Criminal Law – Double Jeopardy – Acquittal and De Novo Investigation – High Court Order Quashed – The High Court ordered reinvestigation and subsequent prosecution despite appellant’s prior acquittal – Held: Such direction violates the constitutional protection under Article 20(2) and statutory safeguards under Section 300 Cr.P.C., which bar retrial for the same offence once acquitted – High Court order and subsequent proceedings quashed [Paras 35-38].

Power of Appellate Court – Scope of Section 386 Cr.P.C. – The High Court, while exercising powers under Section 386, can order retrial but not reinvestigation – Reinforcing principles of fair trial, retrial is permitted only in exceptional cases where procedural irregularities render the trial ineffective – High Court overstepped its jurisdiction by directing reinvestigation [Paras 26-30].

Principle of Autrefois Acquit – Statutory and Constitutional Protections – The Court reiterated that double jeopardy prohibits retrying a person for the same offence post-acquittal unless specific statutory exceptions apply – Reinvestigation directed by the High Court contravenes established criminal jurisprudence [Paras 33-34].

Right to Fair Trial – Impact of Faulty Investigation – Emphasized that lapses in investigation should not prejudice the accused – Reinforcing earlier judgments, the Court ruled that substandard investigation does not justify reopening trials or reinvestigation absent exceptional grounds [Paras 31-32].

Decision: Appeal allowed – High Court order directing reinvestigation by CBI quashed – Appellant acquitted of all charges – Pending applications disposed of.

Scope of Section 195 Cr.P.C. – Applicability to Tribunals – Section 195 read with Section 340 Cr.P.C. mandates that complaints for offences under Sections 193, 199, and 200 IPC, when committed before a Court, must be filed only by orders of the Court concerned – Tribunal not defined as "Court" under law – Held: Offences alleged to have been committed before a Tribunal may be addressed through private complaints rather than following the procedure under Section 195 Cr.P.C..

Private Complaints – Offences under Sections 193, 199, and 200 IPC – Where offences are committed outside a Court, private complaints are maintainable – Tribunal, being outside the definition of "Court," can entertain such complaints – Held: Private complaints are valid for offences committed before the Municipal Building Tribunal in this case.

Quashing of Complaint – High Court’s Jurisdiction under Section 482 Cr.P.C. – High Court quashed the private complaint on the ground that it contravened Section 195 Cr.P.C. – Supreme Court held this reasoning to be erroneous, as the Tribunal was not a Court – Held: High Court order set aside, and private complaint restored for adjudication on merits by the Tribunal.

Decision – Appeal allowed – Private complaint restored to the Tribunal – Supreme Court clarified that the decision is based solely on technical and legal grounds, and the merits of the case remain to be adjudicated by the Tribunal.

Matrimonial Law – Divorce - Mental Cruelty – Filing False Complaints – Section 13(1)(ia), HMA – Divorce Granted – The High Court held that the appellant-wife’s act of filing a false dowry harassment complaint against the respondent-husband and his family, later abandoned, amounted to mental cruelty – Prolonged separation of over 15 years demonstrated an irretrievable breakdown of marriage – Held: Filing false complaints with intent to harass constitutes cruelty, justifying dissolution of marriage – Decision: Decree of divorce granted; appeal dismissed; permanent alimony awarded to the appellant and daughter [Paras 8, 10, 14-16, 27-29, 41].

Desertion – Prolonged Separation – Section 13(1)(ib), HMA – Divorce Granted – The High Court concluded that the appellant’s prolonged separation without reasonable cause and lack of interest in reconciliation amounted to desertion – Held: Willful abandonment of matrimonial obligations constitutes desertion, justifying divorce – Decision: Marriage dissolved due to desertion; permanent alimony granted [Paras 11, 13, 30-33, 40].

Irretrievable Breakdown of Marriage – Prolonged Separation – Article 142 of the Constitution – Relief Granted – The Court acknowledged the irretrievable breakdown of the marriage due to 20 years of separation, during which reconciliation efforts failed – Held: While not a statutory ground, irretrievable breakdown justifies dissolution of a marriage when continuation would only perpetuate distress – Decision: Marriage declared irretrievably broken; divorce decree upheld; permanent alimony granted [Paras 30-33, 41].

Jurisdiction of High Court – Section 100, CPC – Substantial Question of Law – High Court’s Interference Justified – The High Court reversed concurrent findings of the lower courts by addressing substantial questions of law related to the appellant’s conduct and the irretrievable breakdown of the marriage – Held: Such interference is permissible under Section 100, CPC – Decision: High Court’s jurisdiction upheld; divorce decree maintained [Paras 6-8, 17-18, 23].

Permanent Alimony – Financial Independence and Dignity – Alimony Awarded – The Court directed the respondent-husband to pay Rs. 50,00,000/- as permanent alimony to the appellant-wife and an additional Rs. 50,00,000/- for the education and future expenses of their daughter – Held: Alimony ensures financial stability and dignity, safeguarding the rights of dependents post-divorce – Decision: Permanent alimony of Rs. 1 crore awarded to appellant and daughter; payments to be made within four months [Paras 36-40, 41].

Family Law - Irretrievable Breakdown of Marriage – Grant of Divorce under Article 142(1) – The Court dissolved the marriage between the petitioner and the respondent, citing irretrievable breakdown of marriage – The marriage was marred by multiple litigations, allegations of cruelty, and false criminal complaints – Held: The marriage had become emotionally dead and unworkable – Divorce granted under Article 142(1), balancing equities, including permanent alimony to the petitioner [Paras 9.10, 9.15-9.16, 12].

Transfer Petition – Section 25 CPC – Adjudication of Alimony – The Court transferred the divorce petition from Bhopal to Pune for adjudication limited to determining alimony – Alimony fixed at ₹2 lakhs per month or ₹10 crores in lump sum, considering the respondent’s financial status, marriage duration, and circumstances [Para 3.10, 3.13].

Misuse of Criminal Law – Effect on Marital Relationship – The petitioner’s filing of false criminal cases under Sections 498A, 376, and 377 IPC, Look Out Circulars, and arrest of the respondent irreparably fractured the marriage – Such actions amounted to cruelty against the respondent [Paras 9.9, 10].

Exercise of Article 142(1) – Complete Justice Achieved – Broad powers under Article 142(1) were used to dissolve the marriage and provide equitable relief – Held: Prolonged litigation and acrimony necessitated this decision – Relief included permanent alimony balancing fairness for both parties [Paras 9.16, 10].

Decision: Petition partly allowed – Marriage dissolved under Article 142(1) – Alimony to be determined by the Family Court at Pune.

Drug Regulation – Section 26A of Drugs and Cosmetics Act – Centralized Prohibition Mandatory – High Court Orders Set Aside – Appellants holding valid drug sale licenses were restrained by local authorities from selling “Aromatic Tincture of Cardamom” citing misuse as substitute for liquor – Held: Without a notification from the Central Government under Section 26A of the D&C Act, local authorities lack jurisdiction to impose a ban or treat the product as prohibited – Statutory scheme mandates centralized decision-making to prevent arbitrary regional prohibitions [Paras 6–10, 13–14].

Administrative Law – Scope of Section 22 of D&C Act – No Power to Prohibit Licensed Drugs – Local Drug Inspectors’ powers under Section 22 are procedural and limited to enforcement and inspections – They cannot substitute the Central Government’s role under Section 26A – Actions taken by Respondents were beyond statutory powers and unsustainable in law [Paras 11–12].

Constitutional Law – Article 19(1)(g) – Right to Trade – Arbitrary Interference Unconstitutional – Petitioners’ lawful business in selling licensed medicinal product protected under Article 19(1)(g) – Interference by State officials absent legal basis was violative of fundamental rights – RTI replies confirming legality of product further support petitioner’s claim [Paras 4.2–4.4, 13].

Decision – Civil Appeals Allowed – High Court’s orders dated 12.07.2022 and 22.09.2022 set aside – Orders dated 28.02.2022 and 11.04.2022 of State Authorities also quashed – Appellants entitled to resume business without interference unless Central Government issues contrary notification under Section 26A – Respondents directed not to impose curbs absent such statutory authority [Paras 14–17].

Criminal Procedure Code, 1973 – Discharge under Section 239 Cr.P.C. – Prima Facie Case – High Court set aside the charges framed under Section 109 IPC read with Section 13(1)(e) punishable under Section 13(2) of the Prevention of Corruption Act, 1988, and discharged the respondent – Held: The Trial Court correctly found prima facie case against the respondent based on the investigation materials – High Court exceeded its jurisdiction under revision by meticulously analyzing evidence for "clinching material" instead of prima facie assessment – Such analysis was inappropriate at the discharge stage under Section 239 Cr.P.C. – High Court erred in setting aside the charge framed by the Trial Court [Paras 9, 13, 14].

Disproportionate Assets – Prima Facie Evidence – Framing of Charges Justified – Charges were framed against the respondent and her husband for the possession of disproportionate assets – High Court quashed the charges against the respondent, holding that there was no material evidence of abetment – Held: The Trial Court appropriately found a prima facie case, and the High Court’s meticulous examination for "clinching evidence" exceeded its jurisdiction at the discharge stage under Section 239, Cr.P.C. [Paras 5-9, 12].

Abetment and Relationship with Public Servant – Mere Association Not Sufficient for Liability – The respondent’s liability was alleged due to her relationship with her husband, a public servant accused of disproportionate assets – High Court erred by delving into the merits instead of evaluating prima facie suspicion, which is sufficient to frame charges at this stage [Paras 6-10, 15].

Presumption of Innocence – Scope of Section 239, Cr.P.C. – At the stage of discharge, the focus is on whether a prima facie case exists, not the sufficiency of evidence for conviction – The High Court misapplied principles of trial to the discharge stage [Paras 9-13].

Decision: The appeal was allowed. The High Court’s order discharging the respondent was set aside. The Trial Court was directed to proceed with the trial expeditiously, as the case dated back to 2013.

Taxation Law - Central Excise Tariff – Classification of Coconut Oil – Edible Oil vs. Hair Oil - Pure coconut oil marketed in small quantities – Dispute on classification under Heading 1513 (Edible Oil) in Section III-Chapter 15 or Heading 3305 (Hair Oil) in Section VI-Chapter 33 of the First Schedule to the Central Excise Tariff Act, 1985 – Held: Classification depends on the packaging and intended use indicated on the labels – If packaged and marketed as edible oil, it is classifiable under Heading 1513 – Packaging indicating use as a cosmetic or toilet preparation brings it under Heading 3305 [Paras 1-48].

Classification Dispute – Coconut Oil – Heading 1513 or 3305 – Classifiable as Edible Oil – Dispute over classification of coconut oil packaged in small quantities ranging from 5 ml to 2 liters – Court held that pure coconut oil, marketed as edible oil, is classifiable under Heading 1513 unless its packaging indicates use as a cosmetic or toilet preparation under Heading 3305 – Relied on alignment of Indian tariff with the Harmonized System of Nomenclature (HSN) and statutory changes post-2005 [Paras 30-40].

Statutory Interpretation – Role of Harmonized System of Nomenclature (HSN) – Affirmed that the First Schedule to the Central Excise Tariff Act aligns with the HSN – The classification must consider HSN notes unless explicit divergence is legislated in India – Applied to interpret changes in the classification of coconut oil post-2005 amendment [Paras 15-22].

Applicability of the ‘Common Parlance Test’ – Limited to Ambiguity – Emphasized that the common parlance test applies only when statutory provisions and tariff headings lack clarity – Court rejected Revenue’s reliance on the test for classifying coconut oil as hair oil without evidence supporting such use [Paras 41-45].

Onus of Proof – Burden on Revenue for Reclassification – Held: The burden of proof lies on Revenue to demonstrate that goods are classifiable under a specific heading other than the one claimed by the assessee – Revenue failed to prove that coconut oil was marketed as a cosmetic product [Paras 50-55].

Decision – Appeals dismissed – Coconut oil marketed as edible oil classified under Heading 1513 – Revenue directed to bear costs [Para 58].
 

Motor Vehicle Accident – Compensation – Involvement of Vehicle in Accident – Preponderance of Probability – Role of MACT and High Court in Appeal - Claim for compensation due to the death of the deceased in a motor accident – MACT awarded ₹50,41,289/- holding that the accident occurred due to the rash and negligent driving of a truck bearing registration no. MP-19-HA-1197 – High Court set aside the award, citing lack of proof of the vehicle’s involvement – Supreme Court held: Claimants need to establish their case on the preponderance of probability, not beyond a reasonable doubt – MACT’s findings were based on adequate evidence, including eyewitness testimony and the police investigation – High Court’s cryptic and summary reversal of the MACT’s award was unsustainable [Paras 1-19].

Motor Accident Claims – Standard of Proof – Preponderance of Probability – In motor accident claims, proof of the accident and vehicle involvement is based on a preponderance of probability and not beyond reasonable doubt – Held: The MACT's detailed findings supported by evidence stand restored; the High Court erred in summarily setting aside the award [Paras 30-33].

High Court's Role in First Appeals – Obligation to Marshal Evidence – An appeal under Section 173 of the Motor Vehicles Act is akin to a first appeal under the CPC – Held: The High Court failed to discharge its duty of carefully marshalling the evidence, including witness testimonies and documentary proofs, before reversing the MACT’s award [Paras 28-29].

Collusion Allegations by Insurer – Burden of Proof – The insurance company alleged collusion between the claimants and vehicle owner but failed to substantiate its claim through evidence or complaints – Held: The burden to prove collusion lies on the party asserting it; absence of proof strengthens the claimant's case [Paras 35-38].

Application of Multiplier in Compensation – Rejected Challenge – The insurance company's challenge to the multiplier applied by the MACT (11 instead of 9) was rejected – Held: The MACT's reliance on the deceased's age from the post-mortem report and the claim petition was proper; no contrary evidence was provided by the insurer [Paras 40-42].

Judicial Precedent – Importance of Detailed Reasoning in First Appeals – The judgment criticized the High Court for failing to discuss key exhibits such as the FIR, seizure memo, and witness statements, contrary to the established principles of appellate review [Paras 43-45].

Decision – Appeal allowed – High Court's judgment quashed and MACT’s award restored [Para 46].
 

Employment Law – University Recruitment – Teaching Experience as a Criterion – Validity of Regulation – Shortlisting for Interviews – Regulations Interpreted - Respondent 1, an aspirant for the post of Assistant Professor at Allahabad University and its constituent colleges, challenged the non-inclusion of her teaching experience as a guest lecturer and contractual faculty in the shortlisting process – The University relied on Regulation 10(f)(iii) of the UGC (Minimum Qualifications for Appointment of Teachers) Regulations, 2018, which excludes certain types of teaching experience unless specific conditions are met – The High Court read down the regulation, holding it inapplicable for direct recruitment to Assistant Professor posts – Supreme Court held: The High Court erred in reading down Regulation 10(f)(iii), as it was neither challenged nor found ultra vires – Regulation 10(f)(iii) applies to shortlisting, and its application is consistent with the UGC’s recruitment policy [Paras 1-52].

Shortlisting Process – Applicability of Regulation 10(f)(iii) – Legality Upheld – Regulation 10(f)(iii), which mandates specific emolument thresholds for recognizing past teaching experience, was contested as discriminatory – The Supreme Court upheld its applicability, finding it rational and consistent with UGC policy for merit-based shortlisting – The Division Bench of the High Court exceeded its jurisdiction by reading down the provision without declaring it unconstitutional [Paras 32-40].

Article 14 – No Discrimination in Salary-Based Distinction – The emolument-based differentiation under Regulation 10(f)(iii) was challenged as arbitrary – The Court found the provision aligned with quality benchmarks and not violative of Article 14, as teaching experience must meet specified standards [Paras 45-47].

Judicial Review – Limitation on Courts’ Legislative Role – The Court criticized the High Court for judicial overreach in reading down Regulation 10 without adequate constitutional basis or a finding of unconstitutionality – Held that courts must avoid rewriting legislation under the guise of interpretation [Paras 50-55].

Shortlisting Criteria – Rationality and Fairness – Affirmation of Process – The Supreme Court emphasized that rational shortlisting criteria, like Regulation 10(f)(iii), are permissible and necessary in handling a large number of applications for limited vacancies – The University's method of shortlisting was deemed reasonable and upheld [Paras 58-61].

Interpretation of Statutes – Reading Down – Principles Clarified – The Court reiterated that reading down is permissible only to save a provision from unconstitutionality and cannot be used to supplant clear legislative intent – Regulation 10(f)(iii) was found unambiguous and valid as enacted [Paras 63-67].

Decision – Appeals allowed – High Court's order set aside – Regulation 10(f)(iii) upheld – Writ petition by Respondent 1 dismissed [Para 70].