Municipal Law – Change of Land Use – Amendment of Section 173-A – Rajasthan Municipal Corporation demanded conversion charges for changing land use from residential to commercial – Respondents challenged the demand citing earlier Supreme Court judgment – High Court quashed demand relying on un-amended Section 173-A – Supreme Court held amended Section 173-A applicable, validating the demand [Paras 6-12].

Amendment Interpretation – Section 173-A – Amended provision includes restrictions on land use changes beyond state/municipal allotted lands, covers any land use changes non-conforming to Master Plan – Conversion charges applicable for change from residential to commercial use under amended rules [Paras 12-14].

Judicial Precedent – Misapplication – High Court erred applying precedent interpreting un-amended Section 173-A – Supreme Court clarified amended provision extends conversion charges to broader land use changes, aligning with urban planning objectives [Paras 13-15].

Regulated Development – Urban Planning – Legislative intent to ensure planned urban development through conversion charges for land use changes – Conversion charges part of regulatory framework under municipal law [Paras 13-14].

Decision: Appeals allowed – High Court judgments set aside – Municipal Corporation's demand for conversion charges upheld – Respondents may challenge land use classification under Master Plan before Municipal Corporation [Paras 16].

Criminal Procedure – Appeal Against Acquittal – Determining proper forum for appeal in complaint cases – High Court dismissed appeal holding Sessions Court jurisdiction for state appeals – Supreme Court reversed, holding appeals in complaint cases lie to High Court [Paras 7-8, 16-18].

Jurisdiction – Sections 378(1) and 378(4) CrPC – State may direct appeal to High Court except in cognizable and non-bailable offences by Magistrate, directed to Sessions Court – Complaint case appeals specifically under Section 378(4) to High Court – Legal interpretation affirmed by Law Commission reports and legislative amendments [Paras 12-17].

Legislative Intent – Amendment to Section 378 – 154th Law Commission Report led to 2005 amendment – Introduced district-level appeals for certain acquittals to expedite process – State appeals to High Court retained except for specific exclusions – Legislative purpose to check arbitrary acquittals acknowledged [Paras 12, 19-20].

Decision: Appeal allowed – High Court’s order quashed – Complaint-based acquittal appeals to be filed in High Court – Specific leave required for complainant’s appeal upheld – Sessions Court jurisdiction limited to non-complaint state-directed appeals [Paras 21].

Service Law – Apprenticeship and Regular Employment – Appellants contended training period as apprentices should not count towards regular service for ACP Scale – Respondents argued training period should be included – High Court ruled in favor of respondents – Supreme Court reversed, holding apprenticeships do not count towards regular service under ACP Scheme [Paras 3, 18, 27-28].

Interpretation of Apprentice Training – Apprentices Act, 1961 – Apprentices not deemed regular employees – Section 18 specifies apprentices are trainees, not workers – No statutory obligation to employ apprentices after training unless specified in contract – Appointments as Plant Attendant/Technician post-training did not equate to regular service for ACP purposes [Paras 20-24].

Clarificatory Letters and ACP Scheme – Clarificatory letters issued by Board regarding training period – Misinterpreted by High Court – Letters intended for direct recruits undergoing training in regular pay scale, not applicable to respondents – Respondents' training period on fixed stipend, not in cadre, thus not part of regular satisfactory service [Paras 13-16, 28].

Decision: Appeals allowed – High Court judgments set aside – Training period as apprentices not counted towards regular service for ACP Scale – Financial benefits received by respondents not to be recovered, but ACP Scale dates as determined by appellants stand [Para 29].

Civil Procedure – Maintainability of Appeal – Appeal challenged judgment dismissing suit for partition based on alleged forged will – Appellant, aggrieved party, filed appeal against decision of lower court – High Court dismissed appeal as non-maintainable – Supreme Court held High Court erred in dismissing appeal – Legal right of appellant was affected by lower court’s decision, making appeal maintainable [Paras 1-22].

Rights of Aggrieved Parties – Legal Injury – Supreme Court emphasized that an appeal can be maintained by any party who suffers legal injury due to a decree – Appellant's rights as co-sharer affected by the will declared void by trial court but validated by appellate court – Appeal maintainable under Sections 96 and 100 of CPC [Paras 13-21].

Cross-Objections – Order 41 Rule 22 – Supreme Court clarified cross-objection provisions post-1976 amendment – Respondents may file cross-objections to adverse findings without challenging decree – Such cross-objections are adjudicated even if main appeal is withdrawn or dismissed [Paras 18-19].

Decision: Appeal allowed – High Court judgment set aside – Matter remitted to High Court for decision on merits within six months – No opinion expressed on merits of case – Costs to be borne by respective parties [Para 22].

Criminal Law – Conspiracy and Forgery – Appellant, along with co-accused, conspired to cheat the Regional Passport Office, Trichy – Forged documents submitted for obtaining passports – Trial court convicted and sentenced appellant to RI for 2 years with a fine – High Court upheld conviction – Supreme Court reduced sentence to six months considering appellant's circumstances [Paras 1-27].

Defective Investigation – Parallel Proceedings – Appellant contended initial investigation by State Crime Branch and subsequent investigation by CBI was impermissible – Supreme Court held parallel proceedings lawful under Delhi Police Special Establishment Act – Defective investigation not a ground for acquittal unless it affects the root of prosecution case [Paras 7-13].

Evidence – Forgery – Confessional statement led to recovery of forged seals – Prosecution evidence including testimonies of officials corroborated the conspiracy – Evidence of appellant’s involvement and false information in passport applications upheld [Paras 14-24].

Reduction of Sentence – Appellant’s mitigating circumstances considered – Sentence reduced from two years to six months [Paras 26-27].

Decision: Appeal partly allowed – Conviction upheld – Sentence reduced to six months from two years [Para 27].

Criminal Law – Murder Conviction – Appellants convicted for murder based on oral dying declaration – Deceased named assailants to relatives before succumbing to injuries – Trial court and High Court upheld conviction – Supreme Court affirmed the conviction, finding the dying declaration reliable and trustworthy [Paras 1-22].

Oral Dying Declaration – Admissibility and Reliability – Deceased identified assailants in presence of relatives – Testimonies of witnesses found credible – No contradiction or discrepancy in evidence – Medical evidence supported that deceased could speak before death – Court held oral dying declaration valid and credible [Paras 12-20].

Delay in Lodging FIR – Explained – Immediate report (ezahar) lodged at police station by deceased’s father-in-law – FIR registered promptly after death – Court found no fault in delay considering circumstances [Paras 21-22].

Decision: Appeal dismissed – Conviction and sentence upheld [Para 22].

Criminal Law – Murder Conviction – Appellant convicted for murder based on eyewitness accounts – Altercation over property ridge led to fatal attack – Trial court and High Court upheld conviction – Supreme Court affirmed conviction, finding eyewitness testimonies reliable and discrepancies insignificant [Paras 1-21].

Eyewitness Testimonies – Reliability – Eyewitnesses, brother and sister of deceased, provided consistent and credible accounts – Court dismissed argument that their location at the time prevented witnessing the attack – Medical evidence supported the use of described weapons [Paras 14-17].

Delay in Lodging FIR – Explained – Immediate steps taken by relatives and hospital authorities – No undue delay in FIR registration – Court found no fault in delay considering circumstances [Paras 18-19].

Semi-Digested Food – Time of Death – Appellant argued time of death inconsistent with food in stomach – Court referenced medical principles, concluding digestion time varies and does not undermine prosecution’s case [Paras 20-21].

Decision: Appeal dismissed – Conviction and sentence upheld [Para 21].

Clarification/Modification Applications – Grounds of Review – Applications filed for clarification/modification of judgment – Alleged suppression of documents by the State of Madhya Pradesh – Court held such applications tantamount to seeking review – Properly constituted review petitions are the remedy [Paras 1-4].

Circumventing Review Process – Practice Deprecated – Attempt to bypass review procedure by filing applications for clarification/modification/recall – Registrar’s decision to lodge applications upheld – Review should follow proper procedural rules under Order XL of Supreme Court Rules [Paras 5-9].

Relevant Case Law – Reference to previous decisions – Delhi Administration Vs. Gurdip Singh Uban – Practice of avoiding circulation procedure by filing applications for hearing – Court’s reiteration on proper review process [Paras 6-8].

Decision: Applications dismissed – Clarification/modification requests to follow proper review petition procedures [Para 9].

Extra-Judicial Killings – Allegations – Petitioners alleged 1528 extra-judicial killings in Manipur from May 1979 to May 2012 – Plea for investigation into unlawful executions – Supreme Court considered the need for thorough inquiry into specific cases [Paras 1-4].

Constitutional Protections – Article 21 and Article 32 – Court emphasized the importance of protecting the right to life and personal liberty – Rejected the State's plea to defer the examination to NHRC – Supreme Court to examine the matter directly [Paras 4-5].

Insurgency Context – State’s Response – Acknowledged the grave threat of insurgency in Manipur – Detailed the loss of lives among security forces – Emphasized the need for lawful actions even in conflict situations – Cited earlier judgments cautioning against "administrative liquidation" [Paras 6-11].

Commission of Inquiry – Formation – Supreme Court formed a three-member commission to investigate selected cases of alleged extra-judicial killings – Commission to also review the role of state police and security forces in Manipur [Paras 22-23].

Decision: Petition to be further investigated – Commission to submit a report within twelve weeks – Full cooperation and support directed from Central and State Governments [Paras 24-27].