Criminal Law – Circumstantial Evidence – Appellant convicted based on circumstantial evidence for the murder of Baldevraj Seth and his family – High Court upheld the conviction – Supreme Court found no material discrepancies to overturn the High Court’s decision – Emphasized the reliability of the chain of evidence and corroborative testimonies [Paras 1-17].

Confession and Recoveries – Admissibility and Corroboration – Confessional statements of the accused led to recoveries of incriminating items – Supreme Court upheld admissibility under Section 27 of the Evidence Act – Statements corroborated by forensic and eyewitness evidence [Paras 30-31].

Eyewitness and Forensic Evidence – Consistency and Reliability – Statements of eyewitnesses and forensic experts found consistent and credible – Blood stains, finger prints, and forensic analysis supported the prosecution’s case – Supreme Court held the evidence collectively established the guilt of the accused [Paras 9-16, 22-23, 36-38].

Judicial Interpretation – Section 313 CrPC – Appellant’s failure to explain incriminating circumstances during examination under Section 313 CrPC used against him – Supreme Court emphasized the significance of the accused’s responses in forming adverse inferences [Paras 49-53].

Decision – Appeal dismissed – Conviction and sentences upheld – Supreme Court directed the implementation of the sentences as per the trial court’s judgment [Para 53].

Arbitration – Appointment of Arbitrator – Petition under Sections 11(6) and 11(8) of the Arbitration and Conciliation Act, 1996, for an independent arbitrator – Respondent insisted on appointing the Chairman and Managing Director of BEL or his nominee as per the arbitration clause – Supreme Court appointed an independent arbitrator due to reasonable apprehension of bias [Paras 1-54].

Arbitration Clause – Enforcement and Interpretation – The arbitration clause in the Purchase Order mandated disputes be referred to BEL’s Chairman and Managing Director or his nominee – Petitioner requested an independent arbitrator, citing potential bias and lack of impartiality – Supreme Court upheld the request for an independent arbitrator, stressing the importance of impartiality in arbitration proceedings [Paras 2-7].

Communication of Orders – Legal Principles – Order appointing an arbitrator by the respondent communicated late to the petitioner – Supreme Court highlighted that an order takes effect only when communicated to the affected party, aligning with the general legal principle and Section 3(2) of the Arbitration and Conciliation Act, 1996 [Paras 23-31].

Precedents and Judicial Reasoning – Cited multiple judgments affirming that orders and appointments must be communicated to take effect – Supreme Court rejected the respondent's claim that internal appointment sufficed without proper communication [Paras 24-29].

Decision – Petition allowed – Justice Ashok C. Agarwal (Retd.) appointed as sole arbitrator – Directed the registry to communicate the order to the appointed arbitrator for expeditious resolution of disputes [Paras 43-45].

Bar Association – Implementation of Judgment – SCBA and others filed applications concerning the implementation of the Supreme Court's judgment regarding amendments to SCBA Rules – Supreme Court reviewed actions taken by the SCBA and its Implementation Committee, addressing procedural irregularities and ensuring compliance with its judgment [Paras 1-54].

Elections and Membership – Voting Rights – Dispute over eligibility to vote in SCBA elections and the preparation of a voters' list – Supreme Court upheld the need for strict adherence to its directions in the judgment dated 26th September 2011, emphasizing the principle of "One Bar One Vote" [Paras 43-46].

General Body Meeting and Resolutions – Legality and Compliance – Supreme Court scrutinized the resolutions adopted at the SCBA General Body Meeting held on 16th January 2012, finding them non-compliant with the Court's judgment – Declared resolutions invalid due to procedural improprieties and violation of Article 141 [Paras 47-51].

Contempt of Court – Disobedience of Court Orders – Reviewed actions of SCBA members for contemptuous conduct in disregarding Supreme Court's directions – Emphasized the binding nature of its judgments and the duty of SCBA members to comply [Para 50].

Implementation Committee – Role and Function – Affirmed the role of the Implementation Committee in overseeing compliance with the Court’s judgment – Directed the Committee to resume its work and finalize the voters' list while addressing objections [Paras 52-54].

Decision – Interlocutory application allowed – Resolutions from the General Body Meeting on 16th January 2012 declared invalid – Implementation Committee directed to finalize voters' list and proceed with SCBA elections as per Supreme Court's judgment – Contempt petition disposed of [Paras 54-55].

Criminal Law – Conviction and Death Sentence – Appellant convicted for the rape and murder of his four-year-old daughter – Trial court sentenced him to death – High Court affirmed the conviction and death sentence – Supreme Court reviewed the evidence, upheld the conviction but commuted the death sentence to life imprisonment [Paras 1-28].

Eyewitness Testimony – Reliability and Consistency – Testimonies of Roopa Devi (PW3) and Gulla (PW4) found reliable despite minor inconsistencies – Supreme Court held that minor discrepancies do not undermine the overall reliability of the eyewitness accounts [Paras 9-13].

Medical Evidence – Corroboration with Eyewitness Accounts – Injuries on the deceased matched the account given by eyewitnesses – Supreme Court upheld that medical findings supported the prosecution's case [Paras 6, 9-10].

Confessional Statement – Admissibility and Corroboration – Confessional statement of the accused led to the recovery of incriminating items – Supreme Court upheld admissibility under Section 27 of the Evidence Act – Statements corroborated by forensic and eyewitness evidence [Paras 14-16].

Circumstantial Evidence – Chain of Events – Prosecution established a consistent and credible chain of events leading to the appellant's guilt – Supreme Court upheld the circumstantial evidence presented [Paras 14-17].

Doctrine of Implied Powers – Applicability and Limits – Emphasized the significance of implied powers in exceptional cases where evidence lies within the knowledge of the accused – Applied Section 106 of the Evidence Act to infer guilt due to lack of explanation from the accused [Paras 17-18].

Decision – Appeal partly allowed – Conviction upheld – Death sentence commuted to life imprisonment – Appellant to serve a minimum of 30 years without remission before consideration for pre-mature release [Para 27].

Intellectual Property – Copyright – Compulsory Licensing – Appeals against the Delhi High Court's reversal of the Copyright Board’s decision not to grant interim compulsory licenses – Supreme Court examined whether the Copyright Board has the authority to grant interim relief under Section 31 of the Copyright Act – Upheld that the Copyright Board lacks the power to issue interim compulsory licenses as the statute does not expressly confer such authority [Paras 1-45].

Tribunal Powers – Inherent and Implied Powers – Considered whether the Copyright Board, as a statutory tribunal, could exercise inherent or implied powers to grant interim relief – Supreme Court held that in the absence of express statutory provision, tribunals do not possess inherent powers to grant interim relief similar to the final relief sought – Rejected the doctrine of implied power in this context, distinguishing from other tribunals with explicit statutory authority [Paras 39-45].

Doctrine of Implied Powers – Applicability and Limits – Discussed judicial precedents on implied powers of tribunals – Emphasized that implied powers must be essential to the functioning of the tribunal and cannot grant final relief at an interim stage – Supreme Court reiterated that such powers must be explicitly stated in the statute governing the tribunal [Paras 38-45].

Decision – Appeals allowed – High Court's order set aside – Original decision of the Copyright Board restored – Held that the Copyright Board does not have the power to grant interim compulsory licenses under Section 31 of the Copyright Act [Para 45].

Criminal Procedure – Anticipatory Bail – Appeals challenge High Court's directions allowing accused to surrender and seek bail from Magistrate despite denial of anticipatory bail – Supreme Court set aside these directions, emphasizing strict adherence to Section 438 CrPC and the necessity of judicial discretion in granting bail [Paras 1-34].

Judicial Discretion – Scope and Limits – High Court's order granting bail upon surrender despite denying anticipatory bail deemed contradictory – Supreme Court reiterated the need for courts to operate within statutory parameters and maintain judicial propriety – Emphasized that courts cannot indirectly grant what is directly impermissible [Paras 7-16].

Statutory Interpretation – Compliance with Section 438 CrPC – Supreme Court highlighted the importance of adhering to statutory provisions when dealing with anticipatory bail – Directed that such orders must be clear, reasoned, and conform to legal requirements without creating ambiguity or inconsistency [Paras 17-18, 30-32].

Precedents and Principles – Reviewed past judgments to reinforce the necessity for judicial restraint and adherence to established legal principles in bail matters – Reiterated that anticipatory bail should be granted only when justified and within the scope of Section 438 CrPC [Paras 18-21, 26-29].

Decision – Appeals allowed – High Court's directions set aside – Accused directed to seek bail under Section 439 CrPC – Emphasized proper judicial process and adherence to statutory mandates [Para 34].

Public Contracts – Eligibility and Award – Appeal against the High Court's decision upholding the award of a water supply project to Respondent No. 2 – Appellant contested the eligibility of Respondent No. 2, claiming non-compliance with tender conditions regarding balance sheets and single integrated water supply scheme experience – Supreme Court upheld the High Court's decision, finding substantial compliance and no arbitrariness in the process [Paras 1-21].

Tender Conditions – Compliance and Judicial Review – Supreme Court examined compliance with tender conditions – Held that Respondent No. 2 substantially complied with the requirement of filing balance sheets for the past five years and demonstrated experience in executing an integrated water supply scheme – Emphasized judicial restraint in interfering with administrative decisions unless clear arbitrariness or mala fides are established [Paras 8-15].

Public Interest – Timely Execution of Public Projects – Supreme Court noted the importance of timely execution of the water supply project for the benefit of residents in a scarcity-stricken municipality – Interference with the ongoing project deemed detrimental to public interest – Emphasized need for completion within targeted timeline to avoid public hardship [Paras 20-21].

Decision – Appeal dismissed – High Court's judgment upheld – No interference warranted due to substantial compliance with tender requirements and absence of arbitrariness in the award process – Costs assessed at Rs. 25,000 against the appellant [Para 21].

Criminal Law – Murder and Grievous Hurt – The appellant was convicted under Sections 302 and 326 IPC for the murder of Jagannath RambhauShirsath and causing grievous hurt to Muktabai. The incident arose from property disputes and culminated in an attack where the appellant inflicted fatal injuries on the deceased using a knife. The trial court's judgment was affirmed by the High Court. The Supreme Court considered the appellant's plea of private defense but ultimately dismissed it, altering the conviction from Section 302 to Section 304 Part I IPC due to the heat of passion and lack of premeditation​​.

Private Defense – Burden of Proof – The appellant claimed the right of private defense, asserting a reasonable apprehension of injury from the deceased and his family. The Supreme Court emphasized that the burden lies on the accused to substantiate the plea of private defense through positive evidence or prosecution witnesses' testimony. It was determined that the appellant failed to demonstrate a reasonable cause for apprehension of death or grievous hurt, and hence, the plea was rejected​​.

Witness Testimony – Reliability – The court critically evaluated the testimonies of PWs 1, 8, 10, and 11, who corroborated the sequence of the assault led by the appellant. The testimonies, supported by medical evidence, affirmed the appellant's role as the aggressor. The court also scrutinized the recovery of the weapon and the lack of adequate explanation from the appellant regarding his possession of the knife at the time of the incident​​.

Exception 4 to Section 300 IPC – Application – The Supreme Court applied Exception 4 to Section 300 IPC, concluding that the act was committed in a sudden fight without premeditation, altering the conviction to Section 304 Part I IPC. The appellant's custodial sentence was reduced to 10 years considering the absence of undue advantage or cruel behavior during the incident​​.

Decision: Appeal disposed of. Conviction under Section 302 IPC altered to Section 304 Part I IPC with a custodial sentence of 10 years.

Election Law – Corrupt Practices – The appellant's election to the Madhya Pradesh State Assembly was challenged on grounds of corrupt practices, including exerting undue influence, distribution of school bags and financial inducements, and irregularities in the voters' list. The Supreme Court evaluated whether the allegations were sufficiently detailed and substantiated to proceed with the trial. It was emphasized that specific facts constituting the corrupt practices and the candidate's consent are critical to establish a cause of action​​.

Pleadings – Material Facts and Particulars – The court highlighted the necessity for an election petition to contain all material facts and particulars to enable the respondent to understand the case. Vague allegations without specific details of dates, places, and involved individuals are insufficient. The Supreme Court stressed that the allegations of corrupt practices are quasi-criminal in nature and must be strictly proved​​.

Procedural Deficiencies – Amendment of Pleadings – The Supreme Court noted that while procedural defects in the verification of the petition could be cured, the absence of material facts in the original petition is fatal. The High Court's direction to allow the election petitioner to amend the petition was considered contrary to the settled principles of election law, as it would extend the limitation period​​.

Decision: Appeal allowed – Election petition dismissed – The court held that the election petition lacked necessary material facts and did not disclose a complete cause of action. Procedural defects regarding verification were not the sole grounds for dismissal; the substantial absence of material facts warranted dismissal​​.