Civil Writ - Compensation – Multiplier Method – Article 21 of the Constitution – Compensation Upheld – On direction of the Court, former Chief Justice Y.V. Chandrachud quantified compensation for deceased and injured victims using the multiplier method – Held: Multiplier method is well-established and was rightly applied after considering principles from prior rulings and expert opinions – Supreme Court upheld this method with modifications in quantum [Paras 4, 8–10].

Compensation – Death of Housewives – Quantum Enhanced – Estimation of services rendered by housewives was initially fixed at Rs. 10,000–12,000 per annum – Held: This was grossly inadequate – Supreme Court enhanced notional value of their services to Rs. 36,000 per annum and increased the conventional compensation from Rs. 25,000 to Rs. 50,000 [Para 11].

Compensation – Death of Children – Compensation Tripled – Standard award of Rs. 75,000 for children aged 5–10 years was found inadequate – For children aged 10–15 years, contribution assumed at Rs. 12,000 per annum with multiplier of 11 – Held: Revised to Rs. 24,000 per annum with multiplier of 15 – Total award enhanced to Rs. 2 lakhs for children aged 5–10 and Rs. 4.10 lakhs for older children [Para 13].

Compensation – Burn Injuries – Non-Pecuniary Loss – Lump-Sum Award Upheld – Despite absence of detailed medical records from claimants, compensation was awarded based on severity of burn injuries – Held: Compensation ranging from Rs. 3 lakhs to Rs. 10 lakhs appropriate in given context – Additional Rs. 2 lakhs awarded as compassionate compensation to victims with less than 10% burn injuries [Paras 5, 15].

Negligence – Celebration in Hazardous Zone – Liability Acknowledged – Petitioners alleged gross negligence in organising function near hazardous installations, ignoring CrPC Section 144 prohibitory orders – Held: On admitted facts and reports, liability for negligence stood established – Company accepted responsibility and agreed to pay compensation as per Court’s directions [Paras 1, 5].

Adjudicatory Role – Compensation Assessed by Expert – Role of Court Appointed Commissioner – Held: Assessment by Shri Y.V. Chandrachud based on sound legal principles and due fairness – Petitioners’ objections largely rejected except on quantum – No remand for fresh assessment necessary to avoid further delay [Paras 6–7, 16].

Final Relief – Compensation Modified – Appeals Allowed in Part – Supreme Court modified compensation upwards in several categories including housewives and children – Directed disbursement of amounts through account payee cheques or drafts within three months – Recognised contributions of counsel and expert in fair resolution of dispute [Paras 16–18].

Criminal Procedure – Power of Magistrate to Summon Persons Not Shown as Accused – Section 190 CrPC – Power Upheld – Magistrate took cognizance of offence and issued summons to respondent no. 2 who was not named as accused in the charge sheet but listed in column 2 – High Court set aside the summons citing Section 319 CrPC – Supreme Court held this was incorrect – At the stage of cognizance, Magistrate is not limited by the list of accused submitted by the police and can summon any person if materials support it – Application of Section 319 CrPC is premature at this stage [Paras 5–7].

Scope of Section 190 CrPC – Cognizance of Offence, Not Offender – Section 190 empowers Magistrate to take cognizance based on police report and supporting documents – Magistrate may summon persons not named as accused but found to be connected with the offence – Held: Cognizance is of the offence and not of the offender – Magistrate must evaluate the material independently and can proceed against any person involved, even if police did not recommend prosecution [Paras 6–7].

Section 319 CrPC – Not Applicable at Cognizance Stage – Section 319 comes into play during inquiry or trial based on additional evidence – In this case, inquiry had not commenced and trial had not started – Magistrate was still in pre-trial cognizance stage – Reference to Section 319 by High Court was misplaced – Held: Magistrate rightly exercised powers under Section 190 and not Section 319 [Paras 6–7].

Final Decision – Appeal Allowed – High Court’s order set aside – Magistrate’s decision to summon respondent no. 2 under Section 190 upheld – Trial court directed to proceed in accordance with law [Paras 8–10].

Murder – Reversal of Acquittal – Confession Valid and Corroborated – Appeal Allowed – Accused was acquitted by High Court in double murder case of a film actress and her mother – Supreme Court held that the judicial confession of the accused was voluntary and truthful – Corroborated by recovery of stolen articles and unexplained presence of fingerprints inside the victims’ kitchen – Acquittal set aside – Conviction under Section 302/34 IPC restored – Life imprisonment imposed [Paras 5–6, 13–17, 21–24].

Judicial Confession – Retraction Not Sufficient to Discard – Accused retracted confession recorded under Section 164 CrPC – Held: Mere retraction does not invalidate confession – Court must evaluate voluntariness and truthfulness – Once satisfied, confession is admissible – Confession showed detailed planning and execution of murder by accused in conspiracy with co-accused [Paras 12–13].

Corroboration – Fingerprints and Recovery of Stolen Articles – Fingerprints of accused found inside kitchen though he was employed only as a watchman – Recovery of valuables at his instance further corroborated the confession – Court held these circumstances sufficiently supported the prosecution version and validated confession [Paras 21–22].

Extra Judicial Confession – Inadmissible Due to Infirmities – Court declined to rely on extra judicial confession made to PW-30 as accused was intoxicated – Held: In absence of reliable evidence about degree of inebriation, such confession cannot be used for corroboration [Para 20].

Principles of Appellate Interference – Appeal Against Acquittal – Court reiterated that interference in acquittal is permissible if lower court overlooked admissible and credible evidence – High Court erred in rejecting valid confession on flimsy grounds – Trial court’s judgment restored [Paras 23–24].

Decision – Appeal Allowed – Acquittal reversed – Conviction under Section 302/34 IPC restored – Life imprisonment imposed on respondent – Trial court directed to secure custody and execute sentence [Para 24].

NDPS Act – Conviction under Section 21 – Seizure of Buprenorphine – Conviction Upheld – The appellant was found in possession of 25 ampoules of 'Tidigestic' (Buprenorphine) and arrested on the spot – Trial Court acquitted the appellant citing discrepancies in prosecution evidence – High Court reversed the acquittal and convicted the appellant – Supreme Court upheld conviction and sentence of 10 years’ rigorous imprisonment with fine – Held: Conviction based on credible and corroborated evidence [Paras 1–4, 14].

Section 42 – Recording and Communication of Information – No Violation Found – Appellant argued non-compliance with Section 42 due to failure to record and forward information – Court held that police officer (PW5) received information while on patrol and acted immediately to apprehend the accused – Held: In such exigent circumstances, strict compliance was not required and immediate action was justified – No violation of Section 42 [Paras 6–7].

Section 50 – Right to be Searched Before Magistrate or Gazetted Officer – Oral Communication Valid – It was argued that appellant was not informed in writing of his right under Section 50 – Evidence showed oral communication of right to be searched before a Magistrate or Gazetted Officer – Held: Oral intimation is sufficient – No violation of Section 50 [Paras 8–11].

Section 57 – Obligation to Send Report to Superior Officer – Substantial Compliance is Sufficient – Although no formal report was filed under Section 57, prosecution had sent FIR and related documents to superior officer – Held: Substantial compliance was achieved – No prejudice caused to the accused – Prosecution case not vitiated [Para 12].

Decision – Appeal dismissed – Conviction and sentence confirmed – No violation of mandatory provisions of NDPS Act [Para 14].

Criminal Law - Delay in Pronouncement of Judgments – Article 21 of the Constitution – Fundamental Right Violated - Inordinate delay of over two years in pronouncement of judgment after conclusion of arguments by the Patna High Court – Held: Delay violates the right to life and liberty under Article 21 – Supreme Court issued mandatory procedural guidelines for High Courts to prevent such delay and preserve faith in the judiciary [Paras 1-21].

Unlawful Assembly – Common Object – Section 149 IPC – Conviction Partly Set Aside - No sufficient evidence to prove that accused A-3 to A-7 shared common object to commit murder – Held: Conviction under Section 302 read with Section 149 IPC not sustainable – Modified to conviction under Sections 148/149 IPC – Conviction under Section 27 Arms Act upheld [Paras 40-43].

Credibility of Inimical Witnesses – Consistent and Corroborated Testimony – Conviction Upheld - Mere enmity not a ground to discard prosecution witnesses – Where testimony is consistent and supported by medical evidence, conviction sustainable – Held: Evidence of PWs 1, 2, 5 and 6 reliable despite prior hostility [Paras 28, 35].

Medical vs Ocular Evidence – Minor Inconsistencies – No Adverse Impact - Discrepancies in firearm description (rifle vs gun) and number of shots found immaterial – Held: Minor inconsistencies cannot override credible eyewitness testimony and medical findings [Paras 32-34].

Delay in Dispatch of FIR – Section 157 CrPC – Not Fatal to Prosecution - FIR filed within 15 minutes of the incident – No extraordinary or unexplained delay in sending FIR to Magistrate – Held: No inference of fabrication or taint – Trial not vitiated [Paras 29-31].

Hostile Witness – Evidence Admissible – Partial Hostility Not Fatal - PW 12 declared hostile for not naming one accused – Held: His evidence remains admissible – Conviction not affected if corroborated by other reliable witnesses [Para 36].

Right to Speedy Trial – Article 21 – Judicial Directions Issued - Supreme Court reiterated that undue delay in judgment delivery amounts to denial of justice – Issued procedural safeguards including timelines and reporting to Chief Justices for accountability – Held: Delay beyond six months gives party right to seek reassignment of case [Paras 6-10, 17-20].

Benefit to Non-Appealing Accused – Parity Principle Applied - Accused A-7 who had not appealed due to dismissal of SLP also given benefit of modified conviction like co-accused – Held: Supreme Court may extend such relief to avoid miscarriage of justice [Paras 44-45].

Final Decision – Appeals of A-1 and A-2 Dismissed – Appeals of A-3 to A-7 Partly Allowed – Conviction under Section 302/149 IPC set aside for A-3 to A-7 – Convicted under Section 148/149 IPC and Section 27 of Arms Act – Sentenced to 3 years RI – Sentences to run concurrently – If already undergone, they are to be released [Para 46].

Education Law - Post-Graduate Medical Admission – Counselling Procedure – Validity of Rule Restricting Seat Change – Rule Disallowing Change of Subject or College After First Counselling Upheld - Government order provided that no change in allotted subject or college shall be permitted once exercised during counselling – Held: Rule is reasonable and prevents disruption of academic schedule – Permitting seat change after counselling would lead to endless chain reactions and disturb the admission process – Supreme Court affirmed the Division Bench's reasoning and set aside Single Judge's order allowing seat changes [Paras 1-4].

Waitlisted Candidates – Allocation of Vacant Seats – Merit-Based Distribution – Vacant Seats to Go Only to Waitlisted Candidates - Seats falling vacant after counselling due to resignation or reallocation cannot be re-opened for previously admitted candidates – Held: Such seats should only be offered to waitlisted candidates in merit order – Re-opening options for all would prolong counselling, delay commencement of course and potentially affect course duration [Paras 3-4].

Alleged Inequity in Allocation – Fortuitous Circumstances Not a Valid Ground – Apprehension That Lower Ranked Candidate May Get Better Seat - Held: Hypothetical situations like lower-ranked candidate receiving high-demand subject due to resignation by another cannot invalidate otherwise reasonable rules – Fortuitous outcomes do not render the rule arbitrary or irrational [Para 5].

Final Decision – Appeals and SLP Dismissed – Rule Upheld – Held: Rule restricting changes in seat post-first counselling is valid and ensures administrative efficiency – All appeals and SLP dismissed without costs [Paras 6-7].

Criminal Law - Murder – Common Intention – Section 302 read with Section 34 IPC – Conviction Upheld – Deceased Ram Chandra was attacked with sharp-edged weapons by the appellant and co-accused in broad daylight – The act followed an earlier murder case in which the deceased was assisting the accused's opponents – Held: Common intention to kill was proved through motive, simultaneous attack, and coordinated actions – Application of Section 34 IPC proper – Conviction under Section 302/34 justified [Paras 2-9].

Ocular Testimony – Interested Witnesses – Evidence Acceptable – Prosecution relied on eyewitnesses related to the deceased – Held: Relationship of witnesses with victim does not discredit testimony if otherwise trustworthy – PWs 1 and 2 found to be credible and consistent – Courts below rightly relied on their evidence – No interference warranted [Para 10].

Non-Examination of Independent Witness – Not Fatal to Prosecution – Defence raised issue of non-examination of shop owner near place of occurrence – Held: Reasonable explanation accepted due to hostile environment and fear of reprisals – General reluctance of public to depose against known criminal elements noted – Absence of such witness does not vitiate prosecution case [Para 10].

Minor Investigative Lapse – Site Plan Not Indicating Recovery Spot – Not Material – Defence argued that failure to mark spot of blood-stained earth in site plan casts doubt on prosecution – Held: Lapse not significant – Recovery proved through case diary and PW-5's statement – Courts below rightly ignored the omission as immaterial [Para 10].

Section 34 IPC – Principles Reiterated – Common Intention Can Be Inferred from Circumstances – Held: Common intention need not be pre-planned – Can develop on spot – Participation, motive, and coordinated attack sufficient to invoke Section 34 – Each accused liable for acts done in furtherance of common intention [Para 8].

Final Decision – Appeal Dismissed – Conviction and Sentence Affirmed – Supreme Court upheld concurrent findings of Sessions Court and High Court – No merit found in appellant’s defence – Conviction under Section 302 read with Section 34 IPC sustained – Appeal dismissed [Para 11].

Removal from Municipal Office – Abuse of Power – Interpretation of Section 22 of Punjab Municipal Act – Order Quashed – The appellant, elected President of Rajpura Municipal Council, was removed from office by State Government under Section 22 of the Punjab Municipal Act, 1911, on the allegation that he obstructed functioning of the Council by withholding payment for a fogging machine – Supreme Court held that the show cause notice did not disclose the actual basis of the removal order, which relied on events that occurred after the notice and were not put to the appellant – Held: This amounted to violation of principles of natural justice and a colourable exercise of power [Paras 1, 4, 5, 12-13].

Scope of “Abuse of Power” – Section 22 of Punjab Municipal Act – Strict Interpretation Required – The term “abuse of powers” must be construed narrowly – It requires wilful misconduct or dishonest intention – Mere error in decision-making or an unpopular instruction, if not dishonest or habitual, cannot amount to abuse – Held: A single act or disagreement over payment decision, even if erroneous, does not constitute abuse of power under Section 22 [Paras 8-11].

Natural Justice – Show Cause Requirement – Grounds of Removal Must Be Consistent with Notice – Supreme Court emphasized that the ground of removal must be clearly communicated in the show cause notice – Authorities cannot base the final order on different allegations without informing the person concerned – Held: Decision-making without proper notice violates natural justice and renders the order unsustainable [Paras 12-13].

Judicial Review – Perversity in Administrative Action – High Court's Limited Role in Review – Supreme Court found that the High Court erred in treating the matter as beyond the scope of judicial review – Where the administrative order is based on non-existent or irrelevant grounds and shows non-application of mind, such an order is vitiated and liable to be struck down [Paras 13-14].

Decision – Appeal allowed – High Court judgment set aside – Writ petition allowed – Removal order dated 01.10.1999 quashed – Appellant to be reinstated with costs of Rs. 10,000/- [Para 17].

Criminal Law - Sanction for Prosecution – Section 197 CrPC – Reasonable Connection Test – Prosecution Against Public Servant Without Sanction Permitted – Appellant, a former Secretary in the Government of Sikkim, challenged prosecution under IPC and Prevention of Corruption Act for acts related to award of contracts – Held: At this stage, the prosecution can proceed without sanction under Section 197 CrPC – Whether act was in discharge of official duty must be decided after full trial – Accused can raise plea of protection during trial – Court directed that this issue be considered afresh in final judgment based on evidence [Paras 15-17].

Public Servant – Protection under Section 197 CrPC – Not Absolute – Sanction Required Only When Act Inseparable From Official Duty – Held: Only those acts that have reasonable nexus with official duty are protected – If act is done in capacity of public servant, even in dereliction of duty, sanction may be needed – However, if official status merely provided opportunity to commit offence, no protection under Section 197 applies [Paras 5-9].

Criminal Conspiracy – Not Part of Official Duty – Sanction Not Always Required – Held: Entering into a criminal conspiracy to award contracts in violation of Cabinet policy and causing loss to State is not an act done in discharge of official duty – Commission of such offence not protected by Section 197 CrPC at pre-trial stage – Facts must be established during trial to determine applicability [Paras 4, 15-16].

Trial Procedure – When to Decide Question of Sanction – Held: Determination of whether sanction is needed may not be possible at cognizance stage – Court may decide it at any stage, even post-conviction – Where question depends on facts in dispute, it should be addressed after full trial and considered in final judgment [Paras 15-16].

Decision – Appeal Dismissed – Prosecution to Continue – Supreme Court dismissed appeal against High Court order – Directed Trial Court to reconsider issue of sanction under Section 197 at conclusion of trial based on full evidence – Observations in present judgment not to prejudice the trial [Para 17].