Reasoned Judgments – Criminal Conviction: The Supreme Court emphasized that judgments in criminal cases must comply with the requirements of Section 354 CrPC, including a clear reference to points for determination, decisions thereon, and reasons for the decisions. Judgments must show proper application of the mind and evaluation of all evidence on record [Paras 18, 21].

Judicial Sensitivity – Examination of Evidence: The Court criticized the lower courts for failing to adequately examine and appreciate the evidence on record, particularly in serious cases involving allegations of rape. The mere improbability that a father and son could commit rape together cannot be the sole basis for acquittal without proper examination of evidence [Paras 10, 22].

Perverse Findings – Legal Consequences: The Court highlighted that findings based on irrelevant material or ignoring relevant evidence, or findings that defy logic, are considered perverse and infirm in law. Such judgments need to be set aside for failing to meet the legal standards [Paras 11-17].

Decision: Appeal allowed. The judgments of the lower courts were set aside, and the case was remanded to the Trial Court for fresh consideration based on the evidence/material on record, with directions to comply with Section 354 CrPC [Para 23].

Jurisdiction of Security Force Court – Active Duty: The Supreme Court held that the accused BSF personnel were on "active duty" as per the extended definition under Section 2(1)(a) of the BSF Act due to the Central Government's notification. Thus, the bar under Section 47 of the Act for trial by Security Force Court did not apply, and they could be tried by such a court [Paras 5-10].

Discretion under Section 80 of the BSF Act: The Court emphasized that the discretion to choose between a Criminal Court and a Security Force Court must adhere to guidelines under Rule 41 of the Border Security Force Rules, 1969. The Commanding Officer’s discretion was exercised without adhering to these guidelines, rendering the decision vulnerable [Paras 13-22].

Remand for Fresh Consideration: The Court allowed the appeal, set aside the judgments of the lower courts, and remanded the case for fresh consideration by the Chief Judicial Magistrate. The Director General of the Force was given liberty to revisit the issue and file an appropriate application for trial by Security Force Court if deemed necessary [Paras 25-26].

Decision: Appeals allowed. The impugned orders were set aside. The Security Force Court was directed to transmit the records to the Chief Judicial Magistrate for proceedings in accordance with law [Para 26].

Communication of ACR Entries – Natural Justice: The Supreme Court emphasized that all entries in the ACR of a public servant, whether they are poor, fair, average, good, or very good, must be communicated to the individual within a reasonable period. This ensures transparency, allows the individual to improve their performance, and provides an opportunity to challenge unjustified entries, thereby aligning with the principles of natural justice [Paras 3-6, 8].

Promotion and Transparency: The Court noted that the communication of ACR entries is particularly crucial for higher posts where a single adverse entry can significantly impact career progression. Ensuring that public servants are aware of and can contest ACR entries helps maintain fairness and morale within the service [Paras 4-5, 8].

Retrospective Promotion: The Court held that if an ACR entry is not communicated, it should not be used to assess promotion eligibility. The Appellant was granted the liberty to seek retrospective promotion based on the Court's ruling that non-communication of ACR entries violates Article 14 of the Constitution [Paras 8-10].

Decision: Civil Appeal disposed of. The Court approved the view in Dev Dutt v. Union of India (2008) 8 SCC 725 that every ACR entry must be communicated. Decisions contrary to this view, including those in Satya Narain Shukla v. Union of India and Others and K.M. Mishra v. Central Bank of India, were declared not good law [Paras 6, 9].

Review Jurisdiction – Grounds for Review – Union of India sought review of the judgment in Sandur Manganese and Iron Ores Ltd. case, citing misquotation of the Expert Committee's Report and interpretation of statutory provisions – Supreme Court partially accepted misquotation error but upheld the judgment on the substantive issues, finding no error apparent on the face of the record – Review petition dismissed with corrections to the misquoted report [Paras 1-30].

Principles of Natural Justice – Opportunity to be Heard – Petitioner argued non-service of SLP copy denied it the opportunity to present its case – Court noted principles of natural justice require all parties be heard, but found delay in review petition filing was sufficiently explained and condoned [Paras 2-6].

Application of Section 11 of MMDR Act – Virgin and Previously Held Areas – Supreme Court reiterated Section 11's application to both virgin and previously held mining areas, supporting its earlier interpretation and rejecting Union of India's differing view as a ground for review [Paras 21-24].

Statutory Interpretation – Misquoted Expert Report – Court acknowledged clerical error in judgment quoting Expert Committee Report – Corrected misquoted lines but maintained judgment’s validity and conclusions based on statutory interpretation and procedural rules [Paras 17-20].

Decision: Review Petition Partially Allowed for Corrections – Substantive Judgment Upheld – Delay in filing condoned, misquoted lines deleted, judgment otherwise affirmed. Union of India granted further four months to comply with directions issued in the original judgment [Paras 29-31].

Criminal Law – Insanity Defense – Appellant convicted of murder under Sections 302 and 449 IPC – Defense claimed appellant was suffering from Paranoid Schizophrenia and sought protection under Section 84 IPC – Supreme Court held that the burden of proving insanity at the time of the incident lies on the accused under Section 105 Evidence Act – Evidence of past treatment for mental illness insufficient to prove unsoundness of mind at the time of the crime – Appellant's coherent behavior during trial and prior threats negate claim of insanity [Paras 9-19].

Evidence – Burden of Proof – Accused must prove existence of circumstances bringing case within exceptions – Section 84 IPC requires proof of incapability to understand nature of act due to unsoundness of mind at the time of offense – Testimonies of eyewitnesses, medical evidence, and appellant’s conduct considered – Supreme Court found prosecution established guilt beyond reasonable doubt [Paras 10-13, 18-19].

Mental Health – Schizophrenia – Court referred to medical jurisprudence on paranoid schizophrenia – Symptoms and dangers discussed – Legal insanity distinguished from medical insanity – Court emphasized legal criteria for exemption from criminal liability [Paras 13-15].

Decision – Appeal dismissed – Conviction and life sentence for murder upheld – Appellant failed to establish defense of insanity under Section 84 IPC [Paras 19-20].

Criminal Law – Common Object – Conviction under Sections 147, 148, 302 read with Section 149 IPC – Accused formed unlawful assembly with common object to assault the deceased – Evidence established specific overt acts by Chhotelal, Dhaniram, Mohan, Badri, and Govardhan – Others acquitted due to contradictory statements and lack of evidence of overt acts [Paras 11, 19].

Evidence – Credibility – Eyewitnesses PW-5 and PW-12 provided consistent testimonies about the involvement of certain accused – Discrepancies in evidence regarding the presence and actions of other accused led to their acquittal – Supreme Court emphasized need for credible and consistent evidence to establish participation in unlawful assembly [Paras 11, 20].

Procedural Compliance – Section 157 CrPC – Delay in sending FIR to Magistrate – Trial court found no evidence of FIR being antedated or embellished – Supreme Court upheld trial court's finding based on overall credibility of prosecution witnesses and evidence [Para 21].

Judgment Analysis – Supreme Court partially allowed the appeals – Convictions of Dhaniram, Mohan, Badri, and Govardhan affirmed – Other accused acquitted due to lack of evidence of their involvement – Emphasized importance of corroborative evidence in establishing common object and individual participation [Paras 22].

Decision: Appeals partly allowed – Convictions and sentences of Dhaniram, Mohan, Badri, and Govardhan upheld – Satyanarayan, Ramesh, Kanchedi, and Rattiram acquitted – Bail bonds of acquitted appellants discharged [Para 22].

Civil Procedure – Amendment of Written Statement – Defendants sought amendment under Order 6 Rule 17 CPC after 13 years, during trial – Supreme Court held that amendment application filed after long delay and commencement of trial is misconceived – Defendants previously filed applications under Order 6 Rule 16 and Order 8 Rule 9 CPC to withdraw admissions, both rejected – Successive applications for same relief not permissible – High Court's order dismissing amendment application upheld [Paras 14-25].

Admissions in Pleadings – Withdrawal of Admissions – Defendants admitted plaintiff's claim and agreed to transfer patta in written statement – Defendants’ subsequent attempt to withdraw admissions through fresh written statement and amendment application disallowed – Courts emphasized that admissions once made cannot be retracted to introduce a contradictory case [Paras 13-14, 19, 24].

Procedure – Abuse of Process – Multiple applications by defendants to amend written statement and withdraw admissions considered abuse of court process – High Court and Supreme Court rejected successive applications to maintain procedural integrity and fairness [Paras 24-25].

Decision: Appeals dismissed – Orders of High Court and trial court affirmed – Amendment of written statement disallowed [Para 25].

Sentencing Policy – Proportionality – Conviction under Section 307 IPC – High Court reduced sentence to period already undergone citing long pending trial and potential revival of enmity – Supreme Court held reduction unjustified – Emphasized need for sentences to reflect gravity of offence and ensure justice – High Court's reasons found irrelevant and unsustainable [Paras 5-26].

Evidence – Injuries and Medical Reports – Prosecution proved injuries and involvement of accused through eyewitnesses and medical evidence – Trial Court's sentences based on grievous nature of injuries and role of each accused justified – High Court failed to adequately consider medical evidence and impact of injuries [Paras 17-18, 25].

Undue Leniency – Impact on Justice System – Supreme Court reiterated principle that undue leniency undermines public confidence in law – Sentences must be commensurate with crime to maintain justice and deterrence – Emphasized judicial responsibility to impose appropriate sentences [Paras 7-13, 20-24].

Decision: Appeals allowed – High Court's reduction of sentence set aside – Sentences imposed by trial Court restored – Respondents to be taken into custody to serve remaining period of sentence [Paras 26].

Environmental Law – Forest Clearance – OMC challenged MOEF's order rejecting Stage-II forest clearance for 660.749 hectares of forest land for bauxite mining – Supreme Court reviewed compliance with forest rights and environmental statutes – Court emphasized procedural safeguards under the Forest Rights Act and the role of Gram Sabha in protecting community resources and cultural rights [Paras 1-29].

Tribal Rights – Forest Rights Act – Court stressed the importance of recognizing and vesting forest rights in scheduled tribes and traditional forest dwellers – Directed MOEF to take a final decision on forest clearance based on Gram Sabha proceedings – Protection of tribal habitat and cultural rights highlighted as integral to forest conservation [Paras 31-49].

International Conventions – Indigenous Peoples’ Rights – Court referred to various international conventions supporting indigenous peoples' rights to maintain cultural identity and manage community resources – Emphasized adherence to international norms alongside national legislation [Paras 33-38].

Judgment Analysis – Gram Sabha Authority – Supreme Court underscored the authority of Gram Sabha in recognizing forest rights under the Forest Rights Act – Directed MOEF to consider Gram Sabha decisions before granting forest clearance – Reiterated need for state and central authorities to work in consultation with tribal communities [Paras 40-41].

Decision: Writ Petition disposed of – Directed MOEF to make a final decision on Stage-II forest clearance for bauxite mining project based on Gram Sabha proceedings within two months [Para 49].