Criminal Law – Abetment of Suicide – Section 306 IPC – Evidence Insufficient – Presumption under Section 113A of the Evidence Act – Held: Presumption under Section 113A of the Evidence Act requires cruelty as defined in Section 498-A IPC to establish abetment of suicide – In the absence of cogent evidence of cruelty or harassment, the presumption cannot arise – Conviction under Section 306 IPC set aside [Paras 12-13].

Criminal Law – Dowry Prohibition Act – Section 4 – Demand for Dowry – Absence of Independent Corroboration – Held: Allegations of dowry harassment must be supported by credible evidence – Where prosecution fails to establish dowry demand, conviction cannot stand – Conviction under Section 4 of Dowry Prohibition Act set aside [Para 13].

Criminal Law – Appellate Review – Evidence Appreciation – Held: Courts below failed to properly assess evidence against the appellant (brother-in-law) – Conviction set aside due to lack of direct involvement or evidence linking him to abetment of suicide [Para 11].

Evidence Law – Section 113B, Evidence Act – Dowry Death – Applicability – Held: Presumption under Section 113B requires proof of cruelty or harassment soon before death – Absence of evidence of incessant harassment invalidates presumption under Section 113B [Para 13].

Decision: Appeal allowed – Conviction and sentence under Sections 306, 498-A IPC, and Section 4 of the Dowry Prohibition Act set aside.

Criminal Law – Culpable Homicide Not Amounting to Murder – Conversion of Conviction under Section 302 IPC to Section 304 Part I IPC – Sentencing – Appellants convicted for the murder of the deceased by the Trial Court and High Court under Section 302 read with Section 34 IPC – Trial Court sentenced appellants to life imprisonment – On appeal, Supreme Court held that the motive and circumstances of the assault do not establish premeditation or intent to murder – Assault caused by the appellants with deadly weapons proved to have been done with knowledge of likelihood of causing death but without clear intention to kill – Conviction altered from Section 302 IPC to Section 304 Part I IPC – Appellants sentenced to period already undergone, subject to a fine of ₹50,000 each to be paid to the deceased’s family, failing which additional six months simple imprisonment to be served [Paras 90-94].

Witness Testimony – Credibility of Sole Eye-Witness – Sole eye-witness Lata Bai (PW-10), the mother of the deceased, testified to witnessing the assault – Defence challenged her credibility due to delayed recording of her statement under Section 161 CrPC and alleged contradictions – Supreme Court upheld her testimony as credible and corroborated by medical evidence and other witnesses – Minor discrepancies held insufficient to undermine her testimony – Evidence of the hostile witnesses and informant Santosh (PW-6) partially relied upon for corroboration – Trial Court and High Court’s acceptance of her evidence upheld [Paras 50-84].

Motive and Circumstantial Evidence – Motive Not Clearly Established – Motive for the assault by the appellants on the deceased not conclusively proved – No evidence of premeditated intention or prior enmity – Circumstances indicated a sudden quarrel – Recovery of weapons corroborated the assault but motive remained ambiguous – Supreme Court held motive absence not fatal as guilt proved beyond reasonable doubt by other evidence [Paras 90-91].

Hostile Witnesses – Evidentiary Value – Informant Santosh (PW-6) and other non-official witnesses turned hostile – Their partial corroboration of the prosecution case used to support conviction – Supreme Court reiterated that hostile witnesses’ testimony need not be entirely discarded if parts are corroborated by credible evidence [Paras 76-77].

Medical Evidence – Injuries Sustained – Medical evidence confirmed grievous head injuries leading to the deceased’s death due to coma – Injuries consistent with weapons recovered – Medical reports corroborated eye-witness testimony and prosecution narrative – Supreme Court relied on the unchallenged testimony of medical witnesses to affirm the cause of death [Paras 69-70].

Seizure Evidence – Recovery of Weapons – Blood-stained axe and iron pipe recovered at appellants’ instance – Seizure witnesses turned hostile but admitted signatures on seizure memos – Supreme Court held seizure memos proved by the Investigating Officer and recovery valid – Deficiencies in procedure not fatal to the prosecution [Paras 67-68].

Decision: Conviction under Section 302 IPC altered to Section 304 Part I IPC – Sentence of life imprisonment reduced to period already undergone – Fine of ₹50,000 each imposed on appellants to be paid to the deceased’s family – Appeal partly allowed [Paras 93-95].

Narcotic Drugs and Psychotropic Substances Act, 1985 – Taxi Driver – Possession of Contraband – Appellant, a taxi driver, prosecuted under the NDPS Act for recovery of 20 kilograms of ganja from his vehicle – Passengers fled the scene upon interception by police – Trial court convicted appellant based on inability to provide details of passengers – High Court upheld conviction – Supreme Court held: No evidence linking appellant to the contraband – Contraband not concealed, and no incriminating material found on appellant’s person – Conviction set aside [Paras 1–6].

Burden of Proof – Lack of Direct Evidence – Appellant contended ignorance of contraband in the taxi, attributing it to the passengers who fled – Supreme Court observed: Ordinarily, taxi drivers do not record passenger details – Appellant’s failure to provide passenger details insufficient to establish guilt – Prosecution failed to trace the passengers or prove connivance by the appellant [Paras 4–5].

Procedural Lapses – Search and Seizure – Personal search procedure under the NDPS Act not followed – Supreme Court emphasized the importance of compliance with prescribed procedures in NDPS cases to avoid prejudice against the accused [Para 5].

Exoneration – No Evidence of Guilty Intent – Supreme Court noted that appellant made no attempt to flee and no efforts were made to link him directly to the contraband – Held: Mere presence of contraband in a taxi does not automatically establish culpability of the driver in the absence of further evidence [Paras 5–6].

Decision: Appeal allowed – Conviction and sentence under NDPS Act set aside – Bail bonds and sureties discharged [Para 6].

Civil Law - Jurisdiction of Civil Courts – Bar under Section 34 SARFAESI Act – Interpretation of Tribunal Powers – Civil Court jurisdiction is not barred by Section 34 of the SARFAESI Act for matters beyond the scope of the Debt Recovery Tribunal (DRT)’s powers under Section 17 – Reliefs seeking declaration of sale and mortgage deeds as nullity, and possession of property are within the domain of civil courts as such issues involve title disputes and precede the measures taken under Section 13(4) SARFAESI Act [Paras 12-18, 23, 25].

Scope of DRT’s Powers – Section 17 SARFAESI Act – Limitations – The DRT’s authority under Section 17(3) SARFAESI Act is confined to addressing whether measures taken by secured creditors under Section 13(4) are in compliance with the Act – DRT lacks jurisdiction to adjudicate upon disputes regarding ownership, validity of sale deeds, or claims by third parties with adverse title. Use of the term "restore possession" in Section 17(3) confirms that possession can only be returned to a borrower or aggrieved person previously in possession, not to an independent claimant [Paras 17, 23, 39].

Rejection of Plaint – Order VII Rule 11 CPC – Partial Rejection Prohibited – A plaint cannot be partially rejected under Order VII Rule 11 CPC – If any relief survives and is not barred by law, the entire plaint must be allowed to proceed to trial – Even if certain reliefs are arguably barred by Section 34 SARFAESI Act, as long as others survive, the plaint cannot be dismissed in part [Paras 24-25, 34].

Judicial Precedents – SARFAESI Act – Validity of Civil Court Jurisdiction – Reaffirmed principles from Mardia Chemicals Ltd. v. Union of India (2004) 4 SCC 311 regarding limited ouster of civil court jurisdiction under Section 34 SARFAESI Act – Highlighted that title disputes, allegations of fraud, and reliefs outside the DRT's scope remain adjudicable by civil courts [Paras 26-36].

Standard for Bar of Jurisdiction – Interpretation of Statutes – Bar of civil court jurisdiction under special statutes is not to be readily inferred – Statutory provisions ousting jurisdiction must be interpreted strictly, with civil court jurisdiction upheld unless explicitly or implicitly excluded by the statute [Paras 22, 43].

Final Decision – Civil Court jurisdiction upheld for the reliefs sought in the present case – The High Court's restoration of the plaint was affirmed, and all connected appeals dismissed – Observed that proper due diligence in loan transactions, including title clearance, is critical to avoid such disputes [Paras 45-46].

Land Acquisition – Compensation Under 2013 Act – Supreme Court’s Powers Under Article 142 – The respondents, landowners, sought compensation for acquired lands – The Supreme Court, following K.L. Rathi Steels Ltd. (2024) 7 SCC 315, directed that compensation be paid under the 2013 Act – The time for fresh acquisition proceedings under Section 24(2) of the 2013 Act was extended by one year, from 01/08/2024 – Held: Respondents entitled to compensation under the 2013 Act, subject to procedural compliance as outlined in K.L. Rathi (2024) [Para 3].

Article 142 – Exercise of Inherent Powers – Balancing Public and Private Interests – The Court exercised Article 142 powers to ensure uniformity in compensation awards and to balance public interest with private rights – Provisions of Chapters II and III of the 2013 Act (Social Impact Assessment) were dispensed with, given the urban/semi-urban nature of the land – Held: Directions issued to expedite fresh acquisition proceedings, while waiving procedural requirements to ensure fairness and efficiency [Paras 3-4].

Land Acquisition – Procedural Directions – Expedited Compensation Payment – The Court issued specific directions:

a) Time limit for acquisition extended by one year (from 01/08/2024).

b) Status quo to be maintained on possession and land use.

c) Social Impact Assessment waived due to urban nature of land.

d) Pre-2014 notifications deemed preliminary notifications under Section 11 of the 2013 Act.

e) Compensation to be assessed as of 01/01/2014, with all monetary benefits except rehabilitation.

f) Collector to determine compensation as per Section 28, award solatium under Section 30 – Landowners may seek enhancement under Chapter VIII of the 2013 Act.

Held: Orders passed to ensure fair compensation while streamlining procedural requirements [Para 3].

Decision: Miscellaneous Applications Disposed of – Supreme Court extended the time for fresh acquisition proceedings and ordered compensation to be paid under the 2013 Act, with procedural waivers to ensure expeditious resolution – Pending interlocutory applications also disposed of [Paras 5-6].

Juvenile Justice – Plea of Juvenility – Retrospective Application – Procedural Mandate – Benefit under Juvenile Justice Act, 2015 – Appellant raised a plea of juvenility at every stage of proceedings, claiming to be 14 years old at the time of the offence – Trial Court, High Court, and Supreme Court dismissed the plea relying on irrelevant factors such as a bank account – Birth certificates and ossification test confirmed juvenility – Mercy Petition partially allowed, commuting death penalty to life imprisonment with conditions – High Court dismissed Writ Petition challenging Presidential Order and seeking determination of juvenility under Section 9(2) of the 2015 Act – Supreme Court held that procedural mandates under the Juvenile Justice Acts were not followed and the plea of juvenility, being a constitutional mandate, can be raised at any stage – Appeal allowed – Appellant’s sentence reduced in line with the Juvenile Justice Act, 2015 – Directions issued for the Appellant’s rehabilitation and reintegration into society [Paras 33–54].

Judicial Duty – Determination of Truth in Juvenile Justice Cases – Courts are obligated to proactively determine the age of an accused, especially when the accused is illiterate and submits credible evidence – Procedural lapses in earlier adjudications cannot deny rightful relief under social welfare legislations like the Juvenile Justice Act [Paras 47-49].

Rehabilitation and Reintegration – Right to Livelihood under Article 21 – Appellant’s release directed with State Legal Services Authority tasked to ensure rehabilitation and reintegration into society – Emphasis placed on welfare schemes for livelihood, shelter, and sustenance [Para 53].

Decision – Conviction maintained, sentence reduced to align with the Juvenile Justice Act – Appellant directed to be released forthwith if not required in any other case [Para 54].

Arbitration – Delay Attributable to Claimant – Section 14 of the Limitation Act – Interest Granted from Specific Date – Arbitral Tribunal directed interest @ 12% per annum for the delay, which was upheld by the High Court – Held: In peculiar facts, interest allowed only from 06/03/2010, the date on which the Arbitral Tribunal condoned the delay and deemed claims within limitation [Paras 2-3].

Contractual Obligation – Insurance Claim and Delayed Payment – Liability for Interest – Respondent approached legal remedies due to appellant’s refusal to pay – Held: Appellant liable to pay interest for outstanding dues; justice requires modifications to interest start date [Paras 3-4].

Decision – Modification of Interest Period – Arbitral Award modified to calculate interest @ 12% per annum from 06/03/2010 – Appellant directed to pay the balance within four weeks [Para 4].

Accident Claim - Golden Hour – Definition and Significance – Section 162 of Motor Vehicles Act, 1988 – Golden hour defined under Section 2(12-A) as the one hour following a traumatic injury – Critical for saving lives through prompt medical treatment – Held: Cashless treatment during the golden hour is a statutory obligation to uphold the right to life under Article 21 of the Constitution [Paras 1-3].

Motor Vehicle Accident Fund – Establishment and Utilization – Section 164-B of the Motor Vehicles Act – Fund established to finance the treatment of accident victims – Central Motor Vehicles (Motor Vehicle Accident Fund) Rules, 2022 specify utilization, but cashless treatment scheme under Section 162 yet to be implemented – Held: Central Government directed to frame and implement the scheme by 14/03/2025 [Paras 4-8].

Pending Claims – Hit and Run Scheme – Data on claims reveals significant delays due to deficiencies in documentation – Directions issued to GIC to process claims with specified minimal documents and coordinate with claimants to resolve deficiencies – Portal development for claim processing expedited to avoid delays [Paras 10-12].

Decision – Central Government directed to finalize the cashless treatment scheme for golden hour victims by 14/03/2025 and report compliance – Directions issued to General Insurance Council (GIC) to process pending claims and expedite portal development [Paras 8, 12].

Limitation Law – Filing of Subsequent Suit for Specific Performance – Article 113 and Order VII Rule 13 of the Code – Suit Barred – The second suit filed in 2007 for specific performance was barred under Article 113 of the Limitation Act – Held: The second suit must be filed within three years from the rejection of the earlier plaint in 1998; filing the suit beyond 2001 made it time-barred under Order VII Rule 11(d) [Paras 9.8-9.12].

Pleadings – Misuse of Extension Letter – Letter dated 15.07.1991 used in second suit not mentioned in first suit filed in 1993 – Attempt to misuse it for continuity of cause of action – Held: Such reliance was mischievous and inadmissible [Paras 9.9-9.11].

Law of Limitation – Nature and Scope – Doctrine of Continuous Running of Time – Once time starts running under limitation, it continues unless interrupted by statutory provisions – Held: Extension based on pending litigation irrelevant for computing limitation under Article 113 [Para 9.11].

Decision – Second Suit for Specific Performance Rejected – Application under Order VII Rule 11(d) allowed – Appeal allowed, setting aside trial court and High Court orders [Paras 9.12, 10].