Criminal Law - Murder - Indian Penal Code 1860 - Sections 302, 34 - Appellants convicted by Trial Court and High Court based on circumstantial evidence - Supreme Court found that prosecution failed to prove incriminating circumstances beyond reasonable doubt - Last seen theory was weak due to long time gap and missing information on motorcycle ownership - Medical evidence suggested accidental death rather than homicide - Disclosure statements lacked evidentiary value as they followed discovery of facts - Prosecution failed to prove motive or link accused to the crime - Held - Conviction set aside and appellants acquitted - [Paras 1-35].

Evidence Law - Circumstantial Evidence - Indian Evidence Act 1872 - Section 106 - Burden of Proof - Prosecution failed to discharge primary burden of proving case beyond reasonable doubt - Mere absence of explanation by accused does not justify conviction when prosecution fails to build a complete chain - Held - Chain of circumstances incomplete - [Paras 11-13, 16-18].

Criminal Law - Last Seen Theory - Evidence Law - Indian Evidence Act 1872 - Section 3 - Reliability - Last seen circumstance is a weak piece of evidence and insufficient on its own when there is a significant time gap between being seen together and discovery of the body - Held - Circumstance fails to inspire confidence - [Paras 16-19].

Criminal Law - Medical Evidence - Indian Evidence Act 1872 - Section 45 - Opinion of experts - Autopsy report and medical literature indicated death could be result of motorcycle accident - Post-mortem injuries on head consistent with fall on hard surface - Prosecution failed to exclude hypothesis of accidental death - Held - Reasonable doubt created in prosecution story - [Paras 14-15, 20-21].

Decision: Appeals allowed – Judgment and order of the High Court and Trial Court set aside – Appellants acquitted of all charges – Bail bonds discharged.

Criminal Law - Judicial Conduct - Sexual Offences - POCSO Act 2012 - Sensitization of Judiciary - Supreme Court set aside High Court order for erroneous application of legal principles and failure to maintain judicial sensitivity in a case involving a minor victim - Court formulated and approved a report titled Developing Guidelines to Inculcate Sensitivity and Compassion into Judges and Judicial Processes in the Context of Sexual Offences and Other Vulnerable Cases prepared by an expert committee - Held - Guidelines are mandatory for all courts to ensure judicial proceedings are responsive to victim dignity and free from stereotypical language - [Paras 1-24].

Criminal Law - Judicial Language - Constitutional Values - Use of inclusive and sensitive language in judicial writing - Previous guidelines often failed due to an overly anglicised model that ignored linguistic and cultural diversity - New guidelines aim to provide practical and accessible resources for judicial officers to avoid pejorative or discriminatory connotations particularly regarding transgender persons and persons of diverse sexual orientations - Held - Language of courts must be anchored in empathy and dignity to be accessible to all stakeholders - [Paras 7-14].

Criminal Law - Institutional Reform - Victim-centric Justice - Implementation of guidelines through training and dissemination - Registry directed to circulate the publication to all High Courts and Tribunals - National Judicial Academy and State Judicial Academies to publish the handbook and organize orientation workshops for judicial and police personnel - Held - Publication serves as a mandatory guiding resource in matters involving sexual offences - [Paras 17-24].

Decision: Impugned High Court order set aside - Matter remitted to Special Judge (POCSO) Kasganj - Guidelines on sensitive judicial language approved and mandated for nationwide implementation by judicial and police authorities – Registry to ensure dissemination.

Negotiable Instruments Act – Cognizance – Delay in Filing Complaint – Impermissible Cognizance – Respondent filed complaint under Section 138 of NI Act with a delay of two days – Magistrate took cognizance before condoning the delay – Supreme Court held that satisfaction of the Court regarding delay under proviso to Section 142(1)(b) must precede taking of cognizance – Cognizance taken without prior condonation is contrary to law and not a mere curable irregularity – Complaint quashed [Paras 13-15].

Criminal Procedure – Section 482 CrPC – Quashing of Proceedings – Magistrate erred in taking cognizance prior to deciding application for condonation of delay – High Court wrongly treated the irregularity as curable and refused to quash complaint – Supreme Court reversed High Court’s decision and quashed the complaint as the mandatory condition precedent for cognizance was not fulfilled [Paras 6-9, 14-15].

Interpretation of Statutes – Proviso to Section 142(1)(b) NI Act – Supreme Court clarified that legislative intent requires satisfaction regarding delay before cognizance – Reliance placed on Dashrath Rupsingh Rathod v. State of Maharashtra – Procedural safeguard under proviso to Section 142(1)(b) must be strictly followed to protect rights of the accused [Paras 12-14].

Decision: Appeal allowed – Order of Karnataka High Court dated 28.06.2024 set aside – Complaint in CC No. 1439 of 2014 quashed – Held that cognizance taken before condoning delay was impermissible under law [Para 15].

IBC - Insolvency and Bankruptcy Code – Section 7 – Application by Assignee Creditor – Rejected – UV Asset Reconstruction Company filed a Section 7 application against Electrosteel Castings Ltd. (ECL), asserting it was a guarantor for debt availed by Electrosteel Steels Ltd. (ESL) – Application rejected by NCLT and NCLAT on grounds that Clause 2.2 of Deed of Undertaking did not constitute a contract of guarantee – Supreme Court upheld rejection – Held: Clause 2.2 merely obligated ECL to arrange infusion of funds into borrower ESL and lacked elements of a guarantee under Section 126 of the Indian Contract Act – There was no unambiguous promise to the creditor to discharge the debt upon default [Paras 17–25, 1–16].

Contract Law – Guarantee – Requirements under Section 126 ICA – Clause 2.2 of the Deed of Undertaking did not fulfill essential ingredients: no direct promise to creditor, no liability to discharge borrower’s debt – Payment of ₹38 crores by ECL held voluntary, not pursuant to a contractual obligation – Held: “See to it” obligations are not sufficient to constitute a statutory guarantee under Indian law [Paras 19–24].

Insolvency Resolution – Effect of Resolution Plan – Residual Debt – Claim against Third Parties – SREI had accepted Resolution Plan and received equity in lieu of balance debt – Argument that debt stood extinguished rejected – Clause 3.2(ix) of Resolution Plan specifically preserved rights of financial creditors against third parties including existing promoters – Reduction in share value post-resolution led to significant haircut, affirming residual unsatisfied debt – Held: Resolution Plan did not extinguish liability of third-party sureties or security providers [Paras 18–24].

Decision: Appeal dismissed – Deed of Undertaking did not constitute a guarantee – No bar on claims against ECL due to approval of Resolution Plan – Findings of NCLT and NCLAT affirmed – No costs awarded [Paras 25–26].

Criminal Law – Double Murder – Acquittal – Appellant alleged to be driver of vehicle used by shooters in twin murders – Conviction by Trial Court affirmed by High Court – Supreme Court found evidence of key witnesses (PW-7 and PW-10) against appellant to be inconsistent and lacking – No overt act or recovery attributable to appellant – Conviction set aside [Paras 3-8, 11].

Evidence Act – Witness Credibility – PW-7 and PW-10 alleged appellant drove vehicle, but failed to implicate him in original police statements under Section 161 CrPC – Testimony regarding dragging of victim introduced for first time during trial – Court held omissions were fatal to prosecution case against appellant [Paras 7-8].

Criminal Procedure – Section 319 CrPC – Appellant not originally named – Later summoned under Section 319 CrPC – Defense witness DW-1 (DSP) testified appellant was found innocent in initial investigation – DW-2 (owner of vehicle) confirmed vehicle not entrusted to appellant – Absence of link to vehicle or scene of crime [Paras 7, 9-10].

Gang Rivalry – Animosity and Cross-Litigation – Evidence of ongoing gang rivalry and false implications between families of accused and deceased – History of narcotic raids and mutual enmity undermined credibility of prosecution’s narrative – Court declined to uphold conviction based on vague, delayed statements [Para 11].

Decision: Appeal allowed – Conviction and sentence of appellant set aside – Appellant acquitted of all charges – If in custody, to be released forthwith – If on bail, bail bonds to stand cancelled – Judgment limited only to appellant [Paras 12-13].

Criminal Law – Cheating and Criminal Conspiracy – Multiple Victims – Same Transaction – Allegations of inducement and cheating of 1,852 investors pursuant to a single conspiracy to dupe public by false representation of divine powers to multiply money – One FIR registered and remaining complaints treated as statements under Section 161 CrPC – Held, where allegations disclose a single conspiracy with unity of purpose and design, multiple acts of cheating may form part of the same transaction – Registration of a single FIR in such circumstances is legally permissible [Paras 9–11, 18–21].

Criminal Procedure – FIRs – Multiplicity vs Consolidation – High Court held that each deposit constitutes a separate transaction requiring separate FIRs – Supreme Court disagreed – Law does not mandate registration of separate FIRs where subsequent information relates to same cognizable offence or same transaction – Subsequent complaints can be treated as statements under Section 161 CrPC – Multiple FIRs in such cases would lead to unnecessary multiplicity of proceedings [Paras 13–16, 21].

Criminal Procedure – Premature Reference under Section 395(2) CrPC – Reference made by Additional Sessions Judge during pendency of investigation – Held, reference was premature as it was not possible at that stage to determine whether offences formed part of same transaction – Question of consolidation of FIRs or charges arises only after investigation, at the stage of framing of charges [Paras 8, 20–21].

Same Transaction – Tests – Reaffirmation of settled principles – Unity of purpose or design, proximity of time and place, and continuity of action are relevant tests – Tests not required to be cumulatively satisfied – Determination depends on facts of each case – Magistrate to apply these tests on basis of material collected during investigation [Paras 11, 19–20].

Charges and Trial – Sections 218 to 223 CrPC – General rule under Section 218 CrPC mandates separate trial for distinct offences – Sections 219 to 223 CrPC are exceptions permitting joint trial – Where offences form part of same transaction, joint charges and trial permissible under Sections 220(1) and 223(a) & (d) CrPC – If not, separate trials required, subject to statutory limits on joinder of offences [Paras 19–20].

Sentencing – Multiple Offences – Sentencing to be governed by Section 71 IPC read with Sections 31 and 325 CrPC – If offences tried together as part of same transaction, punishment to follow accordingly – Issue of proportionality and concurrency of sentences to be considered by Trial Court on established facts [Paras 3, 22].

Rights of Complainants – Protest Petitions – Even where multiple complainants are treated as witnesses in a single FIR, their right to file protest petitions is preserved – Magistrate duty-bound to consider such protest petitions if closure report is filed or discharge is contemplated [Paras 13, 22].

High Court Judgment – Interference Warranted – Answers given by Delhi High Court to Questions (a) and (b) holding that separate FIRs and charge sheets were mandatory held erroneous – Set aside – Matter left to Magistrate to decide applicability of “same transaction” doctrine at appropriate stage [Paras 21–23].

Decision: Appeal allowed – Judgment dated 08.07.2019 of the Delhi High Court in Criminal Reference No. 1 of 2014 set aside insofar as it answered Questions (a) and (b) – Registration of single FIR upheld – Issue of consolidation of charges/trial to be decided by Magistrate in accordance with law.

Service Law – Reservation – Cadre Allocation – Indian Forest Service Examination Rules, 2013 – A reserved category candidate who avails relaxation in the Preliminary Examination, an integral stage of the selection process, cannot be considered against unreserved vacancies for cadre allocation, even if they secure higher marks in the Main Examination and Interview than a general category candidate – The High Court erred in holding that the Preliminary Examination is merely a screening test and marks obtained therein are not to be considered for final merit, thereby treating the reserved category candidate as a General category candidate for cadre allocation – The Supreme Court held that availing any relaxation at any stage of the examination, including the Preliminary Examination, disqualifies a candidate from being considered against unreserved vacancies as per Rule 14(ii) proviso and Paragraph 9 of the Cadre Allocation Policy – The allocation of the General Insider vacancy to Respondent No. 3 (General category candidate) was upheld as correct – The allocation of Tamil Nadu Cadre to Respondent No. 1 (reserved category candidate) was also upheld – The judgments of the Tribunal and High Court were set aside [Paras 21, 22, 26, 28, 29, 36, 37, 39].

Service Law – Reservation – Relaxed Standards – Eligibility and Selection Criteria – The term 'any' in the context of relaxations or concessions in eligibility or selection criteria at 'any stage of examination' under Rule 14(ii) proviso of the Exam Rules, 2013, is broad and includes relaxation availed in the Preliminary Examination – A candidate availing such relaxation is not eligible to be adjusted against unreserved vacancies – This interpretation aligns with the Cadre Allocation Policy, which mandates selection on 'General Standard' without availing any 'Relaxed Standard' for allocation to unreserved vacancies – The Court emphasized that the Preliminary Examination, though a screening test, is an integral stage of the examination, and any relaxation availed therein has consequences for final cadre allocation – The High Court's view that initial relaxation fades into insignificance if a candidate performs on merit in subsequent stages was rejected – The Supreme Court reiterated that once a relaxation is taken, the candidate cannot claim a general category vacancy [Paras 22, 24, 28, 29, 36].

Decision: Appeal allowed – The impugned final judgment and order dated 06.08.2019 passed by the High Court of Karnataka at Bengaluru in Writ Petition No. 54254 of 2016 (S-CAT) connected with Writ Petition No. 18947 of 2016 (S-CAT), affirming the order of the Central Administrative Tribunal, Bangalore Bench dated 15.03.2016 in O.A. No. 170/00239/2015, are hereby set aside – The notification dated 13.03.2015 issued by the MoEFCC insofar allocating the Karnataka Cadre to Respondent No. 3 and Tamil Nadu Cadre to Respondent No. 1 is upheld as correct in eyes of law and without any alteration [Paras 40, 41].

Criminal Law – Corruption – Disciplinary Proceedings and Criminal Prosecution – Independence of Proceedings – Allegation of demand and acceptance of bribe by Executive Engineer – Successful trap laid by ACB – Departmental enquiry ended in exoneration – High Court quashed criminal proceedings relying on Radheshyam Kejriwal – Held, disciplinary proceedings and criminal prosecution are independent and parallel – Exoneration in disciplinary enquiry does not ipso facto bar criminal prosecution [Paras 2, 9, 13].

Service Law – Standard of Proof – Distinction Between Departmental Enquiry and Criminal Trial – Departmental enquiry governed by preponderance of probabilities – Criminal trial requires proof beyond reasonable doubt – Failure to prove charge in departmental proceedings does not automatically negate criminal culpability – Evidence in each proceeding must be assessed independently [Paras 2, 9–10].

Quashing of Criminal Proceedings – Limits of High Court’s Power – Criminal proceedings quashed solely on basis of disciplinary exoneration held unsustainable – Criminal prosecution cannot be terminated by presuming insufficiency of evidence before trial – Anticipated failure of prosecution cannot be a ground for quashing [Paras 16–19].

Precedent – Radheshyam Kejriwal v. State of W.B. – Scope Explained – Principle that criminal prosecution cannot continue after exoneration on merits applies only where adjudication and prosecution arise under same statute by same authority and substratum of allegation is found non-existent – Not applicable to disciplinary enquiry and corruption prosecution conducted by different authorities [Paras 6–8, 13–14].

Precedent – State (NCT of Delhi) v. Ajay Kumar Tyagi – Applicability Affirmed – Held, Ajay Kumar Tyagi correctly lays down law that exoneration in departmental proceedings does not automatically warrant quashing of criminal case – No conflict with Radheshyam Kejriwal – High Court erred in treating Ajay Kumar Tyagi as per incuriam [Paras 10–13].

Departmental Enquiry – Nature and Evidentiary Value – Enquiry Officer’s report is not conclusive – Disciplinary Authority alone decides guilt or exoneration – Appointment of retired judicial officer as Enquiry Officer does not elevate evidentiary value of report – Enquiry report cannot bind criminal court [Paras 14–15].

Corruption Trap Case – Appreciation of Enquiry Findings – Enquiry exoneration based on non-examination of trap officer and witnesses standing outside office – Held, not an exoneration on merits – Evidence of complainant and independent witnesses sufficient even on preponderance of probabilities – Enquiry Officer and Disciplinary Authority applied incorrect standard of proof [Paras 16–18].

Role of Investigating Agency and Criminal Court – Criminal court has coercive powers to secure presence of witnesses – Failure of witness to appear in departmental enquiry cannot be equated with failure in criminal trial – No presumption of prosecutorial laxity permissible [Paras 16–18].

Effect of Departmental Exoneration on Service – While disciplinary proceedings cannot be reopened due to criminal court findings – Conviction in criminal case would entail service consequences as per applicable rules, expressly reserved by disciplinary authority [Para 19].

Decision: Appeal allowed – Judgment of High Court quashing criminal proceedings set aside – Criminal prosecution directed to continue in accordance with law.