Income Tax - Advance Tax - Liability to Pay - Civil Appeals addressing whether interest under Section 234B can be levied on tax calculated based on book profits under Section 115JA of the Income Tax Act, 1961 - Whether advance tax was payable on book profits under Section 115JA. [Paras 1-10]

Provisions Interpretation - Sections 115JA and 115JB - Held - Specific provisions for MAT (Minimum Alternate Tax) companies under Sections 115JA and 115JB do not exclude the applicability of Sections 234B and 234C - MAT companies liable to pay advance tax and interest under Sections 234B and 234C in case of defaults. [Paras 7-10]

Conflict of Judgments - Kwality Biscuits Case - Karnataka High Court's judgment in Kwality Biscuits Ltd. (2000) not applicable - Differentiation by subsequent judgment in Jindal Thermal Power Co. Ltd. (2006) - Section 115JB a self-contained code. [Paras 9-10]

Decision - Appeals by Revenue Allowed - Assessee's failure to pay advance tax under MAT provisions incurs interest under Sections 234B and 234C - CBDT Circular No. 13/2001 non-applicable to MAT companies - Interest levied justified. [Para 10]

Motor Vehicles Act - Accident Arising Out of Use of Motor Vehicle - Civil Appeal against High Court decision allowing compensation for victims of a fire and explosion following a road accident involving a petrol tanker - Supreme Court upholds High Court’s decision based on precedent.

Interpretation of 'Use of Motor Vehicle' - Held - Explosion and fire in the petrol tanker resulting from an earlier road accident constitute an accident arising out of the use of the motor vehicle - Prior Supreme Court judgment in Shivaji Dayanu Patil applied.

Binding Nature of Precedents - Held - Tribunal must follow Supreme Court's interpretation when facts remain unchanged - Supreme Court’s decision in Shivaji Dayanu Patil is binding and conclusive on similar facts.

Decision: Appeal dismissed, affirming High Court’s judgment granting compensation to the victims.

Criminal Law - Conviction and Sentence Modification - Criminal Appeal against High Court's order converting acquittal to conviction under Section 302 IPC - Incident involving a drunken quarrel where the appellant inflicted a fatal blow with a spade on the deceased - Supreme Court held that the act lacked premeditated intent to kill, thereby warranting conviction under Section 304 Part II IPC instead of Section 302 IPC - Sentence reduced to five years of rigorous imprisonment with benefit of period already undergone - High Court's judgment modified accordingly. [Paras 1-11]

Analysis of Intent and Circumstances - Evaluation of evidence from eye-witnesses and extra-judicial confessions - Held - Evidence established the occurrence of the quarrel and subsequent fatal blow - Accused acted under circumstances of removing a drunken and adamant individual from his house, resulting in an unintended fatal injury - Supreme Court emphasized the absence of premeditated intent to murder, altering the conviction to culpable homicide not amounting to murder under Section 304 Part II IPC. [Para 9-10]

Decision - Modification of Conviction and Sentence - Appeal partly allowed by modifying the conviction from Section 302 IPC to Section 304 Part II IPC - Sentence of rigorous imprisonment for five years awarded with deduction for the period already undergone - High Court's conviction under Section 302 IPC set aside, modifying it under Section 304 Part II IPC. [Para 11]

Criminal Law – Insanity Plea – Appeal against conviction under Section 302 IPC and Section 27 of the Arms Act – Appellant claimed insanity at the time of the offence, invoking Section 84 IPC – The trial court and High Court rejected the insanity plea, leading to the appeal before the Supreme Court – The Supreme Court examined whether the appellant was of unsound mind at the time of the incident – Held that the evidence did not support the appellant’s claim of insanity, and the plea of legal insanity under Section 84 IPC was not established – Conviction and sentence upheld. [Paras 1-13]

Legal Insanity vs. Medical Insanity – Analysis – Held – Differentiation between legal and medical insanity – Legal insanity must be established to absolve criminal liability – Appellant’s behavior post-offence indicated awareness of wrongdoing – Medical evidence insufficient to prove incapacity to understand nature of act at the time of crime – Prescriptions and mental health records did not conclusively prove unsoundness of mind at the crucial time. [Para 9-11]

Onus of Proof – Section 105 Evidence Act – Held – Burden of proving insanity lies on the accused – Proof required by preponderance of probabilities, not beyond reasonable doubt – Appellant failed to discharge this burden – Evidence showed appellant knew the nature and wrongness of the act. [Para 10]

Decision – Conviction and Sentence Upheld – Supreme Court dismisses appeal – Reiterates requirement for clear and convincing evidence to establish legal insanity – Finds no merit in the appellant’s plea, upholding the conviction under Section 302 IPC and Section 27 of the Arms Act. [Para 13]

Criminal Law - Conviction and Sentence Modification - Criminal Appeal against High Court's order converting acquittal to conviction under Section 302 IPC - Incident involving a drunken quarrel where the appellant inflicted a fatal blow with a spade on the deceased - Supreme Court held that the act lacked premeditated intent to kill, thereby warranting conviction under Section 304 Part II IPC instead of Section 302 IPC - Sentence reduced to five years of rigorous imprisonment with benefit of period already undergone - High Court's judgment modified accordingly. [Paras 1-11]

Analysis of Intent and Circumstances - Evaluation of evidence from eye-witnesses and extra-judicial confessions - Held - Evidence established the occurrence of the quarrel and subsequent fatal blow - Accused acted under circumstances of removing a drunken and adamant individual from his house, resulting in an unintended fatal injury - Supreme Court emphasized the absence of premeditated intent to murder, altering the conviction to culpable homicide not amounting to murder under Section 304 Part II IPC. [Para 9-10]

Decision - Modification of Conviction and Sentence - Appeal partly allowed by modifying the conviction from Section 302 IPC to Section 304 Part II IPC - Sentence of rigorous imprisonment for five years awarded with deduction for the period already undergone - High Court's conviction under Section 302 IPC set aside, modifying it under Section 304 Part II IPC. [Para 11]

Criminal Law – Insanity Plea – Appeal against conviction under Section 302 IPC and Section 27 of the Arms Act – Appellant claimed insanity at the time of the offence, invoking Section 84 IPC – The trial court and High Court rejected the insanity plea, leading to the appeal before the Supreme Court – The Supreme Court examined whether the appellant was of unsound mind at the time of the incident – Held that the evidence did not support the appellant’s claim of insanity, and the plea of legal insanity under Section 84 IPC was not established – Conviction and sentence upheld. [Paras 1-13]

Legal Insanity vs. Medical Insanity – Analysis – Held – Differentiation between legal and medical insanity – Legal insanity must be established to absolve criminal liability – Appellant’s behavior post-offence indicated awareness of wrongdoing – Medical evidence insufficient to prove incapacity to understand nature of act at the time of crime – Prescriptions and mental health records did not conclusively prove unsoundness of mind at the crucial time. [Para 9-11]

Onus of Proof – Section 105 Evidence Act – Held – Burden of proving insanity lies on the accused – Proof required by preponderance of probabilities, not beyond reasonable doubt – Appellant failed to discharge this burden – Evidence showed appellant knew the nature and wrongness of the act. [Para 10]

Decision – Conviction and Sentence Upheld – Supreme Court dismisses appeal – Reiterates requirement for clear and convincing evidence to establish legal insanity – Finds no merit in the appellant’s plea, upholding the conviction under Section 302 IPC and Section 27 of the Arms Act. [Para 13]

Criminal Law - Nature of Offence - Conviction and Sentencing - Appeal against High Court's affirmation of conviction under Section 302 IPC and life imprisonment - Incident arising from sudden provocation due to appellant finding his sister with the deceased at an odd hour - Appellant assaulted the deceased with a knife causing fatal injuries - Prosecution relied on two dying declarations of the deceased, both attributing the injuries to the appellant - Eyewitnesses, including the appellant's sister, turned hostile - Conviction based on dying declarations and medical evidence - Supreme Court found the act was not premeditated but a result of sudden provocation - Held: Conviction altered from Section 302 IPC to Section 304 Part-I IPC, sentencing the appellant to ten years rigorous imprisonment. [Paras 1-17]

Role of Provocation and Intention in Determining Offence - Analysis - Held - Appellant's actions lacked premeditation; injuries inflicted due to sudden loss of self-control - Weapon used was not applied with full force; indicating absence of intent to kill - Circumstantial evidence supported alteration of conviction from murder to culpable homicide not amounting to murder under Section 304 Part-I IPC. [Paras 10-17]

Decision - Alteration of Conviction and Sentence - Conviction under Section 302 IPC altered to Section 304 Part-I IPC - Appellant sentenced to ten years rigorous imprisonment - Appeal partly allowed. [Paras 17]

Criminal Law – Conviction under Section 306 IPC in absence of charge – Criminal Appeal against High Court’s judgment converting conviction from Section 304B IPC (dowry death) to Section 306 IPC (abetment of suicide) – Supreme Court held High Court justified in altering conviction due to lack of evidence of dowry demands – Mere omission or defect in framing charge does not invalidate conviction if evidence substantiates the offense – Appeal dismissed. [Paras 10-13]

Dowry Death vs. Abetment of Suicide – Analysis – Held – Distinct nature of offenses under Sections 304B and 306 IPC clarified – High Court correctly identified lack of dowry demand, constituting harassment as the cause for suicide – Presumption under Section 113B of Evidence Act not applicable without dowry-related harassment. [Paras 10-11]

Charge Framing and Conviction – Legal Principles – Held – Conviction under Section 306 IPC upheld despite absence of specific charge – Sections 221(1), 221(2) CrPC invoked to validate conviction based on evidence – No failure of justice found in High Court’s judgment. [Paras 12-13]

Decision:

The Supreme Court dismissed the appeal, affirming the High Court's judgment converting the conviction from Section 304B IPC to Section 306 IPC, citing sufficient evidence of harassment leading to suicide and upholding the principles under Sections 221(1) and 221(2) of CrPC regarding charge framing.

Criminal Law – Conviction and Sentencing – Assault and Public Humiliation – Tribal Rights – Assault and Public Humiliation of Tribal Woman – Appeal against Conviction and Sentence- The appellants were convicted by the Additional Sessions Judge, Ahmednagar, for various offences under IPC and the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, for assaulting and publicly humiliating a tribal woman, Nandabai, by stripping her naked and parading her on the village road. The High Court upheld the IPC convictions but acquitted them under the SC/ST Act on technical grounds, increasing the fine to be paid to the victim. The Supreme Court, while upholding the IPC convictions, criticized the High Court’s acquittal under the SC/ST Act and expressed surprise at the leniency of the punishment, noting the gravity of the offence and the historical oppression of tribals. [Paras 1-16]

Recognition of Historical Injustice Against Tribals – The Court emphasized the historical and ongoing marginalization of tribals in India, noting their status as original inhabitants and the atrocities they have faced over centuries. The Court underscored the need for societal respect and special constitutional protections to uplift the tribals. The judgment discussed the anthropological and historical context of tribal communities, their contributions, and the need for transformative change in the societal mindset towards them. [Paras 17-40]

Decision – Dismissal of Appeal- The Supreme Court dismissed the appeal, maintaining the IPC convictions and expressing the necessity for harsh punishments in cases of such heinous acts against vulnerable communities. The judgment highlighted the inadequacy of formal equality and the importance of substantive equality, calling for societal transformation to correct historical wrongs against tribal communities. [Paras 41]