Mining Leases – Applicability of Rule 25A – Appeals challenge the grant of mining lease to legal heirs of the original applicant, Dr. Sarojini Pradhan, following her death – Examination of whether Rule 25A is retrospective or prospective and if legal heirs can step into the shoes of the original applicant – High Court and Central Government decisions affirmed the substitution of legal heirs – Supreme Court upheld this view, citing principles of res judicata and institutional hearing [Paras 22-35, 40-48].

Institutional Hearing – Natural Justice – Appellants argued that the final order was passed by an official who did not hear the parties – Supreme Court rejected this, upholding the legality of institutional hearings where administrative actions are confirmed by the authorized officials – Previous case law supported the validity of such administrative processes [Paras 36-48].

Res Judicata – Subsequent Law – Appellants claimed subsequent interpretation of Rule 25A should reopen decided matters – Supreme Court held that res judicata principles prevent reopening cases where issues have been finally settled between parties – Reaffirmed that subsequent changes in law do not affect final decisions in past litigations [Paras 30-34].

Decision – Appeals dismissed – Orders of the High Court and Central Government upheld – Legal heirs of Dr. Sarojini Pradhan allowed to continue the application for mining lease – No costs awarded [Para 49].

Negotiable Instruments – Presumptions and Rebuttal – Appellant's complaint under Section 138 of NI Act based on a dishonoured cheque – Respondent contended cheque was issued as security, not for loan repayment – Trial court and first appellate court convicted respondent – High Court reversed conviction, finding rebuttal evidence sufficient – Supreme Court upheld High Court's decision, emphasizing the rebuttable nature of presumptions under Sections 118 and 139 of NI Act and the adequacy of respondent's evidence [Paras 1-16].

Legal Standards – Burden of Proof – Court reiterated the standard of proof for rebutting presumptions under Sections 118 and 139 – Accused need only raise a probable defence, not prove it beyond reasonable doubt – High Court correctly applied this standard, finding the defence version reasonably probable based on the evidence [Paras 19-27].

Evidence – Evaluation – Supreme Court noted critical gaps in appellant's case, such as failure to specify loan date and present supporting documentation – Combined with defence witness testimony and timing of cheque presentation, these gaps supported respondent's rebuttal [Paras 13-16, 26-27].

Decision – Appeal dismissed – High Court's acquittal of respondent upheld – Emphasized the need for careful evaluation of both presumptions and rebuttal evidence to avoid miscarriage of justice [Paras 16, 27].

Education Law – Staff Fixation – High Court directed the Secretary, General Education Department, Kerala, to verify student strength in aided schools with police assistance following allegations of bogus admissions – Supreme Court held police intervention inappropriate for educational environment – Directed implementation of UID-based verification as per State circular dated 12.10.2011 [Paras 2-19].

Administrative Law – Scope of Judicial Directions – High Court's direction for police involvement in student verification deemed excessive – Emphasized administrative mechanisms within educational framework – Suggested modern methods like UID for addressing verification issues [Paras 14-18].

Decision – Appeal allowed in part – Directions for police verification set aside – Education Department directed to implement UID-based verification system – Pending appeals on liability for irregularities to be decided by State Government [Paras 18-19].

Administrative Law – Recruitment and Waiting List – Respondent participated in selection process for Junior Engineer (Civil) Grade-II – Figured in merit list among scheduled caste candidates – High Court directed the state to consider Respondent's appointment after a higher-ranked candidate, Trilok Nath, declined the post – State rejected Respondent’s claim citing expiration of waiting list – Supreme Court held the rejection unjustified and directed the state to appoint Respondent retrospectively with seniority and back wages from date of order [Paras 1-19].

Contempt Jurisdiction – High Court's Directions – State challenged High Court’s order in contempt jurisdiction for exceeding its mandate – Supreme Court invoked Article 142 to ensure complete justice – Emphasized that state’s technical objections should not defeat legitimate claims – Directed implementation of High Court's directions to correct state’s procedural lapse and ensure justice [Paras 14-19].

Decision – Appeals dismissed – State directed to appoint Sat Pal as Junior Engineer (Civil) Grade-II with retrospective seniority – Wages from date of Supreme Court order [Para 18-19].

Criminal Law – Kidnapping and Murder – Appellant convicted of kidnapping a seven-year-old boy, Suresh, for ransom, and subsequently murdering him – Trial court imposed death sentence, confirmed by the High Court – Supreme Court examined the adequacy of circumstantial evidence and the appropriateness of the death penalty – Conviction and death sentence upheld based on detailed evidence and application of principles [Paras 1-28, 32-33].

Circumstantial Evidence – Legal Standards – Supreme Court reiterated the principles for conviction based on circumstantial evidence – Emphasized that each link in the chain of evidence must be proved beyond reasonable doubt and collectively lead to the conclusion of guilt – Referred to established jurisprudence including Sharad Birdhichand Sarda v. State of Maharashtra and Tanviben Pankaj Kumar Divetia v. State of Gujarat [Paras 19-23].

Sentencing – Death Penalty – Rare of Rare Cases – Court reaffirmed guidelines for imposing death penalty, considering both aggravating and mitigating circumstances – Highlighted heinous nature of crime, premeditated actions, and lack of mitigating factors – Affirmed death sentence as the only appropriate punishment given the gravity of the crime and its impact on the victim’s family and society [Paras 29-31].

Decision – Appeals dismissed – Conviction and death penalty upheld – Directions issued for implementation of UID-based verification system to prevent manipulation in school admissions and staff fixation [Paras 18-19, 32-33].

Administrative Law – Pension Eligibility – Respondents appointed as ad hoc Assistant Professors/Lecturers continued for over two decades – High Court granted pension under University Pension Regulations, 1990 – Supreme Court held Respondents were not regularly appointed under the Rajasthan Universities Teachers and Officers (Selection for Appointment) Act, 1974 – Pension benefits denied as their appointments were not in accordance with statutory provisions [Paras 1-38].

Employment Law – Regularization of Services – High Court relied on Section 3(3) of the Act and Regulation 23 for pension eligibility – Supreme Court clarified Section 3(3) only allows stop-gap arrangements and does not confer regular status – Regularization principles under Uma Devi's case not applicable due to statutory limitations and prior court decisions [Paras 22-34].

Judicial Review – Interpretation of Regulations – High Court's interpretation of Regulations 2 and 22 as extending to long-serving ad hoc teachers rejected – Supreme Court emphasized statutory requirement for regular appointments and proper selection process for pension eligibility [Paras 35-37].

Decision – Appeals allowed – High Court's orders set aside – No recovery of amounts already paid to Respondents – Directions for adherence to statutory appointment procedures for pension eligibility [Para 38].

Motor Accident Compensation – Dual Claims – Deceased was a Pump Operator killed in a motor accident – Widow and dependants filed for compensation under the Motor Vehicles Act – Simultaneously, employer deposited compensation under the Workmen's Compensation Act – Tribunal awarded compensation after deducting amount received under Workmen's Compensation Act – Appeal contends dual compensation not permissible under Section 167 of Motor Vehicles Act – Supreme Court held compensation under Workmen's Compensation Act was deposited suo motu by employer, not a choice exercised by dependants – Filing of claim under Motor Vehicles Act constituted election under Section 167 – Deduction ensures no dual benefit [Paras 1-15].

Election of Remedies – Section 167 of Motor Vehicles Act – Claimants must choose either Motor Vehicles Act or Workmen's Compensation Act for compensation – Employer’s suo motu deposit under Workmen's Compensation Act does not constitute claimant's election – First action by claimants was filing under Motor Vehicles Act, establishing their election [Paras 12-13].

Legal Provisions – Interpretation and Application – Sections 8 and 10 of Workmen's Compensation Act provide procedures for compensation deposit by employer and claims by dependants – Employer's deposit does not negate claimants' right to compensation under Motor Vehicles Act if chosen first – Section 167 prevents dual recovery but allows deduction of prior compensation to balance claims [Paras 8-14].

Decision – Appeal dismissed – Tribunal and High Court's compensation award affirmed with deduction for Workmen's Compensation Act amount – Ensures adherence to Section 167's principles and prevents dual compensation [Paras 14-15].

Judicial Appointment – Quo Warranto – Petitioners sought quashing of Respondent No. 3’s appointment as a judge of the Andhra Pradesh High Court – Alleged that criminal proceedings against him were concealed during the appointment process – High Court and Supreme Court Collegia, and Central Government failed to consider the criminal case – Supreme Court held that Respondent No. 3 was unaware of the pending criminal case due to procedural lapses by investigating authorities – Consultation process not vitiated as unknown facts cannot be considered as suppression – Writ of quo warranto not maintainable [Paras 1-33].

Judicial Review – Eligibility vs. Suitability – Differentiated between eligibility (objective fact) and suitability (subjective opinion) for judicial appointments – Judicial review permissible for lack of eligibility or effective consultation – Respondent No. 3 met eligibility criteria – No evidence of deliberate suppression of facts – Consultation process not flawed due to unknown criminal case [Paras 12-15].

Institutional Integrity – Consideration of CVC Case – Applied principles from the Central Vigilance Commissioner (CVC) case regarding institutional integrity – Distinguished facts of present case, emphasizing unknown nature of criminal charges and lack of suppression by Respondent No. 3 – Public interest writ petition found to be an attempt to malign the judge rather than a genuine challenge to the appointment process [Paras 16-45].

Decision – Writ petition dismissed – No grounds for quashing Respondent No. 3's appointment – Costs of Rs. 50,000 imposed on each petitioner to be deposited in the welfare fund for employees of the Andhra Pradesh High Court [Paras 46-47].

Criminal Law – Murder and Conspiracy – Appellant, a Deputy Superintendent of Police, accused of murdering Praveen, who allegedly had an illicit relationship with Appellant's wife – Conviction based on circumstantial evidence and recoveries made at the instance of the Appellant – Supreme Court examined the adequacy of the evidence, procedural aspects, and the applicability of legal principles – Conviction upheld [Paras 1-38].

Circumstantial Evidence – Legal Standards – Reaffirmed principles that each link in the chain of evidence must be proved beyond reasonable doubt – Emphasized that the evidence must be of a conclusive nature excluding all other hypotheses except that of guilt – Applied established jurisprudence from Sharad Birdhichand Sarda v. State of Maharashtra and other relevant cases [Paras 23-24].

Recovery and Identification – Validity – Detailed the recovery of the deceased's body parts and other material evidence at the instance of the Appellant – Emphasized the relevance of DNA evidence and witness testimony – Clarified that minor procedural lapses do not invalidate the core findings if the overall evidence is compelling [Paras 6-11, 30].

Test Identification Parade – Significance – Addressed the non-holding of a test identification parade, noting that the witnesses knew the Appellant from before and the wide media coverage of the case – Held that such a parade was unnecessary in the given circumstances [Paras 33-34].

Decision – Appeal dismissed – Conviction and life sentence upheld – Directed to ensure proper conduct of investigations and trial processes to avoid procedural lapses [Para 37].