Cruelty – Decree of Divorce – Section 13(1)(ia) of Hindu Marriage Act – Divorce Affirmed – The husband filed for divorce on grounds of mental cruelty; the wife filed counter-allegations including domestic violence – Family Court granted divorce which was upheld by the High Court – Supreme Court observed long-standing acrimony and prolonged separation since 2009, holding that false complaints constituted cruelty – Decree of divorce upheld [Paras 3.2–3.7, 7].

Domestic Violence – Compensation – DV Act Proceedings – Wife Entitled – Though initial complaint under DV Act was dismissed, appellate courts found the husband guilty of domestic violence and directed compensation of ₹2,00,000/-, later enhanced to ₹7,00,000/- – SLP against this enhancement was dismissed by Supreme Court – Proceedings under DV Act thus culminated in favour of wife [Paras 3.3–3.5].

Child Marriage Expenses – Contribution by Father – Reasonable Demand – Appellant-wife sought ₹10,00,000/- for daughter’s marriage – Despite husband’s denial of income, Court held he was capable of contributing – Directed to pay ₹10,00,000/- by 15th October 2025 – Held: Contributing to child’s marriage is a natural parental duty irrespective of spousal disputes [Paras 5–10].

Final Decision – Appeals Partly Allowed – Divorce decree affirmed – Supreme Court directed husband to pay ₹10,00,000/- towards daughter’s marriage expenses, failing which the appeals would be revived – Appeals accordingly disposed of [Paras 10–13].

PIL - Disability Rights – Constitutional Interpretation – RPwD Act – Judicial Directions – Court Declares Accessibility a Constitutional Mandate – The Court held that disability is not a deficit but a form of diversity – Failure to provide accessible systems is a constitutional violation – Courts must uphold inclusive frameworks to ensure dignity, autonomy, and equality for persons with disabilities [Paras 1–5, 27–35].

Institutional Care – Systemic Reforms – State Failure in Compliance – Directions Issued – The Court noted longstanding non-compliance by several States and UTs with orders concerning implementation of the RPwD Act – Directed nationwide monitoring through National Law Universities under “Project Ability Empowerment” to audit care institutions and recommend systemic reforms [Paras 6–11, 36–47].

Care Institutions – Monitoring Mechanism – Project Ability Empowerment – Eight National Law Universities assigned regional jurisdiction to inspect institutions housing persons with cognitive disabilities – Detailed thematic parameters outlined including resident profiling, health care, rehabilitation, education, infrastructure, and grievance redressal – Directions given for detailed report within six months [Paras 36–38, 47].

International Law – UNCRPD and Other Treaties – Interpretation and Application – The Court relied heavily on the UNCRPD and international human rights conventions to affirm the dignity and autonomy of persons with disabilities – Recognised the obligation of State parties to ensure community-based care, deinstitutionalisation, and accessibility [Paras 25–34].

Reservation Policy – Section 34 RPwD Act – Upward Migration for Meritorious PwD Candidates – Discriminatory Practice Condemned – The Court highlighted denial of “upward migration” to meritorious PwD candidates in employment, calling it hostile discrimination – Directed Union of India to explain if corrective action has been taken – Held: Reservations must reach the genuinely disadvantaged, and merit-based PwD candidates should not be counted against reserved seats [Paras 48–54].

Final Decision – Monitoring Mandated – Central and State Authorities Directed to Cooperate – Court directed constitution of “Project Ability Empowerment” and ordered all stakeholders including District Magistrates, Social Welfare Departments, and Ministry of Social Justice to fully support the monitoring – Directed interim funding of ₹25 lakhs per NLU and fixed deadline for report submission – Matters listed for further monitoring on 13th March, 2026 [Paras 44–47, 55–57].

Environmental Law – Environmental Clearance – Building and Township Projects – Appeals under Section 22 of the NGT Act filed by CREDAI, Godrej Properties, and Sai Sahara Developers challenging NGT order dated 09.08.2024 – NGT had held that General Conditions (GC) under EIA 2006 Notification apply to Item 8(a) (Building and Construction) and Item 8(b) (Township/Area Development) – Directed MoEF&CC to treat such projects within 5 km of protected areas, critically/severely polluted areas, eco-sensitive zones, and inter-State boundaries as Category A projects requiring clearance by Central EAC – Supreme Court held NGT misread EIA 2006 – Column 5 of Schedule never subjected Items 8(a) & 8(b) to GC – Legislative intent was to decentralize appraisal to SEIAA/SEAC – General Conditions apply only where expressly provided – Kerala HC’s quashing of 2014 Notification was on procedural grounds and did not revive GC applicability [Paras 3, 11–21, 23–25].

Interpretation of EIA 2006 Notification – Literal Rule – Court reiterated that delegated legislation must be read literally – Wherever GC intended, Schedule expressly so provided (e.g., mining, thermal power, river-valley, cement, chemical industries, etc.) – Absence of such stipulation in Column 5 of Entry 8 meant deliberate exclusion – NGT erred in purposive reading contrary to statutory text [Paras 13–14, 26–27].

Sustainable Development – Balance Between Ecology and Development – Court reaffirmed principle of sustainable development as part of Indian constitutional and international law – Noted that while environmental protection is crucial, development cannot be stalled – Real estate projects directly affect housing rights under Article 21 – SEIAAs being expert statutory bodies are better placed to appraise projects in respective States/UTs – Over-centralization would burden MoEF&CC and delay housing delivery [Paras 31–37].

Validity of 2025 Notification – MoEF&CC issued Notification S.O. 523(E) dated 29.01.2025 clarifying that GC does not apply to Items 8(a) & 8(b) – Supreme Court in Vanashakti v. Union of India [W.P. (C) No. 166/2025, order dated 05.08.2025] upheld the Notification (excluding Note 1 to Entry 8(a) exempting industrial sheds, schools, colleges, hostels) – Held such exclusion arbitrary and inconsistent with EP Act – Clarificatory OM dated 30.01.2025 extending notification to Kerala also upheld – Present appeals disposed of in light of coordinate Bench ruling [Paras 22–25].

Jurisdiction of NGT – Court held NGT exceeded its jurisdiction by entertaining abstract policy questions absent a lis or claimant – Sections 14–15 of NGT Act envisage disputes involving relief, compensation, or restitution – Directions altering statutory framework of EIA regime beyond its mandate [Paras 5.7, 7.4, 24.1].

Principles Restated – (i) GC under EIA 2006 never applied to Building & Township projects – (ii) Delegated legislation must be interpreted literally – (iii) SEIAA/SEAC remain competent statutory bodies for appraisal – (iv) Sustainable development requires balancing environmental safeguards with housing needs – (v) NGT cannot transgress statutory limits by issuing directions contrary to legislative scheme [Paras 24.1–24.3, 25].

Decision – Appeals disposed of – Impugned NGT order dated 09.08.2024 does not survive – 2025 Notification (excluding Note 1 to Entry 8(a)) and OM dated 30.01.2025 presently hold the field – No order as to costs – Pending applications disposed of [Paras 25–27].

Anticipatory Bail – Delay in FIR – Allegations of Mutation on Forged Documents – FIR lodged in 2019 regarding mutation entries based on sale deed dated 18.05.1996 executed on forged powers of attorney in names of deceased landowners – Appellants (A5 and A6), Circle Officer and Talathi at the time, certified mutation entries Nos. 15177 and 15180 in 1996, which were later cancelled by Sub-Divisional Officer in 1998 – FIR lodged after more than 20 years – Supreme Court held that long delay cannot by itself efface allegations of misuse of official position in facilitating fraudulent transfer of immovable property [Paras 3–4, 7–9, 11, 13–14].

Official Capacity – Scope of Criminal Liability – Appellants contended that certification of mutation entries was done in discharge of official duty on the basis of facially valid registered sale deed – No role in preparation of forged documents, no dishonest intention, and no personal gain alleged – Supreme Court held that whether appellants shared criminal intent or colluded with beneficiary (A1) is a matter for trial and cannot be conclusively decided at anticipatory bail stage [Paras 5.1–5.2, 9, 12].

Custodial Interrogation – Necessity – Appellants argued case is based on existing documentary evidence and custodial interrogation unnecessary – Court held that even in documentary fraud cases, custodial interrogation may be required to trace the chain of transactions, ascertain complicity, and prevent tampering of records – Appellants had interim protection for nearly six years but did not fully cooperate with investigation – Justification for custodial interrogation upheld [Paras 5.5, 10, 14].

Delay in Bail Adjudication – Constitutional Concerns – Anticipatory bail applications filed in 2019 remained pending in High Court for nearly six years – Interim protection granted continuously until final rejection on 04.07.2025 – Supreme Court strongly disapproved indefinite pendency of bail applications affecting personal liberty – Reiterated earlier rulings (Nikesh Tarachand Shah, Siddharam Satlingappa Mehtre, Satendra Kumar Antil, Rajesh Seth, Sanjay, Rajanti Devi, Kavish Gupta, Amol Vitthal Vahile, etc.) – Directed High Courts and subordinate courts to decide bail/anticipatory bail applications expeditiously, preferably within two months [Paras 15–18.1].

Principles Restated – Anticipatory bail under Section 438 CrPC is a statutory right, not a fundamental right – Courts must balance personal liberty with fair investigation – Prolonged pendency of bail applications amounts to denial of justice – Administrative directions must be issued by High Courts to prioritise bail matters [Paras 16, 16.9, 17–18.1].

Decision – Appeals dismissed – Rejection of anticipatory bail by Bombay High Court upheld – Appellants at liberty to apply for regular bail, which shall be considered on its own merits, uninfluenced by observations in this judgment – Registrar (Judicial) directed to circulate judgment to all High Courts for compliance [Paras 19–20].

Sexual Harassment Complaint – Limitation under POSH Act – Complaint Held Time-Barred – The appellant, a faculty member at NUJS, filed a complaint of sexual harassment against the Vice-Chancellor in December 2023, with the last alleged incident occurring in April 2023 – The LCC rejected the complaint as time-barred – The Single Judge of the High Court reversed the LCC’s decision, holding that subsequent hostile acts extended the limitation – The Division Bench restored the LCC’s rejection, holding the administrative acts post-April 2023 did not constitute sexual harassment or extend the limitation period – Held: The last actionable incident of sexual harassment occurred in April 2023; subsequent administrative measures were unrelated and did not amount to continuing sexual harassment – Complaint was rightly dismissed as time-barred under Section 9 of the POSH Act – Appeal dismissed [Paras 1–2, 4–7, 13–14, 21–26, 29–32].

Continuing vs Recurring Wrong – Application under POSH Act – The Court distinguished between a “continuing wrong” where the injury persists, and a “recurring wrong” where new cause of action arises – Held: The act of April 2023 was a completed act and not a continuing one – Later administrative actions, although adverse, were collective decisions unrelated to any sexual misconduct – Thus, did not revive limitation [Paras 28–29].

Judicial Approach – Rejection of Complaints at Threshold – The Court clarified that while limitation may be a mixed question of law and fact, a complaint can be dismissed at the threshold if it is patently barred by limitation – Analogous to Order VII Rule 11 CPC – This applied in the present case [Para 15].

Final Decision – Appeal Dismissed – The Supreme Court upheld the Division Bench's view that the complaint was time-barred and should not have been revived – However, the Court directed that the judgment noting the wrongdoing be added to the Vice-Chancellor’s resume as a lasting consequence – No relief granted to appellant, but wrongdoing noted [Paras 32–35].

Civil Law – Limitation – Validity of Sale Deed – Plaintiffs claimed 1/3rd share in agricultural land – Alleged that sale deed dated 14.06.1973 executed in favour of defendant was fraudulent and without consideration – Trial Court dismissed the suit as time-barred – First Appellate Court decreed the suit holding that the sale deed was void and suit filed within 12 years under Article 65 Limitation Act, 1963 – High Court affirmed the decree but held Article 59 applied, though suit was still within limitation – Supreme Court clarified that since sale deed was void ab initio, Article 65 (12 years) applied, not Article 59 (3 years) – Appeal dismissed [Paras 3–15, 24–41].

Limitation Act – Article 65 vs Article 59 – Court distinguished between void and voidable instruments – Article 59 applies only to voidable instruments requiring cancellation (fraudulent misrepresentation as to contents) – Article 65 applies to suits for possession based on title where the impugned document is void/void ab initio (fraud as to character or want of consideration) – Plaintiff, not being party to the void transaction, need not seek cancellation – Merely seeking joint possession suffices [Paras 25–29, 31–33].

Evidence – Proof of Fraudulent Sale Deed – Plaintiffs proved that thumb impressions on sale deed were not theirs – Expert testimony unchallenged – Defendant failed to produce original sale deed or prove payment of sale consideration of ₹15,000 – Husband of defendant, alleged to have paid balance ₹6,000, not examined – Attesting witness (brother of defendant) considered biased – Sarpanch attesting witness deceased – Courts held absence of valid execution and want of consideration rendered deed void [Paras 27, 35–38].

Transfer of Property Act, 1882 – Section 54 – Essential element of sale is transfer of ownership for a price – Sale without consideration is void – In present case, defendant failed to prove payment of consideration – Sale deed therefore void, conferring no title [Paras 34–38].

Principles Restated – (i) Void documents need not be cancelled; possession can be claimed under Article 65 – (ii) Burden lies on party relying on sale deed to prove valid execution and consideration – (iii) Limitation runs from date possession becomes adverse, not from date of void deed – (iv) Courts must distinguish between fraudulent misrepresentation as to character (void) and contents (voidable) of document [Paras 28–29, 31–33, 39–40].

Decision – Supreme Court dismissed appeal – Held that sale deed dated 14.06.1973 was void ab initio – Suit filed on 28.02.1984 within 12 years of sale deed was within limitation under Article 65 – High Court erred in applying Article 59 but rightly upheld maintainability of suit – Plaintiffs entitled to joint possession – Appeal dismissed [Paras 40–41].

Tenancy Law - Landlord–Tenant – Challenge to Landlord’s Title – Estoppel against Tenant – Relinquishment Deed of 1953 (Exh. P-18) – Findings of Courts Below Perverse – Tenant inducted in 1953 by Ramji Das under a valid relinquishment deed executed by Sua Lal; rent paid to Ramji Das for decades and, after his death, to the landlady’s husband – Held: a tenant who entered under the landlord and paid rent for over half a century cannot dispute the landlord’s title; courts below ignored material evidence, warranting interference [Paras 5–7, 10–12].

Will/Probate – Production of Probate Order at Appellate Stage – Order 41 Rule 27 CPC – Proof of Ownership in Eviction Suits – High Court erred in refusing to take on record the 09.02.2018 probate order (Probate Case No. 8/2013) – Probate, though not mandatory, imparted legal sanctity to the Will bequeathing the shop to the plaintiff; in eviction suits, ownership need not be established as strictly as in a title suit – Rejection of additional evidence unsustainable [Paras 8–10].

Attornment/Notice – Registered Notice (Exhs. P-9 to P-11) – Presumption of Service – Trial court erred in discarding registered notice for want of acknowledgment – First appellate court (initial round) rightly noted presumption of receipt when sent to correct address; notice conveyed bequest and assertion of ownership – Attornment established; no rent shown paid from January 2000 – Default proved [Paras 11–12].

Bona Fide Requirement – Expansion of Existing Family Business – Adjacent Premises – Landlady intended to join and expand husband’s sweets and savouries business; sons also involved – Need genuine; not disputed – Requirement established [Para 13].

Appellate Interference – Concurrent Findings – Perversity – Where courts below ignore material evidence and proceed on conjectures (suspicion about Will; ignoring relinquishment deed; overlooking presumption on registered notice), interference justified – Orders of trial court, first appellate court (on remand), and High Court set aside [Paras 10, 12, 14].

Relief/Decree – Eviction and Arrears – Suit decreed for eviction on grounds of rent default and bona fide need; arrears payable from January 2000 till delivery – Conditional protection: tenants may remain for six months subject to (i) undertaking within two weeks to vacate in six months and (ii) payment of arrears within one month; failing which, summary eviction permissible [Para 14–15].

Criminal Law - Sections 420, 468, 471 IPC - Forgery – Authorship and Chain of Custody – Sections 463, 464, 468 IPC – Conviction Unsustainable – Alleged tampered documents passed through hands of admission clerk, principal, and university before detection – Prosecution failed to prove appellant authored or had exclusive custody of forged documents – Suspicion, however grave, cannot substitute proof beyond reasonable doubt [Paras 8, 13–14].

Handwriting/Forensic Proof – Absence of Expert Opinion – Visual Overwriting Inference Unsafe – Courts below wrongly relied solely on apparent overwriting without handwriting expert corroboration – Held: When authorship is central to establish guilt, failure to examine expert or direct witness is fatal to prosecution [Paras 9–10].

Mens Rea – Sections 420, 471 IPC – Intention to Cheat Not Proved – Documents scrutinized and stamped by college authorities – No evidence that appellant knew of tampering or had dishonest intention to secure admission – Mental element not established [Para 11].

Section 313 CrPC – Compound and Omnibus Questions – Prejudice Caused – Incriminating circumstances not fairly and distinctly put to accused – Violated valuable statutory right of defence – Reliance on such defective examination impermissible [Para 12].

Benefit of Doubt – Where two reasonable views possible, benefit goes to accused – Prosecution failed to prove exclusive control or authorship of forged documents – Conviction set aside [Paras 13–15].

Decision – Appeal Allowed – Conviction under Sections 420 r/w 511, 468, and 471 IPC together with sentences set aside – Appellant acquitted [Para 15].

Criminal Law - Police Duty – Registration of FIR – Section 154 CrPC – Mandatory Nature – Police informed of MLC involving appellant (head injury from assault during riots) on 14.05.2023 but failed to register FIR – High Court erred in blaming victim’s family for not lodging report – Held: Once information of cognizable offence is received, FIR must be registered; dereliction of duty established [Paras 14–16, 18–19].

Constitutional Bench Precedent – Lalita Kumari v. Govt. of U.P. (2014) 2 SCC 1 – Applied – Registration of FIR mandatory if information discloses cognizable offence; no preliminary inquiry permissible except in limited categories – Police failure in present case contrary to binding law [Paras 16–17].

Eyewitness Testimony – Appellant as Victim and Eyewitness – Aged 17 years – Claimed he witnessed fatal assault on Vilas Mahadevrao Gaikwad and was himself attacked by same assailants – Police ignored testimony and did not investigate identification of assailants – Failure undermined rule of law [Paras 12, 22].

Dereliction of Duty – Superintendent of Police – Section 154(3) CrPC – Appellant’s complaint dated 01.06.2023 ignored by SP, Akola – Failure to act or inquire despite statutory duty – Cause for serious concern; departmental and disciplinary proceedings directed [Paras 20–21].

Police Impartiality – Duty to Act Without Bias – Officers must shed religious/casteist prejudices – Failure to investigate properly in riot context indicates bias or gross negligence – Police must act as neutral guardians of law [Para 23].

Relief/Orders – Appeal Allowed – Direction to Secretary, Home Ministry, Maharashtra to constitute SIT of senior police officers from both Hindu and Muslim communities – SIT to investigate appellant’s assault and related allegations by registering FIR – Disciplinary action against erring officers – Sensitization measures for police force mandated – SIT report to be filed before Supreme Court within 3 months [Paras 24–26].