Education Law - Affiliation and Recognition - National Council for Teacher Education Act, 1993 - Section 14 and 16 - Civil Appeals challenging denial of affiliation and examination permissions for students admitted in various academic sessions - Supreme Court examines validity of admissions prior to recognition and the role of affiliation by the examining body - Held - Admissions made before NCTE recognition are invalid - Institution must obtain both recognition from NCTE and affiliation from the examining body before admitting students - Directions given for regularizing admissions for specific batches subject to eligibility criteria. [Paras 1-23]

Recognition vs. Affiliation - Purpose and Distinction - Analysis - Held - Recognition by NCTE is a prerequisite for affiliation by the examining body - Recognition allows an institution to offer a course, while affiliation permits students to take public examinations - Examining body retains discretion to ensure compliance with its criteria despite NCTE recognition - Automatic affiliation not implied by NCTE recognition. [Paras 15-17]

Admissions and Examinations - Regularization of Admissions - Supreme Court orders regularization of admissions for 2002 and 2003 batches - Admissions made in 1999 without NCTE recognition deemed invalid - Appeals for 2004-2006 and 2005-2007 academic sessions dismissed as infructuous - Directions for fresh admission of 1999 students meeting eligibility criteria without age restriction. [Paras 12-14, 18-19, 21-23]

Decision - Appeals Partially Allowed and Partially Dismissed - Supreme Court dismisses appeals regarding 1999 admissions and 2004-2007 sessions - Allows regularization and result declaration for 2002 and 2003 batches subject to eligibility - Sets aside High Court's direction for damages to students admitted in 2002 and 2003 - Fresh admissions for 1999 students directed without additional fees and age restriction. [Paras 23]

Employment Law - Termination and Reinstatement – Civil Appeal against orders of Tribunal and High Court directing reinstatement and back wages to the Respondent – Respondent appointed for a fixed term of three years – Termination before completion of term challenged on grounds of stigmatic order – Supreme Court finds appointment period ended before Tribunal’s order – No reinstatement beyond expiry of the fixed term – Orders modified to deem Respondent in service up to term end only – No back wages awarded considering Respondent’s conduct and employer’s financial status. [Paras 1-6]

Effect of Stigmatic Termination – Analysis – Held – Reference to unauthorized absence not examined for stigmatic effect as fixed-term appointment ended before Tribunal’s order – Relief beyond fixed-term appointment not justified – Tribunal and High Court orders modified accordingly. [Paras 5-6]

Award of Back Wages – Discretion of Court – Analysis – Held – Conduct of employee and financial status of employer are relevant factors in awarding back wages – In this case, conduct of Respondent and financial status of Appellant do not justify back wages – No back wages awarded. [Para 6]

Decision – Modification of Orders – Supreme Court modifies Tribunal and High Court orders to limit Respondent’s service period to end of fixed term and deny back wages – Appeal allowed in these terms. [Para 6]

Land Acquisition - Res Judicata and Constructive Res Judicata – Civil Appeal against High Court decision dismissing challenge to land acquisition – Appellant's repeated challenges to acquisition of land for Bangalore-Mysore Infrastructure Corridor Project – Supreme Court upholds previous decisions validating acquisition – Doctrine of Res Judicata applies to prevent re-litigation – Appeal dismissed with costs for abuse of court process. [Paras 1-50]

Principle of Res Judicata – Analysis – Held – Doctrine of Res Judicata ensures finality in litigation and prevents abuse of judicial process – Relitigation of issues previously adjudicated is barred – Court emphasizes public policy considerations and the necessity of concluding litigation to maintain judicial integrity and fairness. [Paras 14-21]

Application of Constructive Res Judicata – Examination – Held – Appellant barred from raising issues which could have been litigated in earlier proceedings – The repeated attempts to challenge the acquisition constitute abuse of process – Principles of Res Judicata extend to writ petitions to prevent re-agitation of decided issues. [Paras 19-27]

Decision – Dismissal of Appeal with Costs – Supreme Court dismisses appeal, imposes costs on appellant for misuse of judicial process – State Government directed to complete the infrastructure project without delay – Reaffirms that land acquisition for public purposes should not be impeded by frivolous litigation. [Paras 30-50]

Criminal Law - Disparaging Remarks Against Judicial Officer – Criminal Appeal against High Court order – Appellant, a judicial officer, directed an application under Section 156(3) CrPC to be registered as a complaint and proceeded under Section 200 CrPC – High Court made severe disparaging remarks against the appellant for this decision – Supreme Court holds that High Court's remarks were unjustified and not warranted – Higher courts should observe restraint and avoid using strong language against lower judiciary – Remarks expunged. [Paras 1-13]

Judicial Discretion - Registration of Complaint – Analysis – Held – Judicial officer exercised discretion as per law, calling for a police report and considering affidavits and documents before deciding to proceed under Section 200 CrPC – High Court should not substitute its discretion for that of the lower court unless judicial discretion is shown to be arbitrary or perverse – Supreme Court finds no arbitrariness or perversity in the appellant’s order. [Paras 9-11]

High Court Criticism of Lower Courts – Guidelines – Analysis – Held – Disparaging remarks against lower judiciary can demoralize judicial officers and diminish public confidence in the judiciary – Advised that higher courts should use alternative measures to address perceived judicial errors without public criticism – Supreme Court emphasizes need for judicial restraint. [Para 11]

Decision – Expunction of Remarks – Supreme Court expunges disparaging remarks made by the High Court against the appellant – Directions of the High Court not challenged in appeal remain unaltered – Appeal allowed to the extent of expunging remarks. [Paras 13-14]

Criminal Law - Double Jeopardy - Article 20(2) of the Constitution and Section 300(1) of CrPC - Criminal Appeal against High Court order convicting the appellant under Section 420 IPC - Appellant contends previous conviction under Section 138 NI Act bars subsequent prosecution under Section 420 IPC on the same facts - Supreme Court finds that while Article 20(2) Constitution bars punishment for the same offence, Section 300(1) CrPC extends to barring trials for different offences on the same facts - Held prosecution under Section 420 IPC is barred - Appeal allowed and High Court judgment set aside. [Paras 1-6]

Interpretation of Statutes - Article 20(2) Constitution vs. Section 300(1) CrPC - Analysis - Held - Article 20(2) Constitution restricts double punishment for same offence, whereas Section 300(1) CrPC prevents trial for same facts leading to different charges - In present case, different offences (Section 138 NI Act and Section 420 IPC) arise from same facts, triggering Section 300(1) CrPC protection - High Court erred in allowing subsequent prosecution under Section 420 IPC - Judgment set aside. [Paras 4-6]

Decision - Appeal Allowed - High Court Judgment Set Aside - Prosecution under Section 420 IPC Barred - Supreme Court holds prosecution under Section 420 IPC on same facts as prior Section 138 NI Act conviction violates Section 300(1) CrPC - Appeal allowed - High Court judgment set aside. [Para 6]

Criminal Law - Framing of Charges - Sections 227 and 228 CrPC - Criminal Appeal challenging High Court's adverse observations against the appellant for not framing a charge under Section 302 IPC - Appellant's order framed charges under Sections 304 and 323 IPC instead - High Court noted the appellant's failure to provide reasons for not framing the higher charge - Supreme Court finds such a bald order without reasons raises doubts about the bona fides - Held that some minimum reasons are necessary for dropping or diluting a charge - Appeal dismissed. [Paras 1-26]

Judicial Accountability - Adverse Remarks - Review of Judicial Orders - Held - Adverse observations by High Court were necessary in light of the appellant's order lacking sufficient reasoning for not framing the charge under Section 302 IPC - Appellant's career review and subsequent denial of selection grade justified based on service record - Supreme Court emphasizes necessity for judicial orders to reflect adequate reasoning to ensure transparency and accountability - Appeal dismissed. [Paras 18-26]

Decision - Appeal Dismissed - Adverse Observations and Career Review Justified - Supreme Court upholds High Court's observations and subsequent career review of the appellant - Reiterates the need for judicial orders to provide sufficient reasons, especially when diluting or dropping serious charges. [Paras 24-26]

Criminal Law - Conviction Based on Circumstantial Evidence - Sections 376, 302, and 392 IPC - Appeal against High Court judgment confirming death sentence - Conviction based on identification by eyewitnesses, forensic evidence, recovery of stolen items, and extra-judicial confession - Supreme Court finds that evidence forms a complete chain pointing to appellant's guilt - Appeal dismissed - Death sentence confirmed. [Paras 1-57]

Identification Evidence - Validity of Test Identification Parade - Reliability of Identification by Witnesses - Identification by minor eyewitness corroborated by other witnesses - Supreme Court holds identification in Test Identification Parade valid despite appellant's claim of photograph publication - Conviction upheld based on consistent and credible identification. [Paras 29-33, 42-47]

Forensic Evidence - Fingerprint Evidence - Procedural Validity - Fingerprint of appellant matched with prints found on crime scene - Procedure for taking fingerprints under Identification of Prisoners Act upheld - Supreme Court rejects challenge to procedural validity and accepts fingerprint evidence as conclusive. [Paras 13-14, 54]

Sentencing - Death Penalty - Rarest of Rare Case - Supreme Court upholds death sentence considering extreme depravity, absence of mitigating factors, and appellant's history of similar offences - Death sentence confirmed as necessary for deterrence and societal protection. [Paras 18-23, 56-57]

Decision - Appeal Dismissed - Death Sentence Confirmed - Supreme Court dismisses appeal against High Court judgment - Death sentence for offences under Sections 302, 376, and 392 IPC confirmed - Appellant's actions deemed as falling within the category of rarest of rare cases. [Paras 55-57]

Criminal Law - Double Jeopardy - Article 20(2) of the Constitution and Section 300(1) of CrPC - Criminal Appeal against High Court order convicting the appellant under Section 420 IPC - Appellant contends previous conviction under Section 138 NI Act bars subsequent prosecution under Section 420 IPC on the same facts - Supreme Court finds that while Article 20(2) Constitution bars punishment for the same offence, Section 300(1) CrPC extends to barring trials for different offences on the same facts - Held prosecution under Section 420 IPC is barred - Appeal allowed and High Court judgment set aside. [Paras 1-6]

Interpretation of Statutes - Article 20(2) Constitution vs. Section 300(1) CrPC - Analysis - Held - Article 20(2) Constitution restricts double punishment for same offence, whereas Section 300(1) CrPC prevents trial for same facts leading to different charges - In present case, different offences (Section 138 NI Act and Section 420 IPC) arise from same facts, triggering Section 300(1) CrPC protection - High Court erred in allowing subsequent prosecution under Section 420 IPC - Judgment set aside. [Paras 4-6]

Decision - Appeal Allowed - High Court Judgment Set Aside - Prosecution under Section 420 IPC Barred - Supreme Court holds prosecution under Section 420 IPC on same facts as prior Section 138 NI Act conviction violates Section 300(1) CrPC - Appeal allowed - High Court judgment set aside. [Para 6]

Criminal Law - Framing of Charges - Sections 227 and 228 CrPC - Criminal Appeal challenging High Court's adverse observations against the appellant for not framing a charge under Section 302 IPC - Appellant's order framed charges under Sections 304 and 323 IPC instead - High Court noted the appellant's failure to provide reasons for not framing the higher charge - Supreme Court finds such a bald order without reasons raises doubts about the bona fides - Held that some minimum reasons are necessary for dropping or diluting a charge - Appeal dismissed. [Paras 1-26]

Judicial Accountability - Adverse Remarks - Review of Judicial Orders - Held - Adverse observations by High Court were necessary in light of the appellant's order lacking sufficient reasoning for not framing the charge under Section 302 IPC - Appellant's career review and subsequent denial of selection grade justified based on service record - Supreme Court emphasizes necessity for judicial orders to reflect adequate reasoning to ensure transparency and accountability - Appeal dismissed. [Paras 18-26]

Decision - Appeal Dismissed - Adverse Observations and Career Review Justified - Supreme Court upholds High Court's observations and subsequent career review of the appellant - Reiterates the need for judicial orders to provide sufficient reasons, especially when diluting or dropping serious charges. [Paras 24-26]