Anticipatory Bail – Modification During SLP Pendency – High Court's Jurisdiction Restrained – Stay Issued - The petitioners challenged the anticipatory bail granted to respondent no. 1 in 31 criminal cases related to financial fraud – Despite pendency of SLP, the High Court permitted modification of bail condition allowing travel abroad – Held: Such modification during pendency of appeal before Supreme Court is impermissible and violates judicial discipline – Orders dated 12.08.2025 and 23.08.2025 stayed [Paras 1-11].

Judicial Discipline – High Court Should Exercise Restraint During Pendency of SLP – Doctrine Clarified – Supreme Court reiterated that once an SLP is admitted and notice issued, High Courts must not pass orders that may circumvent or frustrate the proceedings before the apex court – Held: Proper administration of justice demands mutual respect between courts in a hierarchical system – Precedents from Tirupati Balaji Developers and Chhavi Mehrotra relied upon to reinforce judicial propriety [Paras 8-10].

Concealment of Material Facts – Conduct of Accused Under Scrutiny – Show Cause Issued - Respondent No. 1 failed to inform the Supreme Court of filing applications before the High Court for modification of bail terms – Affidavit filed before Supreme Court omitted this material fact – Held: Court expressed grave displeasure and issued notice to explain why anticipatory bail should not be cancelled for suppression of facts [Paras 12-13].

Passport and Travel Restriction – Interim Direction – Supreme Court Mandates Compliance - In view of pending investigation in 31 criminal cases, the Court directed respondent no. 1 to immediately surrender her passport and not to leave India without prior permission – Held: Travel restriction reinstated pending further hearing [Para 15].

Motor Accident Claim – Causal Connection Between Accident and Death – Claim Rejected - The deceased, an Excise Guard, died of pulmonary embolism five months after sustaining leg and finger fractures in a road accident – Supreme Court upheld High Court’s finding that there was no proximate or direct causal link between the accident and death – Held: Death not attributable to accident injuries; post-surgical complications with pre-existing diabetes and hypertension more likely cause [Paras 1-11].

Expert Evidence – Doctor’s Testimony Inconclusive – Medical Opinion Favoured Natural Cause - PW-1, the plastic surgeon, opined the death was due to myocardial infarction, and though stated long bed rest could trigger embolism, he admitted to no post-mortem and acknowledged cardiac risk factors – Held: Absence of conclusive medical evidence and lack of post-mortem weakens claimants’ case; expert's deposition supported natural medical cause [Paras 6-7].

Preponderance of Probability – Not Established – No Clear Nexus Between Injury and Death - Supreme Court reiterated that even in civil cases requiring lesser standard of proof, the causal connection must meet preponderance of probability – Held: Injuries were not serious; death occurred after successful skin grafting – No evidence of extended immobility or bed rest [Paras 8-11].

Final Disposition – High Court Judgment Affirmed – Claim for Death Compensation Denied - Tribunal’s finding of causality reversed by High Court based on medical evidence – Supreme Court declined to interfere, holding the reasoning sound and based on expert medical testimony – Held: No compensation payable for death; claimants still entitled to compensation for injuries [Paras 11-12].

Criminal Trial – Transfer of Case – Allegations Against Presiding Officer – Transfer Directed - The petitioner sought transfer of his pending trial from the current Presiding Officer alleging lack of fairness and transparency – The Delhi High Court rejected the transfer plea – On hearing the Special Leave Petition, the Supreme Court invoked its powers to direct the Principal District and Sessions Judge, Shahdara, to either retain the matter on his own file or assign it to another Court of equivalent jurisdiction – Held: To ensure impartiality and protect the fairness of trial, transfer ordered without expressing any opinion on allegations – Allegations against judicial officer to be unconditionally withdrawn by petitioner [Paras 2-5, 10].

Expeditious Trial – Directions to Trial Court – Three-Month Deadline – The Supreme Court directed the transferee Court to complete the trial within three months from the date of transfer – The parties were instructed to cooperate fully, and in case of non-cooperation, the Court concerned may take strict steps as per law – The State assured full cooperation in production of witnesses – Held: Trial Court must adhere strictly to the fixed timeline and manage its calendar accordingly [Paras 7-9].

Conduct of Litigants – Allegations Against Judicial Officers – Unconditional Withdrawal – During proceedings, the petitioner was queried about the allegations against the trial Judge – Petitioner’s counsel unconditionally withdrew the same and undertook not to make such insinuations in future – Held: Supreme Court accepted the withdrawal and cautioned parties to maintain decorum in judicial proceedings [Paras 10-11].

Decision – SLP Disposed – Transfer and Time-Bound Trial Ordered – In view of the agreement between the parties and interest of justice, the SLP was disposed with specific directions for transfer and expeditious disposal – Registry was directed to communicate the order to the District Judge concerned – Held: No opinion expressed on merits; matter disposed with procedural directions to ensure fair trial [Paras 5-6, 12-15].

Anticipatory Bail – Withdrawal of Previous Applications – Co-Accused Already Granted Bail – Relief Granted - The appellant's anticipatory bail was denied by the High Court solely on the ground that he had earlier withdrawn similar applications – The Supreme Court noted that co-accused were granted bail and had already extended interim protection to appellant – Held: Interim protection confirmed; anticipatory bail granted – Arresting authority directed to release on bail if arrested, subject to Trial Court's terms [Paras 2-4].

Subsequent FIR – Interim Protection Already Secured – No Bar to Current Bail Relief - State submitted that a fresh FIR under Bharatiya Nyaya Sanhita, 2023, was registered against appellant during pendency – The appellant clarified he had secured interim protection in that case from the Sessions Court – Held: Existing relief not affected by subsequent FIR; future applications to be decided independently on merits [Paras 5, 7].

Cooperation in Investigation – Liberty to Cancel Bail If Violated – Investigative Balance Maintained - The Court emphasized that the appellant must cooperate fully with the investigation – Held: Non-cooperation would entitle the State to seek cancellation of bail from Trial Court [Para 6].

Final Disposition – Appeal Allowed – Bail Granted – Appellate Court Clarified Scope of Order - The Court clarified that its order granting bail in this case would not influence other proceedings or applications of the appellant pending elsewhere – Held: Appeal disposed with protection to liberty and due process [Paras 7-8].

Anticipatory Bail – Modification of Conditions – Judicial Propriety – Respondent No. 1 accused in 31 criminal cases involving serious financial offences under IPC and BUDS Act – High Court granted anticipatory bail subject to condition not to leave India without prior permission – During pendency of SLP challenging said bail order, respondent filed application before High Court seeking permission to travel abroad – High Court allowed modification and released passport without disclosing to Supreme Court that such relief had been sought – Held: Conduct of respondent undermines judicial discipline and violates comity between courts – All orders passed by High Court modifying bail conditions during pendency of SLP stayed [Paras 1–11].

Judicial Discipline – Hierarchical Judicial System – Supreme Court emphasized that though High Courts are not subordinate, once a matter is under challenge and seized by the Supreme Court, High Courts must exercise restraint from modifying or passing orders that may prejudice pending proceedings – Reference made to Tirupati Balaji Developers v. State of Bihar and Chhavi Mehrotra v. DGHS highlighting the need for deference and avoidance of parallel jurisdictional exercise [Paras 8–10].

Suppression and Misconduct – Respondent’s Failure to Inform Supreme Court – Though respondent filed application before High Court on 06.07.2025, no disclosure made to Supreme Court when case was listed on 14.07.2025, 25.07.2025, and 25.08.2025 – Counter affidavit dated 14.07.2025 silent on application for modification – Held: Court expresses grave displeasure and issues notice to respondent as to why pre-arrest bail should not be cancelled due to concealment [Paras 12–13].

Interim Directions – Respondent No. 1 restrained from leaving India without permission of Supreme Court – Directed to surrender her passport immediately – Response to show-cause notice to be filed within three weeks with relevant documents [Paras 13–15].

Decision: Orders passed by High Court in Crl.MC No. 6178/2025 and Crl.M.A. No. 1/2025 modifying bail conditions stayed – Show cause notice issued to respondent regarding cancellation of anticipatory bail – Case listed for further orders on 26.09.2025.

PIL - Anand Karaj marriages—Section 6, Anand Marriage Act—States/UTs directed to notify rules within 4 months—Till then, registration to be facilitated under existing marriage registration frameworks without discrimination—Union of India to coordinate and file compliance report—Petition disposed with time-bound directions [Paras 11–16].

Constitutional Duty – Registration of Marriages – Section 6 of the Anand Marriage Act imposes a positive duty on States to establish registration machinery for Anand Karaj marriages – Duty not optional or contingent on population size – Non-notification frustrates legislative intent of 2012 amendment [Paras 7–8].

Civil Consequences of Registration – Marriage certificates enable proof of status for residence, maintenance, inheritance, succession, and enforcement of monogamy – Particularly safeguard rights of women and children – Unequal access across jurisdictions violates equal treatment [Para 9].

Harmonisation with Existing Frameworks – Until rules are notified, general marriage registration frameworks must accept Anand Karaj marriages on the same footing as other marriages – Certificate to record that marriage was solemnised by Anand Karaj where parties so request [Para 10].

General Directions – (i) All States/UTs without rules to notify within 4 months; (ii) immediate registration under existing laws without discrimination; (iii) States with rules to issue clarifications within 3 months; (iv) Nodal officer to be designated within 2 months; (v) Union of India to coordinate and circulate model rules, and file consolidated status report in 6 months [Para 12].

Special Directions – Goa: Interim registration under civil registration offices; Union to extend Anand Marriage Act within 4 months; Goa to frame rules within 4 months thereafter [Para 13]. – Sikkim: Interim registration under 1963 Rules; Union to consider extension under Article 371F(n); Sikkim to notify rules within 4 months after extension [Para 14].

Decision – Writ petition disposed of with directions—Time-bound rule-making mandated—Interim facilitation under existing frameworks ordered—Compliance affidavits to be filed by States/UTs; Union to file consolidated status report in 6 months [Paras 15–16].

Regular Bail – Sexual Offences – Allegations Under IPC Sections 376, 377, 384, etc. – Bail Granted - The appellant was accused of serious offences including rape, blackmail, and assault by a woman nearly twice his age – The FIR was followed by a charge sheet including multiple IPC provisions – The High Court had rejected regular bail – Supreme Court noted interim bail had been granted earlier, and the complainant did not appear despite notice – Held: Considering the nature of relationship, age gap, alleged business dealings, and prolonged custody since 07.08.2024, regular bail is justified – Impugned order set aside – Bail granted on conditions to be imposed by Sessions Court [Paras 1-3, 7].

Frivolous Allegations – Consensual Relationship Plea – Age Disparity – Accused’s Argument Accepted - The appellant contended that the complainant was 42 years old while he was only 21, and that the relationship was consensual and commercial – Supreme Court did not delve into the truth of the claims but acknowledged the argument as relevant for bail consideration – Held: Charges not yet framed; allegations appear doubtful prima facie – No justification to keep appellant in further custody [Paras 2-3].

Failure to Prosecute – Non-Appearance of Complainant – Interim Bail Made Absolute – Despite prior notice and adjournment, the complainant did not appear – Court recorded counsel’s submission that he had no vakalatnama or instructions – Held: Absence of complainant and prolonged interim bail weighed in favour of granting regular bail [Para 2].

Decision  – Impugned Order Set Aside – Appeal Allowed – Supreme Court allowed the appeal, set aside the Delhi High Court’s rejection of bail, and directed that the appellant be released on regular bail upon appearance before Sessions Court on 19.09.2025 – Held: Sessions Court to impose appropriate conditions for bail – Pending applications also disposed of [Paras 6-8].

Anticipatory Bail – Allegations of Rape and Sexual Assault – IPC Sections 376(1), 377, 354A – Bail Granted - The appellant, alleged to be a spiritual leader, was accused of sexually exploiting a married woman and others – The FIR was lodged after delay, and the High Court had rejected anticipatory bail – Supreme Court noted earlier grant of interim protection and found the case suitable for anticipatory bail – Held: Order of High Court set aside; anticipatory bail granted with conditions including cooperation in investigation and restraint from tampering with evidence [Paras 1-3].

False Implication – Allegations of Conspiracy and Blackmail – Delay in Filing FIR - Appellant contended that the complainant and her husband fabricated the case using videos to create false evidence for ulterior motives – Further claimed the relationship was consensual – Held: Without commenting on merits, Supreme Court found grounds sufficient for anticipatory bail as the FIR was belated and under suspicious circumstances [Paras 2-3].

Serious Allegations – Accused as Spiritual Leader – Court Balances Liberty and Investigation – The complainant alleged that the appellant misused his position as a godman to exploit women – The Court recognized the seriousness but emphasized liberty and fair process – Held: Conditional anticipatory bail appropriate; liberty not to be misused, and any breach would lead to cancellation [Paras 2-3].

Decision – Appeal Allowed – Anticipatory Bail Granted – The Supreme Court set aside the Bombay High Court’s order and granted anticipatory bail on furnishing ₹25,000 cash security with two sureties – Directions issued for cooperation and non-interference with evidence – Held: Non-compliance would lead to cancellation of bail [Para 3].

Limitation Law - Motor Accident Claim – Disbursement of Compensation – Review Rejected – Delay Not Condoned – Appellant sought review of Tribunal's disbursement order alleging unfair distribution of compensation among legal heirs – Tribunal rejected review on grounds of delay (6 months, 22 days) and absence of medical evidence – High Court affirmed dismissal – Supreme Court upheld findings – Held: Appellant signed joint application and accepted cheque without protest – Review rightly dismissed [Paras 1–7].

Limitation – Review Application – Sufficient Cause Not Proved – Tribunal and High Court found no credible explanation for delay – Appellant failed to produce medical records to support claim of illness or surgery – Delay appeared to be afterthought – Courts below correctly applied settled principles of limitation law [Paras 3.4, 5, 6.4].

Estoppel – Approbat and Reprobat – Conduct Precludes Challenge – Appellant signed joint disbursal application and received ₹1,00,000/- without demur – Later attempt to challenge disbursement order treated as reversal of conscious conduct – Held: A party who voluntarily accepts benefits under a court order cannot later dispute its validity – No question of fraud or suppression arose [Paras 5.4, 6.1–6.3].

Final Decision – Appeal Dismissed – No Interference Warranted – Supreme Court found no error in decisions of Tribunal or High Court – Appellant’s challenge to disbursement treated as legally unsustainable – Appeal dismissed with observations on conduct [Para 7].