Criminal Law — Dowry Death — Conviction under Section 304B IPC — Law prescribes a minimum of seven years imprisonment for dowry death — No provision for reducing sentence for any reason whatsoever — Conviction and sentence affirmed despite appellants' age and health conditions [Paras 40, 42].

Dowry Death and Cruelty — Sections 304B and 498A IPC, Section 113B Evidence Act — Demand for dowry, harassment, and maltreatment established — Deceased was pregnant and died of poisoning — No delay in lodging FIR — Witnesses consistently supported prosecution’s version — Conviction upheld [Paras 20, 27-35, 42].

Delay in FIR — Not a ground for dismissing prosecution case — Sufficient attempts by complainant to lodge FIR — Court must not overly emphasize delay in FIR lodging [Paras 27-29].

Evidence — Demand for Dowry — Specific instances of demand for dowry sufficiently proven — Additional dowry items such as a buffalo and cash payment were demanded and provided [Paras 30-31].

Proximate Harassment — Section 304B IPC — Harassment for dowry was continuous and proximate to the death — Presumption of dowry death under Section 113B Evidence Act was valid [Paras 32-35].

Decision — Appeal dismissed — Conviction and sentence under Sections 304B and 498A IPC affirmed [Para 42].

Contempt of Court — Withdrawal of Funds — Allegation of withdrawal of large sum of money from Swiss bank account by respondent in violation of court orders dated September 4, 2006, and December 14, 2006 — Respondent contended no withdrawal post orders and closure of account in July 2006 — Bank statement corroborated respondent's claim — No violation of court orders established — Contempt petition dismissed [Paras 32-36].

Burden of Proof — Standard of Proof in Contempt Proceedings — Contempt proceedings are quasi-criminal in nature — Standard of proof required is similar to criminal proceedings — Allegations must be established beyond reasonable doubt — Any doubt or inconsistency benefits the alleged contemnor [Paras 38-42].

Preponderance of Evidence — Contempt Charge — Preponderant circumstances must lead to unimpeachable finding of guilt for contempt — Inconsistent affidavits and ambiguous bank communications insufficient to establish guilt beyond reasonable doubt [Paras 41-42].

Decision — Contempt petition dismissed — Order dated April 1, 2010, holding respondent guilty of contempt, recalled as it was based on erroneous premise [Paras 44-46].

Criminal Law — Rape — Conviction based on Sole Testimony of Prosecutrix — If the sole testimony of the prosecutrix is credible, conviction can be based thereon without need for further corroboration — Prosecutrix was less than 16 years old when raped on several occasions — Her statement, found to be worthy of credence and reliable, requires no corroboration — Consent of minor prosecutrix to sexual intercourse is meaningless — High Court's judgment and order of acquittal set aside — Matter remanded for reconsideration [Paras 29-32].

Evidence — Credibility of Sole Testimony — Detailed statement of prosecutrix before Magistrate u/s 164 CrPC and her testimony before Trial Judge not considered by High Court — High Court should have discussed and analyzed the evidence instead of dismissing it based on a few letters [Paras 30-31].

Right of Appeal — High Court’s Reversal of Conviction — Absence of High Court’s analysis on evidence would take away respondent's right of appeal — Remanding necessary for proper appreciation of case [Paras 31-32].

Decision — Appeal disposed of — Judgment and order of High Court set aside — Matter remanded for reconsideration on merits, including statement and testimony of prosecutrix and applicable law — High Court requested to prioritize disposal of the case [Paras 32-34].

Property Law — Renewal of Lease — Unilateral right of renewal of lease for 25 years under the original lease agreement — Appellant continued to occupy premises after renewal period without executing a fresh lease deed — Appellant continued as a month-to-month tenant — No right to further renewal under statutory provisions after February 28, 2005 — Appeal dismissed with costs [Paras 6-25].

Statutory and Contractual Rights — Distinction between contractual right of renewal and statutory right under Section 5(2) of the Act — Exercise of contractual right does not abrogate statutory right — No fresh deed of lease executed — Appellant exhausted its statutory right under Section 5(2) [Paras 12-23].

Tenant's Status — In absence of fresh lease deed, appellant became a month-to-month tenant — Lessor's termination of tenancy by notice under Transfer of Property Act valid [Paras 19-22].

Decision — Appeal dismissed with costs of Rs. 50,000 — Appellant given two months' time to vacate the suit premises [Paras 25-26].

Motor Vehicles Act — Multiplier Method — Application in Claims under Section 166 — Multiplier specified in Second Schedule of the 1988 Act may be taken as a guide but is not decisive for determining compensation in claims under Section 166 — Just compensation principle requires examination of the unique situation in each case — Reference answered and civil appeals posted for regular hearing [Paras 1-41].

No Fault Liability — Sections 163A and 166 — Claimants have an option to elect remedy under Section 163A or Section 166 — Compensation under Section 163A does not require proof of negligence — Multiplier method for Section 166 claims must ensure fairness, uniformity, and consistency — Standard multiplier table recommended for uniform application [Paras 10-11, 34-35].

Future Prospects — Addition to Income — 50% addition for permanent jobholders below 40 years — 30% addition for those aged 40-50 years — No addition for those above 50 years — Departure from the standard only in exceptional circumstances [Paras 35-36].

Living Expenses — Deduction Standards — One-third for 2-3 dependents, one-fourth for 4-6 dependents, one-fifth for more than 6 dependents — 50% deduction for bachelors unless evidence indicates otherwise [Paras 37-39].

Decision — Reference answered — Guidelines for determining compensation in Section 166 claims approved and directed for uniform application in all pending matters — Civil appeals posted for regular hearing [Paras 40-41].

Land Acquisition — Procedural Violations — Sections 5A and 6(1) of Land Acquisition Act, 1894 — Acquisition of land challenged on grounds of procedural lapses and discrimination — High Court dismissed writ petitions filed by appellants — Supreme Court examined procedural compliance and discriminatory treatment — Acquisition quashed due to non-application of mind by Chief Minister and procedural violations [Paras 1-36].

Discrimination — Article 14 of Constitution — Release of land owned by other entities while retaining appellants' land — Discriminatory treatment without justification — Solitary reason for non-release that land was lying vacant found to be erroneous — State Government's action violated appellants' right to equality [Paras 17, 32-36].

Procedural Compliance — Section 5A(2) and 6(1) — Collector's report on objections and Chief Minister’s non-application of mind — Importance of Section 5A in ensuring a fair hearing before land acquisition — Procedural lapses in considering objections and issuing declarations [Paras 20-34].

Decision — Appeals allowed — High Court’s order set aside — Declaration issued under Section 6(1) quashed — State Government may reconsider objections filed by appellants under Section 5A(1) — Fresh decision to be taken objectively and in accordance with law [Paras 35-36].

Environmental Law — Closure of Plant — High Court directed closure of appellant's copper smelter plant due to procedural breaches and environmental concerns — Supreme Court found the procedural exercise by Tamil Nadu Pollution Control Board (TNPCB) valid and not vitiated by irrationality — High Court erred in interfering with TNPCB's decision — Appeals allowed and closure orders set aside [Paras 1-22].

Judicial Review — Scope and Grounds — Review limited to assessing legality, rationality, and procedural propriety — High Court overstepped its jurisdiction by substituting its judgment for that of the TNPCB without sufficient grounds — Judicial intervention inappropriate where statutory authority's decision is procedurally sound and rational [Paras 22-27].

Environmental Compliance — Consent and Clearance — Appellants obtained required environmental clearances and consents under relevant statutes — NEERI and other reports substantiated compliance with most conditions, and any deficiencies were being addressed — No substantial evidence of persistent non-compliance or significant environmental harm [Paras 28-37].

Compensation for Environmental Damage — Appellants liable for past environmental damage and unauthorized operations — Directed to pay compensation of Rs. 100 crores to be utilized for environmental restoration and local community welfare — Compensation to serve as a deterrent and ensure future compliance [Paras 39-41].

Decision — Appeals allowed — High Court's closure order set aside — Appellants directed to deposit compensation — TNPCB authorized to monitor compliance and issue further directions if necessary [Paras 42-43].

Preventive Detention — Delay in Consideration — Conservation of Foreign Exchange and Prevention of Smuggling Activities Act, 1974 - Section 3(1) — Constitution of India - Article 22(5) — Detention order cannot be quashed solely due to delay in issuance — However, constitutional obligation under Article 22(5) requires prompt consideration of detenu's representation — Unexplained delay breaches constitutional mandate, rendering continued detention illegal — Any delay must be satisfactorily explained to avoid breach of constitutional rights [Paras 11-14].

Independent Consideration — Representation by Detenu — Assertion that representation was not independently considered by detaining authority, though not raised in earlier proceedings, was examined due to habeas corpus principles — Detaining authority must demonstrate independent consideration of representation without being influenced by subordinate officers' endorsements [Paras 5, 10].

Procedural Safeguards — Importance in Preventive Detention — Emphasis on strict compliance with procedural safeguards as the only protection for detenu — Gravity of the offense is irrelevant in preventive detention matters — Procedural lapses affecting the detenu's rights result in setting aside continued detention [Para 9].

Decision — Appeal allowed — Continued detention of detenu declared illegal due to delay in considering representation — Detenu to be released forthwith if not required in any other case — Detention order itself upheld as valid [Paras 17-18].

Military Law — Joint Trial and Juvenility — Army Act, 1950 and Army Rules, 1954 — Respondent, a soldier, charged with theft, unauthorized absence, and possessing counterfeit seals — GCM conducted and punishment awarded — High Court quashed entire GCM proceedings due to some offenses committed when respondent was a juvenile — Supreme Court held joint trial valid for offenses committed after attaining majority — GCM's punishment partly upheld and reduced [Paras 1-28].

Juvenile Justice — Scope and Application — Juvenile Justice (Care and Protection of Children) Act, 2000 — Respondent was a juvenile at the time of some offenses — Plea of juvenility can be raised at any time — Juvenile cannot be tried for offenses committed as a juvenile by GCM — Offenses committed after attaining majority validly tried and sentenced [Paras 10-18].

Severability of Charges — Misjoinder of Charges — Army Rules, 1954 — Rule 79 allows for separate trials for distinct offenses — Joint trial conducted for distinct offenses benefitted respondent — Applying principles of severability, part of GCM proceedings held valid — No prejudice caused to respondent by joint trial [Paras 18-27].

Decision — Appeal allowed — High Court's order set aside — GCM's order of conviction restored — Sentence reduced to five years in light of circumstances and totality of offenses committed after respondent attained majority [Paras 27-28].