Criminal Law - Disparaging Remarks Against Judicial Officer – Criminal Appeal against High Court order – Appellant, a judicial officer, directed an application under Section 156(3) CrPC to be registered as a complaint and proceeded under Section 200 CrPC – High Court made severe disparaging remarks against the appellant for this decision – Supreme Court holds that High Court's remarks were unjustified and not warranted – Higher courts should observe restraint and avoid using strong language against lower judiciary – Remarks expunged. [Paras 1-13]

Judicial Discretion - Registration of Complaint – Analysis – Held – Judicial officer exercised discretion as per law, calling for a police report and considering affidavits and documents before deciding to proceed under Section 200 CrPC – High Court should not substitute its discretion for that of the lower court unless judicial discretion is shown to be arbitrary or perverse – Supreme Court finds no arbitrariness or perversity in the appellant’s order. [Paras 9-11]

High Court Criticism of Lower Courts – Guidelines – Analysis – Held – Disparaging remarks against lower judiciary can demoralize judicial officers and diminish public confidence in the judiciary – Advised that higher courts should use alternative measures to address perceived judicial errors without public criticism – Supreme Court emphasizes need for judicial restraint. [Para 11]

Decision – Expunction of Remarks – Supreme Court expunges disparaging remarks made by the High Court against the appellant – Directions of the High Court not challenged in appeal remain unaltered – Appeal allowed to the extent of expunging remarks. [Paras 13-14]

Criminal Law - Double Jeopardy - Article 20(2) of the Constitution and Section 300(1) of CrPC - Criminal Appeal against High Court order convicting the appellant under Section 420 IPC - Appellant contends previous conviction under Section 138 NI Act bars subsequent prosecution under Section 420 IPC on the same facts - Supreme Court finds that while Article 20(2) Constitution bars punishment for the same offence, Section 300(1) CrPC extends to barring trials for different offences on the same facts - Held prosecution under Section 420 IPC is barred - Appeal allowed and High Court judgment set aside. [Paras 1-6]

Interpretation of Statutes - Article 20(2) Constitution vs. Section 300(1) CrPC - Analysis - Held - Article 20(2) Constitution restricts double punishment for same offence, whereas Section 300(1) CrPC prevents trial for same facts leading to different charges - In present case, different offences (Section 138 NI Act and Section 420 IPC) arise from same facts, triggering Section 300(1) CrPC protection - High Court erred in allowing subsequent prosecution under Section 420 IPC - Judgment set aside. [Paras 4-6]

Decision - Appeal Allowed - High Court Judgment Set Aside - Prosecution under Section 420 IPC Barred - Supreme Court holds prosecution under Section 420 IPC on same facts as prior Section 138 NI Act conviction violates Section 300(1) CrPC - Appeal allowed - High Court judgment set aside. [Para 6]

Criminal Law - Framing of Charges - Sections 227 and 228 CrPC - Criminal Appeal challenging High Court's adverse observations against the appellant for not framing a charge under Section 302 IPC - Appellant's order framed charges under Sections 304 and 323 IPC instead - High Court noted the appellant's failure to provide reasons for not framing the higher charge - Supreme Court finds such a bald order without reasons raises doubts about the bona fides - Held that some minimum reasons are necessary for dropping or diluting a charge - Appeal dismissed. [Paras 1-26]

Judicial Accountability - Adverse Remarks - Review of Judicial Orders - Held - Adverse observations by High Court were necessary in light of the appellant's order lacking sufficient reasoning for not framing the charge under Section 302 IPC - Appellant's career review and subsequent denial of selection grade justified based on service record - Supreme Court emphasizes necessity for judicial orders to reflect adequate reasoning to ensure transparency and accountability - Appeal dismissed. [Paras 18-26]

Decision - Appeal Dismissed - Adverse Observations and Career Review Justified - Supreme Court upholds High Court's observations and subsequent career review of the appellant - Reiterates the need for judicial orders to provide sufficient reasons, especially when diluting or dropping serious charges. [Paras 24-26]

Criminal Law - Conviction Based on Circumstantial Evidence - Sections 376, 302, and 392 IPC - Appeal against High Court judgment confirming death sentence - Conviction based on identification by eyewitnesses, forensic evidence, recovery of stolen items, and extra-judicial confession - Supreme Court finds that evidence forms a complete chain pointing to appellant's guilt - Appeal dismissed - Death sentence confirmed. [Paras 1-57]

Identification Evidence - Validity of Test Identification Parade - Reliability of Identification by Witnesses - Identification by minor eyewitness corroborated by other witnesses - Supreme Court holds identification in Test Identification Parade valid despite appellant's claim of photograph publication - Conviction upheld based on consistent and credible identification. [Paras 29-33, 42-47]

Forensic Evidence - Fingerprint Evidence - Procedural Validity - Fingerprint of appellant matched with prints found on crime scene - Procedure for taking fingerprints under Identification of Prisoners Act upheld - Supreme Court rejects challenge to procedural validity and accepts fingerprint evidence as conclusive. [Paras 13-14, 54]

Sentencing - Death Penalty - Rarest of Rare Case - Supreme Court upholds death sentence considering extreme depravity, absence of mitigating factors, and appellant's history of similar offences - Death sentence confirmed as necessary for deterrence and societal protection. [Paras 18-23, 56-57]

Decision - Appeal Dismissed - Death Sentence Confirmed - Supreme Court dismisses appeal against High Court judgment - Death sentence for offences under Sections 302, 376, and 392 IPC confirmed - Appellant's actions deemed as falling within the category of rarest of rare cases. [Paras 55-57]

Criminal Law - Double Jeopardy - Article 20(2) of the Constitution and Section 300(1) of CrPC - Criminal Appeal against High Court order convicting the appellant under Section 420 IPC - Appellant contends previous conviction under Section 138 NI Act bars subsequent prosecution under Section 420 IPC on the same facts - Supreme Court finds that while Article 20(2) Constitution bars punishment for the same offence, Section 300(1) CrPC extends to barring trials for different offences on the same facts - Held prosecution under Section 420 IPC is barred - Appeal allowed and High Court judgment set aside. [Paras 1-6]

Interpretation of Statutes - Article 20(2) Constitution vs. Section 300(1) CrPC - Analysis - Held - Article 20(2) Constitution restricts double punishment for same offence, whereas Section 300(1) CrPC prevents trial for same facts leading to different charges - In present case, different offences (Section 138 NI Act and Section 420 IPC) arise from same facts, triggering Section 300(1) CrPC protection - High Court erred in allowing subsequent prosecution under Section 420 IPC - Judgment set aside. [Paras 4-6]

Decision - Appeal Allowed - High Court Judgment Set Aside - Prosecution under Section 420 IPC Barred - Supreme Court holds prosecution under Section 420 IPC on same facts as prior Section 138 NI Act conviction violates Section 300(1) CrPC - Appeal allowed - High Court judgment set aside. [Para 6]

Criminal Law - Framing of Charges - Sections 227 and 228 CrPC - Criminal Appeal challenging High Court's adverse observations against the appellant for not framing a charge under Section 302 IPC - Appellant's order framed charges under Sections 304 and 323 IPC instead - High Court noted the appellant's failure to provide reasons for not framing the higher charge - Supreme Court finds such a bald order without reasons raises doubts about the bona fides - Held that some minimum reasons are necessary for dropping or diluting a charge - Appeal dismissed. [Paras 1-26]

Judicial Accountability - Adverse Remarks - Review of Judicial Orders - Held - Adverse observations by High Court were necessary in light of the appellant's order lacking sufficient reasoning for not framing the charge under Section 302 IPC - Appellant's career review and subsequent denial of selection grade justified based on service record - Supreme Court emphasizes necessity for judicial orders to reflect adequate reasoning to ensure transparency and accountability - Appeal dismissed. [Paras 18-26]

Decision - Appeal Dismissed - Adverse Observations and Career Review Justified - Supreme Court upholds High Court's observations and subsequent career review of the appellant - Reiterates the need for judicial orders to provide sufficient reasons, especially when diluting or dropping serious charges. [Paras 24-26]

Criminal Law - Conviction Based on Circumstantial Evidence - Sections 376, 302, and 392 IPC - Appeal against High Court judgment confirming death sentence - Conviction based on identification by eyewitnesses, forensic evidence, recovery of stolen items, and extra-judicial confession - Supreme Court finds that evidence forms a complete chain pointing to appellant's guilt - Appeal dismissed - Death sentence confirmed. [Paras 1-57]

Identification Evidence - Validity of Test Identification Parade - Reliability of Identification by Witnesses - Identification by minor eyewitness corroborated by other witnesses - Supreme Court holds identification in Test Identification Parade valid despite appellant's claim of photograph publication - Conviction upheld based on consistent and credible identification. [Paras 29-33, 42-47]

Forensic Evidence - Fingerprint Evidence - Procedural Validity - Fingerprint of appellant matched with prints found on crime scene - Procedure for taking fingerprints under Identification of Prisoners Act upheld - Supreme Court rejects challenge to procedural validity and accepts fingerprint evidence as conclusive. [Paras 13-14, 54]

Sentencing - Death Penalty - Rarest of Rare Case - Supreme Court upholds death sentence considering extreme depravity, absence of mitigating factors, and appellant's history of similar offences - Death sentence confirmed as necessary for deterrence and societal protection. [Paras 18-23, 56-57]

Decision - Appeal Dismissed - Death Sentence Confirmed - Supreme Court dismisses appeal against High Court judgment - Death sentence for offences under Sections 302, 376, and 392 IPC confirmed - Appellant's actions deemed as falling within the category of rarest of rare cases. [Paras 55-57]

Criminal Law - Certification of Tainted Shares – Appeal against Special Court's order rejecting certification application due to delay – Special Court had fixed a cut-off date for filing applications for certification of tainted shares – Appellant, a bona fide investor, filed application two months post cut-off date – Supreme Court found that the cut-off date fixed by the Special Court had no statutory force – Held that the application should have been entertained, as the appellant was unaware of the certification requirement and cut-off date – Impugned order set aside, appeal allowed, Custodian directed to entertain certification application and ensure payment of dividends on certified shares. [Paras 1-26]

Investor Protection - Role of Custodian and Special Court – Analysis – Held – The Custodian and Special Court must guard investors' interests, especially bona fide investors, who purchase shares without knowledge of their tainted nature – Cut-off dates for certification imposed by the Special Court must not undermine the investors' rights – Statutory duties of Custodian under the Special Court Act of 1992 emphasized. [Para 22-24]

Decision – Allowing Appeal Against Special Court Order – Court allowed the appeal and directed the Custodian to certify the appellant's shares and facilitate the release of accrued dividends – Stressed the need for protecting bona fide investors from undue hardship caused by procedural technicalities. [Para 25-26]

Education Law - Teacher Training Institutions - Cut-Off Dates for Recognition Applications – Appeal against High Court order extending cut-off dates for submission of applications for recognition – Supreme Court examines the validity of cut-off dates specified in the 2007 Regulations – Held that cut-off dates are neither arbitrary nor irrational – Cut-off dates ensure timely processing and decision on applications for recognition to avoid delays and ensure compliance with the requirement of minimum attendance – High Court's decision to strike down cut-off dates and allow late applications was not justified – Regulations and cut-off dates upheld. [Paras 1-29]

Role of State Government - Importance of Consultation – Analysis – Held – State Governments play a crucial role in assessing the need for new teacher training institutions and their capacity to provide trained teachers – Recommendations from State Governments ensure that the number of institutions is aligned with the requirement of trained teachers and budgetary provisions – Council’s decision to incorporate State Government recommendations in the process of granting recognition to institutions is valid and essential for maintaining standards and fulfilling objectives of planned development in teacher education. [Paras 24-29]

Decision – Validation of Cut-Off Dates – Court holds cut-off dates in Regulation 5(4) and (5) of the 2007 Regulations are valid and not in violation of Article 14 – The Council must ensure strict adherence to conditions laid down in the Act and Regulations and the time schedule for processing applications – Appeals allowed, directions issued to ensure compliance with Regulations. [Paras 29-30]