Criminal Law - Prevention of Corruption Act – Appeal Against Conviction - Demand and Acceptance – Contradictory Evidence – Conviction Set Aside – The accused, a Revenue Inspector, was alleged to have demanded and accepted a bribe of ₹2,000 for conducting a drought damage inspection – The Supreme Court found contradictions in the testimonies of key witnesses including PW1 (complainant) and his wife (DW1), lack of corroboration, and absence of pH reaction on the accused’s hands – Held: The prosecution failed to establish demand and acceptance beyond reasonable doubt [Paras 6, 13, 17, 19-20].

Trap Cases – Standard of Proof – No Independent Corroboration – Benefit of Doubt Given – The Court noted the absence of shadow witness corroboration during the alleged bribe transaction and inconsistencies regarding how the money was placed in the accused's motorcycle bag – Held: Guilt not proved beyond reasonable doubt, and benefit of doubt must be extended to the accused [Paras 17-20].

Presumption under Section 20 – Inapplicability Due to Lack of Proven Demand – Although money was recovered, the Court reiterated that the statutory presumption under Section 20 does not arise unless prior demand is proved – Held: The presumption is not attracted where the foundational fact of demand is missing [Paras 21].

Final Decision – Conviction Reversed – Appeal Allowed – The Supreme Court quashed the judgments of both the Trial Court and the High Court – Held: Conviction and sentence under Sections 7 and 13(1)(d) r/w 13(2) of the Prevention of Corruption Act are set aside, and fine, if deposited, shall be refunded [Paras 22-23].

Criminal Law - Murder  – Hostile Witnesses – Acquittal Restored – The Trial Court acquitted all accused due to key witnesses turning hostile and lack of substantive evidence – The High Court reversed the acquittal relying heavily on investigating officers’ testimony and statements under Section 161 Cr.P.C. – Held: The Supreme Court found that conviction cannot be sustained based on inadmissible evidence and reversed the High Court’s decision, restoring acquittal [Paras 1-4, 46-49].

Confession – Section 27 of Evidence Act – Improper Application – Weapons and clothes allegedly used in the murder were recovered on the basis of confession by a co-accused not involved in the actual crime – Held: The discovery did not sufficiently connect the recovered items to the principal assailants or to the crime – Confession lacked legal admissibility under Section 27, especially absent corroborative evidence [Paras 20, 29-30, 38-41].

Use of Section 161 Statements – Inadmissibility Reiterated – High Court relied on Section 161 Cr.P.C. statements affirmed by investigating officers to reconstruct prosecution case – Held: Such statements are inadmissible except for contradiction and cannot substitute for substantive evidence – The approach of relying on IO’s testimony about witness statements violated Section 162 Cr.P.C. and was impermissible [Paras 17-18, 26].

Section 30 of Evidence Act – Confession by Co-accused – Limited Applicability – High Court’s reliance on co-accused confessions to implicate others under Section 30 was erroneous – Held: Such confessions cannot be treated as substantive evidence and may only lend assurance to existing evidence – In absence of independent proof, reliance was impermissible [Paras 40-42].

Standard of Proof – Circumstantial Evidence – Broken Chain – Motive, preparation, and conspiracy were not established by admissible or credible evidence – Held: Circumstantial evidence relied upon by prosecution failed to form a complete chain excluding other hypotheses – Conviction cannot be based on assumptions, moral judgment, or uncorroborated IO testimony [Paras 21-25, 49].

Final Decision – High Court Judgment Set Aside – Acquittal Upheld – Supreme Court restored the Trial Court’s acquittal and ordered immediate release of accused – Held: Moral suspicion cannot replace legal proof; absence of credible evidence left no ground for conviction [Paras 49-51].
 

Taxation Law - Sales Tax – Purchase from Exempt Dealers – Liability of Purchaser – Upheld – The appellants contended that purchase tax under Section 5A of the Kerala Act and Section 7A of the Tamil Nadu Act was not payable when the seller was exempt from sales tax – The Court held that these sections are independent charging provisions and purchase tax is leviable on specified transactions where no sales tax is paid – Held: Purchaser liable when goods are used in manufacture, disposed of without sale, or dispatched out of State [Paras 7-10, 16-17, 31].

Charging Provision – Sections 5A and 7A are Self-Contained – Constitutional Validity Upheld – These sections operate independently of the general sales tax charging provisions and are intended to prevent tax leakage – Held: The legislative competence and constitutional validity of the provisions are affirmed, consistent with the ratio in Hotel Balaji and Devi Dass – The contrary view in Goodyear overruled [Paras 8-10, 16, 19-21, 31-32].

Taxable Goods vs Exempt Transactions – Clarified Legal Distinction – The Court distinguished between ‘taxable goods’ and transactions that are exempt from tax due to notifications – Held: Goods that are generally liable to tax can attract purchase tax even if specific transactions are exempt from sales tax at seller’s end [Paras 8, 22, 26].

Inter-State Dispatch and Legislative Competence – Valid Exercise of State Power – The Court rejected the argument that purchase tax on goods dispatched outside the State amounts to a consignment tax or inter-State levy – Held: The levy is on purchase, not on inter-State movement, and within State Legislature’s competence [Paras 31-32].

Final Decision – Appeals Dismissed – Purchase Tax Valid – Supreme Court upheld the judgments of the High Courts of Kerala and Madras – Held: Sections 5A and 7A impose valid purchase tax in cases where sales tax is not otherwise payable – All appeals dismissed and stay orders vacated [Paras 39-42].
 

Environmental Law – Sand Mining – Mandatory Nature of Valid District Survey Report (DSR) – Appeals Dismissed – The State of U.P. and LOI holders challenged NGT’s order quashing e-auction notice dated 13.02.2023 for sand mining in Saharanpur due to lack of a valid DSR – Supreme Court upheld NGT’s view that a draft DSR cannot form the basis for environmental clearance under the EIA Notification, 2006, and guidelines of 2016 and 2020 – Held: Only a valid, finalized DSR can support EC and e-auction processes; draft DSR is a non-starter for legal compliance [Paras 1.2, 3.2, 19.2, 21–22].

District Survey Report – Legal Status and Importance – Judicial Affirmation – The Court declared DSR as a “document of seminal importance” essential for informed decision-making, environmental clearance, and project appraisal – Emphasized strict adherence to procedure in Appendix X of the EIA Notification – Mandated five-year validity and compulsory public consultation – Reaffirmed decisions in Deepak Kumar and Pawan Kumar cases [Paras 1.2, 10, 11, 14–15, 21].

Decision – E-auction Quashed – Appeals Dismissed – NGT Order Affirmed – The Supreme Court dismissed the civil appeals, affirming the NGT’s quashing of the e-auction for violating mandatory environmental safeguards and DSR requirements – Directed strict enforcement of the regulatory framework and held that absence of a valid DSR invalidates the auction process [Paras 20–22].
 

Criminal Law – Quashing - Matrimonial Disputes – Abuse of Process – Quashing of Criminal Proceedings – Petition Dismissed – Allegations of dowry harassment and physical assault made by wife were contradicted by her own statements and affidavit filed in related matrimonial proceedings – High Court rightly quashed the proceedings under Section 482 CrPC as an abuse of process – Supreme Court upheld the quashing order and dismissed the Special Leave Petition [Paras 1, 8-11].

Contradictory Statements – Inconsistencies in Complaint and Evidence – No Medical Proof – No Specific Allegation – Petition Dismissed – Complaint made under Section 156(3) CrPC was found to have vague and inconsistent allegations, lacking medical evidence despite claims of physical assault – Admissions in matrimonial affidavits contradicted claims of abuse – Court held inconsistencies undermined the credibility of the accusations [Paras 8-10].

Judicial Approach – Precaution in Matrimonial Offences – Need to Prevent Misuse – Cautious Scrutiny Mandated – Courts must exercise caution in matrimonial cases to prevent misuse of criminal law against extended family members – Supreme Court reiterated need to distinguish genuine cases from abuse of process to protect both victims and innocents [Paras 2-3].

Decision – Invocation of Section 482 CrPC Justified – Special Leave Petition Dismissed – Supreme Court found no error in the High Court’s invocation of its inherent powers to quash the criminal case – Proceedings held to be an abuse of process – Special Leave Petition dismissed [Para 11-12].

Civil law – Mark Unregistered Agreement of Sale – Admissibility under Section 49 of the Registration Act – Appeal Allowed – The appellant sought to mark a document dated 01.01.2000 in a suit for specific performance – Trial Court and High Court rejected the plea on the ground that the document was unstamped and unregistered – Held: The proviso to Section 49 of the Registration Act permits admission of such document as evidence of a contract in a suit for specific performance – Reliance placed on S. Kaladevi v. V.R. Somasundaram – The Court clarified the appellant is permitted to introduce the document, subject to objections on relevancy and validity to be decided by the Trial Court [Paras 9–12].

Civil Suit – Suo Motu Dismissal of Declaratory Relief – Improper Exercise of Appellate Jurisdiction – Appeal Allowed – The High Court, while hearing an appeal against denial of interim relief, dismissed plaintiffs’ substantive declaratory prayers based on unregistered agreements under Section 49 of the Registration Act – Held: The High Court could not have summarily disposed of substantive reliefs in the suit or transferred remaining reliefs to be agitated in a different suit – Legality, admissibility, and validity of documents must be determined during trial – The order was unsustainable in law and suit restored to original number [Paras 9–13].

Possession Protection – Injunction Against Dispossession – Relief Granted – Based on concession by respondent that dispossession would not be attempted without due process of law, the Supreme Court directed continuation of injunction restraining respondents from dispossessing appellants pending suit – Clarified that no view was expressed on merits [Paras 6, 13–14].

Decision – Suit Restored – Injunction Granted – Appeal Allowed – The Supreme Court allowed the appeals, set aside the High Court's judgment dated 14.08.2013, and restored Civil Suit (L) No. 2217 of 2012 to its original number before the Bombay City Civil Court – Directed that respondents be restrained from dispossessing appellants during pendency of the suit – No opinion expressed on merits of the matter [Paras 13–14].
 

Motor Accident Claim – Enhancement of Compensation – Syme’s Amputation – Appeal Allowed – Appellant suffered permanent disability due to a road accident and initially awarded Rs. 12.65 lakhs by the High Court – Supreme Court reassessed evidence, enhanced income estimation, and awarded Rs. 17,06,486/- with 9% interest per annum – Detailed reassessment included validated medical expenses, increased amount for pain and suffering, and inclusion of future prospects [Paras 2-7].

Permanent Disability – Assessment of Future Income – Adoption of Reasonable Minimum Wage – Appeal Allowed – Supreme Court held that the income should be reassessed at Rs.10,000/- per month in 2015 for an unskilled worker with 40% future prospects – Previous underestimation by Tribunal and High Court was corrected – Loss of future income recalculated accordingly [Paras 5-6].

Just Compensation – Pain, Suffering, and Medical Costs – Award Enhanced – In view of Syme’s amputation and multiple fractures, compensation for pain and suffering was increased from Rs.1.2 lakhs to Rs.1.5 lakhs – Full reimbursement of medical expenses was allowed based on produced bills, and a separate amount for attendant charges and special diet was granted [Paras 4-5].

Decision – Compensation Enhanced – Appeal Allowed – The total compensation was increased from Rs.12.65 lakhs to Rs.17,06,486/- with interest @ 9% p.a. – The Insurance Company was directed to pay the amount within two months after adjusting already paid amounts [Para 7-8].
 

Criminal Law - Quashing of Criminal Proceedings – Abuse of Process – Sections 186, 353 IPC – Proceedings Quashed – Appellants, associated with anti-trafficking NGO, were charged with obstructing public servants during a rescue operation at a brick kiln – Held: Uncontroverted allegations did not disclose use of force or mens rea required under Sections 186 or 353 IPC – Mere removal of labourers to police station did not constitute obstruction or assault – High Court erred in dismissing petition mechanically without examining legal bars and facts – Proceedings amounted to abuse of court process and were liable to be quashed [Paras 10–29].

Section 186 IPC – Procedural Bar – Registration and Cognizance Impermissible Without Sanction and Complaint by Public Servant – FIR registered without Magistrate’s permission under Section 155(2) CrPC and cognizance taken on police report contrary to Section 195 CrPC – Held: Prosecution under Section 186 IPC simplicitor was legally untenable and vitiated on procedural grounds [Paras 30–32].

Decision – Criminal Proceedings Quashed – Appeal Allowed – Prosecution Declared Malicious and Unlawful – Supreme Court quashed proceedings under Sections 186 and 353 IPC – Found prosecution to be motivated by malice and departmental vendetta – Reiterated wider scope of High Court’s power under Section 482 CrPC to prevent abuse of process and protect individual liberty [Paras 28–36].