Maternity Leave – Central Civil Services (Leave) Rules, 1972 – Rule 43 – The appellant, a government employee, applied for maternity leave for her first biological child – Leave was denied on the ground that she had two stepchildren from her husband's previous marriage, thereby exceeding the limit of two surviving children stipulated under Rule 43 – Tribunal and High Court upheld the denial – Supreme Court allowed the appeal, holding that the appellant’s entitlement to maternity leave for her first biological child is independent of her prior availing of child care leave for her stepchildren [Paras 1-30].

Purposeful Interpretation – Beneficial Legislation – The court emphasized that maternity leave provisions must be construed to support the continuance of women in the workplace, recognizing child birth as a natural incident of life – Rejected a literal interpretation that would disadvantage families not conforming to traditional structures – Affirmed the purposive approach to extend benefits under social welfare legislation to non-traditional families [Paras 15-26].

Constitutional Rights – Articles 15(3), 21, and 42 – The court reinforced that beneficial provisions for women under Article 15(3) and the right to privacy and dignity under Article 21 support the appellant's claim – Emphasized the State's duty under Article 42 to provide just and humane work conditions, including maternity relief [Paras 21-26].

Decision – Appeal allowed – Judgments of the High Court and Central Administrative Tribunal set aside – Appellant entitled to maternity leave under Rule 43 – Directed release of benefits within two months [Paras 28-30].

Criminal Law – Quashing of Proceedings – Section 482 CrPC – High Court dismissed the appellant's application to quash criminal proceedings related to an offense under Section 376 IPC – Supreme Court allowed the appeal, holding that the allegations did not prima facie constitute the offense of rape – Consensual relationship between the parties negated the essential ingredients of Section 376 IPC [Paras 3-15].

Consent and Misconception of Fact – Sections 375, 376 IPC – The complainant and appellant were in a consensual relationship from 2013 to 2017 – The complainant's marriage and subsequent divorce were acknowledged – Allegations did not establish that the appellant's promise to marry was false at inception and intended to induce a sexual relationship – Supreme Court emphasized the need for a clear distinction between breach of a promise and a false promise made with dishonest intent [Paras 10-14].

Revisional Jurisdiction – Scope – Supreme Court reiterated the cautious exercise of powers under Section 482 CrPC – Interference warranted only when the FIR or charge-sheet does not disclose any cognizable offense or is manifestly attended with mala fide intentions [Paras 7-9].

Decision – Appeal allowed – High Court's order set aside – Application under Section 482 CrPC allowed – Case Crime No. 11 of 2018, charge-sheet dated 23 April 2018, and the order taking cognizance dated 24 May 2018 quashed [Paras 15-16].

Criminal Law – Charge Framing – High Court set aside the trial court's order framing charges of rape and POCSO Act offenses against the accused – Supreme Court found the High Court's reasoning, particularly on delay in lodging FIR, incomprehensible and erroneous – Reiterated that charges should be framed based on prima facie evidence and strong suspicion, not proof [Paras 20-31].

Revisional Jurisdiction – Scope – Emphasized that the revisional jurisdiction should be invoked sparingly, primarily to correct gross errors or jurisdictional issues – Interference at the charge-framing stage should be minimal, allowing the trial to proceed unless there's clear abuse of process [Paras 21-27].

Delay in FIR – Not a Ground for Discharge – Supreme Court held that delay in lodging FIR cannot be a sole ground for discharging the accused – The truthfulness and sufficiency of evidence are to be tested during the trial [Para 20].

Decision – Appeal allowed – High Court's order set aside – Trial court directed to proceed with the trial based on the original charges framed – Observations made for deciding the appeal not to influence the trial court's final judgment on the merits [Paras 31-32].

Mutual Funds – Winding Up – SEBI Regulations – FIFA sought commission for mutual fund distributors from the date of winding-up notices – Court held that Regulation 52 applies only when the scheme is in operation and not after the winding-up notice – Commission payment is not an expense connected with winding up under Regulation 41(2)(b) [Paras 1-9].

Regulatory Interpretation – Recurring Expenses – Court clarified that recurring expenses under Regulation 52, including distributor commission, are applicable during the scheme's operation – Post-winding-up, such expenses are not permissible – Transparency regulations do not confer additional rights to claim expenses during winding up [Paras 3-9].

Order – Application dismissed – FIFA's claim rejected – Franklin Templeton's statement on bearing liquidation expenses recorded [Paras 10-11].

Urban Development – Building Plan Sanction – Fire Safety Regulations – Appellant purchased property and applied for building plan sanction – Initially sanctioned for 15 meters height – Later amendments to Master Plan allowed 17.5 meters with stilt parking – Revised plan submitted but not sanctioned due to lack of fire clearance – High Court dismissed appellant's writ – Supreme Court allowed appeal, finding inconsistency between Fire Service Rules and Master Plan – Directed SDMC to consider revised plan and mandated harmonization of conflicting regulations.

Constitutional Law – Right to Equality – Arbitrariness – Rule 27(2) of the Delhi Fire Service Rules, 2010 found to be inconsistent with the amended Master Plan for Delhi, thus violating Article 14 of the Constitution – Supreme Court emphasized the need for uniformity and non-arbitrariness in regulatory frameworks.

Judicial Review – Administrative Directions – Writ Jurisdiction – High Court's refusal to grant relief was erroneous due to lack of proper consideration of amendments to Master Plan – Supreme Court’s intervention justified to prevent miscarriage of justice and uphold statutory compliance.

Decision – Appeal allowed – High Court’s judgment set aside – SDMC directed to process and consider the revised building plan – Directed amendment of Fire Service Rules to align with the Master Plan for Delhi – No order as to costs 

Criminal Law – Conviction based on suspicion – An accused cannot be convicted on the basis of suspicion, no matter how strong – The prosecution must prove the guilt beyond a reasonable doubt – Conviction and sentence set aside due to lack of conclusive evidence and inconsistencies in the prosecution's case [Paras 1-21].

Extra-Judicial Confession – Caution in Acceptance – Extra-judicial confessions must be corroborated and treated with caution – The court highlighted the importance of not solely relying on such confessions for conviction without supporting evidence [Paras 15-16].

Circumstantial Evidence – Chain of Evidence – For a conviction based on circumstantial evidence, the chain of evidence must be complete and conclusive, excluding every other hypothesis except that of the accused's guilt – Prosecution failed to establish such a chain in this case [Paras 18-19].

Decision – Appeal allowed – Conviction and sentence of the appellant set aside – Accused acquitted of all charges – Bail bonds discharged [Paras 22-23].

Industrial Disputes – Retrenchment – Principle of law that re-employment of retrenched workmen does not entitle them to claim continuity of service applies only to bona fide retrenchments – The retrenchment followed by an offer of re-employment on new terms and conditions found not bona fide – Tribunal and High Court set aside retrenchment orders and reinstated employees with continuity of service and 75% back wages [Paras 1-18].

Re-Employment – Continuity of Service – Tribunal held retrenchment not bona fide – Employees entitled to continuity of service once retrenchment orders are set aside – Applicable principles reaffirmed from Cement Corpn. of India Ltd. v. Presiding Officer Industrial Tribunal-cum-Labour Court and Anr. (2010) 15 SCC 754 and Maruti Udyog Ltd v. Ram Lal and Ors. (2005) 2 SCC 638 [Paras 16].

Back Wages – Proof of Unemployment – Tribunal and High Court correctly awarded 75% back wages based on the employees' consistent testimonies of being unemployed post-retrenchment – Employer failed to provide evidence of gainful employment for retrenched employees [Paras 17-20].

Decision – Appeal dismissed – High Court's judgment affirmed – Reinstatement with 75% back wages upheld – Parties to bear their own costs [Para 20].

Constitutional Law – Right of Persons with Disabilities – The downgrading of seniority of a physically disabled candidate transferred to his home district was held to be arbitrary, unreasonable, and discriminatory – Supreme Court emphasized that any rule or executive instruction affecting seniority of disabled persons, when transferred for their benefit, would violate Articles 14 and 16 of the Constitution [Paras 2-33].

Disability Rights – UNCRPD – The principles of the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) ratified by India were reiterated – State obliged to give effect to UNCRPD, ensuring that disabled persons are not marginalized or excluded from mainstream society – Fundamental rights to equality, life, and dignity extended to disabled persons [Paras 27-31].

Employment – Seniority – Supreme Court held that the transfer of disabled persons under beneficial circulars should not affect their seniority at the State level – The explanation to Sub-Rule (10) of Rule 29 of the Rajasthan Educational Subordinate Services Rules, 1971, was held inapplicable to physically disabled candidates transferred under the circular [Paras 32-33].

Decision – Appeal allowed – Judgments of Single and Division Bench of High Court set aside – Office Order dated 11th September 2007, downgrading the appellant’s seniority, quashed – Respondents directed to restore the appellant’s seniority in the State list considering past service [Paras 34].

Partition Suit – Ancestral Property – High Court dismissed the plaintiff's claim that properties at villages Pirangut and Nande were joint family ancestral properties – Supreme Court held that the property at Pirangut was indeed ancestral based on evidence including a written memorandum of settlement and mutation records – The property at Nande was held as self-acquired by the defendant – Equal shares granted to all legal heirs in the Pirangut property [Paras 2-15].

Family Settlement – Evidence – Memorandum of settlement dated 23.12.1961 and mutation entry demonstrated the joint family nature of the Pirangut property – Testimonies of family members supported the claim – High Court’s findings on gift by Raghunath to Pandurang found unsupported by evidence [Paras 8-14].

Judicial Precedents – Legal Principles – Reaffirmed principles regarding ancestral property and partition as established in Vineeta Sharma v. Rakesh Sharma & Ors. (2020) 9 SCC 1 and other relevant cases – Property distribution aligned with recent judgments ensuring equal rights to daughters in ancestral property [Para 15].

Decision – Appeal allowed – High Court's judgment set aside – Preliminary decree granted – All parties including daughters to receive equal 1/10th share in Pirangut property – Directions issued for final decree from competent court [Paras 15-17].