Civil Procedure – Delay in Adjudication – Second appeal filed in 2001 dismissed for non-prosecution in 2003 – Restored in 2006 but admitted only in 2011 – Supreme Court emphasized the need for expeditious judicial process – Highlighted the corrosive effect of adjournments and indolence in judicial proceedings – Urged adherence to procedural norms and proactive case management to avoid unnecessary delays [Paras 2-34].

Judicial Responsibility – Role of Judges and Lawyers – Emphasized the mutual duty of the Bench and Bar to avoid delays – Stressed the importance of judicial discipline and commitment to timely justice – Advocated for a mechanism to ensure prompt disposal of cases, urging High Courts to adopt effective measures to prevent inordinate delays [Paras 11-12, 32-33].

Constitutional Mandate – Right to Speedy Trial – Reiterated that the right to a speedy trial is intrinsic to Article 21 of the Constitution – Highlighted that delays undermine public confidence in the judicial system – Called for collective responsibility of all judicial functionaries to uphold the right to speedy justice [Paras 23-27].

Decision: Special leave petition disposed of – Emphasized the need for High Courts to address delays and manage cases efficiently – No specific directions issued but request made to the Chief Justices to adopt necessary measures for timely justice [Para 34].

Criminal Law – Death Penalty – Rarest of Rare Doctrine – Appellant convicted of double murder of wife and daughter – Gruesome manner of killings following previous conviction for rape of daughter – High Court confirmed death penalty considering aggravating factors – Supreme Court revisited the appropriateness of the death penalty under the "rarest of rare" doctrine – Mitigating factors considered [Paras 1-24].

Reformation and Rehabilitation – Mitigating Circumstances – Appellant's claim of strained family relations and frustration considered – Supreme Court emphasized the potential for reformation and possibility of rehabilitation – Life imprisonment instead of death penalty deemed appropriate [Paras 10-20].

Judicial Principles – Balancing Aggravating and Mitigating Factors – Supreme Court reiterated principles from Bachan Singh and Machhi Singh cases – Emphasized that death penalty should be imposed only when life imprisonment is inadequate – Detailed analysis of aggravating and mitigating factors essential in determining sentence [Paras 11-17].

Decision: Appeals allowed in part – Death sentence commuted to life imprisonment – Appellant to serve life imprisonment till the end of natural life, subject to remission by appropriate government under statutory provisions [Paras 24-35].

Administrative Law – License Fee Enhancement – Appellants occupying railway property as licensees since pre-independence – Enhanced license fee challenged as unreasonable – High Court dismissed writ petitions – Supreme Court considered geographical location and market rates – Enhancement deemed necessary but should not be retrospective from 1980 [Paras 1-10].Welfare State – Equitable Distribution – Appellants claimed welfare state duty to provide shops at nominal fees – Court acknowledged state’s duty to balance public welfare and resource generation – Emphasized that welfare does not entail unwarranted privileges for a particular class [Paras 8-9].Judicial Review – Retrospective Application – Notice of enhancement from 1987 applied retrospectively to 1980 – Supreme Court found retrospective application unjustified – Enhancement applicable prospectively from 1987 [Para 10].Decision: Appeals partly allowed – Notice for enhanced license fee to apply prospectively from 1987 – Interim orders vacated – No costs [Paras 10].

Industrial Law – Wrongful Termination – Respondent allegedly forced to resign – Labour Court found resignation voluntary – High Court overturned, finding resignation coerced – Supreme Court upheld High Court's decision, emphasizing the need for compliance with Section 25F of the Industrial Disputes Act for lawful termination [Paras 5-12].Writ Jurisdiction – Articles 226 and 227 – Scope and Standards – High Court's power to interfere with findings of fact by Labour Court – Permissible if findings are perverse or based on no evidence – Certiorari and supervisory jurisdiction detailed as corrective measures against gross errors of jurisdiction or manifest injustice [Paras 8-12].Judicial Review – Findings Based on Evidence – High Court's scrutiny revealed discrepancies and contradictions in Labour Court's findings – Supreme Court affirmed High Court's assessment, finding Labour Court's conclusion unsupported by material evidence [Paras 10-12].Decision: Appeal dismissed – Reinstatement with 25% back wages affirmed – Costs of Rs. 10,000 imposed on the appellant [Para 12].

Industrial Law – Wrongful Termination – Respondent allegedly forced to resign – Labour Court found resignation voluntary – High Court overturned, finding resignation coerced – Supreme Court upheld High Court's decision, emphasizing the need for compliance with Section 25F of the Industrial Disputes Act for lawful termination [Paras 5-12].Writ Jurisdiction – Articles 226 and 227 – Scope and Standards – High Court's power to interfere with findings of fact by Labour Court – Permissible if findings are perverse or based on no evidence – Certiorari and supervisory jurisdiction detailed as corrective measures against gross errors of jurisdiction or manifest injustice [Paras 8-12].Judicial Review – Findings Based on Evidence – High Court's scrutiny revealed discrepancies and contradictions in Labour Court's findings – Supreme Court affirmed High Court's assessment, finding Labour Court's conclusion unsupported by material evidence [Paras 10-12].Decision: Appeal dismissed – Reinstatement with 25% back wages affirmed – Costs of Rs. 10,000 imposed on the appellant [Para 12].

Civil Procedure – Interim Mandatory Injunction – Suit under Section 6 of the Specific Relief Act – Plaintiffs claimed possession of properties based on a marital relationship with deceased Ibrahim Khan – Alleged dispossession after his death – Trial Judge refused interim relief – Appellate Bench reversed decision granting possession to plaintiffs – Supreme Court emphasized high threshold for mandatory interim relief and adherence to judicial discretion principles [Paras 2-16].

Possession and Title – Section 6 Specific Relief Act – Limited scope to restore possession irrespective of title – Interim relief standards require strong prima facie case, irreparable harm, and balance of convenience – Appellate intervention justified only when trial court's discretion is palpably incorrect [Paras 12-15].

Judicial Discretion – Appellate Review – Standards for appellate interference with trial court's discretionary orders – Reiterated principles from Wander Ltd. v. Antox India Pvt. Ltd. – Appellate court should not substitute its discretion unless trial court's view is untenable – Current reversal not consistent with settled principles [Paras 14-15].

Decision: Appeal allowed – High Court order set aside – Trial Judge's order restored – Trial expedited with direction for disposal within six months [Para 16].

Criminal Law – Right to Speedy Trial – Prolonged Detention – Appellant detained for over twelve years awaiting trial under NDPS Act – Supreme Court highlighted the need for expeditious trial and the fundamental right to speedy trial under Article 21 – Issued comprehensive directions to address delays in NDPS cases [Paras 1-4].Judicial Reforms – Procedural Efficiency – Directed immediate notification of fourth proviso to Section 309(2) CrPC to restrict adjournments – Encouraged use of "session's trials" for consecutive examination of witnesses – Emphasized minimal adjournments and prioritized disposal of NDPS cases [Paras 6-12].Forensic Support – Strengthening Narcotics Labs – Directed establishment of more Central and State Forensic Science Laboratories (FSLs) with adequate staffing and resources – Emphasized timely furnishing of test reports and standardized equipment across labs to ensure consistency and reliability [Paras 15-19].Re-testing Restrictions – Strict Time Frames – Prohibited routine re-testing and re-sampling of narcotics samples – Allowed only in exceptional cases within fifteen days of receipt of initial test report – Ensured alignment with Section 52A NDPS Act for swift disposal of hazardous substances [Paras 23-25].Monitoring and Oversight – Designated Nodal Officers – Required appointment of nodal officers for monitoring NDPS cases – Ensured communication between courts and departments to prevent delays [Paras 26-27].Decision: Appeal disposed of – Issued detailed directions to Central and State Governments for expeditious trial and effective management of NDPS cases – Closed with appreciation for assistance provided by legal representatives and officers [Paras 30-32].

Criminal Law – False Allegations – Complainant accused appellant of misbehaving and administering intoxicants – Subsequent charges of rape on false promise of marriage – Mobile phone records disproved complainant's presence at the alleged crime scene – No scientific evidence supporting poisoning claims – Charges found baseless [Paras 2-21].Evidentiary Standards – Mobile Phone Call Records – Analysis revealed inaccuracies in complainant's allegations – Cross-referencing locations and call logs disproved presence and actions of the appellant – Digital evidence considered conclusive [Para 18].Legal Principles – Quashing Criminal Proceedings – High Court's jurisdiction under Section 482 CrPC – Supreme Court delineated steps for quashing baseless criminal proceedings – Emphasized use of impeccable evidence to rule out allegations [Paras 19-21].Decision: Appeal allowed – FIR and subsequent proceedings quashed – Observations emphasized judicial responsibility to prevent abuse of process and uphold justice [Para 22].

Criminal Law – Forgery and Fabrication – Complaint alleged forgery of sale deeds to claim ownership of land – High Court quashed FIR and investigation – Supreme Court held allegations sufficient to constitute offences – Emphasized need for thorough investigation to ascertain facts [Paras 3-10].Judicial Review – Section 195 CrPC – Applicability – High Court erred in applying Section 195(1)(b)(ii) CrPC – Constitution Bench decision clarified applicability only to documents forged during custodia legis – Alleged forgery occurred prior to court proceedings, thus outside scope of Section 195 [Paras 11-12].Inherent Powers – Quashing Criminal Proceedings – High Court's jurisdiction under Section 482 CrPC and Article 226 – Supreme Court reiterated limited scope for quashing FIRs – Allowed only in rare cases where allegations do not constitute any offence – Investigative process should not be stifled prematurely [Paras 7-10].Decision: Appeal allowed – High Court's order quashing FIR set aside – FIR and investigation to proceed – Clarified that neither investigating agency nor trial court should be influenced by observations regarding the merits of the case [Paras 13-14].