Civil Writ – Constitutional Law - Public Authority – Meaning under Article 12 – Air Force School Not a “State” – The Supreme Court held that the Air Force School, though administered by the Indian Air Force Educational and Cultural Society and staffed by IAF personnel, did not satisfy the test of pervasive control by the State – The school is financially autonomous, not directly funded by government grants, and operates under a non-statutory code – Held: The school is not “State” within Article 12 and is not subject to writ jurisdiction [Paras 20–25].

Service Dispute – Contractual Employment – Writ Petition Not Maintainable – Teachers appointed through private contractual arrangements challenged their termination via writ petitions – The Court found that no statutory provisions governed their service and the dispute did not involve public law elements – Held: Remedies lie in private law; writ jurisdiction under Article 226 is not available [Paras 14, 22–24].

Education Code – Nature and Effect – Not Having Statutory Force – The Education Code relied upon by appellants was not issued under statute and had no legal binding effect – Held: Administrative codes of private societies cannot confer public law remedies in the absence of statutory backing [Paras 21–23].

Funding – Absence of Government Grants – Autonomy in Financial Management – The audited accounts showed no receipt of public funds or grants – Contributions stemmed from fees and non-public funds like welfare contributions from IAF personnel – Held: Absence of financial dependence on State negates classification as “State” [Paras 13–21].

Decision – Appeals Dismissed – Majority Opinion – The Supreme Court affirmed the High Court’s decision that the Air Force School is not “State” under Article 12 and therefore writ petitions against it are not maintainable – Civil remedies are open to the appellants outside writ jurisdiction [Para 25].

Dissent – Pervasive Control by IAF – Writ Maintainable – Justice Ahsanuddin Amanullah dissented, holding that the School, managed by IAF officers and constructed on IAF land with welfare funding, performs a public function – He opined that the IAF exercises pervasive control, and therefore, writs are maintainable against the School under Article 226 – Held: The school is an “authority” under Article 12 and its employment decisions are subject to judicial review [Dissenting Paras 5–30].

Road Safety – Public Interest Litigation (PIL) – National Highways – Implementation of Control of National Highways Act, 2002 – Directions issued to remove unauthorised occupation from National Highways and establish enforcement mechanisms – Court found the absence of dedicated inspection teams and grievance redressal portals violated statutory mandates – Held: Centre and Highway Administrations must constitute inspection squads, grievance portals, and public reporting mechanisms to ensure road safety [Paras 1-3, 5, 10, 13-14].

Highway Administration – Failure in Statutory Duties – Rule 3 of Highway Administration Rules, 2004 (as amended in 2019) – Highway Administrations failed to enforce mandatory duties such as SOP formulation, enforcement monitoring, and grievance resolution – No concrete data or compliance with SOPs submitted – Held: Detailed affidavits with implementation timelines to be filed; strict enforcement of Rule 3 required [Paras 8-9, 13].

Encroachments – Section 24 and 26 of 2002 Act – Lack of Survey and Eviction Mechanisms – Court found that despite legal powers to detect and remove encroachments, Highway Administrations lacked proactive enforcement – No regular surveys, no public complaint channels, and negligible action taken despite notices – Held: Mandatory regular inspections, citizen complaint portal, and toll-free reporting system to be established [Paras 2-7, 11-12, 14].

Public Accountability – Digital Tools and Surveillance – Rajmargyatra App – Incomplete Implementation – App intended for highway users’ complaints lacked redressal transparency and citizen feedback – Court directed upgrade of app with tracking features, status updates, and appeal mechanisms – Also ordered creation of portal with full complaint and response visibility [Paras 12-13].

Judicial Monitoring – Continuing Mandamus – Enforcement Timeline – Recognizing persistent failure of executive bodies, Court retained writ petition on file to ensure periodic judicial review and enforcement of compliance – Directed Union of India and MoRTH to file action-taken affidavits within three months – Surveillance teams with police coordination to be constituted for highway patrolling [Paras 14, 16].

Decision – Interim directions issued – Highway Administration and Union of India to implement SOPs, launch public portal, upgrade mobile app, establish patrolling teams, and file compliance reports within three months – Case to remain pending as continuing mandamus – Next compliance hearing on 15 September 2025 [Paras 16(i)-(viii)].

Civil Writ – Service Law - Performance Appraisal – Role of IAS Officers in IFS PAR – Government Order Quashed – Government of Madhya Pradesh issued a G.O. on 29th June 2024 allowing IAS officers to participate in the appraisal of IFS officers – Held: Such appraisal structure is contrary to Supreme Court’s binding rulings in Santosh Bharti and P.C. Wadhwa cases – Only officers from the IFS cadre can serve as reporting/reviewing authorities up to the level of Additional PCCF, with exceptions for PCCF level – Government Order quashed for violating binding judicial orders [Paras 1-3, 34-39].

Constitutional Governance – Contemptuous Nature of Administrative Orders – Judicial Orders Must Be Followed – The impugned G.O. was issued despite existing Supreme Court directions and without seeking clarification or modification – Held: The G.O. is contemptuous and demonstrates administrative disregard for the rule of law – Court refrains from initiating contempt proceedings but warns against future violations [Paras 36-39].

Service Jurisprudence – Reporting Authority Hierarchy – IFS Confidential Reports – Reporting and reviewing officers must be immediate superiors within the same department – Past judicial interpretations and DoPT/MoEF circulars reiterated this – Evaluation by non-IFS officers is impermissible unless officer works outside the department – Observed: Superior officers must be in higher rank and grade than the one being appraised [Paras 11-20, 24-26, 30-33].

Judgment – Government Order Struck Down – Relief Granted – The impugned G.O. dated 29th June 2024 is quashed and set aside – State directed to reframe rules within one month in compliance with the directions issued by the Court in Santosh Bharti and clarified by MoEF and DoPT [Paras 41-42].

Criminal Law - Sections 420, 406, 467, 468, 473, 474, and 120B of the Indian Penal Code, 1860 - Quashing of FIR – Forged Lease Deed Used – FIR Restored – Allegation that accused used a forged lease deed to sell land and obtained ₹10 lakh as advance – Held: High Court erred in quashing FIR by relying on defence plea that accused were unaware of forgery or were willing to return money – Such issues are matters for trial – FIR restored for continuation of investigation and trial [Paras 2–10].

Plea of Defence – Not a Ground for Quashing – Accused Claimed to Be Victims Themselves – Rejected – Supreme Court reiterated that defence pleas cannot be considered at FIR stage – Even willingness to refund money does not negate commission of cognizable offence – Quashing order set aside [Paras 8–10].

Multiple FIRs – Distinct Transactions – Not Barred – Separate Victims, Separate Offences – Held: Presence of other FIRs relating to similar modus operandi does not make the current FIR a second FIR for the same offence – Each transaction with separate victim constitutes a distinct offence [Para 10].

Final Relief – FIR Quashing Set Aside – Criminal Proceedings to Continue – Supreme Court held that allegations made out a prima facie case – Investigation having culminated in a charge sheet, FIR and proceedings restored for trial – Appeal allowed [Paras 10–11].

Criminal Law - Criminal Complaint – Bar of Limitation – Section 468 CrPC – Cognizance Set Aside – Magistrate took cognizance only under Section 323 IPC (maximum punishment: one year) after three years of the alleged incident – Held: Section 468 CrPC applies; the complaint is barred by limitation – The Magistrate's and High Court’s orders set aside; complaint quashed [Paras 3–11].

Interpretation – Section 468(3) CrPC – Scope Limited to Joint Trial – Not Applicable When Cognizance Taken for Single Offence – Though the complaint alleged multiple offences including one under Section 452 IPC (punishable with up to seven years), cognizance was taken only under Section 323 IPC – Thus, the benefit of extended limitation under Section 468(3) CrPC not available – High Court misread the provision [Paras 6–9].

Legal Principle – Act of Court Cannot Prejudice – Limitation Relates to Date of Offence – Where delay in cognizance is due to court’s process and not complainant’s fault, bar may not apply – However, no justification or extension under Section 473 CrPC invoked in this case – Hence, bar under Section 468 CrPC attracted [Para 8].

Final Relief – Complaint Quashed – Cognizance Beyond Limitation Invalid – Appeal Allowed – The Supreme Court quashed Complaint Case No.13176 of 2018 – Cognizance taken on 27 September 2019 was beyond limitation for an offence under Section 323 IPC, alleged to have occurred on 5 September 2015 [Paras 10–11].

Criminal Law – Circumstantial Evidence – Murder Trial – Last Seen Together – Conviction based solely on the theory of ‘last seen together’ without corroborative evidence – Appellant convicted under Sections 302 and 201 IPC by Trial Court, affirmed by High Court – Supreme Court found chain of evidence incomplete – Held: Last seen theory alone, absent recovery of weapon or conclusive motive, insufficient to sustain conviction – Acquittal granted [Paras 7-9, 15, 18-25].

Evidence Act – Last Seen Theory – Weak Circumstantial Evidence – Witnesses PW-1, PW-2, and PW-13 saw deceased last in the company of appellant – However, no recovery made at appellant’s instance and no admission of guilt – Stone allegedly used in the offence recovered near the body, not via any disclosure under Section 27 Evidence Act – Blood stains found but blood group not matched – Held: Suspicion not sufficient to convict in criminal jurisprudence [Paras 13-18, 22-24].

Motive and Recovery – Absence of Clear Intent or Physical Evidence – Prosecution failed to establish any convincing motive linking the appellant to the murder – Allegations about suspicion over wife’s fidelity speculative and unsupported – No recovery of weapon from accused or based on his confession – No conclusive forensic linkage between the accused and the crime – Held: Conviction cannot rest on conjecture or hypothetical intent [Paras 16-18, 22-23].

Criminal Jurisprudence – Burden of Proof – Chain of Circumstances – Prosecution must establish a complete and unbroken chain of evidence – Contradictions in witness accounts regarding recovery site – Appellant did not abscond, joined search for deceased, and showed no guilty conduct – Held: Circumstantial evidence failed to exclude every hypothesis except guilt – Benefit of doubt extended [Paras 10-12, 15-16, 23].

Precedents – Standard for Circumstantial Conviction – Legal principles from Sharad Birdhichand Sarda, Kanhaiya Lal, and Sujit Biswas reiterated – ‘Last seen together’ rule cannot be the sole basis of conviction without supporting evidence – Absence of motive, lack of recovery, and inconclusive forensic analysis undermine prosecution case – Held: Strong suspicion cannot replace legal proof [Paras 12, 20-21, 24].

Decision – Appeal allowed – Conviction and sentence under Sections 302 and 201 IPC set aside – Appellant acquitted – Directed to be released if not required in any other case [Para 25].

PIL - Domestic Violence Act – Implementation of Statutory Duties – Section 6 to Section 11 of the Act – Directions Issued – The petitioner, a public interest organization, sought effective implementation of the Protection of Women from Domestic Violence Act, 2005 – The Court found gaps in the appointment of Protection Officers, availability of shelter homes, medical aid, legal assistance, and publicity of rights – Held: States and Union Territories directed to designate officers from Women and Child Departments as Protection Officers within six weeks – Further directed to identify shelter homes at District and Taluka levels within ten weeks – NALSA to ensure legal aid under Section 12 of the Legal Services Authorities Act, 1987 is widely publicized and made accessible – Union of India also directed to fulfil its duties under Section 11 – Initial compliance steps mandated for effective nationwide implementation of the Act.

Taxation Law - Income Tax Act – Deductions under Chapter VI-A – Interpretation of Section 80-IA(9) – Clarified Scope of Restriction – Section 80-IA(9) restricts allowance of deduction under other provisions to the extent profits are already claimed under Section 80-IA – Held: The Section does not bar computation of deductions under other sections; rather, it limits the aggregate deduction allowed, preventing duplication – Deduction under each section may be computed separately, but the total cannot exceed profits from eligible business [Paras 19-21, 23-24].

Legislative Interpretation – Meaning of “Allowed” vs “Computed” – Different Stages of Deduction – The Court distinguished between ‘computation’ and ‘allowance’ of deduction – Held: Section 80-IA(9) affects the stage of allowing deductions, not their computation – As long as aggregate deductions do not exceed profits of the business, computation under multiple sections is permissible – Bombay High Court’s view upheld [Paras 22-24].

Judicial Consensus – Approval of Bombay High Court View – Rejection of Contrary Interpretations – Supreme Court endorsed reasoning of Bombay High Court in Associated Capsules Pvt. Ltd. case – Declined to follow Delhi and Kerala High Court decisions that interpreted Section 80-IA(9) restrictively – Harmonious construction preferred to avoid anomalous results [Paras 22-24].

Decision – Reference Answered – Interpretation Settled – Held: Deduction under Section 80-HHC should not be reduced by the amount allowed under Section 80-IA – Both deductions to be computed independently – However, aggregate deduction under heading ‘C’ of Chapter VI-A must not exceed profits and gains of eligible business – Reference concluded accordingly [Paras 23-25].

Civil Law – Partition Suit – Rejection of Plaint – Plaintiffs (mother and son) filed a suit for partition, possession, declaration, injunction, and accounting in respect of properties allegedly purchased from joint family funds – Defendant No.2 (Shaifali Gupta) and Defendant No.5 (subsequent purchaser) filed applications under Order VII Rule 11 CPC for rejection of plaint alleging bar under Benami Transactions (Prohibition) Act, 1988 – Trial Court and High Court rejected the applications – Supreme Court upheld the decision, holding that the issues were mixed questions of fact and law requiring trial [Paras 1–14, 19, 29].

Benami Transactions – Bar under Section 4 of Benami Act – Defendants argued that suit properties stood in names of individuals, hence benami and suit barred – Plaint averred properties were Joint Hindu Family properties purchased from joint family business income – Court held plaint did not disclose properties as benami ex facie – Whether properties were benami is a factual issue requiring evidence – Suit not barred under Section 4 [Paras 23–28].

Civil Procedure – Order VII Rule 11 CPC – Application for rejection of plaint must show suit is barred by law based solely on plaint averments – Defendants failed to establish bar under Benami Act based on plaint alone – Application rightly dismissed – Reliance placed on precedent from Pawan Kumar v. Babu Lal, (2019) 4 SCC 367 [Paras 13, 28–29].

Plea of Female Hindu Ownership – Section 14 Hindu Succession Act – Defendant raised argument of absolute ownership by female Hindu under Section 14 for the first time before Supreme Court – Court declined to entertain as not pleaded or argued before courts below – Also held Section 14 does not bar such a suit [Paras 30–31].

Decision: Special Leave Petitions dismissed – Applications under Order VII Rule 11 CPC rightly rejected – Suit to proceed on merits – No interference warranted under Article 136 of the Constitution [Paras 32–33].