Judicial Delay and Political Influence – Withdrawal of Prosecution – Case involving accused, including a politically influential individual, facing trial for double murder – Accused successfully delayed trial for nearly three decades through repeated adjournments – Trial Court allowed withdrawal of prosecution against one accused (Chhote Singh) citing good public image – High Court's repeated adjournments criticized – Supreme Court highlights misuse of political power to evade justice – Order of Trial Court allowing withdrawal of prosecution against Chhote Singh set aside – Directions for expeditious trial [Paras 1-18].

Withdrawal of Prosecution under Section 321, CrPC – Trial Court's order criticized for relying on accused's political standing rather than merits of the case – Withdrawal cannot be granted solely on good public image, especially in serious crimes – Need for strict scrutiny in cases involving influential individuals to prevent miscarriage of justice [Paras 11-12].

Prolonged Pendency of Criminal Revisions – High Court's multiple adjournments allowing dilatory tactics – Supreme Court directs High Court to expedite hearing of remaining criminal revisions and trial – Original Trial Court record to be sent back for timely conclusion of trial [Paras 13-18].

Decision – Appeal allowed – Criminal Revision No. 2107 of 2012 before Allahabad High Court allowed – Trial Court's order dated 19.05.2012 set aside with respect to Respondent No.2 (Chhote Singh) – High Court directed to re-evaluate pending revisions [Paras 16-18].

Foreigners Act – Burden of Proof – Appellant declared a foreigner for failing to discharge the burden under Section 9 of the Foreigners Act – Tribunal’s finding based on insufficient evidence and improper procedural handling – Supreme Court emphasized the need for authorities to have concrete material before alleging a person’s foreigner status – Miscarriage of justice identified due to lack of initial evidence and procedural errors by authorities – Appellant’s consistent documentation of residence in India before the cut-off date considered significant [Paras 1-38].

Citizenship – Proof of Nationality – Appellant presented voter lists and certificates showing his and his parents’ residence in India prior to 1971 – Tribunal dismissed these documents based on minor discrepancies – Supreme Court held that minor discrepancies in names and dates in voter lists and other documents are not sufficient grounds to dismiss claims of citizenship – Emphasis on careful consideration of evidence in cases with severe consequences like deportation [Paras 39-45].

Procedure – Natural Justice – Tribunal and authorities failed to provide sufficient material and grounds to appellant at the inception of the proceedings – Violation of natural justice principles – Supreme Court stressed the necessity of sharing material with the accused to allow for a fair defense – Tribunal’s actions deemed procedurally flawed and unjust [Paras 36-42].

Decision: Appeal allowed – Tribunal’s and High Court’s decisions set aside – Appellant declared an Indian citizen – Authorities directed to issue necessary documentation confirming appellant’s citizenship [Para 45-48].

Misuse of Criminal Proceedings in Commercial Dispute – Appeal against frivolous criminal proceedings initiated for personal vengeance in a civil matter – Accusations of cheating and forgery in a financial transaction between corporate entities – Abusing legal system by disguising a commercial dispute as a criminal case, leading to unnecessary litigation and misuse of judicial resources [Paras 2, 14, 32-34].

False Claims and Jurisdiction Manipulation – Manipulation of jurisdiction by providing misleading addresses – Complainant filed case in an inappropriate forum with false addresses, demonstrating a malicious attempt to harass and abuse the legal process [Paras 22-24, 27, 33].

Investment and Shareholding Dispute – Dispute over investment and shareholding in private companies – Decision of the complainant to invest in equity misrepresented as a loan transaction – Shareholding affected by merger and amalgamation of companies, a subject of civil law [Paras 4-7, 27-30, 35].

Delayed Legal Recourse and Arbitration Proceedings – Delay in taking legal steps for recovery of alleged dues – Dispute referred to arbitration by Delhi High Court, highlighting its civil nature [Paras 15, 32, 35].

Decision and Imposition of Costs – Appeals allowed, FIR and subsequent proceedings against appellants quashed – Imposition of costs on the complainant for misuse of legal system and false litigation, to be deposited for the benefit of legal community [Paras 36-39].

Land Acquisition – Determination of Market Value – Assessment of market value of acquired land for flood protection wall – Appeals concerning compensation awarded by Land Acquisition Officer and Reference Court – High Court’s rejection of Blue Zone classification as per statutory requirements – Supreme Court upholds Reference Court’s award for market value at Rs. 100 per sq. ft., with no deductions for development charges considering acquisition purpose [Paras 1-74].

Potentiality of Land – Evaluation of Non-Agricultural Use – Analysis of land’s potentiality for non-agricultural use at the time of acquisition notification – Recognition of surrounding developments and existing municipal limits – Examination of comparable sale instances – Supreme Court concurs with Reference Court’s findings on land potential and comparable market rates [Paras 30-46].

Evidence and Procedural Requirements – Admissibility of Secondary Evidence – Evaluation of evidence provided by parties, including maps and affidavits – Court emphasizes need for definitive statutory evidence when relying on regulatory restrictions like ‘Blue Zone’ – Affidavit from State clarifying applicable bylaws and regulations during relevant period considered [Paras 18-29, 37-45].

Market Value Determination – Comparable Sales Methodology – Analysis of sale exemplars provided – Emphasis on selecting transactions between unrelated parties – Rejection of suspicious transactions close to notification date – Supreme Court supports Reference Court’s use of unrelated transactions at Rs. 100 per sq. ft. for valuation [Paras 53-64].

Statutory Benefits – Grant of Additional Compensation – Directions for interest on enhanced compensation amount – Period for rental compensation established – Court orders adjustments to reflect accurate statutory entitlements [Paras 67-73].

Decision: Civil Appeals partly allowed – High Court judgments set aside – Market value for land fixed at Rs. 100 per sq. ft. for specified portions, with statutory benefits upheld – Appeals dismissed in related cases – No order as to costs [Paras 1-74].

Divorce – Irretrievable Breakdown of Marriage – Exercise of Article 142 Powers – Appeal by husband challenging the High Court’s order dismissing his divorce petition – Husband and wife lived together for only 43 days in total – Separation period of over 22 years – Continuous legal battles and acrimonious relationship – Supreme Court exercises powers under Article 142 to dissolve marriage, emphasizing that continuation of the legal relationship is unjustified given the complete failure of the marriage [Paras 1-20].

Irretrievable Breakdown of Marriage – Constitutional Powers – Court refers to precedents where it exercised Article 142 powers to dissolve marriages in similar circumstances – Highlights recent Constitution Bench ruling in Shilpa Shailesh v. Varun Sreenivasan which affirms the Court’s discretion to grant divorce on grounds of irretrievable breakdown even if one spouse opposes [Paras 13, 18-19].

Cruelty and Legal Battles – Husband alleges cruelty due to refusal of marital obligations and initiation of false criminal proceedings by wife – Supreme Court finds that actions and prolonged separation indicate a failed marriage beyond repair – Acknowledges continuous disputes and legal harassment by the wife post-separation [Paras 2-17].

Decision – Appeal allowed – Marriage dissolved under Article 142 – No permanent alimony awarded as both parties are qualified professionals with sufficient earnings – High Court’s order set aside [Para 20].

Order II Rule 2(3) CPC – Leave to Sue Separately – Respondent sought leave under Order II Rule 2(3) CPC for filing a separate suit for recovery of arrears and damages – Trial Court and High Court found no relinquishment or omission in the first suit to bar the second suit – High Court affirmed separate causes of action for the two suits – Appeal dismissed – Court held that the object of Order II Rule 2(3) CPC is to avoid multiplicity of suits and prevent defendants from being vexed twice for the same cause. However, it does not bar suits based on different causes of action, as was the case here. The respondent had specifically reserved its right to claim arrears and damages in the first suit and had taken leave to file a separate suit. [Paras 4-12, 17-18].

Order VII Rule 11 CPC – Rejection of Plaint – Application under Order VII Rule 11 CPC by appellant for rejection of respondent’s claim for arrears and damages – High Court found no merit in the application – Distinction between relinquishment and omission of claims under Order II Rule 2 CPC emphasized – Appeal dismissed – Court observed that the appellant’s application for rejection of the plaint was based on a misinterpretation of the principles under Order II Rule 2 CPC. The respondent had neither relinquished its claims nor omitted to claim the reliefs sought in the second suit, thus the application under Order VII Rule 11 CPC was rightly dismissed by the lower courts [Paras 7, 12].

Leave and License Agreement – Termination and Subsequent Litigation – Original agreement dated 25.11.2008 superseded by another agreement dated 01.12.2010 – Dispute arose due to default in payment of storage charges – Legal notice issued by respondent on 27.11.2014 – Respondent instituted suit for permanent injunction and possession in O.S. No.101 of 2015 – Appellant filed a commercial suit for declaration regarding extent of the warehouse area – Respondent granted leave under Order II Rule 2(3) CPC to file a separate suit for arrears and damages – Multiple suits filed by both parties leading to the present appeal [Paras 4-11].

Commercial Suit – Separate Causes of Action – High Court’s observation that suits were based on different causes of action – First suit related to possession and permanent injunction – Second suit related to recovery of arrears and damages – No relinquishment or omission of claims – Respondent had reserved its right to claim arrears and damages in the first suit and sought leave to file a separate suit – Distinction between causes of action and claims for different reliefs highlighted [Paras 12, 17].

Precedents and Judicial Reasoning – Reliance on Bharat Petroleum Corporation Ltd. Vs. ATM Constructions Pvt. Ltd., 2023 SCC Online SC 1614 – Court reiterated that suits for possession and suits for claiming damages for use and occupation are based on different causes of action and can be separately maintained – Application of legal principles regarding Order II Rule 2(3) CPC and Order VII Rule 11 CPC – Affirmation of High Court’s detailed reasoning and dismissal of appellant’s contentions [Paras 16-18].

Decision – Appeal Dismissed – Held – The second suit filed by the respondent was maintainable – No infirmity found in the impugned order – Supreme Court affirmed the High Court’s view that both suits were based on different causes of action – Pending applications disposed of [Para 19-20].

Adverse Possession – Limitation and Burden of Proof – Appellant-State claimed ownership based on adverse possession since 1958 following the donation of land for constructing a Veterinary Hospital – Trial Court decreed possession in favor of plaintiff due to lack of proof of donation – First Appellate Court reversed, acknowledging adverse possession – High Court restored Trial Court’s judgment, noting the absence of detailed adverse possession claims – Supreme Court found the suit barred by limitation, upholding appellant’s continuous possession as proof of adverse possession and ownership [Paras 1-33].

Vague Pleadings – Rejection of Suit – High Court failed to consider that plaintiff’s vague plaint lacked specific dates and details regarding construction awareness, allowing circumvention of the limitation law – Supreme Court criticized the vague plaint for lacking material particulars necessary for the case [Paras 15-18].

Ownership Presumption – Section 110 of Indian Evidence Act – Burden of proof for ownership lies on the respondent challenging the appellant’s possession – Possession since 1958 indicated ownership, supported by documentary evidence – Plaintiff’s inability to rebut this presumption resulted in the dismissal of the suit [Paras 30-32].

Decision: Appeal allowed – High Court judgment set aside – First Appellate Court’s dismissal of the plaintiff’s suit confirmed [Paras 33-34].

Quashing of Criminal Proceedings – Defective Vehicle – Compensation in Lieu of Replacement – The High Court quashed the FIR against the respondents for alleged cheating in the sale of a defective BMW car, but directed the replacement of the vehicle with a new one. The Supreme Court, noting the prolonged nature of the dispute and the manufacturer’s compliance willingness, directed a compensation payment instead. It held that the High Court’s direction for vehicle replacement was unjustified once it concluded no cheating was established [Paras 1-15].

Exercise of Article 142 – Compensation Awarded – The Supreme Court invoked Article 142 to grant substantial justice by directing the manufacturer to pay Rs 50 lakhs to the complainant, considering the vehicle’s depreciation and the refusal to accept a replacement. The court emphasized the need for practical resolutions to long-pending disputes [Paras 12-14].

High Court’s Order – Quashing Justified, Replacement Unwarranted – While agreeing with the quashing of the proceedings due to insufficient evidence of cheating, the Supreme Court found the High Court’s direction for replacement incongruous and instead settled the matter with a compensation directive [Paras 10-15].

Decision – Appeals Disposed Of – Held – The High Court’s order for quashing the complaint is sustained; however, its direction for replacing the vehicle is set aside. The manufacturer is directed to pay Rs 50 lakhs to the complainant by August 10, 2024. Compliance with this payment will render all claims satisfied [Para 15].

Criminal Law – Abetment of Suicide – Appeal against High Court order dismissing revision application against Trial Court’s refusal to discharge – Allegations of harassment and physical abuse by wife leading to husband’s suicide – No proximate link established between alleged conduct and suicide – Essential ingredients of instigation or active role in abetment not proved – Appeal allowed, discharge application granted [Paras 1-15].

Section 306 IPC – Instigation and Abetment – Explanation of essential ingredients of instigation and intentional aid under Section 306 read with Section 107 – Requirement of active role, mens rea, and direct act leading to suicide – No evidence of instigation or active participation by accused wife – High Court order set aside, discharge granted [Paras 7-15].

Marital Dispute and Suicide – Examination of evidence and witness statements – Allegations of physical and mental harassment by wife – Statements from complainant and colleagues of deceased – No substantial evidence supporting the allegations – Arguments by appellant regarding deceased’s alcohol addiction and marital disputes considered – Legal principles reaffirmed [Paras 3-6, 10-13].

Procedural Aspects – Discharge Application – Trial Court and High Court’s rejection of discharge application – Appellate scrutiny of legal standards for discharge under Section 227 Cr.P.C. – Emphasis on absence of prima facie case – Discharge granted [Paras 4, 5, 6].

Decision – Appeal Allowed – Held – Impugned High Court order and Trial Court order rejecting discharge application set aside – Discharge application allowed [Para 15].