Criminal Law - Quashing of Criminal Proceedings – Abetment of Suicide – Absence of Mens Rea – No Proximate Link – Appellants were accused of abetting the suicide of deceased Tanu by making derogatory remarks after the alleged murder of Ziaul Rahman by Tanu’s family – Held: To constitute an offence under Section 306 IPC, a clear intention to instigate or aid the suicide must be established – Mere verbal altercation or casual remarks, even if harsh, do not amount to abetment unless they create a direct inducement or coercion to commit suicide – Supreme Court finds no proximate link between the alleged statements and the act of suicide, rendering the charge under Section 306 IPC unsustainable – Criminal proceedings quashed [Paras 17, 21].

Criminal Investigation – Bias and One-Sided Nature – Need for Reinvestigation – The FIR against the appellants was filed belatedly despite the death of the deceased being recorded earlier in hospital and post-mortem being conducted on the same day – Police relied solely on witness statements that parroted the FIR without any independent investigation – Held: The one-sided nature of the investigation raises serious concerns of bias and possible misuse of process – The Director General of Police, Uttar Pradesh, directed to constitute a Special Investigation Team (SIT) to conduct an independent probe into the unnatural death of Tanu, with liberty to re-register the FIR if required [Paras 16, 22].

Principles Governing Abetment of Suicide – Supreme Court Precedents – Application to Facts – Supreme Court reiterates that for an offence under Section 306 IPC, there must be active involvement or direct instigation by the accused – Held: The mere use of harsh words, criticism, or humiliation without any element of coercion or active provocation is insufficient to constitute abetment – Reliance placed on Swamy Prahaladdas v. State of M.P., (1995 Supp (3) SCC 438), Madan Mohan Singh v. State of Gujarat, (2010) 8 SCC 628, and Ramesh Kumar v. State of Chhattisgarh, (2001) 9 SCC 618, where casual remarks and mere allegations of harassment were held insufficient to attract Section 306 IPC – Present case fails to meet the threshold for abetment of suicide [Paras 18-20].

Decision – Criminal Appeal Allowed – Proceedings Quashed – SIT Ordered – Supreme Court finds that the charge-sheet and order of cognizance were issued without due consideration of essential legal ingredients under Section 306 IPC – Held: Continuing the trial against the appellants would amount to gross abuse of process – Proceedings in Case No. 2843 of 2023 before the Judicial Magistrate, Saharanpur quashed – SIT directed to submit a reinvestigation report in a sealed cover within two months – Matter listed for further directions on 15.04.2025 [Paras 22-24].

Criminal Law - Income Tax Act – Prosecution for Late Filing of Returns – Compounding of Offences – Appellant delayed filing income tax returns for AY 2011-12 and AY 2013-14 – Show cause notices issued under Section 276CC of the Income Tax Act, 1961 – Appellant’s compounding application for AY 2011-12 allowed, but rejected for AY 2013-14 on the ground that it was a second offence – High Court upheld rejection – Supreme Court held that the offence for AY 2013-14 was committed before the show cause notice for AY 2011-12, making it the ‘first offence’ under 2014 Guidelines – Held: Compounding rejection was erroneous [Paras 3-10, 81].

Offence Under Section 276CC – Timing of Commission – Whether the offence is committed on the actual date of filing of the belated return or on the day immediately following the due date – Held: Offence is committed on the day following the due date for filing returns under Section 139(1) – Supreme Court relied on Prakash Nath Khanna v. CIT (2004) 9 SCC 686 – Subsequent filing of returns does not negate the commission of the offence [Paras 27-36].

Compounding of Offences – Guidelines for Compounding, 2014 – Expression "First Offence" – Offence is compoundable if committed before the issuance of any show cause notice or departmental intimation – Offences voluntarily disclosed before detection also qualify as ‘first offence’ – Held: Appellant’s offence for AY 2013-14 was committed before the first show cause notice for AY 2011-12, making it eligible for compounding – Rejection by tax authorities and High Court was based on an erroneous reading of guidelines [Paras 60-74].

Nature of Guidelines – Discretionary or Mandatory? – Compounding not a right, but authorities must consider facts and circumstances of each case – 2014 Guidelines allow discretion for compounding even if offences do not fall under general compounding rules – Supreme Court relied on Sports Infratech P. Ltd. v. DCIT, 2017 SCC OnLine Del 6543 – Held: Guidelines should be applied flexibly, and not mechanically, particularly in cases where intent to evade taxes is absent [Paras 76-80].

Decision – Supreme Court allowed appeal – High Court and Chief Commissioner’s rejection of compounding application set aside – Appellant directed to file fresh compounding application within two weeks – Authorities to decide within four weeks – Pending trial stayed – If compounding allowed, trial proceedings to abate; if rejected, trial to continue [Paras 82-85].

Motor Accident Compensation – Enhancement of Compensation – Functional Disability – Future Prospects – Appellant, a 25-year-old labourer, suffered amputation of his right hand below the elbow due to an accident involving a thresher machine attached to a tractor driven negligently by Respondent No.2 – MACT awarded Rs.3,76,090/- considering 20% permanent disability and notional income of Rs.60,000/- per annum – High Court enhanced compensation to Rs.6,61,690/- by increasing permanent disability to 40% – Appellant challenged the High Court order seeking higher assessment of income and functional disability [Paras 3-9].

Assessment of Income – Minimum Wages as Basis – Appellant argued that his income should be assessed at Rs.6,850/- per month as per minimum wages for unskilled workers in 2016 instead of Rs.5,000/- taken by High Court – Supreme Court relied on Gurpreet Kaur v. United India Insurance Co. Ltd., 2022 SCC Online SC 1778, holding that minimum wage notifications can guide income assessment in the absence of documentary proof – Appellant’s income re-evaluated at Rs.6,850/- per month [Paras 10-11].

Functional Disability – Enhancement to 80% – Appellant contended that loss of his right hand rendered him completely incapable of working as a labourer, effectively amounting to 100% functional disability – Supreme Court found merit in the claim and increased the functional disability percentage to 80% – Held: Amputation significantly impairs employment prospects, warranting enhanced compensation [Paras 11-12].

Revised Compensation Calculation – Supreme Court recalculated compensation considering the revised income and 80% functional disability – Applied multiplier of 17 – Future prospects at 40% – Compensation increased to Rs.20,55,452/- under various heads, including medical expenses, attendant charges, special diet, pain and suffering, loss of income, and cost of artificial hand – Substantial increase from Rs.6,61,690/- awarded by the High Court [Paras 12].

Decision – Civil Appeal allowed – Compensation enhanced to Rs.20,55,452/- with interest as awarded by the Tribunal – Impugned orders modified accordingly – Pending applications disposed of [Paras 13].

Criminal Law – Appeal against Conviction under Section 302 IPC – Circumstantial Evidence – Last Seen Theory – Benefit of Doubt – The prosecution relied on last seen theory, claiming that the deceased was last seen with the appellant in an auto on 29th November 2013 – Held: Inconsistent witness testimonies weakened the prosecution's claim – PW-23's statement regarding last seen was not corroborated by PW-2, PW-3, and PW-5 – Uncorroborated last seen evidence cannot establish guilt beyond reasonable doubt – Appellant entitled to benefit of doubt [Paras 31-32].

Evidence Law – Admissibility of Recovery – Section 27 Indian Evidence Act – Procedural Lapses – The prosecution relied on the recovery of a stone, a Gandasa (battleaxe), and gold chains at the instance of the appellant – Held: PW-22 admitted that he and another witness signed multiple seizure memos at the police station rather than at the scene of recovery, raising serious doubts about the authenticity of the recovery process – Further, PW-26, the diver who retrieved the stone and Gandasa, stated that he acted on police instructions and not at the behest of the appellant – Recovery loses evidentiary value due to procedural lapses [Paras 22-26].

Test Identification Parade (TIP) – Flaws in Identification of Gold Chains – Reliability in Question – The prosecution claimed the appellant concealed gold chains belonging to the deceased on the rooftop of his house – Held: TIP was unreliable as witnesses stated that only two gold chains were placed for identification, contradicting the official procedure – Further, PW-2 admitted receiving the gold chains at the police station a day before the TIP, raising concerns of pre-exposure – TIP not conducted per established legal norms – Identification evidence discarded [Paras 28-29].

Prosecution's Failure to Establish Chain of Circumstances – Acquittal Justified – The case rested entirely on circumstantial evidence, requiring an unbroken chain of events leading conclusively to guilt – Held: Prosecution failed to prove motive, last seen theory, and valid recoveries beyond reasonable doubt – Supreme Court applied the five golden principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116 and found the chain of evidence incomplete – Conviction set aside, appellant acquitted [Paras 16-20, 32-33].

Decision – Criminal Appeal Allowed – Conviction Set Aside – Supreme Court set aside the Chhattisgarh High Court and Trial Court judgments convicting the appellant – Appellant directed to be released unless required in any other case – Pending applications disposed of [Paras 33-34].

Criminal Sentencing – Attempt to Murder – Sentence Beyond Statutory Limit – Modification of Sentence – Appellant, enraged over his wife leaving him due to his abusive behavior, attacked his mother-in-law with a billhook, causing grievous injuries, and inflicted simple injuries on his wife – Trial Court convicted him under Section 307 IPC and imposed life imprisonment, along with other sentences under Sections 498A, 324, and 506(II) IPC – High Court reduced sentence under Section 307 to 12 years RI but upheld convictions under other sections – Held: Section 307 IPC permits either life imprisonment or a maximum of 10 years RI with fine – Appellate court cannot impose a sentence beyond the statutory maximum if life imprisonment is not awarded – Sentence under Section 307 IPC reduced from 12 years RI to 7 years RI [Paras 5-8].

Jurisdiction of Appellate Court – Maximum Sentence Under Section 307 IPC – Error in Sentencing – High Court exceeded its jurisdiction by imposing 12 years RI, which is beyond the statutory maximum of 10 years if life imprisonment is avoided – Held: Relying on Jagat Bahadur v. State of Madhya Pradesh, (1966) 2 SCR 822, and Amit Rana @ Koka v. State of Haryana, 2024 SCC OnLine SC 1763, appellate courts cannot impose a punishment higher than the prescribed statutory limit – Supreme Court modifies sentence to 7 years RI under Section 307 IPC while affirming other sentences [Paras 6-8].

Principles of Sentencing – Consideration of Relationship and Injury Severity – The Court took into account the relationship between the appellant and the victims (his wife and mother-in-law) and the grievous nature of the injuries inflicted on the mother-in-law – Held: A balanced approach is required in sentencing, considering both deterrence and proportionality – While the act was premeditated and involved serious assault, a sentence of 7 years RI adequately serves the interest of justice [Para 9].

Decision – Criminal Appeal Partly Allowed – Sentence Modified – Supreme Court modifies the High Court’s sentence under Section 307 IPC from 12 years RI to 7 years RI – Convictions under Sections 498A, 324 IPC upheld – Sentences to run concurrently as directed by the High Court – Appeal partly allowed [Paras 8-9].

Child Custody – Habeas Corpus – Welfare of the Child – Custody Granted to Father - The appellant-father sought custody of his minor child, who was living with his maternal grandparents after the mother’s demise – The High Court denied custody, granting only visitation rights – The Supreme Court held that the father, as the natural guardian, has a superior claim unless there are compelling reasons to deny custody – Considering that the father is well-employed and financially secure, and there are no allegations of abuse, the child’s welfare would be best served in the father’s custody – Ordered a transitional arrangement allowing the child to stay with the grandparents until the academic year’s end before transferring full custody to the father – The grandparents retained periodic visitation rights post-custody transfer. Appeal Allowed. [Paras 8-11].

Motor Accident – Compensation – Future Prospects – Split Multiplier Rejected – Compensation Enhanced - The claimants sought compensation for the death of the deceased in a road accident – The Tribunal awarded ₹28,66,994/-, but the High Court reduced it to ₹19,66,833/- by applying a split multiplier approach, considering pre- and post-retirement income – The Supreme Court held that the split multiplier method is impermissible unless special reasons are recorded – The Court relied on Sarla Verma and Sumathi v. National Insurance Co. Ltd. to determine the appropriate multiplier – Held: The deceased’s full salary should have been considered for loss of dependency, with a 15% increase for future prospects – Compensation was reassessed by applying a multiplier of 9, granting loss of consortium to each claimant, and ensuring fair compensation – Supreme Court set aside the High Court’s judgment and enhanced the compensation to ₹33,03,300/- with interest at 7.5% p.a. as awarded by the Tribunal [Paras 11-14]. Appeal Allowed.

Criminal Procedure – Illegal Arrest – Violation of Article 22(1) – Arrest Declared Unconstitutional – Immediate Release Ordered - The appellant was arrested for financial offences under the IPC—He alleged that he was not informed of the grounds for arrest, violating Article 22(1) of the Constitution—The State argued that the appellant’s wife was informed of the grounds, but no record showed compliance with the requirement to inform the arrestee directly—The Supreme Court reaffirmed that informing the arrestee in a meaningful manner is a fundamental right—Held: Failure to communicate the grounds of arrest to the accused renders the arrest unconstitutional and vitiates any subsequent remand—The appellant was ordered to be released immediately, and the State of Haryana was directed to issue guidelines to ensure strict compliance with constitutional safeguards in future arrests—Further, directions were issued to prevent inhumane treatment of arrested persons, such as handcuffing and chaining to hospital beds [Paras 21-33].

Motor Accident – Just and Fair Compensation – Compensation Enhanced - The appellant, a primary school teacher, suffered serious injuries in a road accident due to negligent driving – The Tribunal assessed the disability at 10% and awarded Rs. 6,17,515/- – The High Court enhanced the amount by Rs. 60,000/- but did not fully account for the extent of injuries and losses suffered – The Supreme Court held that just compensation should be awarded regardless of the amount claimed – Following the principles laid down in precedents, the compensation was recalculated based on loss of income, future prospects, permanent disability (40%), and additional expenses – Compensation enhanced to Rs. 17,82,825/- with interest as awarded by the Tribunal. Appeal Allowed. [Paras 9-11].