Lease Purpose – Agricultural Land – Appeal arose from proceedings under Section 32G of the Bombay Tenancy and Agricultural Lands Act, 1948 – Dispute over whether land leased for sugarcane cultivation – Tahsildar initially found lease was for sugarcane, but was overturned by Sub-Divisional Officer – Tribunal reinstated Tahsildar’s finding – High Court reversed Tribunal, holding lease was not for sugarcane cultivation and Section 43A did not apply to single-person leases – Supreme Court reinstated Tribunal’s finding, holding High Court erred in its reasoning and application of law [Paras 1-8].

Statutory Interpretation – Singular and Plural – High Court held Section 43A(1)(b) applied only to multiple persons, not single lessee – Supreme Court clarified Section 13 of the Bombay General Clauses Act allows plural terms to include singular – Found nothing repugnant in the context to exclude single lessee from Section 43A(1)(b) – High Court’s interpretation would defeat Act’s purpose [Paras 9-12].

Decision – Appeal allowed – High Court’s judgment set aside – Tribunal’s judgment reinstated – Lease for sugarcane cultivation confirmed – Section 43A(1)(b) applicable to single-person leases – Costs not awarded [Paras 12-13].

Judicial Review – Disciplinary Proceedings – Respondents dismissed from service following disciplinary proceedings – High Court directed Appellate Authority to reconsider punishment and impose lesser penalty – Supreme Court held that judicial review of penalty is limited – Courts cannot prescribe specific penalties – Appropriate penalty to be decided by disciplinary/Appellate Authority considering all circumstances [Paras 1-13].

Equality Principle – Article 14 – Identical Charges – High Court directed same lesser punishment for respondents as their co-delinquents – Supreme Court acknowledged disparity in responses to charges – Differentiated penalty justified when co-delinquents accepted charges and apologized early – Courts to ensure parity in penalty only when there is complete parity in conduct post-charge [Paras 14-16].

Decision – Appeals allowed – High Court's direction set aside – Matter remitted to Appellate Authority for fresh decision on penalty – Respondents may present mitigating circumstances – Appellate Authority to consider all aspects and decide within two months [Paras 18-19].

Employment – Suppression of Facts – Appellant terminated for not disclosing involvement in a criminal case – High Court upheld termination – Supreme Court affirmed, stating suppression of material facts amounts to moral turpitude – Clauses in affidavit to be read separately; non-disclosure of criminal case registration valid ground for termination [Paras 1-9, 24].

Misrepresentation – Consequences – Employment obtained through misrepresentation or fraud invalid – Legal principle upheld that fraudulent acts unravel all judicial acts – Appointment by misrepresentation renders employment voidable at employer's discretion – Termination justified even if trial did not result in conviction [Paras 10-23].

Decision – Appeal dismissed – Appellant’s suppression of criminal involvement validated termination – Legal standards and precedents on misrepresentation in employment reaffirmed [Paras 24].

Employment – Eligibility Criteria – Appellant appointed as TGT (Sanskrit) but did not possess required B.Ed degree on the last date of application submission – High Court upheld termination – Supreme Court affirmed, emphasizing eligibility must be judged as on the last date for applications – Provisional appointments subject to verification of qualifications [Paras 1-9, 15].

Misrepresentation – Consequences – Appointment letter stated employment was provisional, subject to verification – Appellant's claim of eligibility due to subsequent result declaration invalid – Eligibility determined by last date for applications, not subsequent events – Appointment based on misrepresentation leads to valid termination [Paras 10-14].

Decision – Appeal dismissed – Appellant’s lack of requisite qualification on application date justified termination – Upholding legal standards on eligibility and misrepresentation in employment [Para 15].

Suspension and Subsistence Allowance – Employee suspended for alleged misappropriation of funds – Departmental proceedings initiated but subsistence allowance not paid – High Court set aside dismissal due to non-payment of subsistence allowance, directed fresh proceedings – Supreme Court upheld High Court’s decision, stressing payment of subsistence allowance during suspension as essential for fair proceedings [Paras 1-18].

Natural Justice – Non-payment of subsistence allowance – Impoverished condition cited for non-participation in departmental proceedings – Supreme Court ruled non-payment violated principles of natural justice, invalidating dismissal – Subsistence allowance deemed necessary for ensuring fair opportunity to defend [Paras 9-15].

Procedural Compliance – Reinstatement and Proceedings – Directed payment of subsistence allowance and initiation of fresh proceedings – Supreme Court modified High Court’s order, specifying arrears and subsistence allowance payments, setting timeline for new enquiry [Paras 18-19].

Decision – Appeal disposed of with modifications – Directed payment of arrears and subsistence allowance – Fresh departmental proceedings to commence post payment, conclude within three months [Para 19].

Criminal Law – Circumstantial Evidence – Appellant convicted for kidnapping, murder, and concealment of a child’s body based on circumstantial evidence – Supreme Court upheld conviction finding chain of circumstances complete and consistent with guilt – No reasonable hypothesis of innocence [Paras 6-18].Homicidal Death – Medical Evidence – Postmortem report confirmed death due to head injuries – Doctor ruled out accidental fall – Supreme Court confirmed death was homicidal based on medical evidence [Paras 9-11].Last Seen Theory – Witness Testimonies – Mother and shopkeeper testified seeing appellant with deceased – Appellant seen buying sweets for deceased – Testimonies corroborated circumstantial evidence of last seen [Paras 12-14].Motive – Wage Dispute – Evidence showed appellant had motive due to wage dispute with deceased’s father – Supreme Court found motive established based on consistent witness testimonies [Para 17].Decision – Appeal dismissed – Conviction and sentence confirmed – No flaws found in lower courts’ judgments based on circumstantial evidence [Para 18].

Compassionate Appointment – Eligibility Criteria – Respondent failed physical test for compassionate appointment as Sub-Inspector – High Court ordered fresh test – Supreme Court ruled second test not justified as compassionate appointments are to mitigate immediate hardship, not for securing specific posts – First physical test aligned with rules ensuring minimum standards of efficiency [Paras 21-23].

Legal Principles – Compassionate Appointment – Supreme Court reiterated compassionate appointment is an exception to general recruitment norms meant to alleviate sudden family crises – It cannot be claimed as a right for a specific post – Efficiency and minimum standards must be maintained [Paras 10-14].

Procedural Rules – Physical Test – Appointment authority's discretion to conduct physical tests upheld – Supreme Court found Inspector General’s order/circular justified under Rule 8(2) to maintain efficiency standards – First physical test outcome binding unless challenged within stipulated rules [Paras 15-20].

Decision – Appeals allowed – High Court’s order for fresh physical test set aside – Respondent may compete for promotion under normal rules with necessary relaxations [Para 22-24].

Equal Pay for Equal Work – Junior Hindi Translators – Respondent sought parity with translators in the Central Secretariat Official Language Service (CSOLS) – Tribunal and High Court found no functional difference – Supreme Court upheld decision based on lack of evidence showing distinction in job functions – Cited principles from Randhir Singh case affirming equal pay for equal work as a constitutional right under Articles 14 and 39(d) [Paras 4-6].

Legal Principles – Directive Principles – Equal pay for equal work read into fundamental rights – Supreme Court reiterated equality clauses under Articles 14 and 16 must have substantive meaning, ensuring equal remuneration for equal work irrespective of departmental distinctions unless functional differences are proven [Para 6].

Decision – Special Leave Petition dismissed – High Court’s decision and Tribunal’s order upheld – Parity in pay granted to Junior Hindi Translators in different departments [Para 7].

Criminal Law – Conviction under Section 498A IPC – Appellant convicted based on the deceased's letter alleging harassment – High Court acquitted the appellant of abetment of suicide but maintained conviction under Section 498A IPC – Supreme Court found no independent evidence supporting the allegations of cruelty – Deceased’s letter not sufficient proof under Section 32(1) of the Evidence Act for Section 498A IPC as cause of death was not in question [Paras 1-18].

Evidence – Admissibility – Deceased’s letter to police alleging cruelty – Supreme Court ruled the letter inadmissible for proving cruelty under Section 498A IPC since cause of death was not in question – No corroborating evidence from witnesses [Paras 14-17].

Decision – Appeal allowed – High Court's judgment set aside – Appellant acquitted of charges under Section 498A IPC – Bail bonds discharged [Paras 18].