Murder and Dowry Death – Sections 302/34, 304-B, 201 IPC – Conviction upheld based on consistent medical evidence and circumstantial evidence – Dowry demands established – Deceased died of burn injuries in her matrimonial home – Defense plea of suicide rejected – Delay in FIR registration considered immaterial given the facts [Paras 6, 13-21].

Circumstantial Evidence – Each incriminating circumstance must be established with reliable evidence – The chain of circumstances must be complete and point only to the guilt of the accused – The court must scrutinize circumstantial evidence closely, especially in the absence of direct evidence [Paras 9-10].

Examination of Accused – Section 313 CrPC – Accused must explain incriminating circumstances – The court must consider the accused’s explanation along with other evidence – Failure to offer a reasonable explanation or providing false answers can complete the chain of circumstances [Para 10].

Appeal against Acquittal – Section 378 CrPC – Appellate court must consider the presumption of innocence and the trial court’s acquittal – Interference is justified only in exceptional cases where the judgment is perverse – Routine interference should be avoided unless compelling reasons exist [Para 7].

Decision - Appeal dismissed – Conviction and sentence upheld – Appellant No. 2 on bail directed to surrender within four weeks – Chief Judicial Magistrate to ensure compliance [Paras 18-21].

Family Pension – Employees Provident Fund Scheme – The widow of an employee is not entitled to family pension if the employee did not exercise the option under the Employees' Family Pension Scheme, 1971 – Notification and communication from the employer were sufficient to inform employees of the scheme – Appeal allowed, Tribunal’s award and High Court judgments set aside [Paras 3-4, 13-15].

Employee Notification and Option – Notification issued by the Regional Provident Fund Commissioner and communication from the appellant-corporation were sent to all employees to exercise their option for the family pension scheme – Several employees opted, while others preferred the provident fund under the CPF Scheme – Widow’s claim after nine years was untenable [Paras 12-14].

Tribunal and High Court's Errors – Tribunal and Courts below erred in not appreciating the facts correctly – Their findings were perverse and warranted interference – Facts indicated the employee had not opted for the family pension scheme and the widow had already received the provident fund amount [Paras 14-15].

Decision:

Appeal allowed – Tribunal’s award and judgments of the learned single Judge and Division Bench of the High Court set aside – No order as to costs [Para 15].

Land Acquisition – Subsequent Purchasers – Purchasers of land post-Section 4 notification do so at their own peril and cannot challenge the acquisition proceedings – They are only entitled to compensation based on the vendor's title – The sale of land post-notification is void against the State [Paras 6-9]​​.

Quashing of Acquisition – Benefit to Non-Objectors – Persons who did not file objections or challenge acquisition proceedings cannot benefit from a court's quashing of declaration under Section 6 in other cases – Land vested in the State cannot be divested even if subsequent proceedings lapse or are void [Paras 10-15]​​.

Vesting of Land – Once land is vested in the State free from encumbrances, it cannot be divested and proceedings under the Act would not lapse even if an award is not made within the statutorily stipulated period​​. The State cannot reconvey the land to the original owners once it has vested [Paras 16-22].

Honest Approach and Equity – Litigants must approach the court with clean hands and truthful intentions – False claims, misrepresentations, and forgery to obtain relief are condemned – Equity demands transparency and good faith [Paras 34-39]​​.

Decision:

Appeals dismissed – Sale deeds in favor of appellants declared void – Appellants ordered to vacate the land – Costs of Rupees Twenty-Five lakhs imposed on appellants to be deposited with the Supreme Court Legal Services Authority within six weeks – Chief Secretary of Tamil Nadu directed to investigate and hold responsible officials accountable [Paras 42-44]​​.

Rape – Conviction and Sentence – Courts are expected to deal with cases of sexual crime against women with utmost sensitivity and sternness – Undue sympathy towards the accused by imposing inadequate sentences undermines societal confidence in the justice system – The High Court's reduction of the sentence from 7 years to the period already undergone (about a year) was unjustified – Sentence of 7 years restored [Paras 6-10, 12-14].

Proper Sentence – Section 376 IPC – The statutory minimum sentence under Section 376 IPC is 7 years, unless adequate and special reasons are provided for a lesser sentence – High Court's lenient view lacked sufficient justification – Emphasis on the need for deterrent sentences in cases involving sexual violence against women [Paras 7-10].

Impact on Society – Sexual violence is a serious crime against the individual and society, violating basic human rights and the right to life under Article 21 of the Constitution – Courts must impose sentences that reflect the gravity of the crime and societal abhorrence – Justice demands that punishment fits the crime, especially in heinous offenses like rape [Paras 12-13].

Decision:

Appeal allowed – High Court's reduction of the sentence set aside – Sentence of 7 years imprisonment restored – Period already undergone by the accused to be set off [Paras 14].

Land Transfer – Charitable Trust – The expression "any person" in Section 154(1) of the Uttar Pradesh Zamindari Abolition and Land Reforms Act, 1950, refers only to natural persons, not to legal or artificial persons like charitable trusts – The Assistant Collector's notice under Sections 166 and 167 was unjustified – Appeal dismissed [Paras 10-11]​​.

Interpretation of Statutes – Natural vs. Legal Persons – The term "person" can include both natural and legal persons, but in the context of Section 154(1), it is limited to natural persons, as indicated by the reference to "family" in the explanation – Legislative amendments clarified this distinction by explicitly including "Co-operative Society" through an explanation added in 1997 [Para 10]​​.

Statutory Provisions – Exceeding Land Limits – Section 154(1) restricts transfer of land that would result in the transferee holding more than 5.0586 hectares – This limit applies to natural persons and their families, not to charitable institutions or other artificial entities [Paras 8-10]​​.

Decision:

Appeal dismissed – Assistant Collector's notice quashed – Charitable institution not included within "any person" under Section 154(1) – No order as to costs [Paras 11-13]​​.

Right to Life – High Court's Jurisdiction – The High Courts possess wide powers and authority to protect and safeguard constitutional rights within their jurisdiction – Petitioner's action of withdrawing proceedings from the High Court and approaching the Supreme Court is disapproved – Supreme Court directs the High Court to restore the withdrawn writ petition and proceed in accordance with law [Paras 5-6]​​.

Petition Under Article 32 – The petition under Article 32 is refused for being filed improperly after withdrawal of the writ petition from the High Court – The petitioner should have pursued the matter effectively before the High Court, which has the same authority as the Supreme Court in such matters [Paras 3-4]​​.

Allegations and Protection – Although allegations in the writ petition do not appear baseless, the Supreme Court cannot entertain the petition due to procedural impropriety – High Court requested to restore the case and ensure protection if warranted [Paras 6-8]​​.

Decision:

Writ petition disposed of with directions to the High Court to restore CWP No. 21234/2011 to its original file and proceed in accordance with law – Supreme Court refrains from commenting on the merits of the case [Paras 8]​​.

Circumstantial Evidence – Conviction Based on Circumstantial Evidence – Conviction can be sustained if the circumstances from which the conclusion of guilt is drawn are fully established, are consistent with the guilt of the accused, and exclude every hypothesis except that of guilt – The chain of evidence must be complete and lead to the conclusion that the accused is guilty beyond a reasonable doubt [Paras 5-6]​​.

Murder and Dowry Death – Sections 302, 304B IPC – The prosecution established that the deceased was ill-treated for dowry, and her death was due to drowning with her hands and legs tied with a saree border – The appellants failed to provide any explanation for the incriminating circumstances, leading to their conviction [Paras 7-14]​​.

Presumption Under Section 106 Evidence Act – When the prosecution proves facts from which a reasonable inference of guilt can be drawn, and the facts are within the special knowledge of the accused, the burden shifts to the accused to provide an explanation – Failure to do so supports the inference of guilt [Paras 19-20]​​.

Decision:

Appeal dismissed – Conviction and sentence by the trial court and High Court upheld – The prosecution's evidence was consistent and conclusive, proving the guilt of the appellants beyond a reasonable doubt [Paras 21]​​.

Criminal Law – Murder and Disposal of Body – Appellant convicted under Sections 302 and 201 IPC for the murder of his wife and disposal of her body. The appellant's absconding did not conclusively prove guilt but added to the circumstantial evidence against him. Recovery of blood-stained items from the appellant's room and car, and the inability to explain incriminating circumstances, supported the conviction [Paras 14, 28-33].

Admissibility of Statements and Recoveries – Section 27 Evidence Act – Statements made by the accused leading to the discovery of incriminating material are admissible. Even if the blood group could not be determined due to disintegration, the presence of human blood supports the prosecution's case [Paras 25, 27, 29-33].

Examination of Accused – Section 313 CrPC – It is obligatory for the accused to provide an explanation for incriminating circumstances during examination under Section 313 CrPC. Failure to explain or providing false answers can complete the chain of circumstantial evidence [Paras 37-38].

Fair Investigation – The appellant alleged unfair investigation and planted evidence. However, the consistent recovery of blood-stained items and the appellant's failure to provide a credible explanation affirmed the validity of the investigation [Paras 3-4, 12].

Decision:

Appeal dismissed – Conviction and sentence upheld – Appellant to serve life imprisonment and pay fines as per the trial court's decision. The concurrent findings of the lower courts were upheld, with the chain of circumstantial evidence deemed complete and conclusive [Paras 40].

Dismissal of Teacher – Compliance with Statutory Provisions – The appellant school failed to comply with Section 40B of the Bombay Primary Education (Gujarat Amendment) Act, 1986, which mandates serving a show-cause notice and obtaining approval from the competent authority before dismissing a teacher. The teacher's dismissal was found to be in contravention of the statutory provisions [Paras 6-7].

Qualifications for Primary School Teachers – The appellant contended that the respondent did not possess the requisite qualification of a Primary Teachers Certificate (PTC) as required under Clause (6) of Schedule F of the Act. However, the respondent argued that his qualifications (B.Sc., B.Ed.) were advertised and accepted at the time of appointment, and similar qualifications were held by other teachers who were not dismissed [Paras 3-4, 19].

Benefit of Own Wrong – The school cannot take advantage of its own mistakes, and the principle "commodum ex injuria sua nemo habere debet" (no one should profit from their own wrong) applies. The case highlighted that the teacher was being victimized for raising concerns about exploitation [Paras 21-22].

Importance of Elementary Education – The court emphasized the constitutional obligation to provide quality elementary education, recognizing its foundational role in achieving social justice, equality, and democracy. The decision reinforced the necessity of employing qualified teachers to ensure the quality of education [Paras 10-14, 16-17].

Decision:

Appeal dismissed – The orders of the Tribunal and the High Court directing reinstatement and back wages for the respondent were upheld. The court found no merit in the appellant's contentions and highlighted the procedural violations and issues of discrimination and victimization [Paras 23-24].