Criminal Law – Murder – Conspiracy – Acquittal – Accused convicted by Trial Court for murder based on motive, last seen theory, and recovery of incriminating material – High Court reversed conviction citing lack of reliable evidence, failure to prove motive, and inadmissibility of call detail records – Supreme Court upheld acquittal – Held: No reliable, cogent or admissible evidence was led to prove conspiracy or direct involvement of accused in the murder of deceased – Acquittal justified [Paras 3, 32-34, 38-41].

Circumstantial Evidence – Last Seen Theory – Reliability – Witnesses claimed to have seen deceased parking scooter outside accused’s house but informed police after more than a month – Conduct found unnatural – High Court rightly discarded their testimony – Supreme Court agreed with finding that prosecution failed to prove “last seen” circumstance beyond reasonable doubt [Paras 23-25].

Evidence – Recovery under Section 27 Evidence Act – Validity – Recovery of blood-stained chunni from accused’s house held inconsequential – No blood grouping done – House remained accessible till police visit – Recovery found unreliable and ineffective in linking accused to crime [Paras 26-27, 32].

Evidence – Electronic Evidence – Admissibility – Call Detail Records – Not supported by certificate under Section 65-B of Evidence Act – Based on handwritten note; scribe not examined – Held: Call detail records inadmissible and cannot be relied upon to prove conspiracy or contact between accused – High Court’s conclusion upheld [Paras 30-31].

Criminal Law – Motive – Land Dispute – Contradictory and improved statements – Alleged motive based on land dispute and threats found to be exaggerated and uncorroborated – Witness contradicted herself on material points – Held: Theory of motive unproved and not supported by substantive evidence [Paras 18-22, 34-35].

Appellate Jurisdiction – Interference with Acquittal – Scope – Reiterated: Acquittal can be reversed only if findings suffer from patent perversity, are based on misreading of evidence, or no other view is possible – Held: High Court’s view was reasonable and supported by record – No grounds for interference by Supreme Court [Paras 39-41].

Decision: Appeals dismissed – Acquittal confirmed – No infirmity found in High Court’s judgment warranting interference.

Criminal Law – Murder vs. Culpable Homicide – Accused (landowners) attacked complainant’s father and uncles during land measurement dispute using sticks, pike and spear – PW-1 (son/nephew of deceased) was sole eyewitness; PW-2 hostile – Medical evidence showed lacerated and contused wounds only; no incised injuries – Weapons used with blunt side – Just Knowledge – No Intention - Though Armed with Sharp Weapons, Only the Blunt Side Was Used - Court held deaths caused by accused established, but absence of intent to kill proved; only knowledge of likely death attributable – Conviction under Section 302 IPC not sustainable – Altered to Section 304 Part I IPC [Paras 7–15].

Eyewitness Testimony – Related Witness – Sole reliance on testimony of PW-1 (related witness) not unsafe where corroborated by medical evidence – PW-2 turned hostile, but prosecution case stood corroborated [Paras 7–10].

Medical Evidence – Nature of Injuries – Only blunt force injuries present; no use of sharp edge despite possession of sharp weapons – Consistent with PW-1’s deposition – Supports conclusion of culpable homicide not amounting to murder [Paras 8, 10–11].

Sentence – Appellants already undergone more than 12 years of imprisonment – Court held sentence already served sufficient to meet ends of justice – Ordered release forthwith if not required in any other case [Paras 15–16].

Decision: Appeal partly allowed – Conviction under Section 302 IPC set aside – Conviction modified to Section 304 Part I IPC – Sentence confined to period already undergone – Appellants directed to be released forthwith if not required in any other case.

Competition Law – Anti-Competitive Agreement – Section 3(3)(b) – Federation boycott – Kerala Film Exhibitors Federation (KFEF) found to have engaged in anti-competitive conduct by threatening distributors and boycotting Crown Theatre for dealing independently – CCI held KFEF and its office bearers guilty – Appeal against COMPAT’s order that set aside penalties on two office-bearers on natural justice grounds – Held: CCI’s notice dated 10.06.2015 satisfied legal requirements, and principles of natural justice were complied with – Penalties restored [Paras 1-3, 37-43, 68].

Due Process – Show-Cause Notice – Section 27 and Regulation 48 – Whether second show-cause notice is mandatory before imposition of penalty – Held: No requirement for separate penalty notice under the Act or Regulations – Furnishing of DG Report and oral hearing suffice – Appellate Tribunal erred in reading additional procedural safeguards into the statute [Paras 15, 35, 52-57].

Section 48 – Liability of Office Bearers – Federation deemed a company under Section 48 – President and General Secretary (Respondent Nos. 2 and 3) held liable for KFEF’s anti-competitive conduct – They failed to prove lack of knowledge or due diligence – Monetary penalties and behavioural remedies imposed – Directions disassociating them from KFEF restored [Paras 41-43, 64-66].

Proportionality – Doctrine of Proportionality – Penalties of 10% of average income not disproportionate – Behavioural remedy barring participation in KFEF’s governance for 2 years justified in light of repeat offences and prior penalty in Case No. 45/2012 – Held: Penalty not shocking or excessive – Consistent with legislative intent to make CCI an effective regulator unlike defunct MRTP Commission [Paras 47-51, 64-66].

Natural Justice – No Violation – DG Report named Respondent Nos. 2 and 3 as key decision-makers – Respondents were issued notice, given opportunity to reply, submit income documents, and were heard – COMPAT’s finding of procedural violation was incorrect – Violation of natural justice not established [Paras 39-41, 66-67].

Freedom of Association – Article 19(1)(c) – Challenge to personal liability of office-bearers under Article 19(1)(c) rejected – Reasonable restrictions under Article 19(4) justified to curb unethical and anti-competitive practices – CCI’s powers under Section 27 not unconstitutional [Para 67].

Decision: Appeal allowed – COMPAT’s order set aside insofar as it interfered with penalty and behavioural remedies – CCI’s full order dated 08.09.2015 restored – Disassociation of Respondent Nos. 2 and 3 from KFEF to take effect from 01.12.2025 for 2 years – Compliance to be reported within 3 months [Para 68].

Insolvency and Bankruptcy Code, 2016 – Resolution Plan – Concurrent Findings – Appeals under Section 62 lie only on a question of law – NCLT and NCLAT concurrently upheld JSW’s plan with minor modification regarding EBITDA – Held: Appeals not maintainable in absence of statutory grounds under Section 61 – Concurrent findings not to be disturbed unless perverse, arbitrary or contrary to statute [Paras 87-96].

IBC – Clause Permitting CoC to Extend Implementation Period – Validity – Clause authorising CoC to extend effective date of implementation by 66% majority not open-ended – No renegotiation or withdrawal of plan involved – Distinguished from Ebix Singapore and Amtek Auto – Held: Such discretion to CoC permissible to address exigencies – Delay not attributable to JSW or CoC but due to litigation, ED attachments and interim orders – Plan validly implemented on 26.03.2021 [Paras 97-128].

IBC – Compliance with IBBI (CIRP) Regulations – Priority of OCs – Resolution Plan submitted when Regulation 38 mandated only liquidation value to OCs – Subsequent amendment (05.10.2018) providing priority complied with via addendum – Ex gratia payment of Rs. 350 crores to OCs beyond entitlement – Later amendment (27.11.2019) inapplicable as prospective – No contravention of law – Promoters cannot raise issue not agitated by OCs [Paras 130-143].

IBC – Upfront Infusion of Funds – CCDs as Equity – JSW infused Rs. 8,450 crore by compulsorily convertible debentures – CCDs mandatorily convertible into equity treated as equity instruments in law (Narendra Kumar Maheshwari, IFCI Ltd.) – Upfront commitment fulfilled – Commercial wisdom of CoC paramount and non-justiciable [Paras 144-152].

IBC – Distribution of EBITDA – NCLT directed distribution based on NCLAT Essar – NCLAT relying on SC Essar held EBITDA not distributable absent provision in RfRP – CoC initially opposed distribution, later took contrary stand in affidavit post-review – Held: RfRP silent, no such claim permissible after plan approval – EBITDA to remain with corporate debtor – Finality of resolution plan cannot be unsettled [Paras 153-171, 185-190].

IBC – Classification of Contingent Creditors – Jaldhi – Claim based on foreign arbitral awards – Withdrawn execution petitions before Calcutta High Court – Awards not deemed decrees under Section 49 of Arbitration Act – Stand of creditor inconsistent – CoC’s commercial wisdom in classifying as contingent creditor upheld – Non-justiciable [Paras 172-180].

IBC – Pre-CIRP Dues – Medi & Darcl – Payments made during CIRP adjusted against services rendered – No CoC approval for pre-CIRP dues – Must be treated only under resolution plan – Appeals dismissed [Paras 181-184].

IBC – Section 32A Immunity – Corporate debtor’s liability for pre-CIRP offences ceases after plan approval – ED attachments and prosecutions could not continue once management changed – Delay due to pendency of such proceedings not attributable to JSW – Implementation valid [Paras 105-123, 116-118].

Decision: Appeals dismissed – NCLAT order dated 17.02.2020 upholding resolution plan of JSW Steel Limited affirmed – Implementation of plan on 26.03.2021 valid – Contingent claims, EBITDA demands, and objections of ex-promoters rejected – Section 32A immunity reiterated – Resolution Plan attained finality [Paras 185-192].

Motor Accident Compensation – Determination of Income – Appellant, 23-year-old loader, lost right leg in lorry accident (01.12.2015) – Tribunal fixed income at ₹9,000 p.m., assessed 85% disability, applied multiplier 18, awarded ₹19,35,400 under various heads – High Court reduced income to ₹8,000 relying on Workmen’s Compensation Act ceiling, further considering only 60% thereof, thereby reducing award to ₹10,41,022 – Supreme Court: High Court erred in importing Workmen’s Compensation Act parameters into MV Act claim – Once claimant elected remedy under MV Act, insurer cannot seek application of Workmen’s Compensation Act provisions – Tribunal’s award restored [Paras 3–6].

Future Prospects – Appellant argued addition of 40% for future prospects (Pranay Sethi) – Court held not permissible since claimant had not appealed against Tribunal award, only insurer’s appeal considered by High Court – Hence no enhancement beyond Tribunal’s award [Para 6.1].

Decision: Appeal allowed – High Court’s judgment dated 23.01.2020 set aside – Tribunal’s award of ₹19,35,400 restored – No further addition for future prospects permitted.

Motor Accident Compensation – Quantum – Future Medical Expenses – Income Assessment – Pillion rider (aged 20) rendered paraplegic (C4–5 fracture) after being run over by car driven rashly – Liability not in dispute; appeal limited to (i) acceptance of medical bills and (ii) income for loss of earning capacity – Insurance company’s objection to bills from Goa rejected; Court accepts verification and directs ₹20 lakhs towards medical expenses beyond HC award; no interest if paid within 4 months – Monthly income reasonably fixed at ₹5,000 (2001) for a B.Com final-year student enrolled with ICAI; 40% future prospects and multiplier 18 applied as per Pranay Sethi – Loss of income computed at ₹15,12,000; total compensation recalculated at ₹40,34,356 with 9% interest from filing till realisation – Additional ₹20 lakhs for medical expenses payable within 4 months, failing which 9% interest from judgment date – Appeal allowed with modification [Paras 2–6].

Insurance Bills – Verification & Place of Treatment – Objection that bills were from Goa/Bengaluru and not Delhi rejected; insurer with nationwide presence cannot plead inability to verify – Justified relocation to Goa due to pneumonia and adverse climate in Delhi – Directed tabulated bills; ₹21 lakhs verified as genuine; net ₹20 lakhs ordered (after HC’s additional ₹1 lakh) towards medical expenses incurred over two decades of 100% disability [Paras 2–3].

Income Determination – Prospective Career – Minimum wages for a “skilled worker” in 2001 (₹3,352/₹3,339) not appropriate proxy for a graduate on track for CA – Court fixes ₹5,000 p.m. (2001) as reasonable; adds 40% future prospects; applies multiplier 18 per Pranay Sethi; computes loss of income at ₹15,12,000 [Para 4–5].

Recalculation of Award – High Court components retained (₹14 lakhs under conventional heads; medical expenses ₹11,22,356) – Total compensation fixed at ₹40,34,356 with 9% interest from petition till realisation – Direction to pay within four months [Para 5].

Additional Direction – ₹20 lakhs towards future medical expenses payable within 4 months; no interest if paid in time; otherwise 9% from judgment date [Para 6].

Decision: Appeal allowed – Award enhanced and directions issued regarding payment timelines and interest.

Judicial Services – Eligibility Criteria – Telangana State Judicial Service Rules, 2023 – Rule 5(5.1)(a) restricting eligibility to advocates practicing in Telangana High Court or its subordinate courts for not less than 7 years – Petitioners challenged rejection of their applications on ground of discrimination and violation of Articles 14 and 233 – High Court dismissed writ petitions holding Rule valid – Supreme Court refrained from adjudicating constitutionality of Rules but permitted qualified petitioners to be appointed as District Judges as a special case without treating it as precedent [Paras 4, 6-9, 11-12].

Recruitment – Judicial Service Examinations – Petitioners permitted by interim orders to participate in written and viva-voce examinations – They secured qualifying marks – Supreme Court directed High Court to declare results and proceed with verification of antecedents – Qualified candidates to be appointed within two months but without arrears of benefits – Seniority to be reckoned from date of actual appointment; existing appointees to rank senior [Paras 8-10].

Civil Judge (Junior Division) – Connected Petitions – Writ petitioners challenging Bar Association enrolment requirement also permitted to appear in exams pursuant to interim order – Supreme Court extended similar relief, directing declaration of results and appointment if qualified [Para 10].

Constitutional Law – Scope of Relief – Supreme Court clarified that directions were confined to peculiar facts and circumstances and would not operate as precedent – All questions of law kept open for determination in future [Para 11].

Decision: Appeals, SLPs, and Writ Petition disposed of – Qualified petitioners directed to be appointed as District Judges as special case – No precedent – Parties to bear own costs.

Motor Accident Compensation – Insurance Policy Validity – Fraud Allegation – Deceased, 21-year-old security guard earning ₹4,000/month, died in road accident on 21.06.2006 – Tribunal awarded ₹3,87,000 with 7% interest against insurer based on insurance policy produced by vehicle owner showing coverage from 17.06.2006 – Insurer later discovered policy validity was fraudulently altered, actual period being 28.06.2006–27.06.2007 – Review before Tribunal dismissed; order not challenged in appeal – High Court upheld Tribunal’s award – Supreme Court: Allegation of fraud not proved during main proceedings, insurer bound to satisfy award – However, in equity, insurer allowed to recover 50% of compensation from owner and driver [Paras 3–6].

Procedural Law – Review Petition – Tribunal rightly dismissed insurer’s review application for lack of review power under Motor Vehicles Act – Insurer’s failure to challenge review dismissal before High Court fatal to its contention [Paras 3.2, 5.2].

Equitable Relief – Recovery Rights – Although insurer liable to pay claimants, permitted to recover 50% of compensation from vehicle owner and driver to balance equities, given fraudulent alteration of policy dates by owner [Para 6].

Decision: Appeal dismissed with modification – Insurer directed to pay award, but entitled to recover 50% from vehicle owner and driver – Any unpaid compensation to be deposited within six weeks.

Criminal Procedure – Delay in Compliance of Supreme Court Order – Jurisdiction of Trial Court – Supreme Court had directed the Judicial Magistrate, 4th Court, Alipore to dispose of case AC-2053/2017 within six weeks from order dated 18.01.2024 – Judicial Magistrate, upon failing to conclude trial in time, passed order on 19.03.2024 declaring loss of jurisdiction due to lapse of time – Supreme Court expresses displeasure – Held: Judicial Officer cannot abdicate jurisdiction merely due to expiry of time fixed by Supreme Court – Proper course was to seek extension of time from higher court [Paras 4–6].

Judicial Conduct – Accountability – Supreme Court directs District Judge concerned to seek written explanation from the Judicial Magistrate – To report back to Supreme Court within one month explaining reasons and circumstances under which the Magistrate concluded he lacked jurisdiction – Directions issued to ensure proper procedural compliance and judicial discipline [Para 6].

Condonation of Delay – Delay in filing modification application condoned – Petitioners granted two weeks’ time to file detailed response explaining delay in conclusion of trial proceedings [Paras 1, 7].

Decision: Delay condoned – Registry directed to forward copy of order to relevant authorities – District Judge to obtain explanation from concerned Magistrate and submit report within one month – Petitioners allowed two weeks to file response.