Matrimonial Law – Enhancement of Permanent Alimony – Quantum of Maintenance – Alimony Enhanced - Appellant-wife challenged High Court’s fixation of permanent alimony at ₹20,000/month – Respondent-husband claimed net income of ₹1,64,039/month and remarriage obligations – Supreme Court found original amount inadequate considering past lifestyle and inflation – Held: Permanent alimony enhanced to ₹50,000/month with 5% increase every two years [Paras 5-9].

Financial Capability – Husband’s Salary and Disclosures – Court Assessment - Respondent submitted salary slips and tax records showing ability to pay more – Court held respondent capable of higher contribution despite remarriage and expenses – Held: Financial disclosures warranted revision of support quantum [Paras 6-7].

Wife’s Entitlement – Standard of Living and Future Security – Court Emphasis - Court noted appellant remained unmarried and relied entirely on alimony – Maintenance must reflect lifestyle during marriage and provide financial stability – Held: ₹50,000/month justified and reasonable [Paras 7-8].

Son’s Support – No Further Mandatory Payment – Court Discretion - Son aged 26 found no longer financially dependent – Held: No obligation on respondent to pay, but may voluntarily assist – Son’s inheritance rights remain unaffected [Para 8].

Decision – Appeal Allowed – Maintenance Revised – Contempt Petition Disposed - Supreme Court modified High Court order, enhanced permanent alimony, and disposed of pending contempt petition accordingly [Paras 9-10].

Constitutional Law – Public Interest Litigation – Heritage Site Modification – Chandigarh Administration challenged High Court orders directing construction of verandah in front of Court Room No. 1 and laying of green paver blocks for parking – High Court issued writs of mandamus emphasizing public utility and sustainable development – Supreme Court upheld both directives – Held: High Court’s directions justified, proportionate, and do not infringe UNESCO guidelines or environmental planning norms [Paras 3, 27-47]

Heritage Preservation – Construction in UNESCO World Heritage Site – Objection raised by Chandigarh Administration citing risk to World Heritage status of Chandigarh Capitol Complex – Court noted verandah proposal was originally considered in 1956 and was not irreversible or major modification – Verandah construction in line with existing structures (Court Rooms 2-9), not infringing Outstanding Universal Value (OUV) – Held: No evidence of formal objections from UNESCO – Construction does not violate para 172 of Operational Guidelines [Paras 4-12, 26-39]

Environmental Planning – Sustainable Development – Green Pavers in Green Belt Area – High Court directed laying of green paver blocks and planting of trees in kutcha parking area used for High Court visitors – Chandigarh Administration objected citing Chandigarh Master Plan 2031 – Court held sustainable development principle requires balancing environmental protection and public utility – Affirmed use of green pavers with tree planting to address parking needs and maintain green cover [Paras 12-14, 40-45]

Judicial Review – Administrative Discretion – Court held High Court administration is best placed to assess needs of Court infrastructure – Earlier administrative decisions (1956) could not preclude reconsideration in present context – Directions aimed at preserving building utility and stakeholder welfare – Use of modern materials and expert advice (e.g., IIT Roorkee) endorsed [Paras 20-23, 36-37]

Decision: Appeals dismissed – High Court orders dated 29th November 2024, 13th December 2024, 7th February 2025, and 21st February 2025 upheld – Contempt proceedings against Chief Engineer kept in abeyance for 12 weeks to allow compliance – Supreme Court confirmed PIL-based directions were valid, proportionate and aligned with constitutional duties [Paras 39, 45-47]

Criminal Law – Appeal Against Dismissal of PIL - Police Encounters – Violation of PUCL Guidelines – 171 Incidents Scrutinised – Appellant alleged systematic failure in compliance with guidelines laid down in PUCL v. Maharashtra – FIRs registered against victims instead of police personnel – Magisterial inquiries and forensic analysis allegedly absent or delayed – Held: While complete breakdown not proven, partial non-compliance identified; directions issued for independent inquiry by Assam Human Rights Commission [Paras 2-6, 18-36].

Public Interest Litigation – Locus Standi – Appellant as Advocate Raised Cause of Victims – State Questioned Maintainability – Court held Appellant acted in public interest given fear and marginalisation of victims’ families – Emphasised need for calibrated mechanism ensuring participation of affected individuals – Held: PIL maintainable, victims’ right to be heard must be ensured [Paras 18-25].

Human Rights Commissions – Role under Protection of Human Rights Act – Supreme Court Expressed Concern over Bypassing of AHRC – AHRC Had Initially Taken Suo Motu Cognizance but Withdrew Due to High Court Proceedings – Held: AHRC reinstated to conduct independent inquiry – Statutory bodies must not be rendered redundant by parallel proceedings [Paras 40-46].

Judicial Remedies – Directions for Independent Inquiry – Confidential Hearings and Victim Protection – Supreme Court directed AHRC to issue public notice inviting victims/families, ensure confidentiality, and facilitate legal aid via ASLSA – Investigation may involve retired/independent officers – State of Assam to provide full administrative cooperation – Held: Protective constitutional remedy warranted; institutional trust in AHRC reaffirmed [Paras 47-54].

Decision: Appeal allowed – Gauhati High Court’s order dated 27/01/2023 set aside – AHRC directed to reinstate and conduct independent inquiry into alleged police encounters – State and Legal Services Authority instructed to aid proceedings and ensure victim participation and protection [Paras 55-56].

Civil Writ - Environmental Contempt – Unauthorized Tree Felling – Violation of Supreme Court Orders – Delhi Ridge Protection Breached – The DDA commenced felling of over 1,600 trees in the protected Delhi Ridge area without prior permission from the Supreme Court as mandated in MC Mehta case – Court held this as willful disobedience and obstruction of justice – Classified as criminal contempt under Section 2(c) of the Contempt of Courts Act, 1971 – Held: Conduct amounted to grave contempt; ecological degradation acknowledged but underlying public purpose considered [Paras 1-20, 33].

Judicial Integrity – Suppression of Facts from Court – Criminal Contempt – DDA Officials Concealed Ongoing Tree Felling – Despite pending application, officials failed to disclose that large-scale tree removal had already commenced – Supreme Court held concealment as deliberate interference in the administration of justice – Held: Such misconduct cannot be shielded by administrative misjudgment and necessitates institutional accountability [Paras 3.18, 11-18, 36].

Public Interest vs. Ecological Harm – Road Construction for CAPFIMS – Balance of Constitutional Morality – Court recognised need for infrastructure serving paramilitary forces and families – Emphasised doctrine of parens patriae and weighed irreversibility of environmental harm – Held: Despite ecological loss, public interest in completion of CAPFIMS access roads justified a restrained approach – Remedial and compensatory afforestation ordered under court supervision [Paras 19-27, 39-41].

Restorative Justice – Directions for Ecological Remediation – Court Oversight and Accountability – Supreme Court ordered afforestation over 185 acres, supervision by expert committee, and levy on affluent beneficiaries – Officials directed to deposit Rs. 25,000 each as environmental fee – Held: Court must respond with constructive remedies to avoid recurrence and uphold ecological safeguards [Paras 28(i)-(x), 42-45].

Decision: Contempt petitions disposed – Respondents held guilty of willful disobedience but given opportunity to purge contempt through time-bound afforestation and restoration – Proceedings against First Respondent (non-cadre officer) closed – Directions issued for institutional reform and future compliance with court orders in ecological matters [Paras 26-36, 44-48].

Criminal Law – Sections 363, 366, 342 of the IPC and Section 6 of the POCSO Act Aggravated Penetrative Sexual Assault – Sentence Reduction – Appellants convicted under Section 6 of the POCSO Act for committing aggravated penetrative sexual assault – Trial Court sentenced them to life imprisonment for the remainder of their natural life – High Court affirmed conviction and sentence – Supreme Court upheld conviction but reduced sentence – Held: Section 6 prescribes minimum sentence of 20 years, and while life imprisonment till natural death is permissible, it must be justified by aggravating circumstances – Appellants were in early twenties at the time of offence and had already undergone five years of incarceration – Sentence reduced to 20 years rigorous imprisonment [Paras 4, 6-10].

Sentencing – Mitigating Circumstances – POCSO Act – Supreme Court noted that the Special Court imposed the harshest sentence under Section 6 of the POCSO Act without considering any mitigating factors – In absence of reasons for awarding imprisonment for natural life and given the youth of the appellants at the time of offence, interest of justice warranted sentencing them to the statutory minimum [Paras 7-9].

Final Decision – Conviction Affirmed, Sentence Modified – Supreme Court did not interfere with conviction under IPC Sections 363, 366, 342 and Section 6 of the POCSO Act – However, sentence modified from life imprisonment to 20 years rigorous imprisonment – Appeals allowed in part [Paras 9–10].

Judicial Service – Age of Superannuation – Petition seeking enhancement of retirement age for subordinate judicial officers from 60 to 62 years in Madhya Pradesh – Petitioners contended parity with State Government employees – Held: No prohibition under earlier Supreme Court directions to increase retirement age – Court clarified that enhancement to 61 years is permissible if allowed by rules and approved by High Court on administrative side – Matter to be considered within three months [Paras 1, 2, 5-7].

Judicial Policy – Clarification of Supreme Court Order – Telangana Precedent Cited – Supreme Court referred to its order in WP(C) No. 643/2015 permitting Telangana High Court to align retirement age of judicial officers with that of State employees – Similar clarification extended to Madhya Pradesh context – Clarification aimed at enabling High Court to make administrative amendments if deemed appropriate [Paras 3-4].

Final Disposition – Writ Petition Disposed – Court clarified that enhancement of judicial officers’ retirement age to 61 years is legally permissible – High Court directed to decide the issue administratively within a stipulated timeframe – Pending applications also disposed [Paras 6-9].

NDPS Case – Grant of Bail – Recovery of Phensedyl Syrup – Bail Granted – Appellants were arrested in connection with a case under Sections 21(c), 27A, and 29 of the NDPS Act – They had been in custody since 22.04.2024 with no prior NDPS-related criminal antecedents – Supreme Court noted the delay in trial, with not even one of eleven witnesses examined – Held: Continued detention not justified in absence of serious antecedents or strong contraband recovery – Bail granted with appropriate conditions [Paras 1-3].

Delay in Trial – Consideration in Bail Matters – Liberty Upheld – Noting that no prosecution witnesses had been examined and trial delay persisted, the Court favored granting bail to secure the right to personal liberty – Directed release subject to conditions ensuring cooperation and preventing tampering of evidence [Para 3].

Criminal Antecedents – Relevance Under NDPS – Distinction Drawn – Although one appellant had prior criminal history, it was not under NDPS provisions – Held: Prior antecedents not serious enough to deny bail where other factors are favorable [Para 2].

Decision – High Court Order Set Aside – Bail Directed – Supreme Court allowed the appeal, set aside the Calcutta High Court’s order dated 11.03.2025, and directed the trial court to release appellants on bail with appropriate safeguards [Para 3].

Criminal Law - Quashing of FIR – Promise to Marry – Consent and Misuse of Legal Provisions – FIR Quashed – Appellant challenged the registration of FIR under Sections 376, 377, 504 & 506 IPC and chargesheet arising out of a consensual relationship – Supreme Court found no material to substantiate coercion, inducement or threat – Held: The consensual nature of the relationship, sustained over time and involving travel and mutual interactions, showed no prima facie offence was made out – FIR found to be manifestly attended with mala fide intentions [Paras 3-10].

False Promise of Marriage – Lack of Intent to Deceive – Quashment Justified – The complainant was an adult, previously married, and voluntarily sustained the relationship – No material to indicate that the appellant never intended to marry from the outset – Promise made while the complainant was still legally married rendered such commitment unenforceable ab initio – Held: The promise was not false in law; prosecution not sustainable [Paras 8(b)-(d)].

Abuse of Process – Categories under Bhajan Lal Case – Criminal Proceedings Quashed – Supreme Court applied categories 5 and 7 of Bhajan Lal guidelines to prevent abuse of legal process – Proceedings found to be maliciously instituted with personal grudge – Held: Continuance of trial would be unjust; appellant discharged [Paras 10-12].

Final Decision – FIR and Proceedings Quashed – Appeal allowed – Impugned High Court order set aside – FIR dated 31.07.2023 and proceedings in RCC No. 378/2023 before Additional Sessions Judge, Karad quashed – Appellant discharged from all proceedings [Para 12].

Criminal Law - Quashing of Criminal Proceedings – Sections 376, 376(2)(n), 377, 504, 506 of the Indian Penal Code, 1860 (IPC) - Allegation of Rape on False Promise of Marriage – Consent and Misuse of Legal Process – Proceedings Quashed – The appellant was accused of rape and unnatural sex on false promise of marriage. FIR was lodged after a prolonged consensual relationship. Supreme Court found the allegations inherently improbable and inconsistent with the complainant’s conduct, including continued physical relationship, financial exchanges, and absence of medical evidence – Held: Relationship was consensual; complaint did not disclose inducement or coercion sufficient to attract charges under Section 376 IPC – Criminal proceedings quashed under categories 5 and 7 of State of Haryana v. Bhajan Lal [Paras 3–10].

False Promise of Marriage – Mens Rea and Misconception of Fact – Absence of Intent to Deceive – No evidence that the accused never intended to marry the complainant from inception – Promise to marry during complainant's subsisting marriage was unenforceable – Consent was not vitiated by misconception of fact under Section 90 IPC – Held: Mere breach of promise, without mala fide intent, does not amount to rape [Paras 8(b), 9].

Abuse of Process – Relationship Turning Sour – Misuse of Criminal Justice System – Relationship breakdown or unfulfilled expectations cannot be criminalized – The court emphasized the need to prevent misuse of rape provisions for personal vengeance – Held: FIR and chargesheet constituted an abuse of process; continuation of trial would amount to injustice [Paras 8(d), 9–11].

Decision: Quashing of Proceedings – Allowed – FIR and Chargesheet Quashed – The Court quashed the FIR dated 25.05.2023 and Chargesheet dated 16.10.2023 registered in Crime No.118/2023, PS Newasa, Ahmednagar, under Sections 376, 376(2)(n), 377, 504, and 506 IPC – Held: Continuation of prosecution would constitute miscarriage of justice – Appeal allowed; proceedings against the appellant quashed [Para 11].