Civil Law - Rejection of Plaint  – Order 7 Rule 11 CPC – Existence of Cause of Action – Rejection Set Aside – The appellant challenged the High Court’s order which had rejected the plaint under Order VII Rule 11 CPC – Held: The plaint disclosed triable issues including whether the sale deeds executed after the revocation of an unregistered power of attorney were valid – The High Court erred in rejecting the plaint by failing to appreciate that the suit was based on two distinct causes of action, particularly the one arising after the revocation of the power of attorney [Paras 8-9.6].

Registration Act – Unregistered Agreement to Sell and Power of Attorney – Effect on Title – No Title Passed – Documents executed by Respondent No.1 including an unregistered agreement to sell and power of attorney do not confer ownership or title under Sections 17 and 49 of the Registration Act – Such documents are inadmissible in evidence for transfer of ownership and can only be used for collateral purposes or in a suit for specific performance – In this case, no such suit for specific performance was ever filed by the respondents – Hence, Respondent No.1 had no authority to execute the sale deeds [Paras 9-9.2].

Transfer of Property – Sale of Immovable Property – Section 54 of Transfer of Property Act – Agreement to Sell Does Not Create Title – It was reaffirmed that an agreement to sell does not create any interest in or charge on the immovable property – Execution of the sale deed without a valid, registered power of attorney was invalid in law [Paras 9.2-9.3].

Jurisdiction of Civil Court – Section 207 of Rajasthan Tenancy Act – Applicability – Civil Jurisdiction Upheld – The dispute relates to ownership and title of immovable property, which is triable by civil courts – Revenue records and mutation entries do not confer title – Hence, the bar under Section 207 of the Rajasthan Tenancy Act does not apply to this case [Paras 10].

Court Fee Deficiency – Opportunity to Rectify – Rejection Improper – It was held that a plaint cannot be rejected solely for insufficient court fees without first affording the plaintiff an opportunity to correct the deficiency – This principle was reaffirmed in line with settled precedents [Para 11].

Decision – Appeal Allowed – Impugned order of the High Court rejecting the plaint is set aside – Order of the trial court refusing to reject the plaint is restored – Trial court directed to proceed with the suit on merits uninfluenced by any observations in this judgment – No order as to costs [Paras 14-15].

Mining Leases – Validity of DMF Contribution Policy – Sections 9B & 15A of MMDR Act – Demand Upheld – The appellant, a sand mining lessee, challenged a Demand Notice requiring payment of 10% of the bid amount to the DMF Trust, asserting violation of Section 9B of the 1957 Act – The Supreme Court held that Section 9B is inapplicable to minor minerals due to Section 14 – Further, State power under Sections 15 and 15A to prescribe DMF contributions is valid – The 2017 State Policy was properly exercised under Rule 68 of the 1963 Rules and was binding – Demand found to be in conformity with Rule 10(2) of the 2017 DMF Rules – Appeals dismissed [Paras 5–26].

Criminal Law  – Sections 303, 307 & 34 of the IPC – Appeal Against Conviction - Suppression of Exculpatory Evidence – Violation of Fair Trial – Acquittal Ordered – Appellants convicted of murder and attempted murder under IPC Sections 302 and 307 based on eyewitness testimonies of PW-4, PW-5, and PW-6 – However, affidavits submitted by PW-5, PW-6, and injured PW-7 during bail proceedings contradicted their court testimonies and exonerated the accused – Investigating Officer admitted knowledge of these affidavits but failed to record supplementary statements or conduct verification – Such non-investigation and suppression violated the right to fair trial guaranteed under Article 21 of the Constitution – Held: Conviction based solely on PW-4's testimony, in absence of corroboration and amid investigative lapses, is unsafe – Conviction and sentence set aside; appellants acquitted [Paras 17-24].

Investigation – Duty of Police – Failure to Conduct Supplementary Investigation – Despite knowledge of contradictory affidavits by eyewitnesses, Investigating Officer did not take steps to verify or rebut them nor documented any attempts to locate the witnesses – This omission compromised the integrity of the investigation and prosecution – The suppression of material evidence affected the fairness of the trial and cast doubt on the credibility of key witnesses [Paras 18-20].

Judicial Practice – Reference to Lower Court Records – Directive Issued – Supreme Court reaffirms that trial court records must not be referred to as “Lower Court Record” – High Courts directed to comply with earlier circular replacing such terminology in court documentation and communication [Para 25].

Decision – Appeal allowed – Judgments of Trial Court and High Court set aside – Appellants acquitted of all charges – Bail bonds cancelled [Para 26].

Criminal Law – Quashing - POCSO Conviction – Role of High Court under Article 226 r/w Section 482 CrPC – High Court Overreach – High Court’s setting aside of the conviction under the POCSO Act and IPC held unsustainable – Supreme Court observed that the High Court misapplied its inherent powers, as serious offences like those under the POCSO Act cannot be quashed merely due to settlement or continued cohabitation between victim and accused – Held: Conviction restored for offences under Section 6 POCSO Act and Section 376(2)(n) & (3) IPC; acquittal for Sections 363 and 366 IPC confirmed [Paras 3, 23-23.1].

Victim Rehabilitation – State Responsibility under Article 21 and JJ Act – Constitutional Mandate Reaffirmed – Supreme Court held that the failure of the State to provide timely rehabilitation and care to a 14-year-old rape victim amounted to a violation of her fundamental right to life with dignity – Directed immediate constitution of expert committee for informed choice of victim, and mandated State to offer financial, educational, and housing support – Held: Non-compliance with Section 19(6) of POCSO Act results in denial of statutory and constitutional rights [Paras 24-26, 37-38, 44].

Sentencing – Article 142 – Complete Justice – Sentence Suspended – Despite confirmation of conviction, Supreme Court refrained from sentencing the accused, invoking powers under Article 142 to avoid further victim trauma and family disruption – Held: Though minimum sentencing under POCSO Act is mandatory, extraordinary circumstances warranted departure – Accused not to undergo further imprisonment; State to act as guardian of victim’s family and ensure rehabilitation [Paras 25-27, 31(a)].

Societal and Systemic Failure – Legal and Social Apathy Noted – Apex Court found a systemic breakdown in child protection measures – Highlighted inadequacies in local Child Protection Committees, lack of counselling and legal aid, and widespread exploitation of victims in the judicial process – Directed Centre to explore implementation of adolescent sexual health education and real-time data tracking mechanisms [Paras 12-13, 18-20, 30-31].

Decision – Conviction Maintained, Sentence Waived – In light of victim’s desire, Committee reports, and victim’s family interest, Court held that sentencing the accused would perpetuate injustice – Ordered permanent rehabilitation framework and periodic compliance reports from State – Union directed to respond with national implementation plan on adolescent protection measures [Paras 31(a)-(f), 32].

Contract Law – Electricity Act - Change in Law – Evacuation Facility Charges – Restitution Principle – Compensation Upheld – Coal India Limited issued a notification dated 19.12.2017 imposing Evacuation Facility Charges (EFC) – Adani Power informed the appellants the next day, claiming this constituted a change in law – APTEL affirmed change in law status and awarded compensation from the date of the notification along with carrying cost at LPS rates – Supreme Court upheld the finding and reaffirmed that the compensation must be provided based on restitutionary principles to restore the economic position of the generator as if the change in law had not occurred [Paras 3–7, 18–21].

Supplementary Bill – Necessity for Prior Issuance – Not a Prerequisite for Compensation – The appellants contended that relief could not be claimed without first raising a supplementary bill – Supreme Court rejected the argument, holding that a supplementary bill is to be raised after adjudication of the change in law event, and cannot preclude entitlement – Held: The absence of a prior supplementary bill does not affect the generator's right to compensation [Paras 24–26].

Interpretation of Article 10.5.1 of PPA – Change in Law via Notification vs Judicial Interpretation – Dispute centered on whether Article 10.5.1(i) or (ii) applied – Court clarified that since the change arose directly from a governmental notification (and not judicial interpretation), Article 10.5.1(i) applied – Held: Notification by Coal India Ltd. triggered compensation from its effective date, not from adjudicatory recognition [Paras 22–25].

Carrying Cost – Compound Interest Justified – Follows Restitutionary Principle – The Court upheld APTEL’s direction to award carrying cost at Late Payment Surcharge (LPS) rates, on a compound interest basis – Found consistent with prior judgments and the economic rationale behind restoring the generator’s position – Reaffirmed that contractual interpretation must reflect the intention of the parties and established jurisprudence [Paras 27–28].

Final Decision – Appeal Dismissed – APTEL’s Award Sustained – Supreme Court held that no substantial question of law arose beyond that already settled in prior decisions – No interference warranted – Appeal dismissed with costs [Paras 28–29].

Maternity Leave – Section 5 and 27 of the Maternity Benefit Act, 1961 - FR 101(a) and Constitutional Interpretation – Maternity Leave Granted – The appellant, a government teacher in Tamil Nadu, sought maternity leave for her first child born from her second marriage – The leave was denied on the ground that she already had two children from her first marriage – Supreme Court held that since the two children are in custody of her ex-husband and the present childbirth is from her subsisting marriage, the appellant is entitled to maternity benefits – Restriction under FR 101(a) must be interpreted liberally in light of constitutional rights and reproductive autonomy [Paras 4.1, 6, 9-11, 34-37].

Reproductive Rights – Article 21 of the Constitution – Maternity Leave as Reproductive Right – Recognized as a facet of the right to life – The Court emphasized that reproductive autonomy includes the right to bear children and access maternity benefits – Maternity leave is not merely a statutory right but part of the broader right to dignity and health under Article 21 [Paras 13-14, 28-31].

Maternity Benefit Act – Guidance in State Service Rules – Though not directly applicable to State Government employees, the provisions of the Maternity Benefit Act provide beneficial guidance – Supreme Court acknowledged that the Act allows maternity benefits even for more than two children, though with a reduced leave period, reinforcing the liberal interpretation required for FR 101(a) [Paras 18-20, 33].

International Norms – Relevance of CEDAW and International Covenants – The judgment draws heavily on international instruments such as CEDAW and the Universal Declaration of Human Rights to underscore that maternity protection is a human right – Reinforces the obligation of the State to provide maternity benefits as part of respect for international law [Paras 22-27].

Final Decision – Division Bench Judgment Set Aside – Maternity Leave Granted – Supreme Court set aside the Division Bench’s judgment of the Madras High Court and directed the State to release maternity benefits under FR 101(a) to the appellant within two months [Paras 36-38].

Criminal Law – Murder Conviction – Acquittal – Appellants convicted under Sections 302 and 307 read with Section 149 IPC and Section 3(1) of Tamil Nadu Prevention of Damage to Public Property Act – Trial Court and High Court upheld conviction based on testimonies of PW-1, PW-2 and PW-9 and corroborative material including fingerprint and recovery evidence – Supreme Court finds serious infirmities in prosecution’s case – Held: Conviction unsustainable as guilt not proved beyond reasonable doubt [Paras 1, 6, 41, 42]

Witness Testimony – PW-1 (Informant and Eye-Witness) – Evidence found unreliable due to political rivalry, exaggeration, inconsistencies, and lack of clarity regarding visibility and identification – Admitted naming 36 persons initially, later retracted against 15 with no objection to their removal – Court held his testimony exaggerated and not confidence-inspiring [Paras 16–21, 29]

Witness Testimony – PW-2 (Chance Witness) – Came forward after 43 days citing fear, but prosecution failed to explain delay or examine companion Abdul Rahman – Court held testimony unbelievable and adverse inference drawn against prosecution for non-examination of material witness [Paras 22–24, 30]

Child Witness – PW-9 (Injured Minor) – Aged 10 years, no preliminary voir dire by Trial Court, no test identification parade conducted – Admitted mother told her details of incident – Court held her evidence inadmissible due to non-compliance with legal standards for examining child witnesses [Paras 25–28, 31]

Circumstantial Evidence – Fingerprint Evidence – Fingerprints of Accused Nos. 2 and 3 alleged on Scorpio car – No Mahazar prepared, photographs not exhibited, procedural irregularities found – Court held fingerprint evidence unreliable [Para 32]

Circumstantial Evidence – Recovery of Weapons – Recovered from common or open locations at different times with questionable reliability – Held: Recovery evidence alone insufficient for conviction in absence of credible primary evidence [Para 33]

Appellate Jurisdiction – Article 136 – Scope of Interference – Reiterated that Supreme Court generally does not interfere with concurrent findings unless manifest illegality or misreading of evidence causing miscarriage of justice – In this case, striking features of evidence overlooked and misread by both lower courts warranted interference [Paras 36–40]

Decision: Appeals allowed – Conviction and sentence set aside – Appellants acquitted of all charges – To be released from custody forthwith if not required in any other case [Paras 41, 42]

Criminal Law  – Supplementary Evidence – Production of CDs at Trial – Permissible Omission – Upheld – CDs seized before filing of original chargesheet but not produced due to inadvertence – Supplementary chargesheet filed with forensic report but without CDs – Supreme Court held omission not fatal – CDs could be produced later with court’s permission without prejudice to accused, following precedent in R.S. Pai – Held: Such production is not barred under CrPC Section 173(5), as the provision is directory, not mandatory [Paras 10-15].

Further Investigation – Section 173(8) CrPC – Scope – Supplementary Chargesheet Valid – Even without “new” evidence – Held: Supplementary chargesheet referring to CDs and CFSL report valid, as CDs were already sent for analysis and referenced therein – Court clarified “further investigation” includes procedural completion of existing evidence, not necessarily discovery of new facts [Paras 11-13].

Evidence – Electronic Evidence – Section 65B Certificate – Admissibility and Authenticity – Kept Open – Court refused to adjudicate admissibility and genuineness of CDs or certificates under Section 65B at preliminary stage – Left open for trial court determination – Appellant permitted to cross-examine witnesses with regard to CDs [Paras 17-18].

Decision – Appeal Dismissed – High Court and Special Court Orders Affirmed – Supreme Court upheld production of CDs and denied relief to appellant – Held: No reason to reconsider precedent in R.S. Pai; no prejudice caused – However, left open issues of authenticity and admissibility for trial [Paras 15, 19].

Criminal Law – Legality of Arrest – Habeas Corpus – Grounds of Arrest Provided – Appeal Dismissed - Appellant challenged arrest of his son as illegal under Article 22(1) and Section 47 of BNSS – Alleged non-disclosure of meaningful grounds of arrest and absence of sanction under Section 17A of PC Act – Supreme Court held: Grounds of arrest were communicated in sufficient detail and in a meaningful manner at time of arrest – Arrest and remand valid under constitutional and statutory provisions [Paras 1–3, 14, 21, 37, 38]

Constitutional Rights – Article 22(1) – Scope and Compliance – Grounds Must Be Meaningful – Held: Compliance with Article 22(1) requires that the arrestee be informed in a manner that imparts sufficient knowledge of the basic facts constituting the arrest – Court found that grounds of arrest given to the arrestee included detailed allegations such as control of liquor trade, collection of kickbacks, and misuse of shell companies – Hence, requirement under Article 22(1) was fulfilled [Paras 20–22, 27–29, 37]

Preventive Arrest – Section 17A of Prevention of Corruption Act – Applicability – Sanction for Arrest – Not Required – Allegation that arrest was illegal due to lack of prior sanction under Section 17A – Rejected by Court – Held: Appellant’s son was not a public servant whose decisions related to official duties invoked protection under Section 17A – Sanction granted for co-accused does not affect legality of appellant’s arrest [Paras 5(B)(iv), 7–10]

Remand and Procedural Safeguards – BNSS Sections 47, 48, 187 – Compliance Found – Appellant alleged delay and procedural impropriety in remand – Held: Arrestee was produced within 24 hours, informed of arrest, and served with remand report – Magistrate confirmed procedural compliance – Court upheld legality of remand [Paras 3(d)–3(e), 11–13, 37]

Decision – Appeal Dismissed – Arrest and Custody Valid – Supreme Court held that the arrest of Kessireddy Raja Shekhar Reddy was not illegal – All constitutional and statutory safeguards were satisfied – Remedy of regular bail left open [Paras 38–39]