Motor Vehicles Act – Light Motor Vehicle (LMV) – Definition and Scope – Transport Vehicles within LMV Classification - The term "light motor vehicle" (LMV) as defined under Section 2(21) of the Motor Vehicles Act (MV Act) includes both private and commercial vehicles, provided their gross weight does not exceed 7,500 kg – The Court held that LMV licenses extend to light transport vehicles within this weight limit – Use of the term “means” in Section 2(21) indicates an exhaustive and inclusive definition, encompassing both transport and non-transport vehicles without requiring additional endorsements under Section 10(2)(e) for driving transport vehicles under this weight [Paras 25, 30, 32, 125].

Licensing Requirements – Harmonious Interpretation – Transport Vehicle and LMV License Classes - Section 3(1) and Section 10 of the MV Act require a specific endorsement for “transport vehicles” – Court held that this requirement applies primarily to medium and heavy transport vehicles exceeding 7,500 kg – For light transport vehicles within the LMV category, no additional endorsement is necessary, ensuring a practical interpretation consistent with the legislative intent and simplifying the licensing process [Paras 35, 85, 126, 131(I)].

Conflicting Judgments – Mukund Dewangan – Upholding LMV Scope – Overruling of Contrary Decisions - The Court upheld Mukund Dewangan (2017), confirming that LMV licenses are valid for light transport vehicles not exceeding 7,500 kg – Overruled contrary judgments in Prabhu Lal, Roshanben Rahemansha Fakir, and Angad Kol, which required separate endorsements for light transport vehicles – Affirmed decisions in Ashok Gangadhar Maratha, S. Iyyapan, and Kulwant Singh, which aligned with this interpretation [Paras 91, 96, 96.3, 131(IV)].

Road Safety and Policy Considerations – Licensing Practicality – Empirical Data on Road Safety - Addressed concerns that LMV license holders operating light transport vehicles could compromise road safety – Court observed that driving skills for LMVs are sufficient for operating transport vehicles within the prescribed weight – Noted absence of empirical data linking LMV-licensed drivers to road accidents due to operating light transport vehicles, and emphasized that additional requirements should be limited to medium and heavy vehicles for road safety and regulatory coherence [Paras 123, 124, 130, 131(III)].

Legislative Intent and Recommendations – Scope for Amendment – Addressing Classification Ambiguities - Court recommended further classification within the LMV category to improve clarity (e.g., LMV Class 1 and LMV Class 2) – Encouraged the legislature to amend the MV Act to provide clearer distinctions between LMV and transport vehicle classes, which could prevent frequent litigation and reduce confusion in license classifications [Paras 120, 128, 129].

Conclusion – LMV License Validity for Transport Vehicles under 7,500 kg – Key Findings

Held that:

(I) A driver holding an LMV license is legally authorized to operate a transport vehicle with gross weight not exceeding 7,500 kg without requiring a separate endorsement for transport vehicle operation;

(II) Section 3(1) requirement for specific licenses for transport vehicles does not override the comprehensive LMV definition under Section 2(21);

(III) Additional eligibility and training requirements apply only to those intending to operate medium and heavy transport vehicles exceeding 7,500 kg;

(IV) Mukund Dewangan (2017) is upheld, not per incuriam, as the judgment's conclusions align with a harmonious interpretation of the MV Act and Rules, despite certain overlooked provisions [Paras 131, 132].

Decision: Reference questions answered to affirm the applicability of LMV licenses to light transport vehicles within the 7,500 kg weight limit, obviating the need for a separate transport endorsement for such vehicles.

Land Acquisition – Determination of Compensation – Additional Compensation for Trees and Borewell – Review Jurisdiction – Appellant sought enhanced compensation for acquired land, including fruit-bearing trees and a borewell – High Court dismissed the award of compensation for these items granted by the reference court in a review application – Supreme Court upheld High Court’s decision, finding lack of admissible evidence supporting the existence of the claimed assets at the time of acquisition – Held: Compensation for the awala trees and borewell on Survey No. 17 set aside as inadmissible evidence was relied upon in review [Paras 2, 4, 6-8, 12].

Incremental Valuation – Cumulative Increase of Market Value – Applicability of Precedent – Appellant argued for a cumulative 10% annual increase in land valuation based on exemplar sale deeds from an earlier judgment – The court clarified that cumulative increase is discretionary and not an absolute rule – Held: Non-cumulative 10% increase in valuation affirmed as consistent with precedent and not arbitrary; cumulative increase was not granted in the exemplar judgment relied upon by the reference court [Paras 14-17].

Scope of Review – Limitations of Review Jurisdiction – Review as Appeal – Review court acted beyond its jurisdiction by granting compensation based on new evidence (2nd Joint Measurement Report) that was inadmissible and produced only at the review stage – Supreme Court ruled that review proceedings cannot serve as an appellate mechanism to re-evaluate facts or introduce new evidence – Held: High Court correctly quashed compensation for awala trees and borewell granted in review application as this exceeded the permissible scope of review jurisdiction [Paras 9-11].

Decision: Appeal dismissed – Supreme Court upheld the High Court’s order setting aside the compensation for awala trees and borewell granted in the review by the reference court, finding no admissible evidence to justify the claim and affirming the lower court's exercise of discretion in denying cumulative market increase – No costs awarded.

Criminal Law – Acquittal – Appeal against Armed Forces Tribunal’s order setting aside conviction – Respondent, an Air Force officer, charged under Section 302 IPC read with Section 149, and alternatively under Sections 325, 342 IPC, along with charges under Sections 45, 65, and 71 of the Air Force Act, 1950 (AFA) – General Court Martial (GCM) initially convicted the respondent under Section 304 Part II IPC read with Section 149 and sentenced him to five years imprisonment with cashiering – Chief of Air Staff confirmed conviction but reduced imprisonment to two years – Tribunal set aside conviction, granting consequential reliefs to respondent, excluding back wages – Supreme Court dismissed appeal against Tribunal’s acquittal order, affirming lack of evidence connecting respondent to deceased’s death – Held: Tribunal’s findings upheld, appeal dismissed [Paras 1, 5, 6, 11, 13].

Evidence of Alleged Assault and Wrongful Confinement – Sufficiency of Evidence – The appellants argued that the respondent was responsible for confining and assaulting the deceased signalman, resulting in his fatal injuries – Held: The evidence failed to establish the respondent’s intent to cause harm; the Tribunal’s findings showed no assault by the respondent, and injuries were attributable to a fall from the vehicle, negating the charges of wrongful confinement and assault [Paras 15-18].

Wrongful Confinement – Applicability of Section 342 IPC – It was contended that the respondent directed the confinement of the deceased, constituting wrongful confinement – Held: The respondent’s intent was not to confine the deceased indefinitely but rather to secure his presence for identification. The evidence did not substantiate any restriction of liberty, as required under Section 342 IPC [Paras 25-27].

Presumption of Innocence in Acquittal Appeals – Judicial Deference to Tribunal Findings – The Court emphasized that in appeals against acquittal, deference is given to findings favoring the presumption of innocence unless there are compelling grounds to overturn the decision – Held: The Tribunal’s judgment was found to be plausible and based on reasonable interpretation of evidence, precluding interference by the Supreme Court [Para 30].

Decision: The appeal is dismissed, affirming the Armed Forces Tribunal's acquittal of Wing Commander M.S. Mander on all charges.

Second Complaint – Maintainability – Code of Criminal Procedure, 1973 – Appeal Allowed – The issue involved whether the second complaint, filed with the same allegations as a previously dismissed complaint following acceptance of a final police report, was maintainable. Held: A second complaint on identical facts is generally not maintainable when the first was disposed of on merits unless exceptional circumstances are demonstrated. The Court upheld the Chief Judicial Magistrate's order dismissing the second complaint, determining that it mirrored the original complaint in both facts and allegations and did not introduce new grounds [Paras 5, 20, 31-32].

Interpretation of Section 300 Cr.P.C. – Application of Double Jeopardy Principles – 'Autrefois Acquit' and 'Autrefois Convict' – Section 300(1) Cr.P.C. invokes the doctrine of double jeopardy, barring a subsequent trial for the same offense if previously tried. However, the Court held this principle inapplicable here as no trial or acquittal/conviction occurred under the initial complaint. Reiterated that procedural dismissals do not constitute acquittal or bar further proceedings unless substantive judgment is reached on identical allegations [Para 9].

Magistrate's Discretion on Protest Petitions – Code of Criminal Procedure, 1973, Sections 156(3), 173, and 202 – No Blanket Bar on Second Complaint – Reviewed four options available to a Magistrate upon receiving a negative report: (1) accepting and closing proceedings; (2) ordering further investigation; (3) conducting or delegating investigation; or (4) taking cognizance as a private complaint. Noted that while second complaints are permissible in limited situations, they require new facts or exceptional justification, which was not presented in this case [Para 12].

Exceptional Circumstances Standard – Absence of New Evidence or Miscarriage in Initial Complaint – The Court emphasized that maintaining repeated complaints requires evidence of exceptional circumstances, such as new facts or procedural errors in the initial handling. Here, the second complaint did not present new evidence or allege factual misunderstandings, and hence failed to meet the standard for exceptional circumstances [Paras 16, 25, 31].

Decision - Judicial Finality and Preventing Abuse of Process – Court affirmed the dismissal of repetitive litigation tactics, emphasizing the judiciary's responsibility to curb frustrated or malicious litigants from repeatedly challenging procedural orders absent substantial grounds. Noted this approach safeguards judicial resources and protects individuals from harassment through legal process [Para 32].
 

Eligibility for Public Employment – Requirement of CCC Certificate at Interview Stage – Termination of Candidates' Services Deemed Arbitrary – Candidates selected under the 2014 recruitment for the post of Technician Grade-II in Uttar Pradesh Power Corporation Limited challenged their termination on the ground that they fulfilled the CCC (Computer Concepts Course) certification requirement at the time of interview, as stipulated in the Corporation’s regulations – Held: Candidates possessing CCC certificates by the interview stage were eligible, and their termination by the Corporation based on the lack of the certificate by the application deadline was erroneous – Court directed reinstatement of candidates meeting the CCC certification requirements at interview stage [Paras 15-16, 26].

Role of Recognized Certification in Public Appointments – Compliance with Article 16 and Requirement of DOEACC/NIELIT Certification – The requirement of a CCC certificate by DOEACC/NIELIT was deemed necessary for entry into public service under Article 16 – Court upheld that self-certification of equivalency was inadequate and that recognized certifications from DOEACC/NIELIT or equivalent qualifications should govern eligibility – Equivalence of certificates must follow formal inquiry and standards; informal certifications were disallowed [Paras 14-15, 19-20].

Interpretation of Advertisement and Service Regulations – Validity of CCC Certification Obtained Before Interview Date – Division Bench’s Order Overturned – Despite conflicting stances by the Corporation, the Court found that the 2014 advertisement and the 1995 Regulations mandated CCC certification only by the interview date – The Court dismissed the contention that the last date for application controlled eligibility, ruling that eligibility compliance at interview suffices under the amended service regulations [Paras 24-25, 27].

Doctrine of Legal Consistency – Contradictory Positions of Respondent Corporation – Respondent Corporation’s shifting stances on eligibility, first accepting DOEACC/NIELIT and later rejecting equivalent self-certified qualifications, constituted a breach of consistent legal approach in hiring practices – Court exercised Article 142 powers to rectify Corporation’s misinterpretation, ruling that candidates were entitled to continued service if CCC certified by interview date [Paras 23, 28].

Equitable Relief Under Article 142 of the Constitution – Reinstatement Without Back Wages but With Service Continuity – Recognizing the misinterpretation of eligibility standards by the Corporation, the Court exercised Article 142 to reinstate the applicants without back wages, but with continuity of service and placement in the seniority list as per the original select list – Relief limited to non-back wage compensation but includes seniority and consequential benefits [Para 29].

Decision:

Appeal allowed, with the Supreme Court ordering the reinstatement of candidates who had obtained the CCC certificate by the interview date, rejecting the Corporation’s termination based on application date eligibility. Candidates were denied back wages but granted continuity in service and benefits, including seniority adjustments, as per the 2015 select list [Para 30].

Judicial Independence – Financial Independence of Judges – Non-discrimination based on Source of Appointment – Held: High Court judges, irrespective of their recruitment source (Bar or judicial service), are entitled to uniform financial benefits to maintain judicial independence – Differentiation between judges based on their pre-appointment service violates Articles 14 and 217 – Directed all judges to have access to the General Provident Fund – The communication dated 13 December 2022 was quashed as unconstitutional [Paras 10-20].

Provident Fund – Section 20 of the High Court Judges (Salaries and Conditions of Service) Act, 1954 – Scope of Proviso – Mandate to extend GPF benefits to all judges of the High Court – Proviso interpreted as preserving benefits accrued before High Court appointment without creating a discriminatory regime – Directed refund of New Pension Scheme contributions and opening of GPF accounts for petitioners [Paras 22-28].

Constitutional Interpretation – Uniform Service Conditions – Financial Security as Integral to Judicial Independence – Emphasized: Salaries, allowances, and pensions of High Court judges determined by parliamentary enactments to ensure uniformity – Article 221 prohibits discriminatory service terms – Equality in post-retirement benefits like GPF underlines judiciary’s homogeneity [Paras 30-33].

Decision: The petitions were allowed, directing that:

A General Provident Fund account be opened for the petitioners, effective from their date of appointment as High Court judges.

Contributions under the New Pension Scheme be refunded to petitioners within four weeks.

The impugned communication dated 13 December 2022 be quashed.

Criminal Law – Murder – Appeal against conviction - Circumstantial Evidence – Requirement of a Complete Chain – Appeal Allowed – The appellant was convicted for murder and disposing of evidence under Sections 302 and 201 IPC based on circumstantial evidence alone. The Supreme Court reviewed whether the evidence constituted a complete and conclusive chain that pointed solely to the appellant's guilt. Held: Conviction based on circumstantial evidence demands an unbroken chain leading to no other plausible explanation but the accused's guilt. Here, discrepancies in witness testimony, questionable recovery evidence, and the prosecution’s failure to prove critical facts undermined the chain of evidence and warranted acquittal [Paras 26-32, 42-45].

Key Principles in Circumstantial Evidence – Panchsheel Principles – Relying on Ramreddy Rajesh Khanna Reddy v. State of A.P., the Court underscored that suspicion cannot substitute proof. For conviction, each link in the evidence chain must conclusively establish guilt. The Court further stressed that any break or inconsistency in circumstantial evidence entitles the accused to benefit of doubt, aligning with established judicial principles [Paras 26-28].

Last Seen Theory – Insufficient Corroboration – The prosecution’s case leaned on the last seen theory, contending that the appellant was the last to be seen with the deceased. The Court held that the time gap and lack of corroborating evidence between the last sighting and discovery of the body introduced doubt, highlighting that such cases require tight proximity and supporting evidence to preclude alternative explanations [Para 28].

Recovery of Alleged Murder Weapon and Other Articles – Lack of Credible Evidence – The prosecution's recovery of the alleged murder weapon and blood-stained items was found unreliable due to procedural lapses and inconsistent testimony. Witnesses contradicted each other, some claiming that police obtained evidence off-site rather than directly from the appellant’s possession, further casting doubt on the integrity of the recovery evidence [Paras 34-37].

Acquittal in Cases with Doubts in Evidence – Gaps in Proof Benefit the Accused – Following precedents, the Court reinforced that circumstantial evidence must unequivocally establish guilt; any gaps favor the accused. Here, inconsistencies in witness accounts and procedural ambiguities in the prosecution’s evidence led to acquittal, underscoring that conviction requires proof beyond reasonable doubt [Paras 41-45].

Decision:

The appeal is allowed, and the judgments of the High Court and Sessions Court are set aside. The appellant is acquitted of all charges due to the prosecution's failure to establish a conclusive chain of circumstantial evidence. If the appellant is on bail, his bail bonds and sureties are discharged, and he is to be released immediately.

Criminal Law – Quashing of FIR – Alleged Offenses under IPC and Atrocities Act – FIR filed for offenses under Sections 376(2)(N) and 506 of IPC, along with Sections 3(1)(R), 3(1)(w), and 3(2)(5) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act – High Court quashed proceedings on the basis of an alleged settlement between the parties, directing the complainant to refund compensation – Supreme Court set aside the High Court's order, remanded the case for verification of settlement, and ordered inquiry if necessary [Paras 2, 9-14].
Settlement in Non-Compoundable Offenses – Guidelines for High Court – Supreme Court emphasized that in cases of serious offenses, especially those involving women and marginalized groups, High Court must ensure the genuineness of settlement – Advised personal presence or virtual appearance of the victim for verification – Directed that affidavits by illiterate complainants must include endorsements that contents were explained in the complainant's language – Found High Court erred by accepting affidavits without proper inquiry into their authenticity or securing complainant’s presence [Paras 7-9].
Evidentiary Concerns – Affidavits and Thumb Impressions – Allegations of suspicious circumstances surrounding the execution of affidavits – Affidavits lacked endorsements explaining content to the illiterate complainant – Appellant argued coercion and improper procedure in obtaining thumb impressions – Supreme Court directed the High Court to examine the appellant’s claims through inquiry by a Judicial Officer if needed [Paras 8-10].
Seriousness of Offenses – Impact on Society – Supreme Court noted that offenses under Section 376(2)(N) IPC and Atrocities Act are grave and affect society at large – Held that even if a settlement is genuine, the court must independently assess whether quashing proceedings would serve justice – Highlighted the need for caution in quashing cases of such nature [Para 7].
Directions on Remand – Supreme Court remanded the case to the High Court for fresh consideration – Directed the appellant to be present before the High Court to clarify her stance – Allowed appellant to file an affidavit addressing the alleged settlement – Empowered the High Court to order an inquiry into the execution of affidavits – High Court instructed to assess both the genuineness of the settlement and the appropriateness of quashing proceedings under Section 482 CrPC or Article 226 of the Constitution [Paras 10-14].
Decision – Appeal Partly Allowed – Supreme Court set aside the High Court’s order quashing criminal proceedings – Restored the quashing petition for reconsideration by the High Court – Directed specific steps for verifying the settlement and deciding its legal effect – Observed that serious offenses demand rigorous judicial scrutiny before quashing [Paras 12-16].
 

Civil Law – Mega Power Policy and Change in Law – Press Release as Binding Legal Instrument – Appeal Dismissed - Mega Power Status and Notification Requirements – Appellants contended that the 01.10.2009 press release announcing the Union Cabinet's decision on the revised Mega Power Policy constituted a legally binding "Change in Law" under Clause 13 of the Power Purchase Agreement (PPA) – The Supreme Court rejected this view, affirming that a press release does not enact or modify existing law and lacks the necessary formalities of a notification under Section 25 of the Customs Act – Held: The extant legal regime was modified only on 11.12.2009 and 14.12.2009 with the issuance of the official notifications and policy documents [Paras 42, 55, 57].

Interpretation of "Law" and "Order" in the PPA – The definition of "Law" in the PPA requires that any change must be implemented through a formally recognized instrument, such as a notification, for it to qualify as a legal enactment – Court held that the term "order" under the PPA did not extend to an informal announcement like a press release – The 01.10.2009 press release was deemed a statement of intent rather than a formal order or legally binding change [Paras 39-43, 48].

Doctrine of Promissory Estoppel – Argument of estoppel advanced by appellants asserting reliance on the press release in their bid submission was rejected – Court found the doctrine inapplicable since PSPCL (respondent) was not the promisor of any customs duty concession – Additionally, the Union of India, as the entity capable of conferring such benefits, was not a party to the agreement, making promissory estoppel inapplicable in inter-party disputes under the PPA [Para 65].

Business Efficacy Test and Clause 13 – Appellants invoked business efficacy to assert that the press release should be treated as law to prevent commercial detriment – Supreme Court clarified that business efficacy cannot override explicit terms of the PPA, which clearly define "Law" and prescribe specific enactment requirements for changes in law – The business efficacy test cannot contradict the express terms, and here the PPA’s requirements were clear and did not accommodate the appellants’ interpretation [Paras 41, 63-64].

Doctrine of Legal Certainty – Supreme Court underscored the principle of legal certainty as fundamental to the rule of law – Held: Allowing a press release to alter legally enforceable terms without official notification would create dual, conflicting legal regimes, which undermines predictability and certainty in contractual obligations – Court emphasized that the formal requirements under the Customs Act and the General Clauses Act must be met for a change in law to be recognized [Paras 58-61].

Notification and Official Gazette Requirements – Section 25(1) of the Customs Act mandates that exemptions must be notified in the Official Gazette – The Court highlighted the importance of compliance with procedural requirements, ruling that the absence of such formal publication invalidates any claim of legal change based on informal announcements or press releases [Paras 50-51].

Decision – Appeal dismissed, with the Court affirming that no "Change in Law" occurred as of 01.10.2009 – Concurrent findings of the lower tribunals upheld, and the appellants' request for benefits based on the press release was denied – PSPCL entitled to adjustments in tariff for the benefits accrued from the formal change in law on 11.12.2009 [Paras 72-73].