Education Law – Eligibility Criteria for Admission – Subsequent Fulfillment of Requirements – Relief Granted – The appellant secured admission to a B.A.M.S. course despite not meeting the eligibility requirement of passing English in the 10+2 examination – His college was later de-recognized, and students were transferred, but he was denied transfer on eligibility grounds – The appellant, acting on a provisional admission letter, reappeared for the 12th class examination, passed English, and completed almost the entire B.A.M.S. course – Held: Given the peculiar facts, including the appellant's substantial completion of the course and compliance with eligibility criteria during his studies, he should be allowed to complete the course and internship, and be issued his degree [Paras 7-9].

Doctrine of Actus Curiae Neminem Gravabit – Court Should Not Prejudice a Party Due to Its Own Actions – The appellant pursued the course under interim orders for nearly six years and completed part of his mandatory internship – The High Court's decision to deny relief disregarded the principle that a court’s action should not cause undue hardship to a litigant (actus curiae neminem gravabit) – Held: Since the appellant had substantially complied with the eligibility requirements and invested significant time and effort, denying him relief would be unjust [Para 8].

Judicial Review – Power to Intervene in Academic Matters – Exceptional Circumstances Justifying Relief – Courts generally do not interfere in academic matters unless there is manifest injustice – The appellant’s admission was initially irregular, but subsequent compliance with eligibility norms and completion of studies justified intervention – Held: Exceptional circumstances warranted setting aside the High Court’s order, ensuring that the appellant is not unfairly deprived of his degree [Para 9].

Decision: Appeal Allowed – The Supreme Court set aside the Madhya Pradesh High Court’s orders dated 18.06.2014 (W.P. No. 10267 of 2012) and 01.08.2014 (Review Petition No. 236 of 2014) – The appellant shall be allowed to complete his course and internship at Shaskiya Swasashi Dhanwantari Ayurvedic Medical College, Ujjain – The concerned authorities shall issue the appellant his B.A.M.S. degree upon completion – No order as to costs [Para 9].

Service Law – Seniority Dispute – Promotion vs. Direct Recruitment – Applicability of Special Rules, 1960 and Subordinate Service Rules, 1966 – Seniority Upheld for Promoted Engineers – The dispute pertained to the seniority of Assistant Engineers in the Kerala Water Authority, where the appellants, promoted from Draftsman-Grade I, challenged the High Court's decision granting seniority to directly recruited engineers – The High Court erred in applying Rule 4(b) of the Special Rules, 1960 at the stage of appointment to Assistant Engineer, as the rule only applies for further promotions – The Supreme Court clarified that once an individual becomes an Assistant Engineer, they can opt for either the degree or diploma quota for further promotion – The seniority list prepared by the Kerala Water Authority was held to be valid – Appeals allowed, and the High Court's judgments set aside [Paras 16-27].

Statutory Interpretation – Avoidance of Absurdity – Harmonious Construction – The interpretation by the High Court created an anomalous situation where a junior employee with a diploma who later acquired a degree could leapfrog a senior employee with both qualifications – The Supreme Court applied the presumption against absurdity, holding that statutory provisions must be construed to avoid irrational results – The Court reiterated that the legislature's intent must be honored through a rational and just interpretation [Paras 28-30].

Precedents – Inapplicability of Chandravathi P.K. Case (2004) 3 SCC 734 – The respondents relied on the Supreme Court's ruling in Chandravathi P.K., which dealt with weightage for service before acquiring a degree – The Court held that the ruling was not relevant to the present case, as it addressed a different issue – The private respondents' reliance on the case was misplaced [Paras 31].

Decision – Appeals Allowed – High Court Judgment Overturned – The Supreme Court ruled in favor of the appellants, restoring their seniority as per the original list prepared by the Kerala Water Authority – The judgments of the Single Judge and the Division Bench were set aside [Para 32].

Criminal Law - Rape – Child Victim – Conviction Restored – Acquittal by High Court Set Aside – The appellant-State challenged the High Court’s decision acquitting the respondent-accused of rape charges – The Trial Court had convicted the accused based on medical evidence and eyewitness testimony but was overturned by the High Court on grounds of contradictions in witness statements – The Supreme Court held that minor inconsistencies in witness statements do not vitiate the prosecution case, especially in cases of child sexual assault – The doctrine of actus curiae neminem gravabit was invoked, emphasizing that delays in legal proceedings should not prejudice the victim – Held: The Trial Court’s conviction is restored, and the respondent-accused is directed to surrender and serve the sentence [Paras 17-22].

Child Witness – Competency and Reliability – Need for Cautious Evaluation – The Supreme Court reaffirmed that child witnesses can be competent if they understand the duty to speak the truth – The victim was unable to testify due to trauma, but her silence and tears were noted as significant indicators of distress – The Court cited Hemudan Nanbha Gadhvi v. State of Gujarat (2019) 17 SCC 523, holding that the inability of a minor victim to testify does not automatically discredit the prosecution case – Held: The testimony of a traumatized child victim cannot be disregarded, especially when corroborated by medical and circumstantial evidence [Paras 12-14, 17].

Medical Evidence – Injuries Indicating Sexual Assault – Corroboration with Circumstantial Evidence – The medical report confirmed fresh injuries to the victim’s private parts consistent with sexual assault – The accused had injuries on his genitalia, supporting the prosecution’s claim of forced intercourse – The defense's argument that the injuries were caused by a nail was dismissed as unsubstantiated – Held: Medical evidence strongly supports the prosecution case, affirming the guilt of the accused [Paras 10, 20].

Circumstantial Evidence – Chain of Events Leading to Conviction – The presence of bloodstains, the victim’s unconscious state, and the accused fleeing the scene corroborated the prosecution's case – The Supreme Court applied the Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116 test for circumstantial evidence, holding that the established facts were consistent only with the guilt of the accused – Held: The circumstantial evidence formed a complete chain pointing to the accused's guilt beyond reasonable doubt [Paras 15-16].

Reversal of Acquittal – Failure of High Court to Apply Settled Principles of Law – The Supreme Court criticized the High Court for failing to independently assess the evidence and merely dismissing the prosecution’s case based on minor discrepancies – Citing State of U.P. v. Krishna Gopal (1988) 4 SCC 302, the Court emphasized that reasonable doubt must be substantial, not speculative – Held: The High Court’s reasoning was legally flawed, and its order of acquittal is set aside [Paras 6, 19].

Decision: Appeal Allowed – The Supreme Court set aside the High Court’s judgment dated 12/07/2013, which had acquitted the accused – The Trial Court’s judgment dated 19/11/1987 convicting the accused under Section 376 IPC is restored – The accused is directed to surrender within four weeks to serve the sentence – No order as to costs [Para 22].
 

Criminal Law – Copyright Infringement – Expert Report – Appellant alleged that respondents copied the design of its bookbinding machine, leading to registration of FIR under Copyright Act, IPC, and IT Act – High Court initially ordered expert opinion by FSL with involvement of an engineer – FSL and IO submitted a report dated 21.03.2019 – Respondents dissatisfied and sought further directions [Paras 3-7].

Procedural Law – Maintainability – Application in Disposed Petition – Second application filed in disposed Special Criminal Application held improper – Supreme Court held that the High Court erred in entertaining the second application post disposal of the main petition and ordering additional expert opinion [Paras 8-14].

Investigation – Validity of Multiple Expert Opinions – Supreme Court held that once the High Court accepted the initial expert report, it was improper to direct IO to obtain a fresh expert opinion – The direction would prejudice the investigation and parties – Investigation should proceed on existing report subject to objections by the accused before the IO [Paras 13-16].

Investigation – Discretion of Investigating Officer – Supreme Court granted liberty to respondents to raise objections before IO regarding expert report – IO to exercise discretion whether further expert opinion is required under applicable laws without mandatory direction from High Court [Para 16].

Decision – Appeal Allowed – High Court’s direction for additional expert opinion quashed – Liberty given to respondents to raise objections before IO – IO permitted to proceed as per law without compulsion to seek second opinion [Paras 16-17].

Environmental Law – Jurisdiction of NGT – Tribunal Exceeded Powers – Appeal Allowed – The NGT directed the appellant to prepare a fresh township plan and obtain Environmental Clearance before further construction – Held: NGT lacked jurisdiction as no substantial question of environmental law under Schedule I of the NGT Act was involved – The Tribunal overstepped its authority by interfering with a Master Plan approved in 2001 and gazetted in 2010 – Order quashed [Paras 10-12].

Auroville Master Plan – Statutory Validity – No Fresh Approval Required – The Master Plan for Auroville was approved by the competent authorities in 2001 and legally notified in 2010 – Tribunal’s direction for a fresh township plan was unwarranted – Held: Once a Master Plan attains statutory status, it cannot be nullified or modified arbitrarily by a judicial forum lacking legislative or administrative authority [Paras 13-14].

Environmental Impact Assessment – Applicability to Auroville Project – No Fresh EC Required – The Ministry of Environment, Forest & Climate Change (MoEF&CC) had clarified that the Auroville Township Project commenced before the EIA Notification, 1994, and thus did not require Environmental Clearance under the 2006 notification – Held: Tribunal’s directive to obtain EC was contrary to the legal position – No new environmental concerns were demonstrated to justify such an order [Paras 14-15].

Precautionary Principle – Misapplication by NGT – No Environmental Violation Established – The Tribunal applied the Precautionary Principle to justify its interference, despite ruling that the disputed land was not a forest under the Forest (Conservation) Act – Held: Precautionary Principle does not grant courts the power to override statutory planning approvals without clear environmental violations – Unsubstantiated concerns cannot override legal frameworks [Paras 16-18].

Final Decision – NGT Order Quashed – Auroville Master Plan Implementation Restored – Supreme Court allowed the appeal, setting aside the NGT’s orders – Held that the appellant is free to proceed with the approved Master Plan, including construction of the Crown Road, without further clearance [Paras 19-20].
 

Criminal Law - Prevention of Money Laundering Act – Discharge Application – Continuing Offence – Appeal Dismissed – The appellant, a retired IAS officer, sought discharge from prosecution under PMLA, contending that the alleged predicate offences were committed before PMLA came into force – High Court dismissed his plea, holding that money laundering is a continuing offence – Held: Money laundering persists as long as proceeds of crime are used, concealed, or projected as untainted – PMLA applies even if predicate offences occurred before its enactment, provided the proceeds are still in circulation – No illegality in High Court’s order rejecting the discharge application [Paras 21-25].

Criminal Law – Retrospective Application of PMLA – No Merit in Appellant’s Contention – Appellant argued that PMLA was applied retrospectively as the alleged offences predated its enforcement – Held: The offence of money laundering is independent of the predicate offence and continues so long as tainted property is in possession or use – Supreme Court in Vijay Madanlal Choudhary v. Union of India, (2023) 12 SCC 1, affirmed that PMLA is not applied retrospectively but as a continuing offence – Appellant failed to prove that the proceeds of crime were not laundered post-enactment of PMLA [Paras 22-24].

Economic Offences – Strict Judicial Approach – Quashing Not Warranted – Allegations against the appellant included large-scale corruption, illegal land allotments, and hawala transactions – Proceeds of crime exceeded ₹1.32 crores, justifying prosecution under PMLA – Held: Economic offences affect national integrity and require strict scrutiny – Courts must be cautious in quashing proceedings at the discharge stage – Appellant’s argument regarding monetary threshold under PMLA was misplaced, as the total proceeds of crime exceeded statutory limits even before the 2013 amendment [Paras 26-30].

Decision – Appeal Dismissed – Trial to Proceed – Supreme Court upheld the High Court’s decision, dismissing the appeal and allowing prosecution to continue – Affirmed that the appellant must face trial given the serious nature of allegations and financial implications of the offence [Paras 35-37].

Negotiable Instruments Act – Dishonour of Cheques – Moratorium under IBC – Quashing of Criminal Proceedings – Appeal Allowed – The appellant, a director of a corporate debtor, issued cheques that were dishonoured, leading to a complaint under Section 138 of the NI Act – A moratorium under Section 14 of the IBC was imposed before the completion of the statutory 15-day period following the notice of dishonour – High Court dismissed appellant’s petition, relying on P. Mohan Raj v. M/S Shah Brothers Ispat Pvt. Ltd. (2021) 6 SCC 258 – Held: P. Mohan Raj was distinguishable as the cause of action in the present case arose after the imposition of the moratorium – Since the appellant, due to the moratorium and Section 17 of the IBC, was no longer in charge of the corporate debtor, he was incapable of fulfilling the demand – Proceedings under Section 138 NI Act against him were impermissible and should have been quashed [Paras 6-12].

IBC – Effect of Moratorium – Protection to Corporate Debtor and its Directors – Proceedings under NI Act Barred – Under Section 14(1)(a) of the IBC, a moratorium prohibits the institution or continuation of suits and proceedings against the corporate debtor – The moratorium extends to all legal actions affecting the corporate debtor, including criminal complaints under Section 138 NI Act if the cause of action arises post-moratorium – Since the appellant ceased to have control over the corporate debtor due to the appointment of an Interim Resolution Professional (IRP), he could not have complied with the demand notice – Held: The proceedings under Section 138 NI Act were barred and deserved to be quashed [Paras 7-11].

Criminal Procedure – Quashing under Section 482 CrPC – High Court’s Error – Quashing Justified – High Court failed to appreciate the distinction between a case where the cause of action under Section 138 NI Act arose before the moratorium and a case where it arose after – Given that the cause of action in this case was post-moratorium, the High Court erred in dismissing the appellant’s petition – Supreme Court invoked its power to quash the proceedings to prevent the abuse of the legal process [Paras 12-13].

Decision – Appeal Allowed – Criminal Proceedings Quashed – Supreme Court set aside the High Court’s order and quashed the summoning order dated 07.09.2018 – Complaint Case No. 15580/2018 pending before the Chief Judicial Magistrate, Chandigarh, also quashed [Para 13].

Criminal Procedure – Registration of FIR – Preliminary Inquiry – Appeal Dismissed – The appellant, a retired IAS officer, challenged multiple FIRs registered against him regarding land allotment irregularities during his tenure as Collector – He sought a direction for a mandatory preliminary inquiry before the registration of further FIRs – High Court dismissed the plea, holding that registration of FIRs for cognizable offences is mandatory under Section 154 CrPC – Held: Preliminary inquiry is required only in limited cases, and not where cognizable offences such as corruption and abuse of office are alleged – Registration of successive FIRs is a matter for investigation and trial, and the appellant has adequate legal remedies, including quashing under Section 482 CrPC and seeking bail – Appeal dismissed [Paras 6-15].

Constitutional Law – Right to Liberty – Articles 14, 20, and 21 – No Blanket Protection Against FIRs – The appellant argued that multiple FIRs violated his right to liberty and were lodged to harass him – Held: Fundamental rights do not provide immunity from investigation if a cognizable offence is disclosed – A blanket order restraining future FIRs or mandating preliminary inquiry in every case would amount to judicial overreach – Courts cannot create procedural safeguards beyond what is provided in law [Paras 10-14].

Precedents – Application of Lalita Kumari Case – No Absolute Requirement for Preliminary Inquiry – The appellant relied on Lalita Kumari v. Govt. of U.P. (2014) 2 SCC 1 to argue that a preliminary inquiry should have been conducted before registering FIRs – Held: Lalita Kumari only mandates preliminary inquiry in limited categories of cases such as medical negligence and family disputes – In corruption cases, where clear allegations of cognizable offences exist, FIRs must be registered without inquiry – Appellant’s reliance on Lalita Kumari misplaced [Paras 11-12].

Decision – Appeal Dismissed – No Relief Granted – Supreme Court upheld the High Court’s decision, dismissing the appellant’s plea – Clarified that the appellant is free to seek other legal remedies, including challenging specific FIRs through appropriate judicial forums [Para 15].

Administrative Law – Auroville Foundation – Power of Governing Board – Validity of Standing Order Upheld – The appellant challenged the High Court's order setting aside Standing Order No. 01/2022, which reconstituted the Auroville Town Development Council – High Court erred in holding that the Residents’ Assembly had a legal right to nominate members to the ATDC – Held: Governing Board, under Sections 11(3), 16, and 17(e) of the A.F. Act, has exclusive authority over the management and implementation of Auroville’s Master Plan – Residents’ Assembly’s role is advisory and does not extend to nominating members to administrative committees – Impugned High Court order set aside [Paras 12-17].

Doctrine of Clean Hands – Suppression of Material Facts – Abuse of Process of Law – The respondent had previously filed Writ Petition No. 22895/2022 challenging the same Office Order dated 01.06.2022, which was dismissed – She filed Writ Petition No. 25882/2022 without disclosing the prior dismissal – Held: Non-disclosure of material facts constitutes abuse of process of law – High Court failed to consider this suppression and should have dismissed the petition on this ground alone [Paras 9-11].

Judicial Review – Limited Scope in Policy Matters – No Judicial Overreach – The High Court wrongly interpreted the A.F. Act and interfered with the validly issued Standing Order – Held: Courts cannot rewrite statutory provisions or introduce procedural safeguards not contemplated in law – Governing Board’s power to constitute committees, including ATDC, is well established in the Act and Rules – Judicial interference in administrative decisions must be limited [Paras 16-18].

Decision – Appeal Allowed – High Court Order Set Aside – Costs Imposed – Supreme Court allowed the appeal, upheld the validity of Standing Order No. 01/2022, and imposed costs of ₹50,000 on the respondent for filing a frivolous petition – Costs to be deposited with the Supreme Court Legal Services Committee within two weeks [Para 19].