Service Law – Departmental Proceedings – Misappropriation – Judicial Review – Gramin Dak Sevak/Branch Postmaster found to have misappropriated public funds; admitted guilt and later deposited amounts – Inquiry conducted with full opportunity; no procedural violation – High Court set aside removal by reappreciating evidence and accepting new plea of coercion – Held: High Court exceeded judicial review jurisdiction; disciplinary authority’s penalty of removal restored – Appeal allowed [Paras 3, 7–12].

Service Law – Departmental Misconduct – Misappropriation of Public Funds – GDS/Branch Postmaster - Irregularities found during inspection (16.06.2011) revealed misappropriation of recurring deposit instalments and insurance premium despite entries stamped in passbooks; corresponding entries missing in official account books – Chargesheet issued (17.12.2013) – Inquiry Officer found charges proved – Respondent admitted embezzlement and deposited amounts; sought forgiveness – Held: Evidence clearly established embezzlement; deposit of misappropriated amount does not absolve misconduct [Paras 2, 5–10].

Judicial Review – Scope under Article 226 – Reappreciation of Evidence Impermissible - High Court examined merits, revisited admissions, and accepted plea of coercion not raised during inquiry – Supreme Court held that judicial review is confined to examining legality of procedure, not merits or sufficiency of evidence – High Court erred in interfering with concurrent findings of Disciplinary Authority, Appellate Authority and Tribunal [Paras 3–4, 11].

Departmental Inquiry – Admission of Guilt – Later Retraction – Effect - Respondent’s statement dated 28.04.2012 admitted spending deposited amounts for household purposes – Retraction on allegation of Inspector’s pressure raised belatedly and rejected – Held: Explanation an afterthought; inquiry and opportunity proper; no defect found in procedure [Paras 7–9, 11].

Banking/Post Office – Fiduciary Relationship – Public Confidence - Court emphasised that banking/postal transactions rely on trust – Passbook entry satisfies depositor; depositor has no means to check official account books – Misappropriation discovered only incidentally; cannot be trivialised as “mistake” or “ignorance” by employee with 12 years of service – Ignorance of rules not acceptable [Para 11].

Punishment – Removal from Service – Proportionality - Considering gravity of involving financial integrity and public trust, punishment of removal held justified – High Court erred in substituting its view on proportionality without finding procedural infirmity – Penalty restored [Paras 10–12].

Decision: Appeal allowed – High Court judgment set aside – Punishment of removal from service upheld [Para 12].

Consumer Protection Act – Definition of Consumer – Commercial Purpose – Corporate purchase of business automation software held directly connected to profit-generation – Not covered by self-employment exception – Held: Appellant-company is not a “consumer” under Section 2(1)(d); complaint not maintainable; appeal dismissed [Paras 15–18, 21–28].

Consumer Law – Commercial Purpose – Dominant Purpose Test – Purchase of Software for Business Automation - Purchase of “Brillio Opti Suite” software by appellant-company engaged in import/export operations had direct nexus with business documentation, tracking shipments, managing export benefits, and improving operational efficiency – Dominant object being profit augmentation—Held: transaction is for a commercial purpose; appellant not a consumer under Section 2(1)(d) of the 1986 Act [Paras 4, 10, 17, 22, 27].

Definition of Consumer – Companies Included but Excluded When Goods/Services Used for Commercial Purpose - Court reaffirms that companies fall within “person” under Section 2(1)(m); however, exclusion clause bars persons availing goods/services for commercial purpose – Corporate use of business-automation software falls squarely within exclusion [Paras 13–14].

Self-Employment Exception – Explanation to Section 2(1)(d) – Inapplicable to Corporations - Exception applies only when goods/services are used exclusively to earn livelihood by means of self-employment – Distinction drawn between individuals earning livelihood and corporations maximising profits – Held: corporate purchaser cannot invoke the exception; software was procured for business expansion and efficiency [Paras 18, 22].

Lilavati Kirtilal Mehta Principles – Dominant Purpose – Nexus with Profit – Applicability - Court applies broad principles: identity of purchaser or value of transaction irrelevant; what matters is dominant purpose – If purchase is linked to profit-generation, it is commercial – Automation of business processes is aimed at reducing costs and increasing profits; hence commercial [Paras 15–16].

Reliance on Sunil Kohli and Paramount Digital – Distinguished - Those decisions involved unemployed individuals purchasing goods for livelihood – Present case involves a well-established corporation already engaged in commercial activity – Therefore, precedents on self-employment do not assist the appellant [Paras 19–21].

Business-to-Business Transactions – Software Licence – Not a Consumer Dispute - Consumer Protection Act primarily addresses business-to-consumer relationships; business-to-business purchases used for profit are excluded from consumer jurisdiction – Software licence here was a B2B commercial tool [Para 10].

Harsolia Motors Clarified – Goods/services with direct nexus to profit-generation constitute commercial purpose; only purchases unrelated to profit (e.g., office AC, refrigerator) fall outside commercial purpose; present purchase directly tied to business operations and profitability [Paras 24–26].

Decision: Appeal dismissed – Appellant not a Consumer - Held: Software purchased for automating business processes and maximising profits constitutes commercial purpose – State Commission and NCDRC right in dismissing complaint as not maintainable – Appeal dismissed; no order as to costs [Paras 28–30].

Inter-State Water Dispute – Cauvery Water Sharing – Mekedatu Project – Tamil Nadu’s challenge to Karnataka’s preparation of DPR for Mekedatu Dam rejected – Supreme Court held: Karnataka only permitted to prepare DPR, subject to expert scrutiny and approval by CWMA – No interference warranted at this stage – Application filed by Tamil Nadu found premature and misconceived – States bound to comply with allocation as per CWDT Award as modified by Supreme Court – Appeal and connected applications dismissed [Paras 1–31]

Water Law – Preparation of Detailed Project Report (DPR) – Objections by Lower Riparian State – Tamil Nadu sought stay on permission granted by Central Water Commission (CWC) to Karnataka for preparing DPR of Mekedatu Dam – Held: CWC’s permission is only for preparation of DPR, not for execution – DPR subject to approval of Cauvery Water Management Authority (CWMA) – No final approval granted yet – Application dismissed as premature [Paras 1, 8, 15–16, 26–27]

Federalism – Inter-State Resource Management – Rights of States – Supreme Court reiterated: Every State has the right to manage water allocated to it under CWDT Award as modified by Court – No State can object to how another State uses its allocated share unless it reduces the share of the complaining State – Karnataka is entitled to utilise its quota through infrastructure like Mekedatu Dam, provided it complies with CWMA directives – [Paras 28–29]

Judicial Deference to Expert Bodies – Role of CWMA and CWRC – Disputes over water release during Monsoon 2023 also raised earlier – Supreme Court reiterated lack of judicial expertise in technical water management – Directed such issues to be handled by CWMA and CWRC – Held: Courts must refrain from interfering when expert bodies are in seisin of the matter – [Paras 21, 24–25, 30]

Environmental Compliance – Reuse and Return of Domestic Use Water – Tamil Nadu sought directions to Karnataka to return 80% treated water to Cauvery River system and not divert it to Pennaiyar basin – Supreme Court: Such grievances must be raised before CWMA and CWC – Directed expert bodies to act expeditiously upon such complaints – Judicial intervention not warranted at this stage – [M.A. No. 1869/2023 – Paras 1–5]

Public Interest Litigation – Water Disputes – Writ Petition seeking enforcement of CWDT Award dismissed – Held: CWMA and CWRC are competent statutory bodies for implementation of Award – No separate judicial direction required – [W.P.(C) No. 914/2023 – Paras 1–2]

Contempt Petition – Alleged Non-Compliance of Water Release – Disposed in view of present judgment – No finding of wilful disobedience – Karnataka reminded of its duty to comply with CWMA directives or face contempt – [Contempt Petition (C) No. 2210/2018 – Para 28]

Decision: Miscellaneous Applications, Contempt Petition, and Writ Petition dismissed – Karnataka may proceed with DPR preparation, subject to expert scrutiny – Tamil Nadu may raise objections before CWMA/CWC – No interference by Supreme Court at this stage [Paras 27, 31]

Environment & Wildlife Protection – Saranda Forest – Mandamus directing Jharkhand to notify 31,468.25 ha (minus six mining-zone compartments) as Wildlife Sanctuary – State’s shifting stands deprecated – FRA rights fully protected – Mining prohibited within 1 km of boundary – Ancillary SAIL infrastructure unaffected [Paras 45–47, 72, 83–101, 102–105].

Wildlife Sanctuary – Mandatory statutory duty – Sections 18 & 26A WPA – State repeatedly admitted 31,468.25 ha (126 compartments) had no mining and high ecological significance – Held: area satisfies S.26A(1)(b) and must be notified as Wildlife Sanctuary – Reduction to 24,941.64 ha unjustified [Paras 12, 45–47, 60–67, 72].

State Conduct – Contradictory affidavits – Prima facie contempt – State shifted between 31,468.25 ha, 57,519.41 ha and 24,941.64 ha; constituted committee citing mining interests; Court held State attempted to mislead – Chief Secretary summoned [Paras 13, 17–20, 23–31].

Expert Evidence – WII Report (2025) – Saranda is critical elephant corridor and biodiversity hotspot; 70% intact forest; vital for Simlipal connectivity – Strong scientific basis for full sanctuary declaration [Paras 61–67].

Mining Impact – Shah Commission Report & MPSM – Mining causes hydrological damage, biodiversity loss, stream drying; critical conservation compartments identified as no-mining zones – State wrongly excluded even these from proposed sanctuary [Paras 74–82, 83–85].

Tribal Rights – FRA 2006 – Apprehensions of displacement unfounded – Sections 3 & 4 FRA and Section 24(2)(c) WPA protect individual/community habitation, cultivation, MFP, grazing and public infrastructure – State criticised for invoking tribal rights without educating communities [Paras 42, 46–48, 86–97].

Constitutional Mandate – Articles 48A & 51A(g) – State obliged to protect forests and wildlife; National Forest Policy 1988 and National Wildlife Action Plan 2017–31 recognised as having statutory flavour – Protected area expansion required [Paras 68–72].

Mining Restrictions – Court reiterates prohibition on mining inside sanctuaries and within one kilometre from boundaries – Direction of 26.04.2023 applied pan-India [Para 102(ii)].

Ancillary Mining Infrastructure – SAIL – Dams, reservoirs, railway lines fall under permissible rights under FRA/WPA – Activities unaffected by sanctuary declaration – IA disposed [Paras 104–105].

Mandamus – State directed to notify entire 1968 Game Sanctuary area (31,468.25 ha) excluding six compartments (KP-2, KP-10, KP-11, KP-12, KP-13, KP-14) as Wildlife Sanctuary within three months – State free to propose additional areas later [Paras 101–102(i)].

Publicity Direction – State to widely publicise that FRA rights (individual and community) remain intact and no displacement will occur [Para 102(iii)].

Decision – IAs disposed – Mandamus issued – Mining restrictions reaffirmed – SAIL IA disposed.

Insurance Law – Boiler & Pressure Plant Policy – Repudiation of Claim – Explosion in registered boiler occurred during currency of fitness certificate – Insurer failed to prove suppression or pre-existing defects – Exclusion Clause 5 not attracted where defects surface only after explosion – NCDRC order set aside; claim restored for determination of quantum [Paras 23, 30–33, 37–41, 43–44].

Insurance Claim – Repudiation – Explosion – The appellant alleged a boiler explosion; insurer did not traverse the specific plea of explosion; survey reports did not conclusively rule out explosion – Held: Explosion deemed established; claim could not be rejected on assumption of mere tube slippage [Paras 23, 30–32].

Contract of Insurance – Duty of Disclosure – No evidence that proposer concealed material facts; no enquiry sought by insurer on age/condition of tubes; boiler validly registered and certified for use under the Boilers Act – Held: No failure of utmost good faith; repudiation unsustainable [Paras 27, 29–36].

Exclusion Clause 5 – Interpretation – Clause excludes defects due to wear, corrosion, deterioration etc. unless such defects “result in explosion” – Where explosion is not denied and defects surface only after the event, exclusion clause cannot apply – Held: NCDRC erred in applying clause 5; clause to be construed to uphold main purpose of policy [Paras 22, 37–41].

Boiler Registration – Evidentiary Value – Boiler had a valid certificate under the Boilers Act; accident occurred during subsistence of certificate – Held: Heavy burden on insurer to displace presumption of fitness; insurer showed no proof of unfitness or fraud; post-accident corrosion findings irrelevant [Paras 25, 32–33, 39].

Surveyor’s Reports – Weightage – Surveyor’s report placed for first time before NCDRC, years after filing – Though expert opinion must be given due weight, belated production and ambivalence regarding explosion cannot defeat claim – No definite finding of pre-existing defects – State Commission justified in adverse inference [Paras 17, 30–32, 38].

Alternative Remedy – Maintainability under Article 136 – Insurer argued appeal not maintainable due to alternate remedy of writ – Held: No inherent bar; matter fully pleaded and ready; relegation would delay justice; Supreme Court may exercise jurisdiction [Para 42].

Relief – Order of NCDRC set aside – Appeals before NCDRC restored for consideration of quantum of compensation only – All other issues closed – Parties to bear own costs [Paras 43–45].

NDPS Act – Bail – Commercial Quantity – Section 37 – High Court granted bail without addressing incriminating circumstances, prior linked seizure, or recording mandatory satisfaction under Section 37(1)(b) – Held: Orders unsustainable – Remanded for fresh consideration; interim bail to continue till reconsideration [Paras 15–22].

Bail – NDPS Act – Commercial Quantity – Mandatory Twin Conditions – Improper Application by High Court - High Court granted bail reasoning that there was no material showing respondent’s knowledge of cocaine in imported pears consignment, absence of antecedents, and prolonged custody – Held: High Court failed to apply mandatory twin conditions of Section 37(1)(b)(i) & (ii) and did not record satisfaction that accused was not guilty or unlikely to commit offence while on bail [Paras 14–19].

NDPS – Conscious Possession – Statements and Circumstances Ignored by High Court - High Court did not consider prosecution’s assertions: respondent placed import orders, controlled logistics chain, coordinated with overseas supplier, and was present during opening of container – Statements under Section 67 NDPS Act and surrounding circumstances prima facie relevant to conscious possession and presumption under Section 35 NDPS Act – High Court erred in ignoring these materials [Paras 15–16].

NDPS – Antecedent Seizure of 198.1 kg Methamphetamine and 9.035 kg Cocaine – Non-consideration - Prosecution relied on earlier seizure (02.10.2022) allegedly linked to same network and involving respondent – This material was not noticed or evaluated in impugned bail orders – Such omission directly affects statutory satisfaction under Section 37 – Order unsustainable [Paras 16–19].

Bail – Long Custody & Delay – Not Alone Sufficient to Override Section 37 - High Court relied on prolonged custody and anticipated delay – Held: these factors, while relevant, cannot override statutory bar under Section 37 unless Court first records mandatory satisfaction regarding innocence and non-likelihood of reoffending – High Court exceeded discretion [Paras 14, 17–18].

Judicial Review of Bail Orders – Commercial Quantity Cases Require Elevated Scrutiny - Supreme Court reiterates that in NDPS commercial quantity cases, ordinary CrPC bail parameters are supplemented by stringent statutory embargo – High Court must engage with all material on record and prosecution's assertions before granting bail [Paras 18–20].

Remand – Fresh Consideration Directed – Interim Bail to Continue - Supreme Court refrains from making factual findings at threshold; sets aside bail orders dated 22.01.2025 & 12.03.2025 – Matter remitted to High Court to reconsider bail afresh keeping Section 37 and all factual materials in view – Interim bail to continue but violation will permit cancellation [Paras 20–22].

Decision: Orders set aside – Matter remanded – Interim bail continued - Appeals disposed of – Bail orders quashed – High Court to decide afresh within four weeks; no opinion expressed on merits [Paras 21–23].

Criminal Law – Second FIR Quashed – Abuse of Process – Appellant was prosecution witness in CBI case involving bribe to GST officials – Following his adverse deposition against university management, second FIR registered accusing him of harboring the accused – Police filed cancellation report but Magistrate took cognizance on protest petition – Supreme Court held second FIR and summoning order unsustainable – Found it to be vindictive prosecution and abuse of process [Paras 2–4, 7].

Criminal Law – Sections Misapplied – Magistrate took cognizance under IPC Sections including forgery and IT Act provisions – Supreme Court held that even if allegations were accepted on face value, only offence under Section 212 IPC (harboring offender) could possibly arise – Attempt to introduce unalleged offences without foundation impermissible – Held: Cognizance order and High Court judgment upholding it are legally flawed [Paras 5–6].

Evidence – Forgery Not Made Out – No specific act of forgery or falsification of electronic records alleged – Appellant was neither author nor user of any allegedly false document – Held: No ingredients of Sections 465–471 IPC or IT Act offences made out [Paras 5–6].

Criminal Jurisprudence – Protection Against Harassment – Court reiterated that prosecution cannot be weaponized to harass or retaliate against witnesses – Vindictive FIRs to suppress testimony undermine rule of law – Cancellation report rightly accepted [Paras 6–8].

Criminal Procedure – Protest Petition – Magistrate’s acceptance of protest petition to reverse cancellation report must be based on cogent material – Present case involved no such material and the complainant’s allegations contradicted the FIR’s own narrative [Paras 3–5].

Civil Law – Counterclaim – Co-defendant – Specific performance – Plaintiff sued sole defendant for specific performance of oral agreement for 0.93 acres – Subsequent impleadment of defendant Nos. 2 & 3 claiming agreement to purchase same land and raising counterclaim for conveyance against defendant No. 1 – Trial Court and High Court permitted counterclaim to avoid multiplicity – Supreme Court applying Rohit Singh and Rajul Mano Shah holds counterclaim under Order 8 Rule 6A CPC must be directed against plaintiff and not co-defendant – Counterclaim of defendants 2 & 3 held not maintainable, found lacking concrete and timely enforceable claim in any event – Liberty to file separate suit declined as claim already barred by limitation – Appeal allowed – Counterclaim set aside and parties relegated to trial on remaining issues [Paras 2, 5-8, 9-15, 16].

Civil Procedure – Counterclaim under Order 8 Rule 6A CPC – Direction of claim – Counterclaim cannot be maintained against co-defendant – Plaintiff filed suit for specific performance against sole defendant for 0.93 acres based on oral agreement and payment of consideration – After impleadment, defendant Nos. 2 & 3 raised counterclaim for transfer of entire land against defendant No. 1 alone – Relying on Rohit Singh v. State of Bihar, (2006) 12 SCC 734 and Rajul Mano Shah @ Rajeshwari Rasiklal Sheth v. Kiranbhai Shakrabhai Patel, (2025) 10 SCR 152, Court reiterates that though counterclaim may be based on a different but connected cause of action, it has necessarily to be directed against the plaintiff and cannot be directed against a co-defendant – Counterclaim of defendant Nos. 2 & 3 therefore unsustainable in law [Paras 2, 4-7, 9-11, 14].

Civil Procedure – Specific performance suit – Impleadment of persons in possession – Non-joinder of necessary parties – Effect – Sole defendant pleaded that defendant Nos. 2 & 3 were in possession of part of the suit property – They were impleaded on their own application – Court holds that once such parties are impleaded, the suit no longer suffers from defect of non-joinder of necessary parties on the ground of possession – Their presence is necessary so that, if decree for specific performance is granted, plaintiff may also seek recovery of possession – However, such impleadment does not legitimise an otherwise incompetent counterclaim against a co-defendant [Paras 6-7, 12, 14].

Specific performance – Competing claims over same property – Lack of concrete and consistent plea by subsequent purchasers – Defendant Nos. 2 & 3 first asserted an agreement to purchase entire land for Rs.5,50,000 with part-payment of Rs.2,95,000 – They also conceded that 43 decimals out of same land were agreed to be conveyed to plaintiff’s father for Rs.2,55,000 and alleged fraudulent alteration in receipt from 43 to 93 decimals – Ultimately claimed at least 50 decimals be conveyed to them based only on part-payment, without a clear agreement for that part – Court finds their stand shifting and “no concrete claim” against property, even for purposes of counterclaim [Paras 5-8, 13].

Limitation – Counterclaim for specific performance – Belated claim – Liberty to file separate suit – Cause of action for defendants 2 & 3 claimed to have arisen on 02.12.2002 – Their impleadment application and counterclaim filed only in 2006 – Court holds that at the time of filing counterclaim, claim for specific performance was already barred by limitation – Consequently, no reason to grant liberty to file a separate suit at this stage when claim is “grossly delayed” and already time-barred – Liberty to institute independent proceedings refused [Paras 7-8, 13, 15].

Civil Procedure – High Court’s supervisory jurisdiction under Article 227 – Approach disapproved – High Court dismissed plaintiff’s Article 227 petition on ground of avoiding multiplicity and observed that maintainability of counterclaim could be decided in the suit – Supreme Court holds that when law is settled that counterclaim cannot be directed against co-defendant, permitting such counterclaim to proceed is impermissible – Order of Trial Court and High Court upholding counterclaim set aside [Paras 3-4, 9-11, 14, 16].

Civil Procedure – Trial to proceed on remaining issues – Scope preserved – While setting aside counterclaim of defendant Nos. 2 & 3, Court clarifies that impleadment of said defendants continues to save suit from defect of non-joinder on ground of possession – No finding is rendered on possession – Trial Court to determine possession and, if so appropriately sought, grant recovery of possession in favour of plaintiff – All contentions except validity of counterclaim kept open for adjudication at trial [Paras 12, 14, 16-17].

Decision: Appeal allowed – Orders of Trial Court and High Court permitting counterclaim by defendant Nos. 2 & 3 set aside – Counterclaim rejected as not maintainable against co-defendant and as time-barred and lacking concrete basis – Defendants 2 & 3 to remain as parties for purposes of adjudication of possession and other issues – Parties relegated to Trial Court to agitate all contentions except that of counterclaim of defendants 2 & 3, which stands finally negatived – Pending applications disposed of [Paras 14-17].

Criminal Law – Curative Petition – Acquittal – Petitioner convicted and sentenced to death in the Rimpa Haldar murder case based on a Section 164 CrPC confession and alleged recoveries under Section 27 of the Evidence Act – Subsequent acquittals in 12 companion cases based on same evidentiary foundation – High Court and later Supreme Court found the confession inadmissible and recoveries unreliable – Held: Manifest miscarriage of justice as identical facts yielded inconsistent judicial outcomes – Curative jurisdiction rightly invoked to preserve judicial integrity [Paras 1, 5, 10, 16]

Curative Jurisdiction – Scope and Principles – Narrowly limited to correcting gross miscarriage of justice and abuse of process – Not a second review – Triggered where outcomes are irreconcilably inconsistent on same factual substratum or where natural justice is violated – Finality yields to constitutional duty in cases of manifest injustice – Reaffirmed that this jurisdiction arises ex debito justitiae and flows from Articles 129, 137, 142 of the Constitution and Order XLVIII of Supreme Court Rules – [Paras 2, 3, 4]

Confession under Section 164 CrPC – Voluntariness and Admissibility – Confession by petitioner found inadmissible in 12 other cases – Petitioner was in continuous police custody for ~60 days before confession – No meaningful legal aid – Investigating Officer’s proximity compromised voluntariness – Repeated references in confession to coercion and tutoring – Magistrate failed to record unequivocal satisfaction on voluntariness – Bar under Section 24 of Evidence Act attracted – Same confession cannot be treated as voluntary in present case when judicially discredited elsewhere [Paras 8.2, 11]

Discovery and Recovery – Section 27 Evidence Act – Alleged recoveries made from open public areas already under excavation – No contemporaneous disclosure memo proved – Contradictions in remand and seizure records – Public and police had prior knowledge of recovery sites – Recovery site not under exclusive domain of petitioner – Held: Essential elements of legal discovery missing – Section 27 inapplicable – Findings already accepted in companion acquittals apply equally here [Paras 8.3, 12]

Forensic Evidence – Insufficiency and Inconsistency – No human bloodstains, tissue, or trace evidence recovered from D-5 despite claims of multiple homicides and dismemberment – DNA analysis aided identification but not authorship – Knives and axe recovered bore no incriminating material – No expert evidence linking implements to injuries or petitioner’s capability to commit acts alleged – Circumstantial chain incomplete – Forensic gaps fatal to prosecution case [Paras 8.4, 8.5, 13]

Investigation – Deficiencies and Fairness – Investigation found seriously flawed – Disclosure not contemporaneously recorded – Remand papers contradicted prosecution theory – No medical documentation during long custody – Confession recording process lacked independence – Failure to investigate key leads (e.g., organ trade angle flagged by Ministry) – Witnesses from household and vicinity not examined – Held: Investigative lapses corroded fairness, reliability and integrity of process [Paras 8.6, 14, 18]

Constitutional Law – Articles 14 and 21 – Right to Equality and Fair Procedure – Conviction cannot stand on evidentiary basis already held legally inadmissible in identical matters – Upholding conviction would violate Article 14 (equality) and Article 21 (life and personal liberty) – Like cases must be treated alike – Disparity in identical records undermines rule of law – Held: Principles of equality and fairness demand relief under curative jurisdiction [Paras 9, 15, 16]

Presumption of Innocence – Grave Suspicion vs Legal Proof – Court reaffirms that criminal conviction must rest on proof beyond reasonable doubt – Suspicion, however strong, cannot substitute for legal evidence – Especially vital where capital sentence is imposed or serious consequences follow – [Para 17]

Final Relief – Curative Petition allowed – Supreme Court judgment dated 15.02.2011 affirming conviction and death sentence set aside – Review order dated 28.10.2014 also recalled – Conviction and sentence under Sections 302, 364, 376, 201 IPC quashed – Petitioner acquitted – Ordered to be released forthwith if not wanted in any other case – Connected SLPs disposed as infructuous [Paras 19–25]

Decision: Curative Petition allowed – Conviction and sentence under IPC set aside – Petitioner acquitted – Release directed – All related proceedings disposed of as infructuous.