Jurisdiction – Special Court Act – Appeals arose from orders of the Special Court dealing with disputes from a financial scandal – Supreme Court examined whether the Special Court properly assumed jurisdiction under Sections 9 and 9A of the Act – Held, the Special Court had jurisdiction to adjudicate claims involving notified persons and their transactions during the specified period [Paras 3-4, 30-31].

Procedural Requirements – Evidence – Special Court relied on the Janakiraman Committee Report and unproved correspondence – Supreme Court criticized reliance on unverified documents and underscored the need for evidence in accordance with the Indian Evidence Act – Reports from non-statutory bodies like the Janakiraman Committee are not admissible as evidence per se [Paras 49-53].

Suppression of Facts – Plaintiff's Conduct – National Housing Bank accused of suppressing material facts – Supreme Court found that the Bank approached the court with unclean hands, failing to disclose the full nature of the transactions and involvement of high-level officials – Such suppression warrants dismissal of the suit [Paras 62-68].

Decision – Appeals allowed – Decree of the Special Court set aside – Suit dismissed on grounds of suppression of material facts and lack of evidence – Supreme Court emphasized resolving disputes between public sector entities through governmental mechanisms rather than prolonged litigation [Paras 71-75].

Departmental Inquiry – Requirement – Appellant challenged the necessity of a full-fledged departmental inquiry when a minor penalty is imposed despite initiating major penalty proceedings – Supreme Court held that the Haryana State Electricity Board Regulations allow the authority to impose a minor penalty without a full inquiry if the authority decides no major penalty is warranted after considering the delinquent's reply – Lower courts erred in requiring a full inquiry [Paras 1-13].Penalty Imposition – Minor vs. Major Penalty – Regulation 7(8) allows the competent authority to switch to minor penalties from major penalty proceedings based on the delinquent’s response – Supreme Court upheld the Board’s decision to impose minor penalty of barring one increment without cumulative effect without a full departmental inquiry [Paras 11-12].Decision – Appeal allowed – Orders of the District Judge and High Court set aside – Supreme Court clarified that minor penalties do not necessitate a full departmental inquiry if procedures outlined in the regulations are followed – Directed consideration of respondent’s due promotion if minor penalty does not bar it [Paras 14-15].

Criminal Law – Sentencing – Respondents convicted under Sections 294 and 307 IPC for shooting and injuring the complainants – Trial court sentenced each respondent to three years’ rigorous imprisonment and a fine – High Court reduced sentence to the period already undergone – Supreme Court held High Court’s reduction without sufficient reasoning inappropriate – Sentence already undergone not commensurate with established guilt [Paras 1-18].

Attempt to Murder – Section 307 IPC – High Court reduced sentences citing non-fatal injuries on non-vital parts – Supreme Court clarified Section 307 IPC does not necessitate injury to vital parts – Intent and knowledge sufficient, and causing hurt with a firearm qualifies under Section 307 IPC irrespective of the injury location [Paras 15-16].

Judicial Approach – Adequate Sentencing – Supreme Court stressed importance of sentences reflecting the crime's severity and societal impact – Inadequate sentences undermine legal deterrence and social justice – Emphasized need for rigorous judicial application in sentencing to maintain public trust and order [Paras 17-18].

Decision – Appeal allowed – High Court’s order reducing sentences set aside – Trial court’s judgment and sentences restored – Adequate punishment reaffirmed for crimes involving serious injury and use of firearms [Para 18].

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].