Criminal Law – Conviction under Section 302 IPC – Appellants challenged conviction under Section 302 IPC with the aid of Section 149 IPC, arguing acquittal of co-accused reduces the number below the statutory requirement for an "unlawful assembly" – Supreme Court upheld conviction under Section 302 IPC using Section 34 IPC, emphasizing the common intention of the accused to commit the murder [Paras 4-13].

Section 149 IPC – Unlawful Assembly – Acquittal of co-accused reduced number of participants below five, challenging application of Section 149 IPC – Court concluded conviction could be sustained under Section 34 IPC based on common intention, despite reduction in number of accused [Paras 4-13].

Evidence Evaluation – Witness Credibility – Appellants questioned reliability of witnesses citing discrepancies – Supreme Court found minor discrepancies non-material, relying on consistent core testimony and timely lodging of FIR to uphold findings of lower courts [Paras 14-15].

FIR and Investigation – FIR validity and investigative lapses questioned – Court confirmed FIR was filed promptly, minor investigative lapses not sufficient to discard prosecution case supported by direct evidence [Paras 15-16].

Exception 4 to Section 300 IPC – Not Applicable – Appellants argued for reduction of charge to culpable homicide not amounting to murder under Exception 4 to Section 300 IPC – Court found attack premeditated and excessive, with multiple severe injuries indicating intent to kill, thus not falling under Exception 4 [Paras 17-18].

Decision – Appeals dismissed – Convictions and sentences affirmed – Supreme Court found no merit in arguments challenging procedural and substantive findings of lower courts [Para 19].

Juvenile Justice – Application of the 2000 Act – Second appellant claimed juvenility based on birth certificate showing age below 18 at the time of the offence – Supreme Court referred to Sections 7A and 20 of the Juvenile Justice (Care and Protection of Children) Act, 2000, as amended, and the ruling in Hari Ram v. State of Rajasthan – Court set aside conviction of second appellant and remitted the case to the Juvenile Justice Board for disposal as per the Act [Paras 9-10].

Criminal Law – Conviction under Section 302 IPC – Sole testimony of PW-13, supported by PW-6 and corroborated by material evidence, established guilt of first appellant – Discrepancies in witness testimonies deemed non-material and insufficient to discredit evidence – Supreme Court upheld conviction of first appellant under Section 302 IPC [Paras 11-13].

Motive – Not Essential with Direct Evidence – Absence of motive was argued but found irrelevant due to direct and reliable eyewitness accounts corroborated by material evidence [Para 13].

Decision – Appeal of the first appellant dismissed, conviction and sentence under Section 302 IPC affirmed – Appeal of the second appellant allowed, conviction set aside, case remitted to the Juvenile Justice Board for disposal within four months [Para 14].

Civil Procedure – Decree under Order VIII Rule 10 CPC – Appellant failed to file written statement under impression that entire amount had been paid – Trial court decreed suit without examining issues or considering whether facts needed proof – Supreme Court held such decrees must reflect reasoning and ensure satisfaction that no fact needs proof despite deemed admission by Defendant [Paras 4-6].

Order VIII Rule 10 CPC – Discretionary Relief – Court emphasized discretion and caution in passing decrees when Defendant fails to file written statement – Judgment must contain reasoning and reflect understanding of facts and controversy resolved [Para 6].

Order IX Rule 13 CPC – Applicability – Not addressed directly; focus on trial court’s failure to adhere to established legal propositions for passing decrees under Order VIII Rule 10 [Para 9].

Decision – Judgment and decree dated 12.11.2003 set aside – Case remanded to trial court for fresh decision – Appellant permitted to file written statement within three weeks – Trial to be concluded expeditiously [Para 10].

Prevention of Corruption – Sanction for Prosecution – Respondent, a Deputy General Manager on deputation, was prosecuted under the Prevention of Corruption Act without sanction from the State Government of Uttar Pradesh – High Court quashed prosecution for lack of valid sanction – Supreme Court upheld High Court's decision, clarifying that removal from office means termination from service, not merely repatriation [Paras 1-12].

Sanctioning Authority – Determination – Court distinguished between power to repatriate and power to remove from service – Repatriation does not equate to removal from office under Section 19(1)(c) of the Act – Only the authority competent to remove from service can grant sanction [Paras 11-12].

Constitution Bench Precedent – Reference to R.S. Nayak v. A.R. Antulay for interpreting "removal from office" – Affirmed that sanction must come from authority with power to terminate service, not just reassign duties [Para 8].

Request for Sanction – Pending Decision – State of Uttarakhand's request for sanction from Uttar Pradesh still pending – Supreme Court directed prompt decision on the request within eight weeks [Paras 13-14].

Decision – Appeal dismissed – Sanction for prosecution must be obtained from appropriate authority [Para 15].

Judicial Officer – Compulsory Retirement – Appellant, a judicial officer, was compulsorily retired following allegations of demanding illegal gratification – Enquiry Officer found Appellant guilty based on statements recorded in preliminary inquiry – High Court dismissed Appellant's challenge – Supreme Court held reliance on preliminary inquiry statements without opportunity for cross-examination violated principles of natural justice [Paras 19-29].

Departmental Enquiry – Standard of Proof – Court reiterated that departmental proceedings, though quasi-judicial, do not require proof beyond reasonable doubt but must be based on preponderance of probabilities – Findings must be supported by evidence and meet natural justice requirements [Paras 6A-F].

Protection of Judicial Officers – Emphasized judiciary's duty to protect honest judicial officers from motivated complaints – Reiterated that judicial officers must be safeguarded to maintain judicial independence and integrity [Paras 6II(a-d)].

Judicial Review – Limited Scope – Clarified judicial review in disciplinary matters focuses on procedural fairness, adherence to principles of natural justice, and existence of evidence – Court does not re-evaluate evidence as an appellate authority [Paras 6III(i-iii)].

Decision – Appeal allowed – Compulsory retirement order set aside – Appellant exonerated of all charges – State of Gujarat directed to pay Rs. 5 lakhs in costs to the Appellant within three months [Paras 30].

Dowry Death and Cruelty – Evidence – Appellants convicted under Sections 304B, 498A, and 306 IPC based primarily on a letter (Ext. 49) allegedly written by the deceased – Supreme Court found grave doubts regarding the authenticity of the letter – Defence evidence suggested the deceased was not at Ahmedabad when the letter was purportedly written – No other substantial evidence of cruelty or harassment by the Appellants [Paras 4-5].

Harassment and Demand for Dowry – Evaluation of Evidence – Letter (Ext. 31) written by PW3 (brother of deceased) indicated the deceased was living happily shortly before her death – Mention of Rs. 33,000/- or Rs. 43,000/- in Ext. 31 insufficient to prove demand for dowry and associated cruelty or harassment [Paras 5-6].

Standard of Proof – Prosecution's Burden – Prosecution failed to prove beyond reasonable doubt that Appellants subjected the deceased to cruelty or harassment in connection with dowry demand – Conviction under Sections 304B, 498A, and 306 IPC not sustainable without such proof [Paras 7-8].

Decision – Appeals allowed – Conviction and sentences set aside – Appellants' bail bonds discharged [Para 8].

Matrimonial Disputes – Quashing of Criminal Proceedings – Appellants sought quashing of criminal proceedings under Sections 498A and 406 IPC and Dowry Prohibition Act following mutual settlement – Trial Court and High Court dismissed the petition citing non-compoundable nature of offences – Supreme Court held High Courts have inherent power under Section 482 CrPC to quash proceedings in matrimonial disputes if parties settle amicably [Paras 6-14].

Scope of Section 482 CrPC – Court emphasized that inherent powers under Section 482 CrPC are wide and should be used to secure ends of justice, especially in matrimonial disputes where genuine settlement is reached – Non-compoundable nature of offences under Section 320 CrPC does not restrict High Court's power to quash proceedings [Paras 11-14].

Encouragement of Settlements – Supreme Court highlighted the importance of encouraging settlements in matrimonial disputes to ensure peace and stability in family life – Courts should exercise discretion to quash proceedings to secure ends of justice and avoid abuse of judicial process [Paras 12-14].

Decision – Appeal allowed – High Court's judgment set aside – Criminal proceedings in Criminal Case No. 4166 of 2011 quashed [Para 15].

Promotion Denial – Sealed Cover Procedure – Respondent's promotion to Group 'A' (Junior Scale) of IRAS was withheld due to pending departmental and criminal proceedings – Supreme Court held that none of the conditions for applying the sealed cover procedure were met as of the relevant date, 21.04.2003 – High Court's decision to direct promotion upheld [Paras 8-12].

Office Memorandum Compliance – The 1992 Office Memorandum specifies conditions for sealed cover procedure, including suspension, pending charge-sheet, or pending prosecution – Supreme Court confirmed none of these conditions were met on the relevant date – Paragraph 2 of the memorandum was decisive; paragraph 7 invoked by the appellant was not applicable [Paras 8, 12].

Precedents – Consistency with Previous Rulings – Court reiterated principles from Union of India v. K.V. Jankiraman that disciplinary proceedings commence only when a charge-sheet is issued – Also referred to Coal India Ltd. v. Saroj Kumar Mishra and Chairman-Cum-M.D. Coal India Ltd. v. Ananta Saha, confirming departmental proceedings start with the issuance of a charge-sheet [Paras 13-15].

Decision – Appeal dismissed – High Court's order directing the respondent's promotion affirmed – No costs awarded [Para 17].

Maintenance – Compromise in Section 125 CrPC Proceedings – Appellant and respondent entered into a compromise under Order XXIII Rule 3 CPC agreeing on a consolidated amount for permanent alimony – Respondent later filed for maintenance under Section 18 of the Hindu Adoptions and Maintenance Act – Supreme Court held that a compromise in a Section 125 CrPC proceeding does not preclude filing for maintenance under Section 18 of the Act [Paras 9-12].

Nature of Section 125 CrPC – Section 125 CrPC provides a summary and speedy relief for maintenance – Order under Section 125 is tentative and does not determine final rights – Maintenance under Section 18 of the Hindu Adoptions and Maintenance Act provides separate relief unaffected by compromise under Section 125 CrPC [Paras 10-11].

Public Policy and Contract Act – Agreements opposed to public policy are void – Compromise in Section 125 CrPC cannot foreclose the remedy under Section 18 of the Hindu Adoptions and Maintenance Act as it would be against public policy [Para 11].

Decision – Appeal dismissed – Suit under Section 18 of the Hindu Adoptions and Maintenance Act is maintainable despite earlier compromise under Section 125 CrPC [Para 12].