Appeal against the High Court's dismissal of petitions under Section 482 CrPC seeking quashing of criminal proceedings under the SC-ST Act on the ground that the alleged offense did not occur in "public view."

Environmental Law - Polluters Pay Principle – Continuing Liability – Section 24, 25 of the Water Act – Environmental Protection – Industrial Pollution – Government Responsibility – Compensation Directed – The court reiterated the absolute liability of polluting industries to compensate affected individuals until environmental damage is fully reversed – Held: The duty to compensate is ongoing, and industries cannot absolve themselves of liability by making partial payments – The State Government is directed to disburse compensation and recover the amount from polluters [Paras 82-83, 91-93, 113].

Government Pay Principle – Accountability of Governmental Agencies – Enforcement Responsibility – Failure to Regulate Polluters – While the Polluters Pay Principle mandates industries to compensate for environmental damage, the Government cannot escape responsibility for its regulatory failures – Held: The State Government is liable to compensate affected individuals in the first instance and recover the same from polluting industries – Court emphasized the need for stringent oversight and proactive environmental governance [Paras 83, 91.1, 113].

Ecocide – Recognition of Environmental Crimes – Severe and Widespread Environmental Damage – The court recognized the concept of "Ecocide" as an emerging environmental crime, involving acts causing significant harm to ecosystems – Held: The pollution in Vellore District amounts to potential ecocide due to continued environmental degradation, necessitating urgent corrective measures [Para 92].

Tannery Pollution – Industrial Emissions – Compliance with Environmental Standards – Zero Liquid Discharge (ZLD) Mandate – Industries claimed compliance with pollution control norms, but the court found no conclusive evidence of full Zero Liquid Discharge (ZLD) achievement – Held: Tannery industries remain responsible for reversing ecological damage until compliance is fully demonstrated – Directions issued for stricter enforcement [Paras 109-112].

Compensation Disbursement – Delay in Relief to Affected Individuals – State Government's Obligation to Ensure Full Payment – The court criticized the delay in disbursing compensation awarded in 2001 and 2009 – Held: The State Government must pay pending compensation within six weeks and recover it from polluters through legal means [Paras 104-106, 115(i)-(ii)].

Regulatory Lapses – Pollution Control Board's Role – Failure in Monitoring Industrial Compliance – The court found that pollution control measures were not effectively enforced despite the existence of regulatory frameworks – Held: State and Central Pollution Control Boards must enhance monitoring, enforce environmental norms, and penalize violations [Paras 112-113].

Judicial Oversight – Compliance Mechanism – Formation of High-Level Committee – Recognizing the need for continuous judicial oversight, the court directed the formation of a committee headed by a retired High Court judge to monitor compliance, assess damages, and ensure ecological restoration – Held: The committee must submit reports periodically and oversee remedial measures [Paras 115(iii)-(vi)].

Advanced Monitoring Measures – IoT and AI-Based Surveillance – Real-Time Pollution Tracking – The court emphasized the need for modern technology to monitor pollution levels – Held: The State Government must install IoT-based sensors at discharge points and use AI to analyze environmental data for regulatory action [Paras 115(ix)-(x)].

Strict Action Against Non-Compliance – Cancellation of Licenses – Penalties for Persistent Violators – The court held that industries repeatedly violating pollution norms must face severe consequences – Held: Authorities must revoke licenses, impose penalties, and take strict legal action against defaulting industries [Paras 115(xv)-(xvi)].

Wastewater Management – Sewage Treatment Plants (STPs) – Municipalities' Role in River Pollution – The court found that untreated sewage from municipalities also contributed to pollution – Held: The State must construct adequate STPs and prevent direct sewage discharge into water bodies [Paras 114, 115(xix)].

Labour Rights – Protection of Tannery Workers – Health and Safety Compliance – Acknowledging hazardous working conditions, the court emphasized the need for worker protection – Held: Tannery workers must be provided with protective gear, annual health checkups, and insurance coverage to prevent occupational diseases [Paras 114, 115(xx)-(xxi)].

Illegal Sand Mining – Impact on River Ecosystem – Immediate Ban and Enforcement – The court noted rampant illegal sand mining as an additional environmental hazard – Held: The State must enforce a strict ban, conduct real-time surveillance using drones and GPS, and impose stringent penalties, including permanent seizure of equipment [Para 115(xxiv)].

Periodic Environmental Audits – Public Transparency – Citizen Participation – The court stressed the importance of regular environmental audits and public access to pollution data – Held: The State Pollution Control Board must publish real-time water quality data, establish citizen complaint mechanisms, and ensure public participation in environmental governance [Paras 115(xviii), (xxvi)-(xxvii)].

Final Decision – Compensation to be Paid – Pollution Control Measures to be Strictly Enforced – Government Directed to Implement Remedial Actions – The court modified the High Court order to direct immediate payment of compensation and stringent enforcement of environmental protection measures – Held: The State Government must ensure compliance and report back within four months [Para 116-118].
 

Maintenance under Section 125 CrPC – Second Wife’s Entitlement – Relief Granted – The appellant-wife was denied maintenance by the High Court on the ground that her first marriage was not legally dissolved, rendering her second marriage void – The Supreme Court held that maintenance laws must be interpreted with a focus on social justice and preventing destitution – Held: Even if the second marriage was legally void, the appellant-wife was entitled to maintenance under Section 125 CrPC, considering the respondent’s knowledge of her prior marriage and their long cohabitation as husband and wife [Paras 10-14].

Expansive Interpretation of "Wife" – Protection Against Vagrancy – The Court referred to Chanmuniya v. Virendra Kumar Singh Kushwaha, (2011) 1 SCC 141, and Badshah v. Urmila Badshah Godse, (2014) 1 SCC 188, to hold that the definition of "wife" under Section 125 CrPC should be interpreted broadly to prevent vagrancy and destitution – Held: A woman who has lived with a man in a de facto marriage cannot be denied maintenance merely due to the absence of legal validity in the marriage [Paras 15-18].

Husband’s Knowledge of Prior Marriage – Bar on Escaping Marital Obligations – The Court noted that the respondent had full knowledge of the appellant’s previous marriage but still married her twice and lived with her – The Court held that a husband cannot benefit from legal technicalities to escape maintenance obligations when he voluntarily cohabited with the woman as his wife – Held: The respondent was estopped from denying maintenance on the basis of legal infirmities in the marriage [Paras 19-21].

Restoration of Maintenance Award – Supreme Court Reverses High Court’s Decision – The Family Court had originally awarded ₹3,500 per month to the appellant-wife and ₹5,000 per month to her daughter – The Supreme Court restored this order, holding that maintenance is a legal duty, not a mere benefit – Held: Maintenance of ₹3,500 per month to the appellant-wife reinstated, with arrears payable within eight weeks [Paras 22-24].

Decision: Appeal allowed – The Supreme Court restored the Family Court’s award of maintenance to the appellant-wife, holding that a strict interpretation of "wife" under Section 125 CrPC would defeat the provision’s social justice objective – Maintenance of ₹3,500 per month granted, payable with arrears within eight weeks.
 

Quashing of Criminal Proceedings – Section 482 CrPC – Summoning Order Lacks Reasons – The appellants were charged with manufacturing and distributing a drug declared as ‘Not of Standard Quality’ – The trial court issued summons without assigning reasons – The Supreme Court reiterated that a summoning order must reflect application of judicial mind and must not be a mere formality – Held: The summoning order was non-speaking and unsustainable – Proceedings quashed [Paras 6-9].

Bar of Limitation – Section 468(2) CrPC – Complaint Filed Beyond Prescribed Period – The alleged offence was based on an Analytical Report dated 15th December 2018 – The complaint was filed in May 2023, well beyond the three-year limitation period – Held: The prosecution was barred by limitation under Section 468(2) CrPC and thus untenable [Para 5].

Judicial Precedent – Summoning Must Reflect Judicial Application – The Court reiterated that summoning an accused in a criminal case is a serious matter and the magistrate must apply his mind – A non-speaking order violates fundamental legal principles – Reference made to the Court’s previous rulings in Pepsi Foods Ltd., Sunil Bharti Mittal, Mehmood Ul Rehman, and Krishna Lal Chawla [Paras 8-9].

Decision – Appeal Allowed – Proceedings Quashed – The Supreme Court allowed the appeal, set aside the High Court’s order, and quashed the criminal proceedings against the appellants [Para 10].
 

Quashing of Criminal Proceedings – Section 482 CrPC – Sale of Drugs without License – Manufacture vs. Wholesale Sale – No Violation Established – The appellants, engaged in manufacturing and selling medical gases, were charged under Section 18(a)(vi) read with Section 27(d) of the Drugs and Cosmetics Act, 1940 for allegedly selling Nitrous Oxide I.P. to an unlicensed firm – The appellants sought quashing of the proceedings, arguing that the firm in question was licensed under Form 25, allowing it to alter, break, repackage, and distribute the product – The Supreme Court held that both the seller and buyer possessed a valid Form 25 manufacturing license, permitting such transactions – Mere absence of a Form 20B wholesale license with the buyer did not make the transaction unlawful – Consequently, the proceedings were quashed [Paras 18-26].

Issuance of Summons – Non-Application of Mind – Summoning Order Must Reflect Reasons – The Trial Court issued process against the appellants without recording any reasoning for taking cognizance – The Supreme Court reiterated that summoning an accused in a criminal case is a serious matter, requiring due application of mind by the Magistrate – Held: The summoning order was mechanical and non-speaking, rendering it unsustainable in law – Proceedings quashed [Paras 32-36].

Interpretation of ‘Manufacture’ – Section 3(f), Drugs and Cosmetics Act, 1940 – Wide Scope – Includes Processing, Alteration, and Packing – The Court clarified that the term ‘manufacture’ includes any process of making, altering, breaking, packing, or relabeling with a view to sale or distribution – Since the buyer was engaged in breaking down and repackaging the drug, it was engaged in a legitimate manufacturing process – Therefore, the sale to such an entity was not illegal [Paras 23-26].

High Court’s Interpretation Flawed – Misreading of Law – The High Court incorrectly held that the license under Form 25 was ‘subject to’ a Form 20B license – The Supreme Court ruled that the prosecution failed to demonstrate how the Form 25 license was in violation of Form 20B conditions – Consequently, the High Court’s decision dismissing the quashing petition was set aside [Paras 39-41].

Decision – Appeal Allowed – Proceedings Quashed – The Supreme Court allowed the appeal, set aside the High Court’s order, and quashed the criminal proceedings against the appellants [Para 41].

Condonation of Delay – Delay of 586 Days in Filing Appeal – High Court’s Decision Set Aside – The High Court condoned the delay of 586 days in filing the appeal by subsequent purchasers, reasoning that they were senior citizens residing abroad and were unaware of the proceedings – Held: Mere passage of time or reliance on vendor’s assurances is not a sufficient ground for condonation – Delay was unexplained and unreasonable – High Court erred in condoning the delay and allowing the appeal – Appeal allowed, delay condonation set aside [Paras 23-24].

Right to Appeal – Grant of Leave to Appeal – Rejection of Impleadment Application – Whether Subsequent Purchasers Can Appeal Against Final Decree – The subsequent purchasers had sought impleadment in the trial court, which was rejected, and the order attained finality – Held: Once impleadment was denied and not challenged, they had no right to seek leave to appeal against the final decree – Findings of the trial court rejecting their impleadment operated as res judicata – High Court’s order granting leave to appeal was unsustainable – Appeal allowed, leave to appeal set aside [Paras 42-43].

Doctrine of Lis Pendens – Section 52 of the Transfer of Property Act – Rights of Transferee Pendente Lite – The subsequent purchasers bought the property while a suit for specific performance was pending and in violation of an injunction order – Held: Transfers made pendente lite are not void ab initio but remain subject to the outcome of litigation – Such transferees cannot claim independent rights against a decree that binds their vendor – They are bound by the outcome of the litigation and have no right to challenge the decree independently – Appeal allowed, rights of the original plaintiffs upheld [Paras 46-48].

Judicial Discretion – Grant of Leave to Appeal – Limits of Appellate Court’s Power – Appeal Allowed – A person who is not a party to the original suit can appeal only if they are directly and adversely affected – The appellate court’s discretion to grant leave should be exercised judiciously and not as a matter of routine – Held: The High Court wrongly exercised its discretion by granting leave to appeal to persons who had no standing – Appeal allowed, High Court’s order quashed [Paras 56-58].

Service Law – Selection Process – Allegation of Nepotism – Rule against Bias – Validity of Appointments Upheld – The selection of Shiksha Karmis was challenged on the ground that several appointees were related to members of the selection committee, violating the principle of nemo judex in causa sua – The Collector quashed the selection without issuing notices to the affected candidates – Held: Mere suspicion of bias without proof is insufficient – The presence of related members did not vitiate the process as they had recused themselves – The challenge based on bias was unfounded – Appeal allowed, selection upheld.

Principles of Natural Justice – Right to Fair Hearing – Violation Rendered Selection Invalid – Audi Alteram Partem Violated – The appointments were canceled without affording the selected candidates an opportunity to be heard – Held: The failure to serve notice to the affected parties was a gross violation of the principles of natural justice – Opportunity of hearing is a fundamental procedural safeguard – The absence of notice rendered the cancellation void ab initio – Appeal allowed, appointments reinstated.

Judicial Review – Appellate Proceedings – Whether Violation of Natural Justice at Initial Stage Can Be Cured in Appeal – No Cure at Appellate Stage – The respondents contended that the hearing before the Revisional Authority rectified any prior defect – Held: The lack of fair hearing at the original stage cannot be remedied at the appellate stage – The procedural flaw at the initial stage irreversibly tainted the entire process – A valid initial decision is a prerequisite for a meaningful appellate review – Appeal allowed, original orders quashed.

Service Law – Continuity of Service – Remedy – Given the long passage of time (over 25 years) since the appointments, remanding the matter for fresh consideration would cause injustice to the appointees – Held: The appointments stand upheld, and no fresh inquiry shall be ordered – The appeal is allowed, and the appointees are entitled to continue in service – Appeal allowed, no further proceedings necessary.

Decision: Supreme Court upheld Justice KV Vishwanathan’s opinion – Appeal allowed – Judgment of the Division Bench set aside – Selection restored as appellants had served for over 25 years – Remanding the matter for fresh consideration would be impractical – Parties to bear their own costs

Reservation in PG Medical Courses – Constitutionality of Domicile-Based Reservation – Violation of Article 14 – The UT of Chandigarh reserved 50% of its State Quota seats for candidates with a background in Chandigarh—The High Court struck down this policy as unconstitutional—Held: Residence-based reservation in PG Medical Courses is impermissible and violates Article 14—The Constitution of India does not recognize State-specific domicile, and all citizens share a common ‘Indian domicile’—Institutional preference is permitted to a reasonable extent, but domicile-based reservation is unconstitutional—High Court’s decision upheld, residence-based reservation struck down [Paras 5-6, 31-32].

Judicial Precedents – Institutional Preference vs. Domicile Reservation – The Supreme Court relied on landmark rulings, including Jagadish Saran v. Union of India (1980) 2 SCC 768, Dr. Pradeep Jain v. Union of India (1984) 3 SCC 654, and Saurabh Chaudri v. Union of India (2003) 11 SCC 146—Held: While institutional preference in PG admissions is permissible under Article 14, domicile-based reservations are not—Such reservations compromise meritocracy and contradict equality principles—Precedents reaffirmed that higher education must be based on merit and not residence [Paras 6-9, 16-17].

Concept of Domicile – Single Indian Domicile – State-Specific Domicile Invalid – The Court clarified that the Indian Constitution recognizes only one domicile, i.e., ‘domicile in the territory of India’—The concept of State-specific domicile is legally untenable—Held: The practice of equating domicile with residence for reservation in education is impermissible—States must refrain from using ‘domicile’ when they actually mean ‘residence’ [Paras 19-24].

Reservation in Higher Education – Merit and Equality in PG Medical Courses – Limited Scope of Residence-Based Reservation – The Court distinguished between UG (MBBS) and PG (MD/MS) courses—While residence-based reservations may be justified for MBBS admissions to promote local healthcare, the same is impermissible in PG courses—Held: PG Medical Courses require the highest level of merit, and compromising it through regional reservations would be detrimental to national interest—Article 14 mandates equal treatment for all students regardless of State of residence—Admissions to be strictly based on NEET rankings—High Court’s decision upheld [Paras 29-30].

Institutional Preference – Validity of Institutional Quota – Reasonable institutional preference upheld—Held: Institutional preference is constitutionally valid but must be kept within reasonable limits—However, additional reservation based on residence is impermissible—50% institutional preference upheld, but residence-based quota struck down [Paras 33-34].

Equitable Relief – No Retrospective Effect – The Supreme Court clarified that its declaration of impermissibility of residence-based reservation in PG Medical Courses will not affect students who have already been admitted or completed their courses—Held: The ruling will apply prospectively to ensure fairness—Future admissions must adhere strictly to merit-based criteria as per NEET rankings—Existing admissions remain unaffected [Para 34].

Criminal Law - Appeal against conviction under Section 302 IPC - Murder – Reliability of Eyewitness Testimony – Conviction Reversed – The appellant was convicted under Section 302 IPC based on the testimony of two eyewitnesses (PW-4 and PW-5) – Both witnesses made significant omissions and contradictions in their statements, including inconsistencies about the number of stab wounds, position of the deceased, and their own locations – Witnesses failed to report the crime to the police immediately, and other eyewitnesses were not examined – Held: The testimony of PW-4 and PW-5 was unreliable due to material contradictions and omissions – Appeal allowed, conviction set aside [Paras 6-7].

Criminal Law – Section 27, Indian Evidence Act – Recovery of Weapon Alone Insufficient for Conviction – The prosecution relied on the recovery of the murder weapon at the appellant’s instance – Held: A disclosure statement without corroborative evidence is insufficient to establish guilt beyond reasonable doubt – Recovery of a weapon alone cannot substitute for substantive evidence of the crime – Appeal allowed, acquittal granted [Para 8].

Burden of Proof – Standard of Proof in Criminal Cases – Reasonable Doubt – The prosecution must prove the guilt of the accused beyond reasonable doubt – The case against the appellant rested solely on unreliable eyewitness testimony and weak circumstantial evidence – Held: Failure of prosecution to discharge its burden – Conviction set aside – Appellant acquitted and ordered to be released unless required in another case [Paras 9-10].