Criminal Law – Murder Conviction – Appellants convicted under Sections 302/149 IPC for the murder of Bhimappa Biradar – Trial court acquitted some accused but convicted others – High Court reversed acquittal and upheld the convictions – Supreme Court confirmed convictions, holding that all appellants participated in the unlawful assembly with common object to kill the deceased [Paras 1-25].

Unlawful Assembly – Common Object – Applicability of Section 149 IPC – Court emphasized that once membership of unlawful assembly is established, each member is vicariously liable for actions of others – Court found substantial evidence that appellants shared common object to commit murder, thereby attracting Section 149 IPC [Paras 20-22].

Witness Testimony – Reliability – Eyewitness accounts consistently corroborated each other regarding participation of all accused in the crime – Court dismissed arguments of inconsistencies in witness statements as minor and not affecting the overall credibility [Paras 15-19].

Delay in FIR – Explained and Justified – Delay due to travel distance to police station and absence of SI at the station – Court accepted explanation, finding no manipulation in FIR filing [Paras 24-25].

Decision – Appeals dismissed – Convictions and sentences of all appellants upheld by the Supreme Court [Para 25].

Criminal Law – Conviction under Prevention of Corruption Act – Appellant Syed Ahmed, a police officer, convicted for demanding and accepting illegal gratification – Trial Court acquitted him but High Court reversed acquittal and convicted – Supreme Court upheld conviction, emphasizing reliable witness testimony and compliance with procedural requirements under the Prevention of Corruption Act [Paras 1-48].

Illegal Gratification – Demand and Acceptance – Clear and unshaken testimony of complainant and corroborative evidence of an independent witness established demand and acceptance of illegal gratification by appellant – Court rejected arguments regarding minor discrepancies and procedural errors, affirming core prosecution evidence [Paras 29-31, 44-45].

Witness Credibility – Minor inconsistencies in witness statements regarding attire of appellant at the time of incident deemed irrelevant – Supreme Court emphasized focus on core issue of demand and acceptance of bribe, not on trivial discrepancies [Paras 39-44].

Delay and Motivation – Court found no merit in arguments of motivated false complaint and delay in FIR filing – Established that complaint was based on concrete evidence of illegal demand and acceptance [Paras 35-38].

Quantum of Sentence – High Court erred in awarding sentence of three months rigorous imprisonment instead of minimum one year as prescribed under Section 13(2) of the Act – However, Supreme Court refrained from altering sentence due to lapse of time and absence of State's appeal on sentence [Paras 46-47].

Decision – Appeal dismissed – Conviction and sentence affirmed by Supreme Court [Para 48].

Workmen's Compensation – Interest on Compensation – The primary question was when compensation under the Workmen's Compensation Act becomes due and the corresponding point in time from which interest is payable. The Supreme Court upheld the decision directing the payment of interest from the date of the accident, affirming that compensation becomes due immediately when personal injury is caused to a workman by an accident arising out of and in the course of employment [Paras 2-8].

Interest – Commencement Date – Compensation under Section 4 of the Act falls due on the date of the accident, and interest under Section 4A(3) is payable from one month after the accident. The Supreme Court clarified that no further adjudication is required to establish the due date for the commencement of interest [Paras 7-8].

Penalty for Delay – Interest is a consequence of default in payment and does not require a finding of unjustified delay. However, for penalty under Section 4A(3)(b), the Commissioner must find the delay to be unjustified and provide the employer an opportunity to show cause [Para 7].

Binding Precedents – The Court emphasized adherence to earlier larger Bench decisions, overruling contrary views expressed in later two-Judge Bench decisions, reaffirming the principle that compensation is due from the date of the accident and interest accrues from one month after that date [Paras 8-12].

Decision – Appeal dismissed – The Court affirmed the decision of the Commissioner for Workmen's Compensation and the Kerala High Court, awarding interest from the date of the accident. Costs were imposed on the appellant [Para 13].

Environmental Law – Ship Dismantling – Applications concerned the entry and dismantling of the ship "Oriental Nicety" in Indian waters. The Court reviewed compliance with environmental safeguards and procedures laid out in the Basel Convention. The ship was allowed to beach and be dismantled after clearance from relevant authorities, with provisions for handling any discovered hazardous materials during dismantling [Paras 1-14].

Compliance with Basel Convention – The ship's entry was conditioned on compliance with Basel Convention norms and prior clearance from the State Pollution Control Board, State Maritime Board, and Atomic Energy Regulatory Board. The Court emphasized adherence to Basel Convention or subsequent Central Government provisions in future cases [Paras 7, 14].

Clearance for Beaching and Dismantling – The ship was inspected and found free of hazardous substances, permitting it to beach for dismantling. Any hazardous materials discovered during dismantling to be disposed of at the ship owner's cost [Paras 12-13].

Regulatory Oversight – The Court noted the establishment of an Inter-Ministerial Standing Monitoring Committee to periodically review the implementation of Technical Expert Committee recommendations, ensuring compliance with environmental standards [Paras 4-5].

Decision – Applications disposed of, allowing ship to beach and proceed with dismantling under strict regulatory compliance. Emphasis placed on adherence to Basel Convention in future cases to ensure a clean maritime environment [Paras 13-14].

Employment Law – Concealment of Criminal Background – The appellant was terminated from his position as a police constable for concealing his involvement in a criminal case during the selection process. The Supreme Court examined conflicting views in previous judgments regarding termination for such concealment and decided to refer the matter to a larger bench for an authoritative decision [Paras 1-34].

Verification of Character and Antecedents – The court emphasized the importance of verifying character and antecedents for positions in the police force, noting that concealment of material information regarding criminal involvement affects the integrity and suitability of candidates for such positions [Paras 3-7, 16-22].

Conflicting Judicial Views – The court reviewed several conflicting decisions from various benches regarding the termination of employees for concealing criminal cases during selection, highlighting the need for a consistent legal standard [Paras 9-29].

Referral to Larger Bench – Due to the conflicting judgments, the matter was referred to a larger bench for a uniform and authoritative pronouncement on the issue [Paras 33-34].

Decision – Matter referred to a larger bench for detailed consideration and an authoritative pronouncement on the legal principles involved in cases of concealment of criminal background by candidates during the selection process [Para 34].

Income Tax – Advance Rulings – The primary issue was the maintainability of challenges to the advance rulings of the Authority for Advance Rulings (AAR) under Articles 136, 226, and 227 of the Constitution. The Supreme Court clarified that AAR is a tribunal within the meaning of Articles 136 and 227, and its rulings can be challenged under these Articles [Paras 1-14].

Tribunal – Definition and Judicial Review – The Court confirmed that AAR exercises judicial functions and its determinations are binding, thus qualifying it as a tribunal under Articles 136 and 227. Consequently, its rulings are subject to judicial review by the High Courts and the Supreme Court [Paras 7-10].

Binding Nature of Advance Rulings – Section 245S of the Income Tax Act makes advance rulings binding on the applicant and the Commissioner of Income Tax, but the rulings can be challenged under Articles 226 and 227 before High Courts or under Article 136 before the Supreme Court [Paras 9-11].

Judicial Superintendence – High Courts have the power to review AAR's rulings under Articles 226 and 227 as part of their constitutional duty, ensuring that such rulings can be scrutinized for legality and correctness [Paras 12-13].

Decision – The Court disposed of the Special Leave Petitions, granting liberty to the petitioners to approach the appropriate High Court under Articles 226 and 227. The High Courts were requested to expedite the hearing of such writ petitions to maintain the purpose of obtaining advance rulings expeditiously [Paras 14].

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].