Civil Law – Refusal of Registration of Documents – Power to Refuse on Title Grounds – Rule 55A(i) Declared Ultra Vires – Sub-Registrar refused to register sale deed under Rule 55A(i) for want of vendor’s title proof – Supreme Court held that under the Registration Act, 1908, Sub-Registrar has no authority to verify title – Rule 55A(i) inconsistent with the parent Act – Held: Rule 55A(i) is ultra vires and invalid [Paras 1–2, 14–16].

Registration Act – Role of Sub-Registrar – Title Verification Not Required – Registrar’s role is administrative, not adjudicatory – Registration cannot be refused solely for lack of vendor’s title proof if procedural compliance is satisfied – Executant’s title is not relevant to registration under the Act [Paras 15–16].

Rule-Making Power – Section 69 of the Registration Act – Scope and Limits – Section 69 does not empower rule-making authority to introduce title-verification requirements – Held: Rule 55A(i) exceeds the statutory scope and conflicts with scheme of the Act – Hence struck down [Paras 10–13, 16].

State Amendment – Sections 22-A and 22-B – Limited Grounds for Refusal – These sections cover specific categories like government lands, encroached properties, and forgery – Held: These do not extend to requiring production of title deeds by vendors in all cases [Paras 8–9].

Decision – Appeal Allowed – Rule 55A(i) declared ultra vires – High Court orders relying on the Rule set aside – Appellant allowed to resubmit sale deed for registration within one month, subject to procedural compliance [Paras 17–19].

Criminal Law – Appeal against rejection of  discharge - Sexual Relationship – Consent and Promise to Marry – Section 376(2)(f) IPC – Discharge Granted - Allegations of rape based on failed promise to marry made by a judicial officer during a consensual relationship with a litigant – Held: Relationship was consensual, complainant was aware of appellant’s marital status, no evidence of false inducement or coercion [Paras 3–5, 13–16, 22].

False Promise to Marry – Distinction Between Breach and Deception – Section 417 IPC – No Offence Made Out - Court reiterated that breach of promise cannot be equated with false promise to constitute cheating – No dishonest inducement or fraudulent intent established – FIR and charges do not sustain allegations under Section 417 IPC [Paras 15, 18].

Criminal Intimidation – Insufficient Evidence – Section 506 IPC – No Threat Established - Alleged threats made by appellant lacked evidentiary support – No credible material to show intimidation of the complainant or her son – Charge under Section 506 IPC not sustainable [Paras 11, 18].

Standard for Discharge – Misuse of Criminal Process – Mini-Trial Not Permitted - At discharge stage, only prima facie material to be considered – Held: Relationship breakdown does not imply criminal offence – Allowing trial to continue would amount to abuse of process and unnecessary hardship [Paras 16–20].

Decision – Appeal Allowed – High Court’s rejection of discharge set aside – FIR quashed and criminal proceedings terminated – Physical relationship held to be consensual, not covered under Sections 376/417/506 IPC [Paras 21–22].

Criminal Law - Discharge in Rape Case – Consent Given in Relationship – Section 376 IPC – Discharge Restored - FIR was filed after the appellant allegedly refused to marry the complainant following years of consensual relationship – Sessions Court discharged the accused on the ground that consent was not vitiated by deception – Held: FIR and charge-sheet show relationship was consensual and not induced by false promise [Paras 6–10, 15].

False Promise to Marry – Distinction Between Breach and False Promise – No Offence Made Out – Supreme Court reiterated distinction between breach of promise and false promise – Held: There is no material to suggest that the appellant never intended to marry from the outset – Relationship sustained for years and included shared domestic moments, thus excluding deceit [Paras 13–14].

Criminal Intimidation – Section 506 IPC – Lack of Prima Facie Evidence – The complaint about threats lacked supporting material – Held: No case of criminal intimidation made out on facts presented in FIR or charge-sheet [Para 15(ii)].

Scope of Revisional Jurisdiction – Improper Interference by High Court – Section 397 CrPC – High Court reversed well-reasoned discharge order despite lack of error or perversity – Held: Revisional jurisdiction must be exercised sparingly and not for re-evaluation of evidence at charging stage [Paras 16–17].

Decision – Appeal Allowed – High Court's reversal of discharge set aside – Sessions Court's order discharging the appellant from offences under Sections 376 and 506 IPC restored – FIR and all criminal proceedings quashed [Para 18].

Criminal Law – Appeal Against Conviction - Sections 3(1)(r), 3(1)(s) of the SC/ST Act – Abuse Not in Public View –Acquittal Granted - Accused allegedly abused complainants using caste slurs during land dispute – Witnesses all related, and evidence showed no member of public was present at time of alleged incident – Held: Requirement of “public view” under clauses (r) and (s) not satisfied, thus no offence under SC/ST Act made out [Paras 7–9, 11].

House Trespass – Contradiction Between Complaint and Oral Evidence – Section 447 IPC – Charge Fails - Original complaint alleged house trespass, but all prosecution witnesses spoke of incident occurring in a field – Held: Contradiction fatal to prosecution case; no evidence of house breaking or unlawful entry into residence [Paras 8–11].

Land Dispute – No Evidence of Illegal Occupation or Forceful Eviction – Section 3(1)(f) SC/ST Act – Not Attracted - Accused allegedly entered disputed land but no proof they forcibly evicted complainants or retained unlawful possession – Held: Clause (f) not applicable, conviction unsustainable [Paras 7, 11].

Witness Credibility – All Prosecution Witnesses Related – No Independent Corroboration - Testimonies inconsistent regarding location, language used, and events – Held: Evidence unreliable and insufficient for conviction [Paras 6–9].

Decision – Conviction Set Aside – Accused Acquitted – High Court and Trial Court orders set aside – Bail bonds cancelled – Appeal allowed [Para 11–13].

Motor Accident Compensation – Insurer’s Liability – Vehicle Identification Disputed – MACT Award Restored - Deceased died in accident involving a speeding Verna car – MACT awarded ₹33.63 lakhs against owner and insurer jointly – High Court exonerated insurer based on delayed witness statement and alleged unreliability – Supreme Court held that evidence including police investigation, charge sheet, and owner’s admission supported finding of insurer liability – MACT order restored [Paras 3–6, 16–24].

Witness Credibility – Delay in Disclosure – Not Fatal per se – PW2 disclosed vehicle registration after two and a half months, but was corroborated by police investigation – Supreme Court held delay not fatal if otherwise supported by evidence – Testimony not discredited merely due to late disclosure [Paras 7, 17–18].

Negligence in Civil Proceedings – Standard of Proof – Based on Preponderance – Reliance placed on Mangla Ram v. Oriental Insurance Co., (2018) 5 SCC 656 – Held: Civil liability in motor claims is determined by preponderance of probabilities, not criminal standard of proof – Acquittal or delay in criminal trial not decisive [Paras 9, 19].

Owner’s Non-Appearance – Presumption Against – Respondent No.2 failed to appear in MACT, High Court, and Supreme Court despite service – Supreme Court held that owner’s silence and absence signified no viable defence – Presumption of liability valid [Paras 20–22].

Decision – Appeal Allowed – High Court Judgment Set Aside – MACT Award Restored – Insurer held jointly liable along with vehicle owner – Directions passed based on peculiar facts; no bearing on pending criminal proceedings [Paras 24–25].

Consumer Law  - Marine Insurance – Repudiation Of Insurance Claim - Interpretation of “Voyage to Commence and Complete Before Monsoon Sets In” – No Breach Found – Insurance policy required voyage to start and complete before onset of monsoon – Appellant commenced voyage on 06.06.2013, vessel was damaged due to bad weather – Held: Clause was not a material condition precedent, was vague and incapable of strict compliance for voyage from west to east coast – Repudiation not justified [Paras 1–3, 12–15, 18].

Contra Proferentem – Applicability Rejected – Phrase “before monsoon sets in” interpreted literally – Supreme Court held clause was clear and not ambiguous on its own terms – Hence, principle of contra proferentem (against insurer) not applicable – However, clause was found to be waived or immaterial in context [Paras 13–15].

Implied Waiver – Awareness of Monsoon Timing – Policy Covered Foul Weather Period – Court held insurer was aware the voyage would run into monsoon window – Condition could not be enforced in a manner that nullified the policy’s core purpose – Term likely a boilerplate clause – Deemed waived by conduct [Paras 17–18].

Absurdity in Enforcement – Clause Rendered Policy Illusory – Treating condition as mandatory would leave assured without remedy if voyage interrupted by insured peril – Held: Clause could not be treated as a condition precedent – Would result in defeating intent of insurance itself [Paras 18–19].

Decision – Appeal Allowed – NCDRC order set aside – Matter remanded to NCDRC to determine quantum payable to appellant under policy – Parties to appear on 29.04.2025 – Expeditious disposal directed [Paras 20–21].

Consumer Law - Insurance Claim – Fire and Special Perils Policy – Liability Not Disputed – Appellant acknowledged liability for damage caused to respondent’s premises under insurance policy due to collapse following heavy rainfall – However, dispute arose regarding quantum of compensation awarded by the NCDRC – Held: Appeal limited to reconsideration of compensation amount [Paras 1, 7].

Quantum of Compensation – Improper Evaluation by NCDRC – NCDRC relied solely on assessment of respondent's surveyor introduced for the first time in rejoinder – Appellant had no opportunity to contest or respond to such assessment – Held: NCDRC erred in accepting such assessment without independent evaluation or giving appellant opportunity to lead evidence [Paras 5, 8-10].

Remand for Reassessment – Fresh Consideration Directed – Supreme Court held that compensation must be determined afresh after allowing both parties to adduce evidence – Matter remanded to NCDRC for reevaluation – Ordered that deposited amount remain in fixed deposit until final adjudication [Paras 10-12].

Decision – Appeal Partially Allowed – Quantum of compensation set aside – Matter remanded to NCDRC for fresh determination of payable compensation under insurance policy – Parties to bear their own costs [Para 11-12].

Criminal Law - Murder  – Appeal Against Reversal of Acquittal – Section 302 IPC – Conviction Set Aside - Trial Court acquitted accused husband citing insufficient evidence of homicide – High Court reversed based only on failure to prove alibi and presumption under Section 106 – Held: Presumption under Section 106 cannot solely justify reversal where prosecution failed to prove death as homicide – Acquittal restored [Paras 1–6, 9–10, 14].

Presumption under Evidence Act – Section 106 – Not Sufficient Alone – Husband’s Duty to Explain Death – Held: Section 106 cannot be the sole basis for conviction without evidence of homicidal death – Husband's explanation was plausible, noted in initial police intimation, not disproved by investigation [Paras 5, 9–10].

Medical Evidence – Cause of Death Unclear – No Evidence of Strangulation or Homicide - Postmortem showed ligature mark only on front of neck, no signs of throttling or ante mortem injuries – Expert did not clarify whether death was homicidal or suicidal – Held: Cause of death remains indeterminate, suspicion alone insufficient [Paras 4, 11].

Alibi – Failure to Prove Not Enough – No Burden to Establish Innocence – Accused’s claim of being on duty was not proven false by police – Initial report supported his version – Held: Failure to establish alibi does not amount to proof of guilt where prosecution evidence is lacking [Paras 7–8].

Dowry Cruelty and Suicide – Section 498A & 306 IPC – No Evidence of Harassment – Relatives’ Testimony Insufficient - No history of physical violence or cruelty found, no injuries on body – Mere complaints of laziness not enough to sustain charges – Held: No evidence to sustain conviction under 498A or 306 IPC [Paras 12–13].

Decision – Appeal Allowed – High Court Conviction Set Aside – Acquittal by Trial Court Restored – Accused to be released forthwith if not required in other cases – Bail bonds cancelled [Paras 14–15].

Tenancy Law - Deemed Tenancy – Limitation on Successor Rights – Five-Year Cap – Defendant Not Protected – The petitioner, son of the deceased tenant, continued in possession after father’s death in 2016 – Held: As per Section 2(g) of the West Bengal Premises Tenancy Act, 1997, tenancy of dependent heirs (except spouse) is limited to five years – Plaintiff entitled to possession as statutory tenancy ceased in 2021 [Paras 4-6, 16-18].

Judgment on Admission – Order XII Rule 6 CPC – Decree Upheld – Plaintiff relied on specific admissions in written statement, including acknowledgment of tenancy under father and cessation of rent payment post 2021 – Held: Trial court rightly decreed suit under Order XII Rule 6 CPC based on clear, unambiguous admissions; upheld by High Court and Supreme Court [Paras 9-12, 44].

Admissions in Pleadings – Legal Effect – Defendant Bound by Own Statements – Admission of deceased father’s status as tenant, and acknowledgment of rent cessation after statutory period proved sufficient to constitute judgment on admission – Held: Court not bound to permit trial where admissions conclusively determine claim [Paras 26-35].

No Right to Raise New Grounds at SLP Stage – Argument on Inapplicability of Tenancy Act Rejected – Petitioner claimed WBPT Act not applicable – Held: This argument was never raised before trial court or High Court and contradicts petitioner’s earlier conduct, including application under Sections 7(1) & 7(2) of the Act – Argument barred [Paras 45-46].

Judicial Efficiency – Dissemination of Judgment – Circulation Ordered – Supreme Court directed this judgment to be circulated to all High Courts and through them to District Judiciary to streamline disposal of eviction cases based on admission [Para 48].

Final Decision – SLP Dismissed – Supreme Court affirmed eviction decree passed by trial court and upheld by High Court based on admissions in written statement and application of Section 2(g) of the 1997 Act [Paras 44, 47].