Criminal Law - Rape and Murder of Minor – Sections 302 and 376 of the IPC - Death Sentence Commuted to Life – Conviction Confirmed – Appellant was convicted for raping and murdering a 6-year-old girl and sentenced to death—Supreme Court upheld the conviction based on eyewitness testimony of child and adult witnesses and corroborative medical evidence—However, it held that the case did not fall within the ‘rarest of rare’ category to warrant death penalty—Held: Conviction under Sections 302 and 376 IPC upheld; sentence modified to life imprisonment and 10 years’ RI, respectively, to run concurrently [Paras 1–9].

Circumstantial and Direct Evidence – Chain Complete – The prosecution established that the victim was last seen with the accused—Multiple witnesses (including child witness PW5) deposed that the accused took the girl to the cinema—Postmortem confirmed rape and smothering as cause of death—Scratch marks on accused’s genital also noted—Held: Combined effect of evidence sufficiently proves guilt beyond reasonable doubt [Paras 2–6].

Child Witness – Evidence Found Reliable – PW5, an 8-year-old boy, clearly testified seeing the victim leave with the accused—Statement remained consistent and unshaken in cross-examination—Held: Child witness competent and credible—Testimony lawfully relied upon by courts below [Paras 5–6].

Medical Evidence – Confirms Sexual Assault and Asphyxiation – Doctors confirmed rape and homicidal death by blocking of mouth and nose—Clothing and forensic findings consistent with sexual assault—Injury on accused consistent with struggle—Held: Medical findings support prosecution case and corroborate oral testimony [Paras 6–7].

Sentence – Not ‘Rarest of Rare’ – Mitigating Factors Considered – Supreme Court took note of accused's young age (under 22), lack of prior criminal record, and absence of overt physical injury to victim—Held: Though heinous, act not so depraved as to merit death—Sentence commuted to life imprisonment for murder and 10 years’ RI for rape [Paras 8–9].

Criminal Law - Abetment of Suicide – Section 306 IPC – Presumption under Section 113A Not Attracted – Conviction Set Aside – The appellant was convicted for abetment of suicide following the death of his wife within one year of marriage – Suicide note and dying declaration clearly exonerated the accused of any responsibility – Held: No instigation or intentional aid proven – Mere quarrel or casual statement does not constitute abetment – Presumption under Section 113A is discretionary and not mandatory – Conviction under Section 306 IPC quashed, Acquittal [Paras 12–13, 19–23].

Cruelty – Section 498A IPC – Sustained – Sporadic instances of verbal and physical abuse established through letters and witness testimony – Though not linked to the suicide, such conduct fell within the ambit of cruelty under Section 498A – Held: Conviction under Section 498A justified and sentence of two years RI affirmed [Paras 8–9, 24].

Presumption under Section 113A – Discretionary Nature – The Court held that the presumption of abetment of suicide by a married woman under Section 113A is not automatic – It must be supported by evidence showing that cruelty was proximate and linked to the act of suicide – Held: In this case, the presumption was rebutted by clear exculpatory evidence in the form of the suicide note and dying declaration [Paras 11–13, 22].

Dying Declaration and Suicide Note – Clear Exoneration of Husband – The deceased's dying declaration and letter addressed to her husband took personal responsibility for her suicide and stated that no one should be blamed – Held: Such documents inspire confidence and directly rebut the prosecution’s theory of abetment [Paras 15–17].

Mens Rea for Abetment – Not Established – The accused allegedly told the deceased “go wherever you want” after an argument – Held: Such remarks, in absence of intent or provocation, do not amount to abetment – Essential ingredient of mens rea under Section 107 IPC not satisfied [Paras 19–20].

Decision – Appeal Partly Allowed – Conviction under Section 306 IPC set aside – Conviction under Section 498A IPC upheld – Sentence of two years RI for cruelty to run as imposed by the courts below [Para 24].

Criminal Law – Appeal Against Quashing Of Complaint - Forgery – Criminal Proceedings – Section 465, 468, 471 IPC – Criminal Process Revived – The appellant alleged forgery of her signature and others on a dissolution deed of a partnership firm—Trial Magistrate, after recording preliminary evidence, issued process under relevant IPC sections—High Court quashed proceedings citing pendency of related civil suit—Supreme Court held that civil and criminal proceedings can coexist and quashing at threshold stage not justified—Order of Magistrate restored [Paras 2–4, 16–18].

Scope of Section 482 CrPC – Quashing Power to Be Exercised Sparingly – The Court reiterated that inherent powers to quash proceedings should be exercised only in rare cases—Held: Criminal complaint disclosing prima facie offence cannot be quashed merely because genuineness of the same documents is under challenge in civil proceedings—Complaint revealed a cognizable offence of forgery and criminal conspiracy [Paras 7–10].

Overlap with Civil Proceedings – Not a Ground for Quashing – Court held that pendency of a civil suit relating to same documents does not bar prosecution for forgery—Criminal proceedings have higher standard of proof and distinct procedure—Held: Allegations of forgery must be tested independently in criminal trial—Civil nature of dispute does not dilute criminal culpability [Paras 9, 12, 15, 17].

Magistrate's Role – Application of Mind Established – Magistrate issued process only after recording statements of complainant and expert witness under Section 200 CrPC—Held: High Court failed to examine whether issuance of process was arbitrary—Order of Magistrate reflected prima facie satisfaction and due procedure [Para 4, 16].

Judicial Precedents – Scope of Inherent Powers – Reaffirmed legal principles from R.P. Kapur, Bhajan Lal, Trisuns Chemicals and Medchl Chemicals cases—Held: Criminal justice system must not be undermined by premature interference unless complaint is inherently frivolous or absurd—Supreme Court emphasized separate tracks of civil and criminal proceedings [Paras 7–13].

Decision – Appeal Allowed – Impugned judgment of High Court set aside – Criminal complaint reinstated – Magistrate directed to proceed in accordance with law and decide on merits [Para 18].

Criminal Law - Murder – Right of Private Defence – Conviction Partly Modified – The accused were acquitted by the trial court for causing two deaths and injuries in a group clash near their residence—High Court reversed acquittal and convicted all under Sections 302 and 149 IPC—Supreme Court held that the incident originated near the house of accused, and evidence showed they were initially attacked—Held: Accused had right of private defence—Only accused Ramesh exceeded that right—His conviction modified to Section 304 Part II IPC—Others acquitted [Paras 1–4, 25–33].

Common Object – Section 149 IPC – Not Attracted – Court held that there was no unlawful assembly with a common object to commit murder—Alleged acts were not premeditated—Others in the group did not share intention to kill—Held: Conviction of other accused under Section 149 IPC unsustainable—Only individual liability applicable [Paras 27–29].

Transferred Malice – Applicability of Section 301 IPC – Second gunshot fired by accused Ramesh intended for one person hit a bystander (Jamuni Bai)—Court held that when right of private defence is exceeded, and a different person is unintentionally killed, Section 301 IPC applies—Conviction for culpable homicide under Section 304 Part II upheld [Paras 31–32].

Non-Explanation of Injuries – Not Fatal but Significant – Accused sustained grievous injuries including fracture—Prosecution failed to explain injuries—Held: Strengthens defence version and supports plea of private defence—Absence of explanation indicates suppression of true origin of conflict [Paras 15–18].

Private Defence – Scope under IPC Sections 96–102 – The Court reiterated that right of private defence is a statutory right and can extend to causing death in appropriate circumstances—Held: Accused were under threat near their residence and had no intention to initiate aggression—Action justified except in case of Ramesh who used excessive force [Paras 23–26].

Burden of Proof – Section 105 Evidence Act – No Requirement of Specific Plea – Accused need not specifically raise defence under Section 313 CrPC—It can be established through evidence on record—Held: Failure to plead does not defeat lawful defence where facts support it [Para 24].

Decision – Appeals Partly Allowed – Conviction of Ramesh under Section 302 IPC modified to Section 304 Part II IPC—Sentence of 7 years RI for each count with concurrent running affirmed—Conviction under Section 27 Arms Act upheld—All other accused acquitted—Bail bonds discharged [Para 33].

Criminal Law - Rape and Murder of Minor – Conviction Set Aside – Acquittal Ordered – The appellant was convicted for rape and murder of a 5-year-old child and sentenced to death by the trial court—High Court upheld the conviction but commuted death sentence to life imprisonment—Supreme Court held that none of the circumstantial evidence established guilt beyond reasonable doubt—Held: Suspicion, however grave, cannot replace proof—Conviction set aside and appellant acquitted, Acquittal [Paras 1–11].

Circumstantial Evidence – Legal Requirements Not Met – The prosecution relied on five circumstances: last seen, abnormal conduct, recovery of blood- and semen-stained underwear, false alibi, and absconding—Court held that none of these, individually or cumulatively, proved the case—False alibi and absconding not established; recovery evidence inconclusive—Held: In absence of cogent and complete chain of evidence, conviction unsustainable [Paras 5–9].

Last Seen – Child Witness Not Reliable – The only testimony on last seen was from a 4-year-old child examined after one year—Statement lacked time or date specificity—Other girls or shopkeeper not examined—Held: Evidence too vague and unreliable to support conviction [Para 5(i)].

Abnormal Behaviour – Not Incriminating – Question asked by accused about punishment for rape and murder held insufficient—Court held such query could stem from fear or nervousness under police scrutiny—Held: Not indicative of guilt or mens rea [Para 5(ii)].

Recovery of Clothes – Forensic Link Not Established – Underwear stained with blood and semen recovered at accused's instance—However, ownership of clothes not proved—Blood group of accused not known—Possibility of self-blood contamination not ruled out—Held: Not reliable as incriminating evidence [Para 5(iii)].

Plea of Alibi – Not Raised – High Court erred in assuming false alibi—Court clarified no such plea was taken by accused under Section 313 CrPC—Held: Denial of being on leave from job does not constitute legal alibi—False alibi cannot be used as an adverse inference [Para 5(iv)].

Absconding – Not Proved – Accused was repeatedly present before police, including on 21st March—Arrest memo failed to show absconding—Held: No evidence of conscious evasion—Inference of absconding unjustified [Para 5(v)].

Principles of Criminal Justice – Grave Suspicion Not Enough – The Court reiterated that guilt must be established beyond doubt—Brutality of crime cannot substitute for evidence—Prosecution must exclude all hypotheses consistent with innocence—Held: Courts must guard against convictions based on emotion over evidence [Paras 7–8, 10].

Decision – Appeal Allowed – Conviction under Sections 302 and 376(2)(f) IPC set aside – Appellant acquitted and released unless required in another case [Para 11].

Criminal Law – Quashing of FIR - Corruption – Inordinate Delay in Sanction – Violation of Article 21 – Proceedings Quashed – Appellant, a retired Executive Engineer, was accused of possessing disproportionate assets amounting to ₹50,600 – No sanction granted for over 13 years – Supreme Court held that delay violated the right to speedy trial under Article 21 and rendered trial futile – Held: Permitting prosecution at such belated stage would amount to injustice – Proceedings quashed [Paras 2–4, 6, 9–10].

Right to Speedy Trial – Article 21 – Delay in Investigation and Sanction – Court reiterated that right to speedy trial encompasses all stages including investigation and grant of sanction – Delay must be explained and justified – Held: In this case, State failed to justify 13-year delay, and authorities themselves were unconvinced about the strength of the case – Proceedings could not continue [Paras 5–7].

Public Interest – Delay Defeats Anti-Corruption Purpose – Court emphasized that corruption cases must be tried expeditiously in public interest – Held: Delay in prosecution either shows administrative inefficiency or is used to harass accused – In either case, it compromises justice – Accused’s career, promotions, and personal liberty affected by prolonged pendency [Paras 6–7].

Sanction for Prosecution – Failure to Grant Within Reasonable Time – Despite recommendations in 1992 and again in 2000, sanction was never formally granted until after appeal was filed in Supreme Court – Held: Post-facto grant of sanction insufficient to cure prolonged inaction – State conduct indicated lack of seriousness in pursuing prosecution [Paras 4, 6].

Decision – Appeal Allowed – Proceedings initiated under PS No. 0017/88 quashed – Order of High Court set aside – Further prosecution held to be unjustified and a mere ritual – No further orders required [Paras 9–10].

Criminal Law - Murder – Common Intention – Conviction under Section 302, 34 IPC Upheld – Appellants jointly assaulted their brother with lathis and chura leading to his death – Though no formal charge under Section 34 IPC, Supreme Court held that common intention was evident from the manner of attack, refusal to stop even after intervention, and denial of water to the injured – Held: Conviction under Section 302 read with Section 34 IPC valid – No prejudice caused due to absence of charge under Section 34 [Paras 10–16].

Ocular Testimony – Reliability of Injured and Natural Witnesses – Wife of deceased (PW 4) sustained injury during attack and deposed credibly – Her testimony corroborated by other eyewitnesses (PW 9 and PW 11) and medical evidence – Held: Witnesses were natural and their presence at scene established – Evidence consistent and trustworthy [Paras 11–12].

Framing of Charge – Section 34 IPC – No Fatality Due to Omission – Court reiterated that absence of a formal charge under Section 34 does not vitiate conviction if evidence proves common intention – No failure of justice shown – Applied ratio from Willie Slaney and related precedents [Paras 13–14].

Common Intention – Inferred from Conduct – Court noted that the attack was not spontaneous – Refusal to give water to the injured victim and persistent assault demonstrated premeditation – Held: Common intention developed at the scene and was evident in coordinated actions of the assailants [Para 15].

Appellate Duty – Reappraisal of Evidence in Criminal Appeals – Though High Court affirmed the trial court without detailed reasoning, Supreme Court undertook its own review of facts due to the long passage of time since the incident – Held: Findings of lower courts fully supported by evidence – No interference warranted [Paras 10, 16].

Decision – Appeal Dismissed – Conviction under Section 302 IPC read with Section 34 IPC sustained – Sentence of life imprisonment affirmed [Para 16].

Education Law - Postgraduate Medical Admission – State's Power to Prescribe Reservation – MCI Regulation 9 Prevails on Eligibility Standards – Appeals Allowed – The State of Punjab issued a notification lowering minimum qualifying marks for admission to postgraduate medical courses and making reservations – High Court struck down the notification for being contrary to MCI’s Regulation 9(2) – The Supreme Court upheld reservation under Article 15(4) as a constitutional prerogative of the State but quashed the reduced marks criterion as violative of MCI's prescribed standards – Held: States may make reservations, but cannot dilute academic standards fixed by MCI under Entry 66 List I [Paras 1-2, 9-12, 19].

MCI Regulations – Minimum Marks of 50% Mandatory – Relaxation to 40% Held Invalid – Regulation 9(2) of the Postgraduate Medical Education Regulations, 2000 prescribes a 50% qualifying mark for entrance tests – Held: States cannot unilaterally reduce this to 40% or exempt subjects altogether – Standards fixed by MCI are binding under Article 246 read with Entry 66 List I [Paras 13, 16-19].

Reservation Power – Article 15(4) – Independent of MCI Role – The Court held that while MCI determines standards, reservation for socially and educationally backward classes is within State’s domain under Article 15(4) – Held: States are empowered to implement reservation without MCI approval, provided academic standards are not compromised [Paras 10-12].

Hybrid Mode of Selection – Combination of Marks and Entrance – Not Properly Adopted – The State’s claim that selection was based on cumulative MBBS performance and entrance test was rejected – Held: Admission based solely on entrance test means Regulation 9’s minimum 50% requirement is binding – No valid hybrid procedure followed [Paras 14-16].

Private Colleges – Reservation in Government Quota Valid – Open Question for Management Seats – The Court noted that the Government can apply reservation policy to its 50% quota in private colleges – On management quota, Court left issue open due to insufficient data – Held: Matter can be adjudicated in future cases with appropriate pleadings [Para 20].

Decision – Appeals Allowed – Reservation under Article 15(4) upheld – Lowering of eligibility marks struck down – Notification upheld in part and set aside in part – Fresh selection to be conducted in accordance with MCI Regulations [Paras 19, 21].

Criminal Law - Dowry Death – Conviction Under Section 304B IPC Set Aside – Acquittal Ordered – Appeal Allowed – The appellant was convicted under Section 304B IPC for the death of his wife, who committed suicide within seven years of marriage – Supreme Court held that while the victim was mentally disturbed by the appellant’s immoral conduct, there was no credible evidence to show she was harassed or subjected to cruelty “for or in connection with” dowry demand – Serious omissions, contradictions, and lack of independent corroboration in prosecution evidence rendered the conviction unsustainable – Acquittal directed [Paras 2-12].

Essential Ingredients of Section 304B IPC – Not Fulfilled – Though the death occurred within seven years of marriage and was unnatural (burn injuries), the prosecution failed to establish the two critical ingredients: cruelty or harassment “soon before death” and its connection with a dowry demand – Held: Mere mental cruelty due to immoral behavior does not meet the threshold under Section 304B unless clearly tied to dowry [Paras 5-6, 10].

Evidentiary Deficiencies – Vague, General Testimonies – Lack of Corroboration – Witnesses (mother, father, brother of deceased) gave inconsistent, vague statements – No neighbors or independent witnesses examined – Contradictions in prior statements undercut reliability – Crucial letters from deceased omitted mention of dowry harassment – Held: Conviction cannot rest on such infirm testimony [Paras 9-10].

Conduct of Accused – Immoral Acts Cause of Suicide – Not Dowry Related – Evidence suggested the deceased was emotionally distressed due to the appellant bringing women of “bad character” home – The suicide note (Exbt. P/9) expressed fear and dismay but made no reference to dowry or financial demands – Held: Cause of death linked to non-dowry related cruelty; thus offence under Section 304B not established [Paras 8-10].

Duty of High Court – Failure to Reappraise Evidence – Judgment Set Aside – High Court merely affirmed trial court findings without independent scrutiny of material evidence – Failed to consider contradictions and omissions in prosecution case – Held: Appellate court must reassess evidence, especially when liberty is at stake [Paras 7, 11].

Decision – Appeal Allowed – Conviction and sentence under Section 304B IPC set aside – Appellant acquitted and directed to be released forthwith if not required in any other case [Para 12].