Sex Workers – Committee Inclusion – The Union of India sought the removal of Durbar Mahila Samanwaya Samiti from a panel constituted by a previous order, citing the Samiti's advocacy for the decriminalization of sex work and the repeal of the Immoral Traffic (Prevention) Act, 1956. The Supreme Court rejected this request, recognizing the Samiti's valuable contributions to understanding the problems faced by sex workers [Paras 1-7].

Modification of Reference Terms – The second modification requested by the Union of India was to change the wording of a reference term that could be interpreted as encouraging sex work. The Court agreed to modify the wording to emphasize the dignity of sex workers in accordance with Article 21 of the Constitution, without encouraging prostitution [Paras 8-9].

Decision – Application partly allowed – Durbar Mahila Samanwaya Samiti to remain on the committee; the third reference term modified to: "Conditions conducive for sex workers to live with dignity in accordance with the provisions of Article 21 of the Constitution" [Paras 7-10].

Criminal Law – Murder Conviction – Appellant convicted for the murder of his first wife, Sita Devi, with a knife, her body later found in a decomposed state in Gorai Creek – Conviction based on circumstantial evidence including the last seen theory, recovery of the body and weapon, and bloodstained clothes – Appellant's motive established due to frequent domestic disputes – Supreme Court upheld the conviction, citing established principles for circumstantial evidence, finding no missing link in the chain of events [Paras 1-14].

Circumstantial Evidence – Chain of Circumstances – Court reiterated principles for appreciating circumstantial evidence, emphasizing that the established circumstances should lead solely to the guilt of the accused, excluding any other hypothesis – Identification of the body and the appellant’s failure to explain the absence of his wife from the matrimonial home were crucial [Paras 8-13].

Section 313 CrPC – Examination of Accused – Appellant's explanation for his wife's disappearance was insufficient – Court highlighted the significance of the accused’s duty to provide an adequate explanation when the facts are peculiarly within his knowledge [Para 14].

Decision – Appeal dismissed – Conviction and life sentence affirmed – Court emphasized the established motive, the appellant’s actions post-crime, and the consistency of the circumstantial evidence in leading to the appellant’s guilt [Para 15].

Land Reforms and Mining Lease – Dispute over mining lease recommendations by the State Government and subsequent withdrawal of those recommendations – Bihar Land Reforms Act and Bihar Reorganisation Act applied – Central Government's approval necessary for state decisions on mineral exploitation – Supreme Court examined statutory provisions and procedural compliance, emphasizing adherence to proper legal channels for granting and withdrawing mining leases [Paras 1-13].

Mines and Minerals Development – Applicability of Mines and Minerals (Development and Regulation) Act and corresponding rules – Legal scrutiny of notifications reserving mineral-rich areas for public sector exploitation – Court assessed validity of notifications from 1962, 1969, and 2006, considering central-state legislative competence and federal structure principles – Affirmed that state reservations need to comply with central statutes and require appropriate approvals [Paras 14-26].

Decision – Appeals were resolved with directions for adherence to statutory norms and proper approvals for mining leases – Legal principles reasserted on central control over mineral regulation and development, as declared by Parliament under the Constitution [Paras 27-41].

Criminal Law – Murder vs. Culpable Homicide – Appeal challenging conviction under Section 302 IPC for murder of the deceased – Appellant argued that the incident occurred due to sudden provocation and without premeditation – Supreme Court analyzed the distinction between ‘murder’ and ‘culpable homicide not amounting to murder’ under Sections 299 and 300 IPC – Court considered the heated exchange, immediate reaction, and lack of prior enmity – Altered conviction to Section 304 Part I IPC, reducing sentence to 10 years rigorous imprisonment and a fine [Paras 1-31].

Distinction between Sections 299 and 300 IPC – Court elaborated on the definitions and differences between ‘culpable homicide’ and ‘murder’ – Highlighted that all murders are culpable homicides but not vice versa – Provided guidelines for determining the applicable section based on the intention, knowledge, and circumstances of the act [Paras 10-19].

Sudden Provocation – Incident occurred due to a dispute over a ladauri (boundary marker) – Heated argument and physical altercation led to the appellant shooting the deceased – No premeditation or previous animosity between the parties – Court found that the act was committed in a sudden heat of passion [Paras 24-27].

Decision – Appeal partially allowed – Conviction under Section 302 IPC altered to Section 304 Part I IPC – Appellant sentenced to 10 years rigorous imprisonment and a fine of Rs. 10,000, in default to undergo simple imprisonment for one month – Judgment modified accordingly [Paras 31].

Criminal Law – Murder Conviction – Appellant convicted for the murder of Kuppa based on dying declaration, eye-witness testimony, and forensic evidence – Dying declaration recorded by police officer after doctor certified the deceased was fit to give statement – Supreme Court upheld the conviction, finding no undue delay in FIR registration and relying on the dying declaration as credible evidence [Paras 1-12].

Dying Declaration – Admissibility and Evidentiary Value – Court emphasized the reliability of dying declarations, particularly when made voluntarily and corroborated by other evidence – Discussed principles from previous judgments, asserting that a dying declaration can form the sole basis for conviction if found trustworthy and credible [Paras 12-17].

Delay in Lodging FIR – Incident occurred at 7:45 PM, FIR registered at 11:30 PM – Court found the delay reasonable given the circumstances, prioritizing immediate medical attention for the deceased over prompt FIR registration – No merit in the contention of inordinate delay [Paras 8-9].

Decision – Appeal dismissed – Conviction and life sentence affirmed – Court found no reason to interfere with concurrent findings of lower courts, emphasizing the clear and voluntary nature of the dying declaration and corroborative evidence provided by eyewitnesses and forensic reports [Paras 18].

Criminal Law – Murder Conviction – Appellant convicted for the murder of Sankar based on eye-witness testimony and medical evidence – Appellant argued delay in FIR and claimed injuries not attributed to him – Supreme Court upheld conviction, noting timely FIR registration and direct evidence linking appellant to the fatal injury [Paras 1-12].

Delay in FIR Registration – Incident occurred at 10:30 AM, FIR registered at 2:45 PM – Court found delay reasonable, given efforts to provide immediate medical attention to the deceased – Rejected appellant’s claim of undue delay [Paras 8-9].

Culpable Homicide vs. Murder – Appellant inflicted fatal injury on deceased with intent – Court rejected argument for reduction to Section 304 Part II IPC, citing premeditation and previous threats – Injury inflicted was severe, directly causing death [Paras 10-14].

Decision – Appeal dismissed – Conviction and life sentence under Section 302 IPC affirmed – Court found no merit in appellant’s claims, emphasized clear evidence of intent and fatal nature of injury caused by the appellant [Para 14].

Criminal Law – Dying Declarations – Appellant convicted for the murder of his wife based on multiple dying declarations – First declaration absolved the appellant, while subsequent declarations implicated him – Supreme Court examined the reliability of each declaration, focusing on voluntariness, corroborative evidence, and the circumstances under which each declaration was made – Upheld the conviction based on the credibility of the second and third declarations, which were consistent and supported by medical and eyewitness evidence [Paras 2-24].

Evidentiary Value of Multiple Dying Declarations – Court laid down principles for evaluating multiple dying declarations, emphasizing the need to consider which declarations are corroborated by other evidence, and the overall circumstances and fitness of the declarant – Found that the initial declaration was influenced by the presence of the appellant and his relatives, while the later declarations were made voluntarily and truthfully [Paras 21-24].

Decision – Appeal dismissed – Conviction and life sentence under Section 302 IPC affirmed – Court found no merit in appellant’s claims, emphasizing the reliability of the second and third dying declarations and the corroborative evidence supporting them [Paras 26].

Criminal Law – Murder Conviction – Appellant convicted for the murder of Ravi Kishore based on circumstantial evidence and corroborative testimonies – Incident arose from a confrontation where the deceased expressed intentions to marry the appellant's daughters, provoking the appellant to fatally attack him – Supreme Court upheld the conviction, citing consistent and credible evidence supporting the prosecution’s case despite hostile witnesses [Paras 1-18].

Circumstantial Evidence – Reliability and Corroboration – Despite key witnesses turning hostile, Court relied on corroborative evidence including forensic reports, witness statements, and the appellant’s failure to explain the presence of the deceased’s body in his courtyard – Detailed examination of 16 circumstantial facts linking the appellant to the crime, leading to a conviction [Paras 14-16].

Decision – Appeal dismissed – Conviction and life sentence under Section 302 IPC affirmed – Court found sufficient evidence to uphold the trial and High Court’s decisions, emphasizing the consistent and credible nature of the circumstantial evidence presented [Paras 18].

Essential Commodities Act – Seizure and Confiscation – Wheat seized from respondents' premises allegedly meant for black marketing – High Court ordered release of seized wheat without proper consideration of statutory provisions – Supreme Court criticized High Court's casual approach, remanded case for fresh consideration – Emphasized necessity of statutory compliance in seizure and confiscation matters [Paras 1-14].

Criminal Procedure – Section 451, 457 CrPC – Interim Release of Seized Property – High Court's order of releasing seized wheat criticized for lack of proper justification – Highlighted procedural impropriety in releasing property without clear ownership proof – Supreme Court underlined requirement for reasoned orders, particularly in cases of essential commodities [Paras 5-11].

Statutory Interpretation – Compliance with Essential Commodities Act – Emphasized statutory obligations under Sections 6-A and 6-E – Noted High Court's failure to adhere to legislative intent and procedural mandates – Importance of detailed judicial reasoning and adherence to statutory framework reiterated [Paras 9-10].

Decision: Appeals allowed – High Court’s orders dated 15.3.2011 and 29.4.2011 set aside – Case remanded to High Court for fresh consideration, emphasizing adherence to statutory provisions and proper judicial scrutiny – Interim order by Supreme Court to remain operative till disposal [Paras 12-14].