Matrimonial Law - Transfer Petitions – Matrimonial Disputes – Amicable Settlement – All proceedings quashed – Multiple litigations were pending between the parties in various courts, including criminal and civil matters arising from matrimonial discord – Held: The Court exercised its power under Article 142 to quash all proceedings including FIRs, complaints, revisions, and petitions to bring an end to the litigation and restore peace between families [Paras 1-4, 11-14, 25-26].

Child Custody – Supervised Visitation – Welfare of the Minor – Custody of the 8-year-old daughter was awarded to the mother with monthly supervised visitation rights granted to the father and his family – Provisions were made for vacation sharing and future conflict resolution through designated mediators from both parties [Para 8].

Maintenance and Alimony – Voluntary Waiver – Previous Maintenance Order Quashed – The wife waived all claims to present and future alimony or maintenance and undertook to bear all expenses for the daughter – In light of this, the maintenance order of Rs. 1,50,000/- per month passed by the Allahabad High Court was quashed [Paras 9-10].

Property Transfer – Conditional Compliance – Transfer of Disputed Land – The wife’s mother was directed to gift specified agricultural land in Aligarh to the husband on an ‘as is where is’ basis – The husband to bear all future litigation and transfer-related expenses – Complete documents to be handed over within stipulated time [Para 17].

Social Conduct – Undertaking of Non-Interference – Apology Mandated – Both spouses agreed not to interfere in each other’s personal or professional lives and to refrain from using their positions to cause harm – Wife directed to publish an unconditional apology in national dailies and on social media as a step toward closure – Said apology shall not be construed as admission of liability and cannot be used to her prejudice [Paras 15, 19-21].

Article 142 – Divorce Decree – Finality to Disputes – Marriage dissolved by invoking Article 142 of the Constitution – All existing and future related litigations barred – Breach of settlement terms to amount to contempt – Divorce decree to be drawn accordingly [Para 25].

Education Law - Admission and Eligibility – Change in Admission Criteria – Unclear Prospectus and Addendums – Appellant applied under the 2020 Prospectus and was granted provisional admission in M.Sc. Environmental Management based on merit – Subsequent addendums excluded private university graduates from eligibility, resulting in her candidature being rejected – Held: Eligibility criteria was not clearly spelt out initially, and addendums created confusion warranting judicial intervention [Paras 2-9, 21-22].

Educational Rights – Degree Cancellation – Article 142 Invoked – After completing the full course with good academic performance and fulfilling all formal requirements including attendance and examinations, the appellant was awarded the degree which was later withdrawn by the university – Held: Degree withdrawal unjust after two years of valid study – Exercise of powers under Article 142 warranted to restore justice [Paras 14-26].

University Accountability – Duty to Ensure Clarity – Prospectus Terms and Delayed Addendums – Respondent University’s ambiguity and delayed amendments caused confusion in eligibility – Appellant’s rejection should have occurred at the initial stage if criteria had been clear – Held: Universities must exercise diligence in declaring eligibility criteria in time to prevent harm to students [Paras 15-17, 22].

Final Relief – Degree to be Restored – High Court Judgments Set Aside – Supreme Court set aside both the single judge and Division Bench judgments of the Himachal Pradesh High Court and ordered that the postgraduate degree conferred on 04.05.2023 be upheld – Cancellation order dated 05.08.2023 declared otiose [Paras 26-28].

Criminal Law - Murder  –Section 302 & 34 of the  IPC – Acquittal Ordered – The Trial Court and High Court had convicted the appellants based solely on the testimony of the deceased’s wife and son – Supreme Court found improbabilities in their presence at the scene, contradictions with the medical evidence, and no corroboration from other witnesses – Held: Conviction unsustainable due to serious doubts in prosecution story – Appeals allowed and appellants acquitted [Paras 1-2, 6-13, 27-34].

Credibility of Interested Witnesses – Eyewitness Testimony Scrutinized – The prosecution relied exclusively on the deceased’s close relatives as witnesses – Their account of reaching the crime scene 16 km away on a bicycle within 30 minutes was found improbable – Held: Interested testimony must be subjected to greater scrutiny – Not safe to convict without corroboration from independent witnesses [Paras 22-27].

Failure of Prosecution – Hostile Witnesses – Doubts in Medical and Ocular Evidence – All independent eyewitnesses including TASMAC shop staff turned hostile – Medical report indicated attack by multiple persons, inconsistent with prosecution claim of two assailants – Held: Glaring omissions and improbabilities raised serious doubts – Prosecution failed to prove guilt beyond reasonable doubt [Paras 30-32].

Benefit of Doubt – Improbability in Presence – No Immediate Reporting to Police – Conduct of eyewitnesses found unnatural – Travelled 16 km back home instead of informing nearby police station – Held: Circumstances raise significant doubt about presence of witnesses at crime scene – Appellants entitled to benefit of doubt [Paras 28-29].

Decision – Conviction Set Aside – Appellants Acquitted – The Supreme Court quashed the convictions passed by the Madras High Court and Trial Court – Ordered immediate release of both accused unless required in any other matter [Para 34].

Service Law – Pension Entitlement – Resignation vs. Voluntary Retirement – Regulation 22 – Pension Denied - Resigned bank employee with over 35 years of service sought pension benefits under 1995 Pension Regulations – Supreme Court held resignation and voluntary retirement are distinct service termination modes – Regulation 22 lawfully excludes pension benefits upon resignation – Held: Employee who resigned cannot claim pension – No violation of Article 14 found [Paras 4.10, 47-53, 59].

Pension Scheme – Judicial Review of Policy – Direction to Amend Regulation – Impermissible – High Court directed Bank’s Board to consider amending Regulation 22 to allow pension to resigned employees – Supreme Court ruled such direction is tantamount to mandating legislation and exceeded judicial bounds – Held: Courts cannot compel executive action in policy framing – Directions (B to D) of High Court set aside [Paras 66-68].

Service Jurisprudence – Beneficial Interpretation – Article 142 – Resignation Due to Mental Depression – Relief Granted - Despite holding resignation disentitles pension, Court exercised Article 142 to grant equitable relief considering mental health and 35+ years of unblemished service – Held: Respondent allowed to opt under 2024 Bipartite Settlement or receive Rs. 5,00,000 as ex gratia if ineligible or unable to refund PF with interest [Paras 71-73].

Precedents – Shree Lal Meena Binding – Other Contradictory Decisions Disapproved – Earlier rulings such as Sheelkumar Jain and Asger Ibrahim Amin disapproved by larger bench in Shree Lal Meena – Conceptual clarity affirmed: resignation entails forfeiture of service unlike voluntary retirement – Reliefs under resignation cannot be extended based solely on length of service [Paras 43-47].

Final Decision – High Court Judgment Modified – Division Bench’s direction (A) setting aside Single Judge's order upheld – Remaining directions (B to D) quashed – Connected appeal dismissed – Lead appeal partly allowed with relief under Article 142 extended as exceptional case [Paras 65-74].

Criminal Law - Anticipatory Bail – Cancellation of Pre-Arrest Bail – Sections 143, 147, 149, 323, 387, 427, 452, 504, 506, 406, 403, 420, 467, 468, 471, 120B, 34 of the IPC -Grave Offences of Property Trespass and Threatening Complainant – Anticipatory Bail Cancelled – The appeals arose from the grant of anticipatory bail to the accused, including the estranged husband of the complainant, in a case of criminal trespass, assault, and damage to property inherited by the complainant from her father – The Supreme Court found that the High Court erred in granting anticipatory bail despite serious allegations of forcible dispossession, concealment of facts, threats to witnesses, and multiple ongoing criminal proceedings against the accused – Held: Considering the gravity of allegations, concealment of facts, violation of bail conditions, and risk of tampering with evidence, the High Court’s order was quashed, anticipatory bail cancelled, and accused directed to surrender with liberty to apply for regular bail [Paras 1-22].

Concealment of Material Facts – Suppression of Crucial Developments – Bail Order Invalidated – The accused misled courts by concealing the setting aside of a civil injunction which was used to justify interim protection from arrest – Held: Deliberate suppression of material developments is sufficient ground to invalidate bail orders [Paras 9, 19].

Violation of Bail Conditions – Threatening of Witnesses and Tampering with Evidence – Bail Cancelled – The accused violated bail conditions by threatening hotel staff and attempting to intimidate witnesses, which amounted to interference with the process of justice – Held: Serious post-bail conduct justified immediate cancellation of bail [Paras 12, 20].

Grave Allegations Require Custodial Interrogation – Accusations of Forgery, Trespass, and Fraudulent Loan Transactions – Bail Denied – The accused faced allegations of property trespass, criminal intimidation, forgery of documents, and misuse of power of attorney for fraudulent financial transactions – Held: Such serious accusations necessitated custodial interrogation, and grant of anticipatory bail was unjustified [Paras 17-20].

Exceptional Remedy of Anticipatory Bail – Cautious Judicial Approach Mandated – Reliance on Srikant Upadhyay v. State of Bihar – The Court reiterated the principle that anticipatory bail is an exceptional remedy to be granted cautiously in serious offences, especially where there is risk of justice being obstructed – Held: The High Court overlooked the established cautionary standards while granting anticipatory bail [Paras 18-19].

Decision – Appeal Allowed – Anticipatory Bail Cancelled – High Court’s Order Set Aside – The Supreme Court allowed the appeals, quashed the High Court order dated 19/06/2024, cancelled anticipatory bail, and directed the accused to surrender within two weeks, permitting them to apply for regular bail as per law [Paras 21-22].

Civil Law - Title Dispute – Registered Will and Oral Family Settlement – Title Declared in Favour of Second Wife – The Supreme Court adjudicated upon the rival claims of legal heirs regarding agricultural land after the death of Metpalli Rajanna – The Court accepted the validity of a registered Will executed in favour of the second wife, Lasum Bai, supported by corroborative oral family settlement, holding that she had rightful ownership over the suit schedule properties – Held: Decree of the trial Court granting absolute ownership to the second wife restored; High Court’s interference set aside [Paras 1-13].

Genuineness of Will – Registered Will – Presumption of Validity – Will Upheld - The Court upheld the registered Will dated 24th July, 1974, noting that the defendant, Muthaiah, admitted the signature of the testator – Held: Registration of the Will raises presumption of genuineness, especially when the principal beneficiary (defendant) also derived substantial benefit under the same Will, negating suspicion [Paras 9-10].

Oral Family Settlement – Admissibility and Effect – Family Arrangement Recognised - The Court recognised the existence and binding nature of oral family settlement made by the father to prevent disputes among heirs, corroborated by revenue records and long-standing possession – Held: Oral family settlement supplemented by Will validly distributed property among heirs [Paras 9-11].

Possession and Unchallenged Sale – Validity of Sale Deeds – Uninterrupted Possession Confirmed Ownership - Plaintiff's possession over disputed property and valid sale deeds executed in favour of third parties (including Janardhan Reddy) were recognised – Held: Non-challenge to sale deeds by defendant and consistent possession established rightful ownership [Paras 4.6, 11].

High Court’s Error – Reversal of Decree Without Justification – Trial Court's Judgment Restored – The Supreme Court held that the High Court erred in reducing the plaintiff’s share from full ownership to 1/4th share, despite clear evidence supporting full ownership – Held: Trial Court’s decree based on sound reasoning rightly granted absolute title to Lasum Bai; High Court's judgment reversed [Paras 12-13].

Final Decision – Appeals Allowed in Favour of Plaintiff – Full Ownership Restored - Civil Appeal No. 5921 of 2015 allowed, Civil Appeal No. 5922 of 2015 dismissed; declaration of title and permanent injunction granted in favour of plaintiff, restoring the trial Court's judgment [Para 13].

Custodial Torture – Illegal Detention – Registration of FIR Directed – Investigation Transferred to CBI – Counter FIR Quashed – ₹50 Lakhs Compensation Awarded – In a case involving shocking custodial torture of a serving police constable, including mutilation of genitalia during illegal detention, the Supreme Court reversed the High Court’s judgment refusing to register FIR or transfer investigation – Held: In view of grave injuries, fabricated counter FIR, and institutional bias, FIR to be mandatorily registered, investigation transferred to CBI, malicious counter FIR quashed, and interim compensation of ₹50,00,000 awarded to the victim for violation of fundamental rights under Article 21 of the Constitution [Paras 1-38].

Mandatory FIR Registration – Lalita Kumari Principle – Refusal to Register FIR Invalid – The Court held that once cognizable offences such as grievous custodial torture are disclosed, FIR registration is mandatory and cannot be circumvented by ordering a preliminary inquiry – Held: High Court erred in directing inquiry by interested police officers; direction issued for immediate registration of FIR and independent investigation [Paras 10-14].

Independent Investigation – Conflict of Interest – CBI Investigation Ordered – Local police involved in the offence cannot be entrusted with investigation – Held: In cases of custodial torture implicating local police, transfer to CBI is required to ensure independence, credibility, and fair inquiry under Article 21 [Paras 15-23].

Quashing of Counter FIR – Abuse of Process – Counter FIR Quashed – FIR registered against the victim under Section 309 IPC held to be malicious and part of an institutional cover-up – Held: Counter FIR lacked credibility and was quashed under Bhajan Lal principles as an abuse of criminal justice process [Paras 28-33].

Compensation for Violation of Fundamental Rights – Interim Compensation Granted – Considering egregious violation of Article 21, gross custodial torture, and systemic apathy, Supreme Court granted ₹50 lakhs interim compensation to the appellant – Held: Compensation recoverable from erring officials post CBI probe, without prejudice to further civil remedies [Paras 34-37].

Constitutional Mandate – Custodial Violence Cases Demand Highest Judicial Vigilance – Supreme Court reiterated principles from Lalita Kumari, D.K. Basu, Nilabati Behera and others, emphasising duty to uphold human dignity and prevent misuse of state power – Held: Extraordinary jurisdiction under Articles 136 and 142 invoked to protect rule of law and constitutional rights [Paras 10-14, 24-27, 38].

Final Decision – Appeal Allowed – High Court’s Judgment Set Aside – FIR Directed, CBI Probe Ordered, Counter FIR Quashed, Compensation Granted – Supreme Court allowed the appeal, directed CBI to register FIR and conduct investigation, quashed counter FIR under Section 309 IPC, awarded ₹50 lakh interim compensation, and upheld appellant’s right to further legal remedies [Para 38].

Criminal Law - Bail Cancellation – Abuse of Official Position – Sections 376, 328 IPC and Sections 3/4 IT Act, SC/ST Act – Bail Cancelled - The Supreme Court considered an appeal filed by the victim against the grant of bail to respondent No.2, who was accused of serious offences including sexual exploitation and torture of female inmates under her care as Superintendent of a women’s protection home – The High Court had granted bail through a cryptic order without hearing the victim in violation of Section 15A(3) of the SC/ST Act – Held: The Supreme Court cancelled the bail on grounds of non-compliance with statutory rights of the victim and the gravity of allegations, noting the accused’s influence and possibility of witness tampering [Paras 8-29].

Victim's Right to be Heard – Section 15A(3) SC/ST Act – Violation of Victim's Rights – The High Court granted bail without issuing notice to the victim, violating her statutory right to be heard – Held: The Supreme Court quashed the High Court's bail order solely on this ground, emphasizing that non-compliance with Section 15A(3) invalidates bail orders [Paras 8, 25-26].

Grave Nature of Allegations – Custodian Turned Perpetrator – Sections 376, 328 IPC – Bail Cancelled Due to Serious Offences – Allegations involved sexual exploitation of helpless women by the very person entrusted with their protection – Held: Such breach of trust and abuse of official authority warranted cancellation of bail to prevent miscarriage of justice [Paras 20-22].

Societal Impact and Threat to Trial – Influence on Witnesses – Bail Revoked to Safeguard Fair Trial – The Court found a high possibility of the accused influencing witnesses, given her reinstatement in service and access to similar institutions – Held: Bail cancelled to prevent undermining public faith in judicial process and ensure fair trial [Paras 14, 22, 27].

Guiding Principles on Bail Cancellation – Reliance on Precedents – Application of Ajwar v. Waseem and Shabeen Ahmad v. State of UP – The Court reiterated parameters for bail cancellation including gravity of offence, impact on society, and risk to fair trial – Held: Unreasoned bail orders in grievous crimes merit judicial correction [Paras 23-24].

Final Decision – Appeal Allowed – Bail Cancelled – The Supreme Court quashed the High Court order dated 18/01/2024, cancelled the bail of respondent No.2, directed her surrender, and issued safeguards for victims – Held: Appellant's appeal allowed, bail of respondent No.2 stands cancelled [Paras 28-30].

Arbitration Law – Existence of Arbitration Agreement – Clause with Directory Language – Appeal Dismissed – The appellant invoked Section 11 of the Arbitration and Conciliation Act, 1996 seeking appointment of arbitrator based on Clause 13 of the contract, which used the expression “may be sought through arbitration” – The Supreme Court held that mere inclusion of an enabling provision does not amount to a binding arbitration agreement – The Court found no consensus ad idem to refer disputes to arbitration, affirming the High Court's rejection of appointment of arbitrator – Held: Absence of binding arbitration clause precludes reference to arbitration under Section 11 [Paras 1-34].

Judicial Examination – Referral Court’s Role Under Section 11 – Prima Facie Satisfaction Required – Court Clarified – The Court reiterated principles laid down by the seven-Judge Bench in Interplay Between Arbitration Agreements, (2024) 6 SCC 1, holding that under Section 11, the Court must conduct a prima facie examination of the existence of arbitration agreement but cannot compel arbitration in absence of such agreement – Held: Referral Court’s limited examination is essential to prevent frivolous arbitration claims [Paras 14-19].

Interpretation of Contractual Clause – Directory vs Mandatory Language – Non-Existence of Binding Clause – The Supreme Court held that use of directory language like “may be sought” indicates lack of obligation to arbitrate and absence of present commitment to resolve disputes by arbitration – Held: Clause 13 lacked necessary elements of arbitration agreement under Section 7, particularly the binding nature of dispute resolution method [Paras 20-32].

Non-Applicability of Doctrine of Competence-Competence – No Need to Refer Matter to Arbitral Tribunal – The Court rejected the contention that the issue should have been left to the arbitral tribunal under the doctrine of competence-competence – Held: Where prima facie no arbitration agreement exists, the matter should not be referred to arbitration at all [Paras 16-19].

Decision – Appeal Dismissed – No Arbitration Agreement Found – The Supreme Court dismissed the appeal, upheld the High Court’s order refusing to appoint arbitrator, clarified the distinction between enabling dispute resolution clauses and binding arbitration agreements, and directed no costs [Paras 34-36].