene questioned the credibility of the case [Paras 8-17].

Decision – Appeal allowed – Conviction and sentence of the appellant set aside – Appellant to be released forthwith if not required in any other case – The prosecution's case found unreliable, granting the appellant the benefit of doubt [Paras 19-20].

Criminal Law – Conviction under Section 302 read with Section 34 IPC – Appellant (A-3) convicted for murder along with co-accused – Conviction based on the evidence of two eyewitnesses who were relatives of the deceased – Supreme Court finds inconsistencies in their testimonies and lack of corroborative medical evidence – Appeal allowed, conviction and sentence set aside [Paras 1-11].

Evidence Law – Interested Witnesses – Evidence provided by relatives of the deceased scrutinized – No absolute bar on considering such evidence, but requires careful analysis – Court finds that evidence of PW-1 and PW-3 lacked clarity regarding the specific role of the appellant (A-3) – Insufficient to sustain conviction [Paras 7-8].

Medical Evidence – Post-mortem report examined – Doctor (PW-10) confirms multiple head injuries as cause of death – No direct link established between injuries and appellant’s actions as alleged by eyewitnesses – Discrepancy in eyewitness account and medical findings critical in setting aside conviction [Paras 9-10].

Decision: Appeal allowed – Conviction and sentence under Section 302 read with Section 34 IPC set aside – Appellant ordered to be released forthwith if not required in any other case [Para 11].

Education Law – Binding Nature of UGC Regulations – Whether the UGC regulations regarding pay scales and retirement age have mandatory effect on state-run institutions – Supreme Court analyzes constitutional provisions and the statutory framework governing UGC – Determines the extent to which state laws can diverge from UGC guidelines – Holds that UGC regulations, while recommendatory, gain binding effect upon acceptance by state governments as part of a composite scheme involving financial assistance from the central government [Paras 1-44].

Constitutional Law – Legislative Competence – Conflict between state laws and central regulations – Examination of legislative entries in Seventh Schedule, particularly Entry 66 of List I and Entry 25 of List III – Court asserts primacy of central legislation in matters of coordination and determination of standards in higher education – State regulations must align with central norms where conflict arises [Paras 28-38].

Administrative Law – Conditions of Service – Age of Superannuation – State amendments enhancing age of superannuation analyzed – Court considers state discretion in adopting UGC guidelines – Determines that while states have autonomy, acceptance of central financial assistance mandates adherence to comprehensive UGC scheme, including revised retirement age [Paras 9-19].

Decision: Appeals partly allowed – States directed to implement UGC guidelines as accepted in composite schemes – UGC regulations on pay scales and retirement age to be adopted uniformly by states receiving central financial aid – States granted liberty to modify other service conditions within legislative competence [Paras 42-44].

Criminal Law – Conviction for Dacoity – Appellant convicted under Sections 395/397 IPC, Section 25(1A)(b) of the Arms Act, and Sections 3 and 5 of the Explosive Substances Act – Evidence by prosecution witnesses and taxi owner identifying appellant as an accomplice in the dacoity – Appellant claimed limited involvement, only facilitating escape in a taxi – Supreme Court upheld conviction but altered sentence considering appellant’s limited role [Paras 1-11].

Evidence Law – Identification and Testimony – Witnesses identified appellant as standing near the taxi used by dacoits – Taxi owner confirmed appellant was the driver – Consistent testimonies from multiple witnesses, no contradictions – Supreme Court found no reason to disbelieve evidence presented by prosecution [Paras 6-9].

Sentencing – Consideration of Role and Circumstances – Appellant sentenced to 10 years by lower courts – Supreme Court acknowledged appellant’s role was limited to facilitating escape, not directly participating in the dacoity – Sentence reduced to period already undergone (7 years and 6 months) – Directed immediate release of appellant [Paras 10-11].

Decision: Appeal disposed of – Conviction confirmed, sentence reduced to time already served – Appellant to be released forthwith if not required in any other case [Para 11].