Criminal Law – Quashing - Abetment of Suicide – Section 306 IPC – Suicide Note Alleging Cheating – No Proximate Act – FIR Filed 39 Days After Death – Accusations Based on Alleged Discovery of Death Note – Court found delay unexplained and suicide note insufficient to establish instigation or abetment – Citing Prakash v. State of Maharashtra, held that nexus between alleged acts and suicide must be proximate – Quashing of proceedings under Section 306 IPC upheld [Paras 3, 10–13,

15].

Section 420 IPC – Cheating Allegations – Quashing Set Aside – FIR Alleged Forgery, Financial Fraud of Rs. 60 Crores – Supreme Court held that High Court erred in quashing proceedings without evaluating material collected during investigation – Observed that a reasoned analysis was required before discarding cheating allegations – Quashing under Section 420 IPC set aside – Trial to proceed [Paras 6–9, 16–19, 21].

Section 482 Cr.P.C. – Scope of Interference – High Court Cannot Conduct Mini-Trial – Supreme Court reiterated that FIRs cannot be quashed based on premature evaluation of evidence – High Court’s casual and non-reasoned approach while discarding cheating charge found impermissible – Appellants granted liberty to seek discharge before trial court [Paras 5, 12, 22].

Decision: Appeal partly allowed – Quashing of FIR under Section 306 IPC upheld – Quashing of FIR under Section 420 IPC reversed – Trial court directed to proceed in accordance with law – Respondents free to seek discharge under law [Paras 21–22].

Criminal Law – Appeal against conviction - Murder Trial – Contradictory Eyewitness Testimony – Conviction Reversed – Appellant convicted of murder of Zahid Khan alias Guddu— Prosecution relied on four eyewitnesses, but their testimonies conflicted on key facts such as presence, cause of death, and medical disclosure— Delay in recording statements, absence of bloodstains, and nonreporting to nearby police created grave doubts—Held: Prosecution failed to prove case beyond reasonable doubt—Conviction unsustainable [Paras 10–21].

Benefit of Doubt – Previous Enmity and Inconsistent Evidence – Possibility of False Implication – Deceased was a history-sheeter facing multiple criminal cases—Known prior enmity with appellant—Court held that enmity may provide motive but also raises risk of false implication—Contradictions in testimony and lack of corroboration rendered conviction unsafe—Benefit of doubt granted [Paras 20–22].

Eyewitness Reliability – Delayed Statement – Lack of Bloodstains – Witnesses who allegedly carried bleeding deceased to hospital had no blood on clothes—Statements recorded 45+ days after incident—Such conduct and inconsistencies held unnatural and indicative of unreliable testimony [Paras 10–16, 21].

Decision: Appeal allowed – Conviction and sentence under Section 302 IPC set aside – Appellant acquitted of all charges – Already on bail, his bail bonds stand discharged [Paras 23–24].

Civil Law - Contempt of Court - Insolvency Proceedings – Binding Effect of Approved Resolution Plan – Contempt for Continuing Tax Recovery – Petitioner alleged contemnors continued to pursue demands for pre-CIRP dues despite Supreme Court’s ruling in Ghanshyam Mishra – Court reaffirmed that claims not included in approved Resolution Plan stand extinguished under Section 31(1) of IBC – Held: Recovery proceedings by Chhattisgarh authorities are illegal and contemptuous [Paras 3–5, 14–17, 23–24, 34–37].

Contempt of Court – Continuation of Recovery Despite Clear Judgment – State Authorities Issued Demand Notices for VAT, CST, and Entry Tax Post-Resolution – Petitioner specifically part of Ghanshyam Mishra batch – Court held deliberate disobedience despite being notified of judgment – Demand notices quashed – Unconditional apology accepted, no penal action taken [Paras 6–13, 27, 36–37].

IBC Supremacy – Clean Slate Doctrine – All Pre-Resolution Claims Must Be Submitted to

RP – Court emphasized Resolution Applicant must not be faced with undecided claims –

Stakeholders cannot raise belated dues post-approval – Judgments in Essar Steel,

Innoventive, and Rainbow Papers discussed – Rainbow Papers held inapplicable as claim in that case was filed before CoC [Paras 18–22, 28–33].

*Binding Nature of IBC Resolution – Applies Even to Non-Participating Creditors – Court clarified even if State was not a party to insolvency proceedings, approved Resolution Plan is binding – Absence of claim before IRP/RP fatal – Highlights intent to maintain finality and certainty post-resolution [Paras 33–36].

Decision: Contempt petition disposed – Respondents’ conduct held contemptuous but no action taken in view of unconditional apology – All recovery notices and proceedings quashed – Order of Supreme Court in Ghanshyam Mishra reiterated as binding on all stakeholders including government authorities [Paras 34–37].

Land Acquisition – Compensation – Circle Rates – Theory of Deduction Inapplicable under 2013 Act – Appellant challenged award of compensation based on circle rates notified under the Stamp Act – Supreme Court held: Section 26(1) of 2013 Act mandates highest of stamp value, average sale, or consent compensation – Collector’s discretion under Explanation 4 to adjust valuation must be reasoned – Theory of deduction developed under 1894 Act cannot override clear mandate of 2013 Act – No deduction permitted in absence of valid formation of opinion by Collector – Appeals dismissed [Paras 2, 21, 24– 27, 31, 41–43].

Circle Rate – Evidentiary Weight – Scientific Fixation Encouraged – Court analyzed legislative intent behind circle rates and valuation guidelines under 2018 Rules – Emphasized that properly fixed rates reflect fair market value and aid ease of doing business and tax compliance – Directed that fixing of circle rates be done scientifically and transparently by expert bodies – State authorities cannot disown rates they have themselves fixed [Paras 33–39, 42].

Acquisition Act 2013 – Sections 26, 27, 28 – Role of Collector’s Opinion – Collector must apply statutory criteria under Section 26(1) and then assess need for adjustment via Explanation 4 – Any enhancement or deduction must be based on recorded reasons – Collector’s failure to exercise discretion cannot be ground to reduce compensation awarded by Commissioner based on applicable circle rate [Paras 26–27, 31–32].

Arbitration Award – Interference Limited – High Court and District Court rightly upheld award passed by Commissioner under Section 3G(5) of National Highways Act read with Arbitration Act – Award based on correct application of

2013 Act and valuation guidelines – No arbitrariness or legal error shown – Objections rightly rejected under Section 34 of Arbitration Act [Paras 6–7, 12– 13, 31].

Decision: Civil appeals dismissed – Compensation based on Collector’s  Guidelines upheld – No reduction allowed by applying theory of deduction – Circle rates held binding absent valid reasoned departure by competent authority – No costs awarded [Paras 41–43].

Criminal Law – Murder – Appeal against conviction - Inconsistent Witness Testimony – Conviction Set Aside – Deceased Mohan Singh was allegedly attacked by five men – Trial Court convicted all; High Court acquitted one – Remaining four appellants challenged conviction – Supreme Court found key prosecution witnesses (family members) gave embellished versions, timelines contradicted FIR and each other – Held: Evidence untrustworthy, prosecution failed to prove guilt beyond reasonable doubt – Convictions set aside [Paras 7–17, 19].

Delay in Recording Witness Statements – Impact on Credibility – Statements of material witnesses, including child witness and wife of deceased, recorded after 7–17 days – Court held such unexplained delay casts serious doubt on credibility and integrity of prosecution case – Investigating Officer’s testimony confirmed discrepancies [Paras 14, 17].

Medical Evidence – Discrepancies on Cause of Death – Post-mortem attributed death to gunshot injury but later clarified as stab wound – Bullet not recovered – Held: Medical evidence failed to support firearm theory – Seizure of pistol from accused Arun rendered inconsequential [Paras 5, 18].

Benefit of Doubt – Sole Reliance on Dubious Oral Testimony – Court emphasized need for credible, corroborated evidence in criminal trials – Rule of caution invoked due to admitted enmity between accused and deceased – Held: Conviction cannot rest solely on suspicious family testimony – Appellants entitled to benefit of doubt [Paras 16, 19–20].

Decision: Appeals allowed – Judgments of Trial Court and High Court set aside – All four appellants acquitted – Those on bail discharged; remaining accused (Ramlal) to be released unless required in other matters – Fine amounts to be refunded [Para 20].

Land Acquisition – Ownership Dispute – TNHB Ownership Upheld – The Court upheld the High Court's decision confirming that the Tamil Nadu Housing Board (TNHB) was the rightful owner of 4.95 acres of acquired land, including the disputed 0.90 cents – Held: Earlier mistake in judgment recording the area as 4.05 acres was clarified based on the compensation amount which matched acquisition records [Paras 1-2].

Invalid Sale – Ratification Deed Ineffective – Appellant’s Title Rejected - The sale deeds relied upon by the appellant were held invalid as sellers were not owners of the land – The Ratification Deed dated 19.01.2004 had no legal effect – Held: Patta issued in favour of appellant and his predecessors was rightly cancelled [Paras 3-6].

Violation of Court Order – Unauthorized Allotment of Flats – Legal Consequences – The appellant, despite Supreme Court orders, sold two flats to third parties – Held: Allotments made post High Court and Supreme Court orders are void; purchasers may pursue independent remedies against appellant [Paras 7-8].

Equitable Relief – Innocent Third-Party Flat Buyers Protected – Ownership Recognized - The Court, acknowledging TNHB’s lapse and the position of third-party purchasers, allowed 54 flat buyers to retain possession and be treated as absolute owners – Rs. 5 crore deposited by appellant to be treated as consideration for land – Remaining unsold flats to be disposed of by TNHB [Paras 9-11].

Decision – Appeals Disposed of – No Rights Decided as to Appellant’s Claims Against Vendors - The Court declined to decide on any claims appellant may have against those who sold land to him – Appeals disposed of with final directions [Paras 12-14].

Matrimonial Muslim Law - Ex-Parte Divorce Decree – Subsequent Remarriage – Decree Restored – The appellant-wife obtained a divorce decree under Section 2 of the Dissolution of Muslim Marriages Act, 1939 which became final and pursuant to which she remarried and had a child – The Court held that restoration of the matrimonial case would serve no purpose since appellant's subsequent marriage is a significant supervening circumstance – Held: The High Court erred in restoring the case without considering the appellant’s subsequent marriage – Divorce decree dated 25.11.2011 restored [Paras 6-7].

Consent of Respondent – Acceptance of Divorce – Respondent Agrees to Accept Divorce – During the hearing, the respondent-husband accepted the dissolution of marriage and waived further claims – Held: Both parties expressed no objection to closing all disputes and accepted the divorce – Court confirmed restoration of the original decree [Para 7].

Termination of All Pending Litigations – Powers under Article 142 – Court Quashes All Cases – In exercise of powers under Article 142, Supreme Court quashed all pending civil, criminal, and matrimonial cases between the parties filed against each other – Directed that no further proceedings shall continue between the parties and neither party shall have any claim against the other including maintenance or mehar – Held: Complete and final settlement of all litigations between the parties [Paras 11-13].

Final Decision – Appeal Allowed – Impugned order set aside – Original divorce decree dated 25.11.2011 restored – All related cases quashed – Parties barred from initiating any further proceedings against each other – Appeal allowed accordingly [Paras 12-13].
 

Civil Writ - Enforcement of The Drugs and Magic Remedies (Objectionable Advertisements) Act - Definition of Advertisement – Wide and Inclusive Scope – Section 2 of 1954 Act – The Court emphasized that the definition of ‘advertisement’ under Section 2 of the 1954 Act is wide, covering not only printed or broadcast media but also oral announcements, notices, wrappers, labels, and even messages conveyed via light, sound, or smoke – Such advertisements aimed at promoting drugs or magic remedies are brought within the regulatory framework.

Prohibition on Advertisements – Total Bar on Specific Categories – Sections 3, 4, and 5 of 1954 Act – The Court reiterated that there is an absolute prohibition on advertisements relating to drugs and magic remedies for treatment of diseases mentioned under the Schedule or Rules – Misleading advertisements and those creating false impressions are strictly prohibited – The prohibition applies not only to advertisers but also to those involved in publication or preparation of such advertisements.

Implementation Failure – States’ Non-Compliance – The Court observed that despite being in force for over 70 years, the 1954 Act is not being implemented in letter and spirit – Directed the States and Union Territories to appoint sufficient Gazetted Officers and scrutinizing officers as required under Sections 8 and Rule 3 of the 1955 Rules within one month – Emphasized that enforcement machinery is lacking and needs urgent attention.

Creation of Grievance Redressal Mechanism – Mandatory Directions – The Court directed all States/UTs to set up a public Grievance Redressal Mechanism for reporting objectionable advertisements within two months – Mechanism should include toll-free numbers and email facilities – The complaints must be forwarded to the authorized officers who are required to take prompt action and initiate criminal proceedings under the 1954 Act and BNSS.

Sensitization and Public Awareness – Role of Legal Services Authorities – The Court directed the National, State, and District Legal Services Authorities to conduct sensitization programmes to educate the public on the dangers of objectionable advertisements and their adverse health consequences – Highlighted the need for awareness among the masses.

Development of Dashboard – Compliance Monitoring – The Court reaffirmed its earlier direction (Order dated 30th July 2024) that the Union of India, through the Ministry of Ayush, must create a dashboard for recording complaints and actions taken – Granted three months to implement the same – Dashboard to ensure transparency and facilitate prosecution under the 1954 Act.

Non-Compliance by States – Specific Directions to Defaulting States – Court noted non-compliance by 17 States/UTs, including Himachal Pradesh, Maharashtra, and Uttar Pradesh, among others – Ordered these States to file compliance affidavits by 30th April 2025 and to cooperate in setting up grievance redressal systems and enforcement mechanisms.

Final Decision – Writ Petition Disposed of with Directions – The Court issued binding directions to all States, UTs, and the Union of India to implement the provisions of the 1954 Act effectively – Compliance reports to be filed by end of June 2025 – Petition to be listed for compliance monitoring on 14th May 2025.
 

Consumer Law – Delay in Flat Possession – Refund with 9% Interest Upheld – Not 15% – Respondent was allotted a flat in 2010 but possession delayed despite full payment – Supreme Court upheld NCDRC’s direction for refund with 9% p.a. interest – Held: High Court’s enhancement to 15% excessive and unjustified – Refund must be reasonable, not punitive [Paras 4–8, 14].

Article 227 Jurisdiction – High Court Should Not Interfere Lightly – NCDRC Findings

Were Reasoned – Supreme Court found no exceptional circumstances justifying High Court’s interference with NCDRC’s well-balanced order – Article 227 cannot be invoked to re-weigh evidence unless perverse error exists [Paras 12–14].

Compensation – Reduced from ₹10 Lakhs to ₹7.5 Lakhs – Public Authority

Consideration – Respondent claimed ₹10 Lakhs for harassment – SC reduced to ₹7.5 Lakhs noting MHADA is a State instrumentality and no personal malice involved – Balanced compensation awarded [Para 15].

Principle – Refund over Possession – Homebuyer Cannot Be Compelled to Accept Flat – Following Bangalore Development Authority v. Syndicate Bank, SC held that inordinate delay justifies refund with interest – Delivery after long delay unacceptable to consumer rights [Para 14].

Decision: Appeal partly allowed – High Court’s order enhancing interest to 15% p.a. set aside – NCDRC’s order granting 9% interest restored – Compensation modified from  ₹10 Lakhs to ₹7.5 Lakhs – No order as to costs – Pending applications disposed of [Paras 14–15].