Civil Law - Refund of Court Fees – Applicability of Central vs. State Legislation – Inconsistency Resolved – The appellant sought a complete refund of court fees under Section 16 of the CFA, 1870 after resolving a dispute through mediation under Section 89 CPC – Held: Court fees are governed by Entry 3 of List II (State List) of the Constitution; hence, the Maharashtra Court Fees Act, 1959 prevails in the state – No inconsistency arises between the Central and State legislations as the CFA, 1870 is inapplicable in Maharashtra – Appeal dismissed [Paras 11, 14.3].

Mediation vs. Lok Adalat – Distinction in Treatment of ADR Outcomes – The appellant argued equivalence between mediation under Section 89 CPC and proceedings in Lok Adalat for refund purposes – Held: Awards by Lok Adalat under the Legal Services Authorities Act, 1987 are distinct from mediated settlements under CPC – Provisions for full refund of court fees in Lok Adalat awards do not extend to mediation unless specifically provided – High Court’s rejection of this equivalence upheld [Paras 14.3, 14.4].

Administration of Justice – Concurrent and State Legislative Domains – Refund Rules Within State’s Purview – While the administration of justice is a concurrent subject, court fees explicitly fall within the State List – The Maharashtra Court Fees Act, 1959 governs the refund of court fees, including partial refunds for settlements outside Lok Adalats – Appeal rejected as Maharashtra’s legislative competence is well-established [Paras 11, 14.3].

Doctrines of Pith and Substance and Harmonious Construction – Application in Case of Overlapping Laws – The Court employed these doctrines to resolve potential conflicts between Central and State laws – Held: State law is valid within its sphere, and the appellant’s argument for the primacy of Section 16 CFA, 1870 was unsustainable – Maharashtra’s amendment to allow full refunds after 2018 aligns with ADR objectives but was unavailable retroactively for the appellant [Paras 8.1, 8.2].

Discretionary Relief – Refund Allowed Under Article 142 – Considering the amicable settlement and the relatively small amount involved, the Court invoked Article 142 to grant the appellant a refund of the court fees in full without setting a binding precedent [Para 24].

Decision: Appeal dismissed – Appellant granted a discretionary refund of court fees under Article 142 of the Constitution of India, limited to the facts of the case.

Criminal Law – Murder and Cruelty – Conviction Upheld – Appellant charged with murdering his wife, subjected her to cruelty, and attempting to disguise the homicide as suicide – Held: Prosecution established homicidal death through circumstantial evidence, including medical findings, witnesses’ testimonies, and lack of plausible explanation by the accused under Section 106 Evidence Act – Conviction and sentences upheld [Paras 10-21].

Plea of Alibi – Rejection of False Defence – Appellant’s alibi that he was not present at the crime scene during the incident was unsupported by credible evidence – Held: Under principles laid in Binay Kumar Singh v. State of Bihar, the plea of alibi requires strict proof, which was not provided by the appellant – False alibi treated as an additional link in the circumstantial chain [Paras 10, 16].

Non-Rupture of Hyoid Bone – No Sole Indicator of Suicide – Appellant argued that the non-rupture of hyoid bone negated the homicidal nature of the death – Held: As per Satish Nirankari v. State of Rajasthan and medico-legal principles, non-rupture does not conclusively negate strangulation – The courts correctly relied on other evidence, including positioning of the body and absence of signs of self-inflicted injuries, to conclude homicide [Para 17].

Section 106, Evidence Act – Duty of the Accused to Explain Events Within Exclusive Knowledge – Incident occurred in the matrimonial home where the appellant and deceased resided – Appellant failed to provide a satisfactory explanation for the circumstances of the death – Presumption under Section 106 applied to strengthen the prosecution case [Para 20].

Circumstantial Evidence – Chain of Events Firmly Established – Prosecution relied on a chain of circumstantial evidence, including testimonies of witnesses (PW-8), medical reports, and behavior of the accused – Held: The evidence ruled out suicide and strongly implicated the accused – Appeal dismissed [Para 21].

Decision: Appeal dismissed – Conviction and sentences under Sections 302, 201, and 498A IPC upheld – No costs imposed.

Criminal Law – Allegations of Witchcraft – Public Humiliation and Assault – FIR lodged against 13 accused under Sections 341, 323, 354, 354B, 379, 504, 506, 149 IPC, and Sections 3 & 4 of the Witch (Daain) Practices Act for grave allegations including assault, disrobing, and public humiliation of the victims accused of witchcraft – Police filed chargesheet against only one accused, ignoring material implicating others – Magistrate took cognizance against all accused based on available evidence – High Court stayed proceedings against certain accused in a nonspeaking order – Held: Such heinous crimes infringing upon the dignity of individuals demand sensitive and timely adjudication – Stay granted by the High Court was inappropriate, failing to consider prima facie evidence or seriousness of the allegations [Paras 4-7, 10-12, 26].

Human Dignity – Right to Live with Dignity under Article 21 – Prima Facie Case for Trial Established – Allegations of witchcraft led to acts of public humiliation, disrobing, and physical assault of the victims – Held: The Trial Court correctly took cognizance of the case, finding a prima facie case based on evidence, and the High Court erred in staying the trial proceedings mechanically [Paras 8-10, 13-15].

Witchcraft Accusations – Gender Discrimination – Need for Sensitivity and Expediency in Judicial Proceedings – Accusations of witchcraft are often rooted in patriarchal and superstitious practices disproportionately targeting women, especially elderly or marginalized individuals – Court emphasized the duty of the State to protect dignity under international treaties and constitutional mandates [Paras 18-20, 25-28].

Role of the State – Ensuring Justice for Vulnerable Groups – The State's Inaction – Court criticized the State’s failure to challenge the High Court’s stay order and highlighted the need for proactive litigation to uphold the rule of law and justice for victims of heinous crimes [Paras 22-23, 29-30].

Decision: The appeal was allowed. The High Court’s stay order was set aside. The Trial Court was directed to proceed with the case on a day-to-day basis from 15/01/2025, ensuring the trial’s completion without delay. Observations made in the judgment were not to influence the final outcome.

Criminal Procedure Code, 1973 – Discharge under Section 227 Cr.P.C. – Lack of Prima Facie Case – Appellant (Accused No.13) sought discharge under Section 227 Cr.P.C. from charges under Section 27(b) of the NDPS Act – Sole evidence against the appellant was the confession statement of a co-accused (Accused No.1) – Held: Confessional statement of a co-accused is inadmissible under Section 25 of the Indian Evidence Act, 1872, and cannot form the basis for framing charges – No other evidence linked the appellant to the offense – Dismissal of discharge application by the Trial Court and High Court was improper – Appellant discharged [Paras 7, 9-12, 14].
Confession of Co-Accused – Inadmissibility – No Prima Facie Case for Trial – The appellant was arraigned under Section 27(b) of the NDPS Act based solely on the confession of a co-accused – Held: Confession of a co-accused cannot form the sole basis for framing charges against another accused. In the absence of corroborative material or evidence, there was no prima facie case to proceed against the appellant [Paras 12-14, 23-24].

Scope of Section 227, Cr.P.C. – Discharge in Absence of Grave Suspicion – At the stage of discharge, the judge must sift evidence to assess if a grave suspicion exists against the accused – Mere suspicion, unsupported by admissible evidence, does not justify subjecting the accused to trial [Paras 11-15, 20-22].

NDPS Act – Proof Beyond Suspicion Required – In cases under the NDPS Act, strong and corroborated material evidence is necessary due to the stringent nature of penalties – Confession unsupported by medical examination or recovery of contraband is insufficient to frame charges [Paras 18-19].

Decision: The appeal was allowed. The orders of the High Court and the Additional District Judge-Special Court were set aside. The appellant (Accused No. 13) was discharged from CC No. 43 of 2020.
 

Civil Writ - PIL - Judicial Review – Public Contracts – Excessive Delegation Invalidated – Articles 13 and 14 of the Concession Agreement, allowing NOIDA Toll Bridge Company Ltd. to levy toll, were held invalid for violating public policy – Held: Power to levy fees or toll cannot be delegated to private entities as per the Uttar Pradesh Industrial Area Development Act, 1976; only the collection of fees may be delegated [Paras 42-50].

Public Interest Litigation – Maintainability and Delay – Continuous Cause of Action – The PIL filed after 15 years of the Concession Agreement was held maintainable due to continuous public injury and absence of clear disclosure of toll recoveries – Held: Delay in filing a public interest matter does not preclude maintainability where public welfare is at stake [Paras 16-21].

Reasonableness of Toll Policy – Violation of Public Policy – Perpetual Recovery of Costs – Formula in the Concession Agreement led to perpetual recovery of escalating project costs, extending the concession period indefinitely – Held: The agreement imposed an undue burden on public commuters and failed to align with the principles of equity and public trust [Paras 53-65].

Role of the State – Responsibility in Public-Private Partnerships – Lack of Transparency – Selection of NTBCL without competitive bidding and delegation of financial oversight to private stakeholders highlighted misuse of power – Held: Actions violated Article 14, mandating fairness and equality in public governance [Paras 30-40].

Decision: The appeal was dismissed. The High Court's judgment prohibiting the collection of toll and severing Articles 13 and 14 from the Concession Agreement was upheld. NTBCL was directed to cease toll collection immediately.
 

Civil Law - Recovery Proceedings – Public Demand – Jurisdictional Facts – Role of Civil Supplies Corporation - Dispute over recovery of undelivered Custom Milled Rice (CMR) for procurement year 2011-12 – Bihar State Food and Civil Supplies Corporation (respondent) initiated recovery proceedings under the Bihar and Orissa Public Demands Recovery Act, 1914, alleging default by rice millers (appellants) – Supreme Court upheld recovery as a “public demand” under the Act – Held: Civil Supplies Corporation acted as the nodal agency of the State, and the claim qualified as a public demand – Rice millers failed to exhaust statutory remedies, limiting the scope of judicial intervention [Paras 1-42].

Public Demand – Interpretation of Section 3(6) – Recovery Justified – The definition of ‘public demand’ under Section 3(6) read with Clause 8-A of Schedule I is broad and inclusive – Held: The cost of undelivered CMR qualifies as a public demand recoverable under the Act as it pertains to obligations under the State's procurement policy [Paras 45-48].

Nodal Agency – Civil Supplies Corporation’s Status – Valid Recovery – The Bihar State Food and Civil Supplies Corporation acted as the State’s nodal agency in implementing the procurement policy for Custom Milled Rice (CMR) – Held: The Corporation is entitled to recover dues as public demand, consistent with its statutory and contractual obligations [Paras 30-35].

Procedural Safeguards – Adherence to Natural Justice – Allegations of procedural deviations in recovery proceedings were dismissed – Held: Certificate proceedings complied with statutory provisions, and aggrieved parties were provided sufficient opportunities to raise objections and seek remedies [Paras 50-53].

Jurisdictional Facts – Importance of Totality of Circumstances – The Court emphasized the necessity of considering the totality of circumstances, including the contractual relationship and public interest in the procurement scheme – Held: Jurisdictional facts establishing the validity of the recovery proceedings were satisfied [Paras 37-40].

Statutory Remedies – Limitation Waived for Appeals – The Court provided an extended timeframe for the Rice Millers to avail statutory remedies under the Act – Held: Parties may pursue appeals or revisions within 30 days of the judgment, without the bar of limitation [Paras 55-57].

Decision – Appeals dismissed – Recovery proceedings under the Act upheld – Liberty granted to appellants to avail statutory remedies within the extended timeframe [Para 58].
 

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].
 

Environmental Law – Sacred Groves (Orans) – Recognition as Forests – Protection under Forest Conservation Act, 1980 – Directions IssuedForest Conservation – Sacred Groves and Orans – Legal Recognition – Directive for Identification – Sacred groves in Rajasthan hold ecological and cultural importance – The court reiterated the applicability of the Forest (Conservation) Act, 1980, to classify sacred groves as forest lands – Directed the Rajasthan Government to conduct on-ground mapping and classify identified groves without size limitations, focusing on their cultural and ecological significance – Compliance report ordered [Paras 53-56].

Community Rights – Role in Conservation – Forest Rights Act, 2006 – Recognized the historical role of local communities in protecting sacred groves – Directed inclusion of these groves under ‘Community Forest Resource’ provisions – Empowered communities to regulate access and manage conservation [Paras 25-29].

Biodiversity and Cultural Heritage – Recommendations for Sustainable Management – The court emphasized the integration of cultural traditions with ecological preservation – Directed exploration of declaring sacred groves as ‘Community Reserves’ under Section 36-C of the Wildlife Protection Act, 1972, for enhanced protection [Paras 46-49].

Policy Implementation – Rajasthan Forest Policies 2010 and 2023 – Observed the dilution of specific protections in the 2023 policy – Directed the state to restore focused conservation mechanisms for sacred groves as delineated in the 2010 policy [Paras 38-41].

Directions – Implementation of CEC Recommendations – Ordered expeditious implementation of the Central Empowered Committee's recommendations for mapping, demarcation, and notification of sacred groves as forests – Constituted a monitoring committee to ensure compliance [Paras 56-58].

Decision – Interlocutory Application disposed of with directives for recognition and conservation of sacred groves – State and Union Governments tasked to ensure protection through legal and policy frameworks – Matter listed for compliance report on 10/01/2025 [Para 59].

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].