Criminal Law  – Suo Motu Revision – Conviction Beyond Trial Court Charges – High Court, during appeal by accused challenging conviction under Sections 354 and 448 IPC, exercised suo motu revision and convicted him under Section 306 IPC – No appeal or revision had been filed by State or victim – Held: High Court exceeded its jurisdiction – Revisional power under Section 401 CrPC cannot be exercised to convert acquittal into conviction or enhance sentence in an appeal filed solely by the accused [Paras 6–7, 15–16].

Criminal Appeal – Scope of Appellate Powers – Section 386 CrPC – Appellate Court cannot enhance sentence in appeal filed by accused – Expression “but not so as to enhance the same” under Section 386(b)(iii) CrPC bars such enhancement – Held: Appeal by accused cannot result in worse outcome – Principle of “no reformatio in peius” applies – High Court erred in awarding stricter sentence while deciding accused’s appeal [Paras 9–11, 13–14].

Natural Justice – Right Against Prejudice in Appeal – Appellate remedy must not operate to the prejudice of appellant – Doctrine of fairness and equity demands that a person should not be put in a worse position for availing legal remedy – Held: High Court’s action violated natural justice and fundamental fairness – Conviction under Section 306 IPC unsustainable [Paras 10–11, 14].

Appellate Law – No Reformatio in Peius – Protection Against Harsher Outcome – Principle of “no reformatio in peius” prohibits appellate or revisional courts from worsening the position of an appellant when the appeal is filed solely by the accused – High Court’s action in convicting the appellant for a graver offence (Section 306 IPC) in his own appeal violated this doctrine – Held: Accused cannot be penalized merely for exercising his statutory right of appeal – Such action undermines fair trial principles and judicial propriety [Paras 10–11].

Precedents – Binding Effect – Application of Ratio in Sachin v. State of Maharashtra – Supreme Court followed binding precedent in Sachin v. State of Maharashtra, Crl. Appeal Nos. 2073–2075 of 2025 – Clarified that appellate courts cannot invoke revisional powers while deciding appeals filed by accused to enhance sentence or add fresh conviction without any corresponding appeal by prosecution [Paras 9–10].

Decision – Appeal partly allowed – Conviction and sentence under Section 306 IPC set aside – Conviction under Sections 354 and 448 IPC affirmed – Appellant to undergo sentence and fine as imposed by Trial Court – High Court’s enhancement of sentence quashed [Paras 16–17].

Labour Law – Section 25-O, 39 of the Industrial Disputes Act, 1947 - Industrial Closure – Deemed Closure – Appellants, Harinagar Sugar Mills Ltd. (HSML), were engaged in biscuit manufacturing solely for Britannia Industries Limited (BIL) for over three decades – Following termination of the Job Work Agreement by BIL effective 27.11.2019, HSML applied for permission to close business under Section 25-O of the Industrial Disputes Act, 1947 – Application dated 28.08.2019 was not acted upon within statutory period – Authorities failed to communicate any order within 60 days – Held: Deemed closure under Section 25-O(3) took effect [Paras 3.4, 3.6, 8, 18].

Administrative Law – Validity of Orders – Competent Authority – High Court had accepted communication dated 25.09.2019 by Deputy Secretary as valid refusal order – Supreme Court held Deputy Secretary had no authority under Section 25-O – Minister was the ‘appropriate Government’ – No delegation to Deputy Secretary shown – Office file noting by Minister endorsing subordinate's comment is not valid ‘order’ without reasons and application of mind – Internal notings lack legal sanctity unless formally communicated and reasoned [Paras 15–17].

Constitutional Law – Right to Business – Freedom to Close Business – Article 19(1)(g) includes right to shut down business – Industrial Disputes Act imposes reasonable restrictions – Court emphasized that freedom under Article 19 must be balanced with statutory provisions – Section 25-O provides procedure ensuring both employer's and workers' rights are considered – However, lack of action by competent authority within statutory period cannot fetter business freedom [Paras 10–13, 19].

Compensation – Interim Relief – During proceedings, appellants deposited Rs. 4 Crores – Offered additional Rs. 10 Crores ex gratia compensation – Supreme Court enhanced this to Rs. 15 Crores – Directed distribution among eligible workers within 8 weeks – Also clarified gratuity dues (~Rs. 4 Crores) are separate and payable in addition [Paras 23–24].

Decision – Appeal allowed – High Court judgment set aside – Deemed closure under Section 25-O(3) affirmed – Communication by Deputy Secretary held without jurisdiction – Minister's passive endorsement not valid ‘order’ – Additional compensation of Rs. 15 Crores to be paid to workers.

Criminal Law – Cruelty under Section 498A IPC – Challenging The High Court's Reversal Of  Discharge - Lack of Specific Allegations – FIR lodged by complainant-police officer alleged cruelty and dowry demands by husband and in-laws – Allegations against in-laws, including five sisters and a tailor, were vague and lacked specific incidents – No medical or documentary evidence to support claims – Held: Allegations were omnibus, unsupported by material evidence, and appeared implausible – Proceedings unsustainable [Paras 10–13].

Limitation – Cognizance under Section 468 CrPC – Complaint Filed Within Time – Though cognizance was taken on 27.04.2004, complaint was filed on 03.07.2002 regarding incidents in 1999 – Supreme Court reiterated that limitation is computed from date of filing complaint, not date of cognizance – Held: Complaint was within three-year period under Section 468; Sessions Court erred in holding case time-barred [Paras 14–18].

Judicial Process – Discharge by Sessions Court – Erroneous Assumptions – Sessions Court discharged accused based on complainant’s status as a police officer, presuming she could not be a victim – Supreme Court held this reasoning was flawed and prejudicial – Victim’s profession cannot be basis to assume absence of cruelty – High Court rightly rejected such assumptions [Paras 12–13].

Misuse of Legal Provisions – Roping in Extended Family – Supreme Court expressed concern over growing misuse of Section 498A by including distant relatives without basis – Allegations against elderly in-laws and non-family individuals lacked specificity – Cited earlier precedents cautioning against such practice – Held: Discharge justified due to absence of prima facie case [Paras 10, 13].

Decision – Appeals allowed – FIR No. 1098/2002 dated 19.12.2002 and Chargesheet dated 27.04.2002 quashed in exercise of Article 142 of the Constitution – No prima facie case made out – Proceedings against appellant and co-accused terminated [Paras 19–20].

Criminal Law – Section 302, 201, 34 of the Indian Penal Code, 1860 (IPC) - Murder Conviction – Acquittal – Appellant Vaibhav accused of killing friend Mangesh using his father’s service pistol – Trial Court convicted under Sections 302, 201 IPC and Section 5 read with 25(1)(a) of Arms Act – High Court upheld conviction relying on circumstantial evidence and conduct of appellant post-incident – Supreme Court held: Circumstantial evidence not conclusive – Alternative theory of accidental death probable – Chain of circumstances incomplete – Acquittal granted under Sections 302 IPC and Arms Act – Conviction under Section 201 IPC sustained with sentence reduced to period already undergone [Paras 3, 4, 14, 15, 29].

Evidence – Circumstantial Evidence – Standards of Proof – No direct evidence of shooting – Appellant admitted to removing body and cleaning crime scene – Supreme Court held: Subsequent conduct (under Section 8 Evidence Act) may raise suspicion but cannot substitute proof – Failure to explain conduct not enough to shift burden – Prosecution must establish guilt beyond reasonable doubt before relying on accused’s silence or behavior – Benefit of doubt must go to accused when two plausible theories exist [Paras 16-18, 21-22, 28].

Medical Jurisprudence – Bullet Trajectory – Defence of Accidental Death – PW-9 (Doctor) did not confirm whether death was homicidal or accidental – Bullet entered through eye and exited downward but hit ventilator above – Inconsistency in trajectory unexplained by prosecution – Supports defence theory that deceased accidentally shot himself while examining pistol from close range – Supreme Court found this version more consistent with medical evidence than prosecution’s [Paras 17-20].

Motive – Relevance in Circumstantial Evidence – No evidence of enmity or ill-will between appellant and deceased – Friends by all accounts – Supreme Court held: Absence of motive in circumstantial evidence case is significant and must weigh in favour of accused – Cannot be overlooked when chain of evidence is otherwise weak [Paras 23-25].

Evidentiary Standard – Preponderance of Probability vs. Beyond Reasonable Doubt – Defence needs only to show reasonable possibility – Prosecution must eliminate all doubt – Failure to explain inconsistencies in chain of events and bullet path fatal – Courts below erred by shifting burden prematurely to accused – Held: Appellant’s explanation plausible; prosecution’s burden not discharged [Paras 22, 26–27].

Decision: Appeal allowed in part – Conviction under Section 302 IPC and Section 5/25(1)(a) Arms Act set aside – Conviction under Section 201 IPC upheld – Appellant sentenced to period already undergone – Appeal disposed [Paras 29-30].

Civil Law – Agricultural Land Transfer – Invalid Sale – Suit land originally ancestral property of plaintiff – Plaintiff, member of Co-operative Society, obtained a loan creating charge on land – Later executed registered Sale Deed dated 02.11.1971 in favour of defendant no.1 (his nephew and son-in-law) without society’s prior sanction – Same day, executed informal reconveyance deed (“Ram Ram Patra”) – Defendant no.1 later sold part of land to defendant no.2 on 15.07.1972 – Plaintiff filed suit seeking reconveyance and possession – Trial Court decreed suit – High Court reversed – Supreme Court upheld High Court judgment – Held: Sale Deeds executed during subsistence of society’s charge are voidable at society’s instance, not void ab initio – Plaintiff, having himself breached statutory bar under Sections 47 and 48 of Maharashtra Co-operative Societies Act, 1960, cannot take benefit of his own wrong – Reconveyance deed held invalid due to lack of registration, indefinite repayment terms, and no proof of tendering amount [Paras 1, 4-7, 9-14, 18-33].

Co-operative Society Charge – Legal Effect – Plaintiff had created charge on suit land by declaration to society – Section 48(d) bars alienation without repaying loan – Alienation in violation of Section 48(e) held “void” only at instance of society – Society never challenged Sale Deeds – Later accepted repayment and released charge – Held: Statutory provision is directory to extent that only society can invoke nullification – Transaction, though illegal initially, becomes legally immune post charge release – Plaintiff cannot assert its invalidity [Paras 20-26].

Doctrine of Void vs Voidable Transactions – Applicability – Sale without society’s sanction deemed void under statute – However, Court distinguished between “void” (nullity ab initio) and “voidable” (valid until avoided) – Emphasized that unless society challenges alienation, transaction remains effective – Plaintiff, being the wrongdoer, estopped from seeking relief under ex injuria sua nemo habere debet – Held: Plaintiff cannot claim transaction to be void and also seek reconveyance based on same [Paras 24-25, 32].

Conditional Sale and Reconveyance – Validity – Plaintiff relied on “Ram Ram Patra” (informal deed) to claim conditional sale – Deed was unregistered, not on stamp paper, lacked repayment terms, interest, or timeline – Court held it lacked legal enforceability – Also, plaintiff failed to prove any demand or tender of Rs. 5,000 to invoke reconveyance – Held: Deed insufficient to prove sale was conditional – Registered Sale Deed held to be outright and unconditional [Paras 28-30].

Bonafide Purchaser – Defendant No.2’s Status – Defendant no.2 purchased land on 15.07.1972 based on registered Sale Deed – Plaintiff claimed land undervalued, but failed to prove market rate – Defendant no.2 had no knowledge of “Ram Ram Patra” – Held: Defendant no.2 is bonafide purchaser for value without notice – Plaintiff’s claims rightly rejected by lower courts [Paras 27, 31].

Decision: Appeal dismissed – High Court's judgment upheld – Plaintiff’s suit for possession and reconveyance rejected – No costs awarded – Reconveyance deed and claim of conditional sale not accepted – Plaintiff estopped from taking benefit of own breach of statutory bar under Co-operative Societies Act.

Civil Law - Industrial Land Allotment – Cancellation by UPSIDC – Appeal dismissed – Kamla Nehru Memorial Trust challenged UPSIDC’s cancellation of land allotted for floriculture – Court found that the appellant defaulted in payments, failed to execute lease deed, and did not comply with agreed conditions – UPSIDC followed due procedure including multiple legal notices – Cancellation upheld as lawful and justified [Paras 3-4, 14-26, 35].

Frustration of Contract – Non-demarcation and Possession Claims – Not Sustained – Appellants alleged that UPSIDC failed to hand over demarcated land and caused delay – Court held that the land was demarcated in 2005 and acknowledged by the appellant – Possession could only follow execution of lease deed, which the appellant failed to perform – No frustration of contract found [Paras 9-17].

Procedural Compliance – Legal Notice Requirement under Clause 3.04 – Satisfied – Appellant argued that three legal notices were not issued as required by the Manual – Supreme Court held that communications from 2004, 2005, and 2006 constituted valid legal notices conveying default, liability, and consequence – Procedural fairness upheld – No prejudice caused by lack of “legal notice” label [Paras 18-24].

Chronic Default – Failure to Pay and Seek Concessions – Held Unjustified – Repeated requests by appellant for interest waiver and rescheduling reflected deliberate avoidance of obligations – Dues unpaid for years despite rescheduling – Court held that persistent default undermined contractual integrity and justified cancellation [Para 25].

Public Trust Doctrine – Industrial Land Allotment – Application to UPSIDC – Court invoked public trust doctrine to critique hasty allotment without competitive process – Emphasized that public resources must be allotted with transparency, due diligence, and in furtherance of public purpose – Directed State to ensure future allotments uphold constitutional and public trust norms [Paras 27-34, 38].

Illegal Reallotment – Cancellation of Allotment to Private Company – UPSIDC’s allotment of same land to M/s Jagdishpur Paper Mills Ltd. during litigation was held contrary to public policy – Reallotment annulled – Any money received to be refunded with interest [Para 36].

Conclusion and Directions – Appeal dismissed – UPSIDC’s cancellation upheld – State directed to adopt transparent and fair procedure for all future land allotments – Subject Land to be reallotted only through such procedure [Paras 35, 37-39].

Decision: Appeal dismissed – Allotment cancellation upheld – Further reallotment declared illegal – Directions issued to ensure transparency in future public resource allocations.

Criminal Law – Murder - Sections 302, 404 IPC – Appeal Against Conviction - Circumstantial Evidence – Five Golden Principles – Sharad Birdhichand Sarda principles reiterated – Guilt must be fully established by conclusive circumstances – Chain of evidence must exclude every other hypothesis except guilt of the accused [Paras 6.1-6.2].

Murder Trial – Last Seen Theory – Deceased last seen with accused night before body found – Supported by credible testimony of PW-5, PW-11, PW-12 – Testimony of hostile witnesses partly relied upon where consistent – Time lapse of 3 days not fatal where death timeline supported by medical opinion – Held: Last seen theory convincingly established [Paras 10.5-10.5.9].

Forensic and Ballistic Link – Weapon Recovered at Instance of Accused – D.B.B.L. gun bore signs of discharge and matched spent cartridges – Pellets and wads found in skull could be fired from gun – Ballistic and medical evidence consistent with prosecution case – Held: Forensic link strongly corroborates guilt [Paras 10.6-10.7.3].

Recovery of Articles – Mobile and Gold Chain Belonging to Deceased – Recovered at instance of accused – Shopkeeper identified transaction – Chain recovered from accused – Recovery admissible and corroborative [Paras 6.12, 7.6, 10.6.2].

Abscondence and Misleading Conduct – Accused absconded from 11.07.2006 to 22.07.2006 – Attempted to mislead family and friends – Indicative of guilty mind – Relevant corroborative conduct under Section 8 of Evidence Act [Paras 6.10, 7.3, 9.5].

Motive – Loan of Rs. 4000 and Insult – Though motive held not fully established, conviction not vitiated – Absence of motive not fatal when other circumstantial evidence is strong – Held: Motive not essential if guilt proven otherwise [Paras 6.6, 7.1, 10.6.1].

Decision – Appeal Dismissed – Conviction under Sections 302 and 404 IPC and Arms Act confirmed – Held: All links in circumstantial chain established beyond reasonable doubt – No perversity or illegality in concurrent findings of lower courts – Interference under Article 136

Environmental Law – Urban Redevelopment – Recreational Park vs. Historical Water Body – Appeal allowed – High Court had directed restoration of a lake allegedly obliterated due to a beautification project by MCGM – Supreme Court found no conclusive evidence that the water body was functional at the time of redevelopment – Held: Transformed urban green space offers significant public and ecological benefit – Restoration would cause more environmental harm – Directions issued for future ecological balance [Paras 2-4, 9, 13-20].

Public Trust Doctrine – Scope and Application – High Court relied heavily on public trust doctrine to direct restoration – Supreme Court held that while public trust doctrine obliges protection of environmental resources, it must be harmonized with sustainable development and practical realities – One public utility transformed into another which continues to serve the community – Doctrine does not require mechanical restoration when doing so harms current public interest [Paras 10-13].

Ecological and Social Utility – Recreational Park as Urban Oasis – The park, with matured trees and recreational facilities, has become vital to the community’s health, leisure, and biodiversity – Demolition would result in felling of trees, loss of Rs. 5 crore public funds, and risk of creating a stagnant water body prone to disease – Supreme Court found the transformed ecological value of the park outweighed theoretical restoration of the lake [Paras 14-17].

Post-Facto Sanction – Legal Effect – Collector’s 2014 sanction characterized by High Court as contradictory and ineffective – Supreme Court noted that even if sanction was irregular, the overriding issue is current utility and irreversible transformation – Sanction’s rider limiting land use to recreation provides legal safeguard against future misuse [Para 18].

Delay and Fait Accompli – Belated Environmental Challenge – Writ Petition filed nearly five years after commencement and one year post-completion – Delay considered fatal – Court held that delayed challenges to environmental change, after substantial transformation and public reliance, cannot justify restoration that may now be counterproductive [Para 19].

Conclusion and Directions – Final Relief – High Court judgment set aside – MCGM directed to: (i) maintain park in perpetuity as public green space; (ii) explore creation of alternative water body nearby; (iii) restore other water bodies in the city; and (iv) report compliance biannually for 3 years – State Government free to implement further environmental initiatives in the region [Paras 21-22].

Decision: Appeal allowed – High Court’s order directing demolition and restoration of lake set aside – Directions issued for ecological compensation and preservation of current green space.

Criminal Law - Bail Cancellation – Post-Election Violence – Grave Offences – Bail Revoked - Accused were granted bail by High Court despite serious allegations of violent attack, house vandalism, and attempted sexual assault linked to political vendetta – Supreme Court held that the allegations were grave enough to shake the conscience of the Court and cast doubt on the fairness of trial if accused were on bail – Held: High Court's orders granting bail set aside [Paras 3, 14, 20-21].

Failure of Local Police – FIR Registered Only After Judicial Intervention – CBI Directed to Investigate - Victim’s complaint of politically motivated violence was initially suppressed by local police – FIR registered only after High Court directed CBI investigation – Held: Delay and obstruction by local authorities lends credence to allegations and underscores accused’s influence [Paras 4-6, 14-16].

Trial Obstruction – Delay Due to Accused’s Non-Cooperation – Bail Misused - Trial had not progressed due to repeated non-appearance of accused – CBI submitted that accused were actively interfering with judicial process – Held: Non-cooperation of accused necessitated cancellation of bail [Paras 9-10, 19].

Democratic Process – Targeted Violence – Threat to Democracy – Bail Denied - Supreme Court condemned the attack as a direct assault on democratic rights, carried out with the intent to terrorize opposition supporters – Held: Conduct and objective of the accused showed vengeful suppression of political dissent, undermining rule of law [Paras 17-18].

Directions for Expedited Trial – Witness Protection Ordered – Trial to be Concluded in 6 Months - Supreme Court directed trial court to conclude proceedings within six months – State authorities directed to ensure safety of complainant and witnesses – Held: Any obstruction to these directions may be reported directly to the Court [Para 22].