Land Acquisition – Compensation – Exemplar Allotment by Beneficiary Body – Valid Basis – Enhanced – Supreme Court held that GIDC’s own allotment of nearby Plot No. 7/1 at ₹180/sq. mt. (1988) for commercial use is a valid exemplar for valuation of appellants’ acquired agricultural land – Allotment considered sufficiently proximate in time and location to use as base rate with adjustments [Paras 6–10, 14].

Market Value Determination – 5% Increment for One-Year Gap – 50% Deduction for Development and Size – Applied – Court granted 5% increase to ₹190/sq. mt. to account for time gap between exemplar allotment and acquisition notification (1989), and applied 40% deduction for development plus 10% for largeness – Final rate fixed at ₹95/sq. mt. [Paras 10–14].

Claim for Fruit Trees – No Evidence of Income – No Additional Award – Appellants claimed higher compensation for fruit-bearing trees (lemon, mango, guava) – Court found no proof of yield or sale income – APMC report only confirmed existence of trees – Compensation of ₹1,06,300/- as awarded by SLAO affirmed [Para 15].

Standard of Valuation – Judicial Guesswork Permissible – Precision Not Required – Court reiterated that market valuation involves judicial estimation and approximation – Not an algebraic exercise – Broad principles and prudence sufficient [Paras 11, 13].

Decision: Appeal allowed partly – High Court’s judgment dated 14.08.2015 and Reference Court’s award modified – Compensation for acquired land enhanced from ₹30 to ₹95 per sq. mt. – SLAO’s award revised accordingly – All statutory benefits and interest to be granted as per law – No additional compensation for trees [Paras 17–18].

Civil Law - Gift vs. Will – Determination of Nature of 1985 Document – Settlement Deed Held Valid – Despite the document being titled as a Will by the father, the Supreme Court held that its content, structure, and operative clauses evidenced a gift/settlement in praesenti – The donor retained life interest and limited rights, but unequivocally conveyed ownership to the daughter – The High Court rightly reversed concurrent findings of the lower courts – Held: The deed conveyed vested rights in praesenti and cannot be treated as a Will [Paras 10-15.2].

Acceptance of Gift – Proof from Conduct – Gift Upheld – The donee had presented the gift for registration and was in possession of the original deed – These acts amounted to valid acceptance under Section 122 – Delivery of physical possession not essential for a valid gift – Conduct evidenced acceptance and made the gift irrevocable [Paras 6.1, 6.2, 6.4, 11.1, 14.1, 15.2, 18].

Unilateral Revocation of Gift – Not Permissible – Cancellation Deed Void – Defendant No.1 (father) could not unilaterally cancel the 1985 gift/settlement – The cancellation deed and the subsequent sale deed executed in 1993 were declared void and non-binding on the donee – Held: Once accepted, a gift cannot be revoked unilaterally unless specifically provided in the instrument [Paras 6.4, 11, 14.1, 18].

Possession and Mutation Entries – No Presumption of Ownership – Appellant’s Reliance on Possession Invalid – Possession and revenue record mutation post-sale deed in favour of appellant did not establish ownership – Such entries only indicate who pays revenue and carry no presumption of title [Paras 6.6, 18].

Composite Nature – Gift and Settlement Elements – Retention of Life Interest Not Fatal – A document may contain elements of both gift and settlement – Reservation of life interest does not negate the immediate transfer of ownership – Nomenclature is irrelevant; content determines character – Document must be read harmoniously to give effect to the transfer [Paras 11.3-11.5, 14,

15.2].

Final Decision – Appeal Dismissed – Gift/Settlement Confirmed – The Supreme Court affirmed the High Court’s judgment – Ext.A1 document declared a valid settlement deed – Cancellation and sale deeds held invalid – Appeal dismissed with no order as to costs [Paras 20-21].

Criminal Law - Murder – Common Intention – Conviction Under Section 302/34 IPC – Conviction Upheld – The appellant along with two co-accused allegedly assaulted the deceased with a knife leading to his death – Courts below found consistent eyewitness accounts confirming the appellant’s presence and role – Minor discrepancies in witness statements were not found fatal – Held:

Conviction under Section 302 read with Section 34 IPC justified – Benefit of Section 304-I not applicable due to appellant being armed with knife indicating prior intent [Paras 3, 6, 20, 23].

Delay in Recording Statements – Explanation of Riot and Law-and-Order Issues – No Adverse Inference – Delay of 2/3 days in recording eyewitness statements under Section 161 CrPC explained due to communal tension and police’s focus on restoring law and order – Held: Delay not fatal to prosecution where satisfactorily explained [Paras 21].

Non-examination of Informant as Prosecution Witness – Informant Examined as

Defence Witness – No Prejudice – Trial Court had benefit of her testimony which aligned with FIR and other eyewitness accounts – Held: No adverse inference due to party examining her as defence witness instead of prosecution [Para 22].

Remission and Premature Release – Right to Consideration Under Applicable Policy – Liberty to Apply Afresh – Appellant had completed over 14 years of actual imprisonment and over 20 years with remission – Rejection based on incorrect interpretation of policy (requiring 24 years including remission) – Held: Appellant may file fresh representation which shall be considered in light of law and beneficial policy in force at time of eligibility [Paras 24-30].

Final Decision – Appeal Dismissed – Conviction and sentence under Section 302 IPC confirmed – Liberty granted to appellant to reapply for remission, to be considered expeditiously within three months [Paras 31].

Criminal Law - Rape Allegation – Promise of Marriage – Quashing of Proceedings – Appeal Allowed – The appellant sought quashing of criminal proceedings alleging rape and cheating on the ground that the relationship was consensual and the alleged promise of marriage, if any, came post facto – Supreme Court found that there was no inducement through false promise of marriage preceding the sexual relationship – The complainant’s own statements did not reveal coercion or inducement prior to intercourse – Held: Continuation of prosecution would amount to abuse of process – Proceedings quashed [Paras 7-13].

Consent and Coercion – Inconsistent Allegations – Statements of Victim Contradictory – The Court noted the victim’s repeated voluntary visits to the hotel and lack of immediate complaint despite alleged trauma – The allegations of coercion and forceful intercourse were held to be incompatible with the surrounding circumstances – Held: The narrative was inherently improbable and prosecution unsustainable [Paras 8-12].

Exercise of Inherent Powers – Section 482 CrPC – Justified in Exceptional Cases – Supreme Court emphasized that continuation of baseless prosecution would violate fairness and liberty – Held: This was a fit case for exercise of inherent powers under Section 482 to quash the trial pending before the Sessions Judge, Mahila Court, Erode [Para 13].

Final Decision – Appeal Allowed – Proceedings in S.C. No. 49 of 2022 quashed – Pending applications disposed of [Paras 14-15].

CBI Investigation – Jurisdiction of High Court – Direction Set Aside – The High Court while granting bail directed CBI investigation based on a statement under Section 161

CrPC – Supreme Court held that such a direction in a bail proceeding exceeded jurisdiction under Section 439 CrPC – Held: No exceptional circumstance justified invoking extraordinary power – Direction to CBI quashed [Paras 2, 6-8].

Scope of Bail Jurisdiction – Improper Extension to Investigative Oversight – The High Court issued directives after bail was granted by relying on unverified statements and confronting the Investigating Officer in court – Held: The jurisdiction in bail ends with the decision on bail and cannot extend to supervising or altering the course of investigation [Paras 3, 6-7].

Precedents on Jurisdictional Limits – Reaffirmed – The Court relied on earlier decisions including State of West Bengal v. CPDR, M. Murugesan, Seemant Kumar Singh, and

Man Singh Verma – Held: Courts must refrain from overstepping their statutory jurisdiction in criminal proceedings [Paras 3, 6].

Final Decision – Appeal Allowed – Impugned order set aside to the extent of CBI direction – Bail not opposed by State and left undisturbed – No interference with investigation facts [Paras 8-9].

Criminal Law – Registration of FIR - Inquest Proceedings under Section 174 CrPC – Limited Scope – Not a substitute for Investigation – Held: The purpose of an inquest under Section 174 CrPC is limited to determining the apparent cause of death and cannot substitute a criminal investigation when complaints disclose cognizable offences – Mere conclusion by police that deaths were due to depression does not justify non-registration of FIR – Inquiry under Section 174 does not extinguish the statutory duty under Section 154 CrPC [Paras 21-24].

Registration of FIR – Mandatory Duty under Section 154 CrPC – Held: When complaints disclose a cognizable offence, police is statutorily bound to register an FIR – Preliminary inquiry not permitted – Delhi Police’s failure to register FIRs in both cases despite serious allegations of caste-based discrimination and possible abetment of suicide was in violation of Lalita Kumari and Bhajan Lal principles [Paras 30-34, 39-40, 46].

SC/ST (Prevention of Atrocities) Act – Applicability of Section 18A – Held: The Act mandates registration of FIRs without any preliminary inquiry – Allegations of caste-based atrocities fell squarely within the framework of the Act – Police and institutional inaction violates statutory and constitutional duties [Paras 42-43, 46].

Hostel Deaths – Alleged Murders Mischaracterized as Suicides – Allegations ignored – Held: Written complaints by victims’ family members alleging murder, caste-based abuse, suspicious circumstances (e.g., signs of physical assault, bleeding, position of body) were dismissed without proper investigation – Police relied on postmortem and general statements to prematurely close the cases [Paras 3-6, 13-14].

Institutional Response – Failure of IIT Delhi to Investigate or Support – Held: IIT Delhi failed to initiate any impartial internal inquiry into allegations – No record of providing support or engaging with victim families – Delay in informing families, lack of transparency in crisis management highlighted systemic apathy [Paras 5-10, 15-17].

Educational Institutions – Duty of Care and Support – Held: Institutions are expected to act as ‘loco parentis’ and must proactively safeguard mental health of students – Failure to respond to early signs of distress or discrimination can lead to tragic consequences – Emphasized that IITs and similar institutions must establish systems to detect and prevent student suicides [Paras 47, 66].

Mental Health and Student Suicides – National Concern – Held: Rise in student suicides, especially among marginalized communities, is a systemic issue – Court recognized academic stress, discrimination, and lack of institutional empathy as root causes – Emphasized need for national reforms and accountability in higher education [Paras 53-58, 67-69].

Constitution of National Task Force – Held: Court directs setting up of an expert body to study causes of student suicides and recommend institutional reforms – Task Force to include psychiatrists, academics, and experts in education and equity – Interim report to be filed in four months; final in eight months – Supreme Court to monitor compliance [Paras 69-83].

Decision – FIRs Directed to be Registered – Appeal Allowed – Held: Complaints disclose cognizable offences under IPC and SC/ST Act – Police directed to register FIRs and commence investigation – Probe to be conducted by officer not below Assistant Commissioner of Police – Supreme Court retains seisin of the matter for monitoring investigation and implementation of institutional reforms [Paras 48, 84].
 

Civil Law – Title Suit – Declaration and Possession – Appellants' claim over suit land based on court auction in 1970 followed by sale deed and continuous possession – Trial Court decreed in appellants' favour but High Court reversed citing lack of documentary proof of original assignment to Govindu – Supreme Court held appellants established continuous possession and title through court auction and registered sale deed – State failed to prove legal resumption or title – Held: Appellants’ possession since 1970 and supporting evidence establish title – State’s claim of assigned land not supported by credible documents – Appellants entitled to compensation in lieu of land due to public construction [Paras 6–7, 16–18, 25–29, 85–86, 114–115]​.

Possession and Ownership – Presumption under Section 110 Evidence Act (now Section 113 of BSA, 2023) – Appellants in uninterrupted possession since 1970 – State unable to rebut presumption of ownership by proving its title – Court reiterated that possession raises prima facie presumption of ownership – State’s inability to show resumption order or patta documents undermines its claim – Held: Burden was on State to prove lawful resumption and ownership, which it failed to discharge [Paras 83–85]​.

Resumption Proceedings – Legality and Procedure – State claimed land was resumed in 1989 as assigned land under a conditional patta issued in 1943 – No resumption records or D-form patta were produced – DW1 (Mandal Revenue Officer) admitted issuance of patta passbook and revenue receipts to appellants – Held: Absence of resumption documentation renders takeover of land illegal – Constructed government building cannot defeat appellants’ right to compensation [Paras 18, 23, 114–116]​.

Limitation and Delay – Suit filed in 1996 for recovery of possession – State contended suit was barred due to 1989 resumption – Supreme Court observed appellants' uninterrupted possession until dispossession, and that State failed to prove due process of resumption – Held: Suit was maintainable and not barred by limitation as possession and cause of action were sufficiently proved [Paras 4, 114]​.

Government Land vs Private Title – Differentiation – Court emphasized difference between Land Patta Holders and Government Allottees – Highlighted that Pattadars have heritable, transferrable rights, whereas government assignees may not – In this case, appellants were recognized as Pattadars with legal standing under the 1971 Act – State could not produce assignment documents or invoke 1977 Act restrictions retroactively [Paras 40–44]​.

Compensation – Relief granted in lieu of land restoration – Court declined to order restoration of possession due to longstanding construction – Directed State to compensate appellants monetarily for wrongful dispossession of legally held land – Applied equitable principles where public purpose construction already completed [Paras 114–116]​.

Right to Property – Article 300-A of Constitution – Protection Against Deprivation Without Authority of Law – State Cannot Resume Land Without Due Process – Even if land is assigned, it is “property” under Article 300-A – Appellants held Pattadar Passbooks and paid land revenue – Held: The deprivation of property by the State without lawful authority violates Article 300-A – Compensation is constitutionally mandated [Paras 123-126].

Unconstitutional Conditions – No Compensation Clause in Assigned Land Patta – Clause Held Invalid – A clause in patta that deprives assignees of compensation on resumption was held unconstitutional – Violates fundamental rights under Articles 14, 21 and 31-A – State must not impose conditions requiring surrender of constitutional rights to receive government benefit – Held: State must compensate assignees at full market value even on resumption [Paras 115-122].

Section 80 CPC – Mandatory Statutory Notice – State Ignored Legal Notice – Adverse Inference Drawn – Appellants had issued valid notice under Section 80 CPC before filing suit – State failed to respond or act on it – Held: Statutory notice under Section 80 is not a mere formality; lack of response is against public policy and can attract adverse inference in trial [Paras 93-113].

Decision: Appeal allowed – High Court judgment set aside – Appellants held to have lawful title and possession – Entitled to compensation for deprivation of land due to illegal resumption by State.

Criminal Law - Murder – Alteration of Conviction – Sudden Fight Without Premeditation – Conviction Altered to Section 304 Part I – The appellant was convicted under Section 302 IPC for assaulting the deceased with a stick while his co-accused used the blunt side of an axe – Held: The incident occurred in a sudden fight without premeditation, and the nature of weapons and injuries did not suggest intent to kill – Exception IV to Section 300 IPC attracted – Conviction altered to Section 304 Part I and sentence reduced to period already undergone [Paras 12–14]. 
 
Appreciation of Evidence – Related and Interested Witnesses – Credibility Not Rejected Merely Due to Relationship – The appellant contended that the eye-witnesses were related to the deceased – Held: Relationship does not disqualify testimony; evidence of interested witnesses must be scrutinized cautiously, but cannot be discarded solely for that reason [Paras 8–9]. 
 
Nature of Weapons – Use of Stick and Blunt Side of Axe – No Undue Advantage or Cruelty – The Court noted that if the accused intended to kill, the sharp side of the axe could have been used – Use of agricultural tools and nature of assault indicated absence of cruelty or intent to cause death [Paras 12–13]. 
 
Sentencing – Period Already Undergone – Appellant Served 6 Years 10 
Months – Considering reduction of conviction to Section 304 Part I, the Court directed release based on sentence already served [Paras 14–15]. 
 
Judgment – Appeal Partly Allowed – Conviction Modified – The conviction under Section 302 IPC was set aside and altered to Section 304 Part I – Appellant sentenced to period already undergone and ordered to be released forthwith [Paras 15]. 
 

Limitation Law – Condonation of Delay – Liberal Approach for State – Delay Condoned with Costs – The appellant challenged the High Court’s order condoning a 1537-day delay in filing a Second Appeal by the respondent-State – The Court acknowledged that though the law of limitation applies equally to the Government, in the peculiar facts involving valuable Government land and absence of mala fides, delay deserved to be condoned – COVID-19 and prior filing of a Review Petition were also considered as contributing factors to delay – Held: The delay is condoned subject to cost of Rs. 50,000 payable by the State to the appellant – Second Appeal to be heard on merits [Paras 12, 15, 18-22]. 
 
Discretionary Power – Section 5 of Limitation Act – Not Mandatory to Condone Delay 
Even if Cause Shown – Exercise of Discretion Must Consider Negligence and Due Diligence – The appellant argued that the State was negligent and failed to show sufficient cause; Court emphasized that discretion to condone delay under Section 5 is not automatic and must be exercised judicially – However, due to the nature of the land and interest of substantial justice, discretion was exercised in favor of State [Paras 7-9, 12, 15]. 
 
Possession of Government Land – Dispute Involving State and Private Party – Necessity of Adjudication on Merits – The Court observed that the land in question was recorded as Government land and remained in the State's possession, reinforcing the need for a decision on merits rather than on limitation grounds alone – Suit originally dismissed, reversed in appeal, warranting further judicial scrutiny [Paras 1112]. 
 
Delay in Filing Review and Appeal – Two-Step Delay Considered Collectively – The Court accepted that a substantial portion of the delay was due to prior attempt to file a Review Petition, followed by Second Appeal filing delay due to pandemic – The delay from 2015 to 2020 was thus analyzed holistically [Paras 10, 12, 15]. 
 
Judgment – Appeal Dismissed – High Court Order Condoning Delay Upheld – Costs Imposed – The Supreme Court upheld the High Court’s order condoning the delay in filing Second Appeal – However, imposed costs of Rs. 50,000 to be paid by the State within one month, failing which the Second Appeal would be dismissed – Liberty granted to both parties to contest on all grounds before the High Court [Paras 19-23].