Civil Law - Maintainability of Fresh Suit – Dismissal under Order IX Rule 2 – Fresh Suit Permitted – Supreme Court upheld that dismissal of earlier suit under Order IX Rule 2 followed by dismissal of restoration application does not bar filing of a fresh suit under Order IX Rule 4 CPC, subject to limitation – Both remedies are simultaneous and not mutually exclusive [Paras 8-21].

Res Judicata – No Bar to Fresh Suit – Dismissal under Order IX Rules 2 and 3 – Supreme Court held that dismissal of a suit under these rules is not an adjudication on merits and does not constitute a "decree" or "judgment" as defined under CPC – Hence, principle of res judicata not attracted [Paras 22-26].

Evidentiary Value of Wajib Dava – Considered Valid – High Court’s approach affirmed – Supreme Court agreed that document (Exhibit P-1) relied upon by plaintiffs (Wajib Dava of 1952) was rightly considered for proving ownership, and objections based on lack of registration were rejected [Para 27].

Interpretation of Order IX Rule 4 CPC – Privy Council View Affirmed – Supreme Court reaffirmed the interpretation that remedies under Order IX Rule 4 (filing fresh suit or seeking restoration) are not mutually exclusive – Reliance placed on Privy Council and Indian High Courts precedents [Paras 10-21].

Decision – Special Leave Petition Dismissed – Supreme Court upheld High Court’s judgment restoring Trial Court’s decree in favour of plaintiffs – No error found warranting interference – Petition dismissed with pending applications disposed of [Paras 28-29].

Hindu Law – Nature of Property – Self-acquired vs Ancestral – Suit Property Held Self-acquired – The property, originally allotted to a brother under a partition and later purchased by Defendant No.1 (father of plaintiffs), was held to be self-acquired as it was bought from independent funds and loan—not from joint family nucleus – Sale by Defendant No.1 to the appellant upheld [Paras 9–19].

Doctrine of Blending – No Evidence of Voluntary Conversion to Joint Family Property – The plaintiffs failed to show that the self-acquired property was voluntarily thrown into the common stock – Court held mere familial use or absence of separate accounts insufficient to establish blending – Doctrine not applicable [Paras 20, 28].

Reappreciation of Evidence – High Court's Overreach Under Section 100 CPC – Error Corrected – Supreme Court criticized the High Court for re-evaluating factual findings of First Appellate Court without substantial question of law – Held: High Court acted beyond jurisdiction and misapplied Section 103 CPC [Paras 12–14].

Partition and Status of Property – Effect of Registered Partition – Partition Converts Ancestral Property into Separate Property – Once partition occurred, share allotted to Defendant No.1 became his self-acquired property – Subsequent purchase of another share was with separate resources and not subject to coparcenary rights [Paras 17–19].

Decision – High Court Judgment Set Aside – Trial Court Judgment Restored – Appeal Allowed – Appellant’s title under registered sale deed upheld – Plaintiffs’ suit for partition dismissed [Para 21].

Consumer Law - Medical Negligence – Vicarious Liability of Hospital – Liability Modified – Supreme Court upheld the findings of negligence against the hospital and its doctor based on medical records and conduct – However, reduced the hospital’s liability from ₹15 lakhs to ₹10 lakhs in light of partial deposit already made and lack of expert evidence challenging standard of care – Doctor’s liability of ₹5 lakhs upheld, having already been paid [Paras 10–16].

Assessment of Compensation – Death of Young Graduate – Quantum Partially Reduced – The deceased was 27 years old, a B.Tech graduate, working in a factory and supporting his family – NCDRC awarded ₹20 lakhs (₹15L hospital + ₹5L doctor) – Court acknowledged justification but held ₹10 lakhs (already deposited with interest) as adequate compensation from hospital in present circumstances [Paras 13–15].

Burden of Proof – Medical Literature and Expert Testimony – Absence of Direct Medical Expert Evidence – Court noted that while the hospital submitted literature supporting its procedures, no expert deposed to explain the application of that literature to the facts – This justified upholding negligence findings but supported reduction of compensation quantum [Paras 3–5].

Final Decision – Appeals Partly Allowed – Negligence Findings Affirmed – Compensation by Hospital Fixed at ₹10 Lakhs Plus Interest – Doctor’s Compensation of ₹5 Lakhs Already Complied – Balance directed to be disbursed to complainant on application to Registrar [Paras 15–17].

Criminal Law - Cruelty to Woman – Section 498A IPC – Conviction Maintained – Appellants convicted for mentally and physically abusing deceased, who later self-immolated – Dying declaration ruled out dowry angle but confirmed cruelty – Conviction upheld by Supreme Court as based on concurrent findings of fact by Sessions Court and High Court [Paras 2–6].

Probation of Offenders Act – Non-Consideration by Courts Below – Matter Remitted – Neither Sessions Court nor High Court considered release on probation under Section 4 of the Probation Act or Section 360 CrPC – Court held such consideration mandatory where applicable – Omission held to result in failure of justice [Paras 10–14, 26–28].

Applicability of Probation Act in Tamil Nadu – Confirmed – Based on precedent (State v. A. Parthiban) the Court affirmed that the Probation Act has been in force in Tamil Nadu since 1964 – Non-obstante clause in Section 4 overrides Section 360 CrPC [Paras 19–20, 26].

Benefit of Probation – Judicial Duty to Consider – Remand for Limited Reconsideration – Court clarified that release on probation is not a right, but when statutory criteria are fulfilled, courts must consider it and provide reasons if denied – Matter remitted to High Court to obtain probation officer’s report and decide accordingly [Paras 28–31].

Decision – Conviction Affirmed – Sentence Referred Back – Appellants not required to surrender till High Court decides probation application – Supreme Court commended assistance of amicus [Paras 31–35].
 

Criminal Law - Juvenile Justice Act – Quashing - Applicability of Section 75 – Actual Charge or Control Requirement – Charge Quashed – The appellant, Chairman of the Managing Committee of a school, was summoned under Section 75 of the JJ Act for failure to install CCTV cameras as per Guidelines issued by the Directorate of Education following an incident of sexual assault of a 4-year-old student by another minor – Held: For Section 75 to apply, it must be shown that the person had "actual charge" or "control" over the child – Mere administrative control over the institution does not amount to control over every student – Summoning order and High Court’s confirmation thereof quashed [Paras 7–9].

Criminal Liability – Role of Moral vs. Legal Responsibility – No Presumption of Criminal Control – It was argued that the appellant was morally responsible as Chairman – Court held moral responsibility is irrelevant unless legal control or actual charge over the child is established under the statutory framework – Moral responsibility cannot substitute for the statutory requirement under criminal law [Para 8].

Criminal Procedure – Summoning of Accused – Legal Prerequisite – Summons Not Sustainable – Where foundational requirements of the statute are not met, issuance of process against an individual is not justified – Summons issued by Special Court and affirmed by High Court found to be unsustainable and liable to be set aside [Para 9].

Decision – Appeal Allowed – Summons and High Court order quashed – Clarified that findings are limited to the appellant and shall not affect proceedings against other accused before Special Court [Paras 9–10].

Criminal Law – Murder – Appeal Against Acquittal - Dying Declarations – Non-compliance with Section 313 CrPC – Acquittal Upheld – The Supreme Court held that the prosecution’s failure to put the contents of the dying declarations to the accused during examination under Section 313 CrPC prejudiced the accused – As such, the declarations could not be relied upon for conviction – Further remand to rectify this defect after 14 years would cause undue prejudice – Appeals dismissed [Paras 16–23, 27].

Minor Witness – Competency of Child Witness – Procedural Lapse – The minor son of the deceased, who was presented as an eyewitness, was not subjected to preliminary questioning by the Trial Court to assess competence – Major contradictions in testimony led the Court to hold the evidence unreliable – Testimony not considered safe to rely on for conviction [Paras 10–14].

Contradictory Evidence – Medical Evidence and Dying Declarations – Burn Injuries on Co-Accused and Accused – The prosecution failed to explain injuries on the co-accused who later died and the accused who sustained 20% burns – This weakened the prosecution case and added to reasonable doubt about their role in the incident [Paras 24–25].

Appeal Against Acquittal – Judicial Review – Principles Reiterated – The Court reiterated that if the High Court’s view is a possible one based on evidence, even if another view is possible, the acquittal should not be interfered with – High Court's decision upheld despite some differences in interpretation [Paras 26–27].

Judicial Directions – Compliance with Section 313 CrPC – Procedural Safeguards Suggested – The Court directed that High Courts must verify the adequacy of Section 313 statements at the appellate stage to prevent prejudice and suggested trial courts seek assistance from counsels to ensure proper questioning under Section 313 CrPC [Para 28].

Decision – Appeals dismissed – Acquittal confirmed – No interference warranted as prosecution failed to establish guilt beyond reasonable doubt due to procedural and evidentiary lapses [Para 30].
 

Civil Law - Deemed Conveyance – Jurisdiction of Competent Authority under MOFA – Scope Limited – Upheld - Competent Authority under Section 11(3) of MOFA granted deemed conveyance over entire plot including area allotted to appellant – Held: Authority can issue certificate of deemed conveyance but cannot conclusively adjudicate title – Parties may seek civil remedy for title disputes [Paras 20-22, 37(ii)].

Leasehold Rights – Protection under Deemed Conveyance – Condition Imposed - Although deemed conveyance granted in favour of co-operative society, the certificate mandated execution of perpetual lease in favour of appellant in respect of distinct sub-plot – Held: Such condition valid and binding in light of deed of dissolution and lease agreement – Appellant's rights as perpetual lessee upheld [Paras 34-36].

Competent Authority – Summary Nature of Proceedings – No Cross-examination Permitted – Limited Adjudicatory Role - Proceedings under MOFA are quasi-judicial but summary in nature – Authority is not to conclusively decide complex title disputes – Writ interference discouraged unless order is manifestly illegal [Paras 19-21, 37(i)-(iii)].

Registering Officer – No Power to Revisit Certificate – Limited Role - Registrar under Section 11(5) of MOFA cannot review merits of deemed conveyance certificate – May refuse registration only if procedural or statutory preconditions unmet (e.g., consent, stamp duty, injunction) – Role confined to registration compliance [Paras 22-23, 37(iv)].

Final Decision – Appeal Dismissed – Appellant’s Rights Preserved - Supreme Court upheld High Court and Competent Authority’s orders – Appellant’s leasehold rights in “Arun plot” protected and remain unaffected – Civil suit remedy preserved for title adjudication [Paras 36, 38].

Land Acquisition – Compensation Determination Date – Section 26(1) Proviso RFCTLARR Act – Appeal Allowed - The High Court fixed market value as on 01.01.2014, the date of RFCTLARR Act’s commencement – Held: This is contrary to Section 26(1) proviso which mandates that compensation must be determined with reference to the date of Notification under Section 11 – Such notification not yet issued; hence fixing an earlier date is unlawful and prejudicial [Paras 2, 5, 9–14].

Utilization Without Acquisition – State’s Admission – Acquisition Pending - State admitted unauthorized use of 0-11-41 ha land without initiating acquisition or paying compensation – Held: Compensation must be based on lawful process commencing with a valid Section 11 Notification – Appellant entitled to compensation as per rates on the notification date when issued [Paras 4–6, 11].

Statutory Interpretation – Use of “Shall” in Section 26 – Legislative Mandate Binding - The Court reiterated that use of the word “shall” in the proviso reflects the mandatory nature of the requirement – Judicial discretion cannot override explicit statutory provision – No deviation permissible unless statute so allows [Para 9].

Final Decision – Appeal Allowed – High Court Judgment Set Aside – Direction to Follow Section 11 Notification Date - Supreme Court set aside the High Court order dated 21.08.2024 and directed that compensation be calculated as per the date of the future Notification under Section 11 of RFCTLARR Act, 2013 [Paras 13–14].

Criminal Law - Suspension of Sentence – Section 389 CrPC – Scope and Judicial Discipline – High Court Order Set Aside - The High Court suspended the sentence of the convict under POCSO on the ground of doubtful age of victim without conclusively reversing the trial court's finding – Held: Suspension of sentence under Section 389 requires judicial restraint and cannot pre-empt trial court findings unless clearly unsustainable – High Court acted beyond its remit [Paras 6–9].

Victim’s Age – Trial Court Finding Final Till Overturned – Suspension Unjustified - Trial Court had convicted the accused based on established minor status of victim – Held: Until overturned in appeal, the trial court’s finding must be respected – Grant of suspension based on speculative doubt over age cannot be sustained [Para 9].

Societal Interests and Sentence – Balancing Test – Supreme Court Caution - The Court reaffirmed the balance between rights of the convict and societal interests, especially in serious offences against children – Held: Suspension of a 20-year sentence in such a case does not serve public interest or the cause of justice [Paras 9–10].

Final Decision – Appeal Allowed – Suspension Revoked – Surrender Ordered - Supreme Court set aside the High Court's order of sentence suspension – Directed the convict to surrender forthwith – Liberty granted to approach High Court for bail if appeal not heard within 18 months [Paras 10–11].