Constitutional Law – Validity of State Legislation – Appellant challenged the constitutionality of Sections 3, 5, 8, and 9 of the Andhra Pradesh Protection of Depositors of Financial Establishments Act, 1999 – Argued that the State lacked legislative competence as the subject "banking" falls under Entry 45, List I of the Seventh Schedule – Supreme Court upheld the constitutionality of the Act, citing similar legislation in Tamil Nadu, Maharashtra, and Pondicherry, which had been upheld in prior judgments [Paras 1-14].

Competence of State Legislature – Overlapping Entries – Court held that the Andhra Act in pith and substance falls under Entries 1, 30, and 32 of List II of the Seventh Schedule – Emphasized that overlapping between Entries does not invalidate the State legislation as long as it is within its competence and does not conflict with Central legislation [Paras 10-12].

Definition of Financial Establishment – Applicability to Cooperative Banks – Court rejected the contention that Vasavi Cooperative Bank does not fall under the definition of "financial establishment" under Section 2(c) of the Andhra Act – Clarified that the exclusion applies to entities owned and controlled by the State or Central Government, which did not cover the Cooperative Bank in question [Para 13].

Decision:

Writ Petitions dismissed – Sections 3, 5, 8, and 9 of the Andhra Pradesh Protection of Depositors of Financial Establishments Act, 1999, held constitutional – Criminal proceedings and attachment of properties against Petitioners under the Act upheld [Para 14].

Medical Education – Renewal of Permission – MCI rejected the renewal of permission for the third batch of MBBS students at Chintpurni Medical College citing deficiencies – College argued that deficiencies were rectified and that surprise inspection was not justified – Supreme Court upheld MCI's decision, emphasizing the importance of maintaining minimum standards [Paras 10-20].

Surprise Inspection – Justification and Findings – Court supported the surprise inspection conducted by MCI, highlighting its necessity to verify compliance and rectify deficiencies – Found the deficiencies noted in the surprise inspection to be fundamental and crucial [Paras 18-20].

Principles of Natural Justice – Administrative Function – MCI's decision to deny renewal based on inspection reports not vitiated by the lack of a further hearing – Emphasized the role of MCI as an administrative authority ensuring compliance with minimum standards [Paras 19-21].

Decision:

Writ Petition (C) No. 590 of 2013 allowed – MCI's decision to deny the renewal of permission for the third batch of 150 MBBS students for the academic year 2013-14 upheld – I.A. No. 2 of 2013 in SLP (C) No. 28480 of 2012 disposed of accordingly [Para 21].

Tender Evaluation – Essential and Non-Essential Terms – Appellant's tender disqualified for not submitting the latest Income Tax Return – High Court upheld disqualification – Supreme Court held non-submission of Income Tax Return as non-essential, directing KMDA to reconsider the bid [Paras 1-14].

Judicial Review – Scope and Grounds – Court reiterated principles from Tata Cellular v. Union of India – Focus on legality, procedural propriety, and rationality of administrative actions – Judicial review limited to ensuring fair and lawful decision-making process [Paras 8-9].

Legal Precedents – Stare Decisis – Court emphasized adherence to established precedents – Criticized excessive reliance on multiple case citations, stressing importance of following binding precedents and maintaining judicial economy [Paras 6-7].

Administrative Discretion – Correction of Errors – Recognized scope for correcting non-essential errors in tenders – Encouraged fair consideration of bids, avoiding undue technical disqualifications where substantive compliance exists [Para 13].

Decision: Appeal allowed – High Court's judgment set aside – KMDA directed to proceed further with the appellant's bid, ignoring the non-submission of the latest Income Tax Return as it was deemed a non-essential term [Para 14].

Criminal Law – Witness Testimony – Appellants convicted for murder based on the testimony of the sole eyewitness, Adikesavan (PW-1) – Eyewitness was a close relative of the deceased – Court held the testimony reliable and corroborated by medical evidence, rejecting the argument that being related rendered him unreliable [Paras 9-15].

Delay in FIR – Explained – Incident occurred at 3:00 p.m. on January 5, 1999 – FIR lodged at 10:00 p.m. same day – Delay explained as due to the witness informing another family member and travelling to the police station – Court found the explanation satisfactory and the delay not detrimental to the prosecution case [Paras 7-8].

Nature of Offense – Section 302 IPC vs. Section 304 Part II IPC – Appellants argued for reduction of offense to culpable homicide not amounting to murder – Court rejected the argument, noting the brutal nature of the assault and the clear intention to kill, evident from the injuries and actions of the accused [Paras 17-18].

Decision:

Appeal dismissed – Conviction and sentence under Section 302 IPC upheld – Court found no reason to alter the conviction to Section 304 Part II IPC [Para 19].

Property Law – Saleability of Flats – Appellant company challenged the attachment and sale of a flat mortgaged by a shareholder (Respondent No. 5) – Court held that a shareholder's right to occupy a flat is a species of property and thus transferable and mortgageable – Articles of Association of the company cannot restrict this right [Paras 10-14].

Articles of Association – Non-Statutory Nature – Court noted that Articles of Association do not have the force of a statute and cannot prohibit the transferability or mortgage of a shareholder's interest in the flat [Paras 13-14].

Right of Pre-emption – Appellant company entitled to right of pre-emption but not at a value lesser than the market value of the flat at the time of sale – High Court's directions affirmed [Para 15].

Decision:

Appeal dismissed – High Court's order upholding the attachment and sale of the flat affirmed – Appellant's right of pre-emption maintained at market value [Para 16].

Civil Procedure – Review and Clarification – Appellants challenged the High Court’s clarification order in a review application, which allowed RMOs additional weightage within the 40% open category seats for MD course admissions – Supreme Court upheld the High Court's order on the basis that appellants' admissions were not adversely affected [Paras 2-8].

Academic Matters – Time Sensitivity – Court emphasized the need for timely action in academic matters – Rejected the application for impleadment due to delayed filing, highlighting the necessity of strict adherence to time limits in academic disputes [Para 7].

Legal Questions – Reserved for Future – Court decided not to settle the broader legal questions regarding the High Court's order, restricting the application of the order to the specific facts of the case [Para 8].

Decision:

Appeal dismissed – High Court’s order upheld – Application for impleadment dismissed – Broader legal questions left open for future consideration [Para 9].

Negotiable Instruments Act – Dishonor of Cheque – Time-Barred Action – Appellant presented four cheques which were dishonored – After initial dishonor, cheques were re-presented and dishonored again – Appellant issued a fresh notice and filed a complaint – Supreme Court held that prosecution based on second or successive dishonor of a cheque is permissible provided statutory conditions are met [Paras 2-10].

Legal Precedents – Overruling Prior Decisions – Supreme Court overruled the decision in Sadanandan Bhadran v. Madhavan Sunil Kumar which held that prosecution must be initiated upon the first dishonor of a cheque – New ruling allows for prosecution on subsequent dishonors if statutory requirements are satisfied [Para 10].

Decision:

Appeals allowed – High Court’s order set aside – Prosecution based on the second or successive dishonor of cheques upheld as permissible under the Negotiable Instruments Act, 1881 [Para 11].

Criminal Law – Death Penalty – Appellant convicted for murdering his wife and two sons with scissors, and attempting to murder his daughter – Trial court sentenced appellant to death under Section 302 IPC and life imprisonment under Section 307 IPC – High Court confirmed the sentences – Supreme Court examined the application of Section 354(3) of CrPC and the rarest of rare doctrine – Held, circumstances did not warrant death penalty; sentences modified to life imprisonment and seven years for respective offenses [Paras 1-29].

Murder and Attempt to Murder – Facts and Evidence – Appellant, a tailor, under financial and emotional stress due to his son's illness, killed his wife and sons, and attempted to kill his daughter, who survived and testified – Medical and forensic evidence corroborated her testimony – Supreme Court reviewed evidentiary support and upheld the conviction but reconsidered the death penalty [Paras 8-11, 25].

Mitigating Factors – Poverty and Emotional Distress – Supreme Court considered appellant's socio-economic conditions and the psychological strain leading to the crime – Referenced jurisprudence on mitigating factors, including poverty, lack of premeditation, and potential for reform – Emphasized legislative shift towards life imprisonment as the norm and death penalty as the exception [Paras 15-26].

Judicial Discipline and Comity – Importance of adhering to binding precedents – Review of previous cases influencing death penalty – Supreme Court underscored the need for judicial comity and the careful application of guidelines for sentencing in capital cases [Paras 16-18].

Decision – Appeals allowed in part – Conviction under Sections 302 and 307 IPC upheld – Death sentence modified to life imprisonment, with an additional seven-year term for attempt to murder – Clarification on consecutive running of sentences in case of remission or commutation [Paras 27-29].

School Tribunal – Appeal Against Supersession – Appellant appointed as Headmaster, approved by the Education Officer – Respondent No. 1, a former in-charge Headmaster, filed an application challenging the appointment after nearly 10 years – School Tribunal dismissed the application for condonation of delay – High Court remanded the matter to Tribunal, holding limitation provisions inapplicable – Supreme Court set aside High Court’s order, emphasizing the necessity of reasonable time even if no limitation is prescribed [Paras 1-8].

Limitation and Delay – Application of Reasonable Time – Supreme Court held that even in absence of a specific limitation period in the statute, an appeal must be filed within a reasonable time – Noted inordinate delay of 9 years and 11 months as unreasonable – Referred to precedents underscoring the importance of timely pursuit of legal remedies [Paras 7-8].

Decision – Appeal allowed – High Court order set aside – Tribunal’s order dismissing the application for condonation of delay affirmed [Para 8].