Sentencing Principles – Proportionality and Gravity – The Supreme Court reiterated the principle that sentencing should be proportionate to the nature and gravity of the offence committed – The courts must ensure that the punishment reflects the seriousness of the crime and serves the interests of society while not being unduly lenient or harsh [Paras 2-4].

Bigamy – Serious Offence – The Court emphasized that bigamy, as defined under Section 494, IPC, is a serious offence deserving substantial punishment – The maximum sentence prescribed is seven years of imprisonment, reflecting the legislature's view on its seriousness [Paras 14-15].

Undue Leniency – Flea-Bite Sentence – The High Court's imposition of 'imprisonment till the rising of the court' was deemed too lenient for the serious offence of bigamy – The Court held that such a sentence did not align with the principles of proportionality and did not serve as an adequate deterrent [Paras 15-18].

Enhancement of Sentence – The Supreme Court modified the sentence imposed on the accused from 'imprisonment till the rising of the court' to six months of simple imprisonment – The fine was also adjusted from Rs. 20,000 each to Rs. 2,000 each, with a default sentence of three months of simple imprisonment for non-payment [Paras 19-20].

Special Circumstances – Child’s Welfare – Considering the welfare of the child born to the accused, the Court ordered a staggered surrender for serving the sentences – First, the second accused would serve the sentence, followed by the first accused after the second accused's release, ensuring continuous parental care for the child [Para 20].

Decision – Appeal allowed – The Supreme Court enhanced the sentence of the accused to six months of simple imprisonment with a reduced fine – The Court ordered a special arrangement for the surrender of the accused to protect the welfare of their young child [Paras 20-21].

SEBI Regulation – Liquidation of Attached Assets – Petitioners sought directions for SEBI to liquidate assets and distribute proceeds to investors – Court constituted a High-Powered Sale Committee (HPSC) to auction assets and ensure investor claims are satisfied – HPSC to involve experts, create a property database, and engage e-auction service providers [Paras 1-18].

Article 142 of the Constitution – Complete Justice – Court invoked Article 142 powers to constitute HPSC to address the complexity and ensure justice – SEBI and Petitioners directed to fully cooperate with HPSC – Petitioners’ interim bail granted due to long incarceration and ongoing trials [Paras 6-17].

Investor Refund Process – HPSC tasked to identify investors, determine refund amounts, and manage the escrow account – Refund process to be publicized widely – Emphasis on a transparent and efficient refund process [Para 8].

Remuneration of HPSC Members – Court outlined remuneration for HPSC Chairperson and members, reimbursable from sale proceeds – HPSC to ensure timely liquidation and refund process [Para 11-12].

Administrative Assistance – SEBI to assist HPSC with office setup and infrastructure – HPSC to manage website and process claims/objections – Completion of the sale process targeted within one year [Para 10].

Decision: Writ Petition allowed – HPSC constituted to oversee asset liquidation and investor refund – Petitioners granted interim bail – SEBI and concerned states directed to cooperate with HPSC [Paras 7, 17].

Compromise Decree – Legal Validity – The compromise decree dated 20.08.1984 was contested on the grounds that no written compromise signed by the parties was presented, thus failing the requirements under Order XXIII Rule 3 CPC – The Supreme Court held that mere statements by parties do not satisfy the legal mandate of a written and signed compromise – Order XXIII Rule 3 CPC requires a lawful agreement in writing, without which the decree cannot be considered valid [Paras 12-23].

Doctrine of Lis Pendens – Applicability – The Court analyzed the effect of the sale deed executed on 22.08.1983 during the pendency of the appeal – Held that the sale deed is not affected by the doctrine of lis pendens under Section 52 of the TP Act as the statements by parties indicated collusive conduct – The purchaser's rights were upheld despite the pending litigation, as the sale deed was not challenged [Paras 17-18].

Compromise and Agreement – Requirements under CPC – Emphasized that a compromise decree must be based on a written agreement signed by the parties and proven before the Court – The lack of such a document rendered the alleged compromise in the first appeal invalid [Paras 19-21].

Decision – Appeal allowed – Orders of High Court and first Appellate Court set aside – Trial Court’s judgment dismissing the suit confirmed – Reiterated the necessity of strict adherence to procedural requirements for compromises under Order XXIII Rule 3 CPC [Paras 24-25].

Family Law – Interim Maintenance – Appellant sought full payment of arrears of interim maintenance – Respondent directed to pay only 20% of the total arrears by the High Court – Supreme Court modifies this, directing payment of Rs. 2 crores as a one-time settlement considering financial status, social standing, and ongoing litigation – Judgment reaffirms that maintenance is to prevent destitution rather than punishment [Paras 1-33].

Irretrievable Breakdown of Marriage – Dissolution – Marriage between parties found irretrievably broken down due to prolonged separation and multiple failed reconciliations – Supreme Court exercises its power under Article 142 of the Constitution to dissolve the marriage, underscoring the futility of continuing a dead marriage [Paras 14-21].

Maintenance Considerations – Permanent Alimony – Principles for determining alimony discussed – Factors include income, lifestyle, dependents, obligations, and future prospects of both parties – Balanced approach towards determining fair amount – Rs. 2 crores fixed as permanent alimony to be paid by respondent to appellant within four months [Paras 22-33].

Decision – Appeals allowed – Marriage dissolved under Article 142 – Permanent alimony of Rs. 2 crores awarded – All pending cases to be disposed of accordingly [Paras 34-37].

Constitutional Law – Scheduled Castes – Authority to Amend – The State Government of Bihar's resolution to merge the caste "Tanti-Tantwa" with 'Pan/Sawasi' in the Scheduled Castes list was challenged – Held, the State Government lacks the authority to amend or alter the Scheduled Castes list, which can only be done by Parliament through legislation – The resolution was found to be unconstitutional and was quashed [Paras 1-25].

Judicial Review – Competence of State Government – The Court emphasized that the competence to modify the Scheduled Castes list lies solely with Parliament under Article 341 – State Government's action was beyond its jurisdiction and deemed mala fide – High Court's support of the State's resolution was erroneous [Paras 12-36].

Impact on Beneficiaries – Posts filled under the impugned resolution – Directed that the posts under Scheduled Castes quota filled by "Tanti-Tantwa" members be returned to Scheduled Castes category – The affected members to be accommodated under their original category of Extremely Backward Classes [Paras 39-42].

Decision: Appeals allowed – Resolution dated 01.07.2015 quashed – Posts to be reallocated appropriately.

E-Auction Process – Bid Mistake – The appellant's bid of 140.10% in an e-auction for a mining lease, significantly higher than the preceding bid of 104.05%, was claimed to be a typographical error – The Supreme Court held that the system's lack of a mechanism to rectify such errors and the appellant’s immediate attempt to inform the respondents constituted a bona fide mistake – The Court recognized the principles of proportionality and reasonableness in addressing the appellant’s grievance [Paras 10-20].

Equitable Relief – Mistake in Bid – The Court applied the principles from W.B. State Electricity Board v. Patel Engg. Co. Ltd., allowing equitable relief when a mistake is promptly reported – The appellant’s actions were deemed bona fide, and the error was not intended to gain undue advantage [Paras 15-19].

Doctrine of Proportionality – Applying the doctrine, the Court noted that forfeiture of the entire security deposit for a bona fide error was punitive and disproportionate – Directed the appellant to pay Rs 3 crore instead, balancing state and private interests [Paras 23-25].

Decision – Appeal partly allowed – Impugned communication quashed – Directed fresh e-auction and appellant to pay Rs 3 crore to the first respondent, failing which the bank guarantee may be encashed – Part of the amount to be used for local charitable purposes [Paras 26-27].

Exemption from Fees – Market Fee vs. Rural Development Fee – Appeal against the denial of exemption from Rural Development Fee under the 2003 Industrial Policy – Respondent sought exemption, claiming similarity with other industries granted such benefits – High Court dismissed initial writ and subsequent modification application – Supreme Court finds both fees distinct under separate statutes – Policy only explicitly exempts Market Fee, not Rural Development Fee – Exemption from Market Fee does not imply exemption from Rural Development Fee [Paras 7-30].

Interpretation of Industrial Policy, 2003 – Distinction between fees levied under different statutes – High Court’s non-adjudication on merits regarding the exemption – Supreme Court emphasizes clear separation of statutory provisions and objectives of the two Acts – Respondent’s assumption of combined exemption deemed overreaching policy’s scope [Paras 21-24].

Effect of State Communications – Analysis of various notes and letters relied upon by Respondent – Supreme Court notes withdrawal of key letters and clarifies non-application of exemptions – Subsequent clarifications reinforce separate consideration for exemptions under Market Fee and Rural Development Fee [Paras 25-27].

Decision – Appeals allowed – Orders dated 27.01.2010 and 24.09.2010 set aside – High Court’s dismissal of Civil W.P. No. 14847 of 2009 upheld – No exemption from Rural Development Fee granted – Pending applications disposed of [Para 30-31].

Overcharging – Recovery Powers – The NPPA issued demand notices for overcharging on the drug Roscilox, requiring the appellant to deposit both the overcharged principal amount and the interest – The NPPA's authority to recover overcharged amounts is rooted in Paragraph 13 of the DPCO, which empowers the government to recover amounts accrued from charging prices higher than those fixed or notified under the DPCO [Paras 4-5].

Definitions – Dealer and Distributor – The DPCO definitions of 'dealer,' 'distributor,' and 'wholesaler' show overlapping roles – A 'distributor' includes any stockist appointed by a manufacturer, which encompasses roles performed by 'dealers' – The appellant's dual role as a 'distributor' and 'dealer' does not exempt it from the ambit of Paragraph 13 of the DPCO [Paras 6, 10-11].

Judicial Review – Scope of Appeal – The appellant's attempt to question the validity of the demand and the computation under Paragraph 19 of the DPCO was not entertained by the Supreme Court, as these issues were not properly raised before the Delhi High Court – The Court restricted its review to whether the appellant falls within the reach of Paragraph 13 [Paras 7-8].

Corporate Veil – Piercing the Corporate Veil – The High Court's exercise of piercing the corporate veil to find overlapping identities between the appellant and its group companies was acknowledged but not re-evaluated by the Supreme Court – The appellant's own admissions in its replies to the NPPA confirmed its direct contact with the manufacturer [Paras 9-10].

Laudable Objective – Price Control – The DPCO aims to control drug prices to ensure affordability for the common man – The Court emphasized the importance of not restricting the interpretation of the DPCO's provisions, which are intended to prevent overcharging by those involved in the manufacture and marketing of drugs [Para 11].

Inconsistent Versions – Lack of Documentation – The appellant's inconsistent versions and failure to provide firm documentation about its arrangements with manufacturers undermined its claim of being merely a 'dealer' – The appellant could not establish a clear factual foundation to support its exemption from Paragraph 13 [Paras 12-13].

Decision – Appeal dismissed – The Supreme Court found no error in the High Court's rejection of the appellant's claim – The Court upheld the NPPA's demand notices and vacated the status quo order previously granted [Paras 14-15].

Discharge Application – Scope and Consideration – The Supreme Court reiterated that the scope of consideration under Section 227, Cr.PC, is confined to the 'record of the case and the documents submitted therewith' by the prosecution – Defence materials cannot be considered at this stage – The court must determine whether there is sufficient ground for proceeding against the accused based on prosecution materials alone [Paras 3-4, 12].

Legal Interpretation – Record of the Case – Emphasized that 'record of the case' under Section 227, Cr.PC, refers only to prosecution materials and not any defence materials – Highlighted the decision in State of Orissa v. Debendra Nath Padhi that clarified this legal position [Paras 3-4].

Criminal Conspiracy – Ingredients and Proof – For a charge of criminal conspiracy under Section 120B, IPC, there must be prima facie evidence of an agreement between two or more persons to commit an illegal act – Mere suspicion or conjecture is insufficient – The materials on record did not support an accusation of conspiracy against the appellant – Referred to R. Venkatakrishnan v. CBI and Ajay Aggarwal v. Union of India & Ors. for defining the essential ingredients of conspiracy [Paras 25-28].

Evaluation of Evidence – Limited Scope – The court must only sift the evidence to determine whether a prima facie case exists – It should not engage in a detailed evaluation of the evidence, which is the function of the trial – The decision to frame charges should be based on a strong suspicion arising from the prosecution's materials – Cited Yogesh alias Sachin Jagadish Joshi v. State of Maharashtra and State of Tamil Nadu v. N Suresh Rajan & Ors. for these principles [Paras 15-16, 19].

Procedure – Obligations of the Court – The court has an obligation to apply its judicial mind to the prosecution's materials to determine if there is sufficient ground for proceeding – The decision to discharge must be reasoned, especially when rejecting a discharge application, to facilitate appellate review [Paras 21-23].

Custodial Death – Lack of Evidence – In this case, the materials on record did not provide sufficient ground to proceed against the appellant for the custodial death – There was no evidence of his involvement in the alleged torture or conspiracy – The Trial Court's suspicion was not based on concrete evidence but on conjectures [Paras 22-23, 30].

Decision – Appeal allowed – The Supreme Court set aside the High Court's order dismissing the application under Section 482, Cr.PC, and the trial court's order rejecting the discharge application – The appellant was discharged from the case as there was no sufficient ground for proceeding against him based on the prosecution's materials – The court clarified that its observations were specific to the appellant and not applicable to the other accused in the case [Paras 35-36].