Criminal Law – Negligence and Recklessness – Supreme Court upheld the High Court’s decision to convict the appellant under Sections 279 and 304-A IPC – The High Court reversed the trial court’s acquittal based on reliable eyewitness testimony and circumstantial evidence establishing rash and negligent driving – Emphasized the doctrine of res ipsa loquitur where the mere occurrence of an accident implies negligence in certain circumstances [Paras 35, 36, 38, 39].

Section 313 CrPC – Examination of Accused – The provisions of Section 313 are mandatory, providing the accused an opportunity to explain the evidence against him – Failure to serve notice under Section 133 of the Motor Vehicles Act did not cause prejudice to the accused, who was identified by eyewitnesses [Paras 35, 36].

Res Ipsa Loquitur – Application in Criminal Cases – The principle of res ipsa loquitur applies to criminal cases of accidents, indicating negligence when the cause of the accident is unexplained and the circumstances imply fault – The accused was identified as the driver fleeing the accident scene, establishing prima facie evidence of negligence [Paras 13, 18, 21].

Decision: Appeal dismissed – High Court's conviction upheld – No jurisdictional error in the High Court's reversal of the trial court's acquittal [Paras 40].

Civil Procedure – Interest on Delayed Payments – Supreme Court held that respondents who accepted the allotment of commercial plots through a public auction on an "as is where is" basis are legally obliged to pay interest, penal interest, and penalty on delayed installment payments – The terms and conditions of the auction and allotment letter, including the installment facility, bind the respondents, and any delays in providing basic amenities by PUDA do not exempt them from these obligations [Paras 3, 6, 11-12].

Contractual Obligations – Auction Terms and Conditions – The Court emphasized that participants in the auction accepted the plots with full knowledge of the terms, and cannot later claim exemption from interest and penalties due to delayed provision of amenities – The auction terms and allotment conditions are binding, and the respondents’ acceptance of these terms precludes them from contesting the obligations arising therefrom [Paras 14-15].

High Court’s Misinterpretation – The High Court erred in applying the precedent set in Municipal Corporation Chandigarh and Others v. Shantikunj Investment Pvt. Ltd. – The Supreme Court clarified that auction of plots on an "as is where is" basis inherently includes acceptance of current conditions and future development timelines [Paras 13-14].

Decision: Appeals allowed – High Court's judgments set aside – Respondents held liable to pay the interest, penal interest, and penalties for delayed installment payments – No order as to costs [Paras 15].

Education Law – Discipline and Misbehavior – Supreme Court held that the High Court's interim order staying the expulsion of a student for alleged gross misbehavior, based on an unconditional apology, was not appropriate – Emphasized the importance of maintaining discipline within educational institutions and allowing the University to complete its disciplinary processes without judicial interference at the interim stage [Paras 18-19].

Judicial Review – Interim Orders – The Court highlighted that it only entertains appeals against discretionary interim orders of the High Court in exceptional cases where there are grave repercussions or a clear miscarriage of justice – The interim order in this case was deemed unsustainable as it interfered with the University's disciplinary jurisdiction and lacked a legal basis [Paras 16-17].

Disciplinary Proceedings – University’s Authority – The University’s decision to expel the student was based on serious allegations of assaulting a professor – The Supreme Court noted that disciplinary matters and the internal administration of educational institutions should generally not be interfered with by courts to maintain an environment conducive to education [Paras 19-20].

Decision: Appeal allowed – Impugned interim order set aside – Liberty granted to the respondent to revive his writ petition challenging the disciplinary order, and the High Court is expected to decide the matter expeditiously [Paras 21-23].

Preventive Detention – Delay in Issuing and Executing Detention Order – Supreme Court quashed the order of detention under COFEPOSA due to unexplained and unreasonable delay in both issuing and executing the detention order – Detaining authority failed to act promptly and did not provide satisfactory explanations for the delays [Paras 13-14, 22-24].

Article 22(5) of the Constitution – Emphasized the mandate that the grounds of detention must be communicated to the detenu without delay, and the detenu must be afforded the earliest opportunity to make a representation against the detention order – Delays in communication and execution of the order must be satisfactorily explained to uphold the validity of the detention [Paras 8, 12-13].

Judicial Precedents – Referred to multiple judgments highlighting that delays in serving and issuing detention orders, if unexplained, vitiate the detention order – Cited cases where courts have quashed detention orders due to similar delays [Paras 9-11, 15-21].

Decision: Appeal allowed – High Court's judgment set aside – Detention order dated 14.11.2006 quashed due to inordinate delay in execution and issuance without proper explanation – No further direction for release as the detention period had already expired [Paras 29].

Prisoners' Rights – Wages for Labour in Prison – Supreme Court directed that the appellant, who was engaged in the Medical Inspection (MI) room as an assistant during her imprisonment, be allowed to make a fresh representation for wages – Emphasized that prisoners sentenced to rigorous imprisonment are required by law to undergo hard labour and are entitled to wages for the same – Court ordered an inquiry by the visiting Judge to ascertain if additional wages are due [Paras 7, 9-10].

Labour Classification and Wages – Detailed the classification of labour into hard, medium, and light labour as per the Delhi Prisons Rules – Highlighted that female convicts’ tasks are limited to two-thirds of the maximum tasks prescribed for adult male convicts – Provided the wage structure and the process for determining and paying wages to prisoners [Paras 7, 10].

Procedural Directives – Directed the appellant to make a fresh representation to the visiting Judge with all details of the work done during her custody – Ordered the visiting Judge to inspect the records and pass an order within three months, ensuring any additional amount due as wages is paid within four weeks thereafter [Paras 10-11].

Decision: Appeal disposed of with directions – Appellant to submit a representation for wage claims – Visiting Judge to verify and decide on the entitlement of additional wages, if any, with the assistance of legal services and jail authorities [Paras 10-11].

Constitutional Law – Scheduled Tribe Certificate – Supreme Court held that the appellant, whose caste certificate as 'Halba' was invalidated on the ground of being 'Koshti', is entitled to protection against ouster as per the precedent set in State of Maharashtra v. Milind – Protection extended to appellant despite the invalidation of her caste certificate due to prevailing confusion and historical treatment of 'Koshti' as 'Halba' [Paras 10-13].

Service Law – Protection Against Ouster – Appellant’s service, having attained finality before the judgment in Milind's case, should be protected against ouster – Directed reinstatement with continuity of service but no back wages – The appellant will not receive any further benefits on the basis of the invalidated caste certificate [Paras 13, 16-17].

Judicial Precedents – Application and Distinctions – Referred to various cases including Milind, R. Vishwanatha Pillai, and Sanjay K. Nimje to highlight the scope and application of protection against ouster in cases of invalidated caste certificates – Clarified that protection is not extended in cases involving fraud or falsification of caste status [Paras 7-9, 11, 15-16].

Decision: Appeal allowed – Order of the High Court set aside – Directed reinstatement of the appellant in service with continuity for all purposes except for back wages – Protection from ouster granted based on precedents and factual context [Paras 16-17].

Public Health and Environment – Bhopal Gas Tragedy – Supreme Court directed the continuation of various measures for the rehabilitation and medical care of the Bhopal Gas victims – The Court transferred the case to the High Court of Madhya Pradesh for better and effective control – The directions include ensuring proper medical treatment, research, and monitoring of healthcare facilities [Paras 1-41].

Judicial Oversight – Transfer to High Court – The Court found it appropriate to transfer the matter to the High Court of Madhya Pradesh for day-to-day management and supervision – Highlighted the need for localized and efficient judicial oversight to handle the ongoing issues effectively [Paras 21, 35].

Monitoring and Advisory Committees – Powers and Functions – Reiterated the roles of the Monitoring Committee and the Advisory Committee – Directed the State of Madhya Pradesh to provide adequate office space and infrastructure to these committees – Authorized the Monitoring Committee to oversee medical facilities and hear grievances of gas victims [Paras 22-24, 30].

Research and Healthcare – Directed the ICMR and NIREH to carry out research with exactitude and ensure its benefits reach the gas victims – Emphasized the need for computerization of medical records and issuance of health booklets and smart cards to the victims [Paras 27-29, 31].

Decision: Writ Petition transferred to the High Court of Madhya Pradesh – Issued detailed directions to ensure continued medical care, research, and rehabilitation for the Bhopal Gas victims – Directed various authorities to comply with these orders and facilitate the effective functioning of committees and healthcare initiatives [Paras 35, 37-41].

Administrative Law – Powers of Officer Commanding-in-Chief – Supreme Court held that the Officer Commanding-in-Chief the Command under Section 52(1) of the Cantonments Act, 1924, has the power to annul decisions of the Cantonment Board even if the matter was referred by an invalid or incompetent reference under Section 51(1) – This power is broad and expansive, meant to correct decisions prejudicial to the health, welfare, or discipline of the forces [Paras 6-10, 12-13].

Jurisdiction and Authority – Scope of Sections 51 and 52 – The Court clarified that Section 52 is in two parts: (1) for decisions coming to the Officer Commanding-in-Chief otherwise than by reference under Section 51(1); and (2) for decisions specifically referred under Section 51(1) – Both parts authorize annulment of Board decisions after providing an opportunity to show cause [Paras 9-11].

Judicial Precedents – Validity of Actions under Statutory Powers – Citing established legal principles, the Court emphasized that the validity of an action is not affected by incorrect recital of the statutory provision as long as the power exists under the statute – Referred to precedents supporting this view [Paras 12-13].

Decision: Appeal allowed – High Court's judgment set aside – Case remanded to the High Court for consideration of other contentions raised in the writ petition by the respondent, to be decided expeditiously [Paras 14-15].

Right to Free Legal Aid – Constitutional and Statutory Provisions – Supreme Court emphasized that under Article 21 and Article 39A of the Constitution, as well as Sections 12 and 13 of the Legal Services Authorities Act, every person in custody is entitled to free legal aid at all stages of the judicial process, including appeals – The right to legal representation is an inalienable part of a fair trial and due process [Paras 5-9, 21].

Obligation of Courts – Ensuring Legal Representation – Courts are obligated to inform the accused or convict of their right to legal aid and ensure they are provided with legal representation if they are unable to afford it – Failure to provide legal aid violates the fundamental rights of the accused under Article 21, rendering the trial or appellate proceedings constitutionally infirm [Paras 10-14, 21].

Judicial Precedents – Right to Legal Aid – The Court cited previous judgments affirming the right to free legal aid, including Hussainara Khatoon v. Home Secretary, State of Bihar, Khatri v. State of Bihar, and Suk Das v. Union Territory of Arunachal Pradesh – Highlighted that an accused need not request legal aid; it is the Court’s duty to offer and ensure it [Paras 10-14].

International Perspective – Right to Legal Representation – Referred to decisions from New Zealand and Australia, indicating the global recognition of the right to legal representation as essential for a fair trial – Noted the proactive approach of Indian courts in contrast to the more passive approach in other jurisdictions [Paras 17-20].

Decision: Appeal allowed – High Court's judgment set aside – Case remanded to the High Court for a fresh hearing after providing the appellant with legal representation at State expense – High Court requested to expedite the hearing [Paras 21-22].