Criminal Law – Caste-Based Discrimination in Prisons – Caste-Based Allocation of Prison Labour – Violation of Constitutional Rights – The petitioner, Sukanya Shantha, sought to challenge caste-based discrimination in prison manuals and their provisions, which prescribed labour and prison duties based on caste identity – Supreme Court held that several provisions of prison manuals in different states were unconstitutional for violating Articles 14, 15, 17, 21, and 23 of the Constitution – The impugned provisions were found to perpetuate caste-based labour divisions, thereby reinforcing historical patterns of discrimination against marginalized castes and denotified tribes [Paras 171, 172, 196].

Prison Manual Rules – Direct and Indirect Discrimination – Provisions such as requiring marginalized castes to perform menial tasks like cleaning and sweeping were found to directly discriminate against them – Phrases such as “suitable caste” and “accustomed to such duties” were held to indirectly perpetuate caste-based discrimination – The court held that such rules reinforced caste hierarchies and deprived prisoners of dignity and equal treatment in violation of constitutional principles [Paras 170, 173, 174, 177].

Constitutional Provisions – Classification and Discrimination – The Supreme Court reiterated that caste cannot be a valid principle of classification unless used to uplift marginalized communities – Caste-based classifications in prison manuals for labour, food preparation, and segregation of prisoners were declared unconstitutional, as they lacked rational nexus with prison reform and discipline and violated substantive equality under Article 14 [Paras 161-170].

Habitual Offender Provisions – Discrimination Against Denotified Tribes – The provisions in various prison manuals defining “habitual offenders,” especially targeting denotified tribes, were struck down – The Court emphasized that labeling members of certain communities as “habitual criminals” based on vague and broad definitions perpetuates systemic discrimination – States were urged to reconsider their habitual offender laws in line with constitutional mandates [Paras 213-219].

Forced Labour – Article 23 Violation – Imposing certain types of work, considered degrading, upon prisoners based solely on their caste was held to be forced labour under Article 23 – The court emphasized that assigning menial jobs to marginalized caste inmates without their consent constituted a form of coercion and violated their constitutional rights [Paras 189-195].

Judicial Directions – The Court directed all states and Union Territories to revise their prison manuals within three months to eliminate caste-based discrimination – The Union government was ordered to amend the Model Prison Manual, 2016, and the Model Prisons and Correctional Services Act, 2023, to address caste-based discrimination – The court also mandated regular inspections by legal aid authorities to ensure compliance and prevent discriminatory practices inside prisons [Paras 231-232].

Decision: Writ petition disposed of – Provisions declared unconstitutional – Compliance reports to be filed within three months [Para 232].

Taxation Law – Power to Levy Tax – Quasi-Judicial Function – The power to levy tax is a sovereign function, but its exercise must conform to constitutional provisions like Article 265, which mandates that taxes can only be levied or collected by law – Article 265 distinguishes between “levy” and “collection,” where levy includes both imposition and assessment – Assessment is a crucial element in taxation, encompassing computation, imposition, and recovery of tax – Held, the assessment process is a quasi-judicial function requiring fairness and impartiality in determining tax liability [Paras 21-24].

Quasi-Judicial Function – Reassessment and Vested Rights – Once an assessment is made, it creates vested rights for the taxpayer – Reassessment, which vacates the original assessment and substitutes it with a fresh order, is a quasi-judicial act – The assessing officer's role is to prevent tax evasion but must ensure fairness and adherence to law, as outlined in CIT v. Simon Carves Ltd. – Held, any reassessment must be preceded by proper legal procedures, including obtaining necessary sanctions and giving notice to the taxpayer [Paras 25-27].

Jurisdiction – Time Limits for Reassessment – Under Section 34 of the Income Tax Act, 1922, reassessment is subject to time limits – Notices issued beyond the prescribed time are invalid – The Supreme Court in S S Gadgil v. Lal & Co. affirmed that statutory time limits on reassessment are jurisdictional bars and cannot be waived – Any reassessment notice issued beyond these limits is without jurisdiction and void [Paras 28-29].

Interpretation of Taxing Statutes – Strict Construction – Taxing statutes must be interpreted strictly according to their plain meaning – Courts cannot expand or assume legislative intent beyond the statute's language – In case of ambiguity, the interpretation favoring the taxpayer should be adopted – However, while the charging provisions are to be strictly interpreted, machinery provisions are construed to give effect to the legislative intent, ensuring the statute remains workable [Paras 33-37].

Harmonious Construction – Conflict between Provisions – In case of conflict between provisions of the same or different statutes, courts must adopt a harmonious construction to reconcile both provisions – A non-obstante clause can give overriding effect to a particular provision but must be limited to the extent intended by the legislature – Implied repeal is applied only when two statutes are irreconcilable, and the later law is presumed to repeal the earlier by implication [Paras 39-44].

Reassessment under New and Old Regime – Section 149 of the Income Tax Act – The new regime reduced the time limit for issuing reassessment notices from four to three years, and extended the time limit to ten years for cases where income escaping assessment exceeds INR 50 lakhs – The Court held that notices issued after 1 April 2021 under the old regime are deemed to be issued under the new regime, and any reassessment notice exceeding the new regime's limits must be dropped [Paras 45-53].

Effect of TOLA (Taxation and Other Laws Act) – TOLA was enacted in response to the COVID-19 pandemic to relax time limits for compliance with statutory obligations – The Supreme Court held that TOLA extends the time for issuing reassessment notices under Section 148 till 30 June 2021 – Therefore, any notices issued before this extended time are valid, but notices issued beyond the surviving period are time-barred and invalid [Paras 54-67].

Sanction for Reassessment – Requirement under Section 151 – The Court emphasized that obtaining prior sanction from the specified authority is a mandatory precondition for issuing reassessment notices – The requirement under the new regime stipulates higher authority for approvals, ensuring procedural fairness – Any notice issued without this sanction is void and without jurisdiction [Paras 73-76].

Conclusion – The reassessment notices issued under the old regime between 1 April 2021 and 30 June 2021 are deemed as notices under the new regime – Any reassessment notice exceeding the prescribed time limits, as extended by TOLA, is invalid and must be set aside – Appeals allowed for the Revenue, and reassessment notices must be issued within surviving time limits where applicable [Paras 114-118].

Criminal Law – Murder Conviction – Partial Acquittal – Two separate criminal appeals were heard together – Appellants accused of killing two victims, Brij Bihari Prasad, a legislator, and his bodyguard, at IGIMS hospital, Patna – Trial court had convicted the appellants for offences under Sections 302 and 307 IPC – High Court acquitted several accused, finding inconsistencies in the prosecution's case, particularly with respect to key witnesses and the timing of the FIR – Supreme Court upheld the conviction of two appellants, Mantu Tiwari and Vijay Kumar Shukla @ Munna Shukla, while acquitting others on the basis of insufficient evidence and benefit of the doubt – Held: Conviction under Sections 302 and 307 IPC restored against Mantu Tiwari and Vijay Kumar Shukla [Paras 43-44].

Witness Testimony – Credibility and Hostility – Key prosecution witnesses included Paras Nath Chaudhury (PW-1), Mahant Ashwani Das (PW-25), and Amarendra Kumar Sinha (PW-10) – Paras Nath's testimony was crucial, but High Court had disbelieved it on account of contradictions and his relationship to one of the deceased – The Supreme Court, however, held that the inconsistencies were not significant enough to dismiss his entire testimony – Several other witnesses, including Amarendra Kumar Sinha, turned hostile but their core testimonies were deemed credible in parts – Held: Indian law does not follow the doctrine of "falsus in uno, falsus in omnibus" (false in one thing, false in everything), and reliable portions of testimony should be accepted [Paras 16, 22].

Circumstantial Evidence – Non-Recovery of Vehicles and Weapons – Eyewitnesses had identified the vehicles used by the assailants but the vehicles and weapons, including the carbine of the deceased bodyguard, were not recovered – Prosecution's failure to recover the weapons was deemed insufficient to undermine the credibility of the eyewitnesses, as the facts and circumstances of the case strongly supported their testimonies – Held: Non-recovery of weapons does not necessarily negate guilt in light of strong corroborative evidence [Paras 27-29].

Conspiracy Charge – Insufficient Evidence – Prosecution alleged a criminal conspiracy involving several of the accused, including Suraj Bhan Singh and Ram Niranjan Chaudhary, based on a purported jail meeting – However, the main witnesses to the conspiracy turned hostile and there was no corroborative evidence – Phone records and testimony related to a post-incident celebration were also found insufficient to substantiate the conspiracy charge – Held: Acquittal of the accused on conspiracy charges upheld due to lack of substantive evidence [Paras 36-39].

Decision: Convictions restored for Mantu Tiwari and Vijay Kumar Shukla under Sections 302 and 307 IPC – Life imprisonment affirmed – Acquittal of others upheld due to insufficient evidence and benefit of the doubt [Paras 43-44].

Criminal Law – Quashing of Charges – Appellant arraigned for offences under Section 120B IPC and Section 12 of the Prevention of Corruption Act, 1988 – Accused No. 13 alleged to have facilitated transfer of ₹50 crores through his company M/s Cornerstone Property Investments Pvt. Ltd. – High Court upheld the charges against him – Supreme Court quashes proceedings against the appellant due to insufficient material to implicate him directly – Held: Appellant’s company not arrayed as an accused, and no evidence showing his involvement in conspiracy or personal benefit – Case against him amounts to a travesty of justice [Paras 10, 12]​.

Conspiracy and Corruption – Alleged Routing of Funds – Appellant, as Managing Director of M/s Cornerstone Property Investments Pvt. Ltd., allegedly facilitated the transfer of ₹50 crores from Accused No. 3's company to three shell companies – Prosecution contends funds were routed as bribe money benefitting Accused No. 1’s company (M/s Jagati Publications Pvt. Ltd.) – Supreme Court finds no material implicating the appellant in these companies or transactions – Absence of key accused, including companies involved, weakens the case against the appellant [Paras 5, 10]​.

Corporate Liability – Non-Arraignment of Company – Appellant’s company not made a party to the chargesheet despite being the alleged vehicle for routing illegal funds – Supreme Court refers to precedents (Sunil Bharti Mittal, SK Alagh) emphasizing that a director cannot be prosecuted without arraigning the company unless clear material implicates the individual – No material here to suggest appellant's involvement in criminal conspiracy beyond acting in a professional capacity [Paras 10, 12]​.

Decision: Appeal allowed – Proceedings quashed against the appellant – Supreme Court clarifies its decision has no bearing on ongoing proceedings against other accused, including Accused Nos. 1, 3, and 14, involved in the alleged conspiracy​.

Environmental Law – Air Pollution – Implementation of Directions – CAQM's Failure to Enforce Orders – The Supreme Court reviewed the compliance report submitted by the CAQM on the enforcement of directions issued regarding stubble burning and air pollution control. Despite the issuance of multiple directions, including one on 10th June 2021 and another on 12th April 2024, the Court found that neither the State of Haryana nor the State of Punjab had effectively implemented these orders. The CAQM had also failed to follow up on its own orders or initiate prosecutions under Section 15 of the Environment (Protection) Act, 1986 [Paras 7-14].

Stubble Burning – Ineffective Monitoring and Enforcement – The Court noted the high number of illegal stubble burning incidents between 15th and 30th September 2024 (129 in Punjab and 81 in Haryana) and criticized the nominal compensation recovered from violators. The lack of effective monitoring and enforcement was evident from the minimal actions taken by the authorities [Paras 10-12].

Appointment of Experts – CAQM – Lack of True Experts – The Court raised concerns regarding the qualifications of the expert members in the CAQM. It warned that if the appointed experts were found to lack requisite qualifications, it may invoke its powers under Article 142 of the Constitution to appoint additional experts in the field of air pollution. The Central Government was directed to clarify the expertise of three independent technical members and the qualifications of the Chairperson under Section 3(2) of the CAQM Act [Paras 14-17].

Decision:

The State Governments of Punjab and Haryana were directed to file affidavits regarding their compliance with the CAQM’s directions within ten days. The Central Government was asked to submit explanations on the expertise of CAQM members and the vacancy of NGO members. The matter was listed for further hearing on 16th October 2024.

Criminal Law – Abetment of Suicide – Section 306 IPC – Insufficient Evidence for Abetment – The appellants, senior officers of Hindustan Lever Ltd., were accused of harassing the deceased, Rajeev Jain, by coercing him into accepting a voluntary retirement scheme. The deceased allegedly committed suicide following a meeting where he was humiliated. The Supreme Court held that there was no direct or proximate incitement by the appellants to drive the deceased to suicide. Mere workplace pressure or demotion does not constitute abetment unless it directly instigates the act of suicide. The appeal was allowed, and the criminal proceedings were quashed [Paras 6-10, 16].

Application of Section 306 IPC – Requirements of Instigation or Conspiracy – The Court emphasized that to convict someone under Section 306 IPC, there must be evidence of instigation or conspiracy leading to suicide. General workplace disagreements or negative performance feedback do not meet the legal threshold for abetment of suicide [Paras 12-15].

Abuse of Process – Quashing of Proceedings – The Supreme Court noted that the prosecution was an abuse of legal process as no clear mens rea for abetment of suicide was demonstrated by the prosecution. The proceedings against the appellants were quashed as they would lead to unnecessary harassment without a plausible link between the appellants' actions and the suicide [Paras 19-21].

Decision:

Appeal allowed – Criminal proceedings against the appellants quashed.

Quashment of Proceedings – Section 120B IPC and Prevention of Corruption Act – Lack of Evidence Against Appellant – The appellant was charged as Accused No. 13 in a case related to a quid pro quo transaction involving public officials and business entities – The High Court refused to quash the proceedings, holding that the contentions raised were matters for trial – Held: Supreme Court quashed the proceedings against the appellant, observing that there was no material evidence connecting the appellant with the alleged conspiracy, beyond his role as Managing Director in a company that transferred funds on behalf of other accused [Paras 1-3, 11-14].

Allegations of Misuse of Official Position and Quid Pro Quo Transactions – The appellant allegedly facilitated transfer of funds through his company, M/s Cornerstone Property Investments Pvt. Ltd., on behalf of Accused No. 3, which were ultimately received by a shell company owned by Accused No. 14 – Supreme Court found that the appellant had no personal involvement or benefit from the transactions and that his company was not implicated as an accused – Held: Allegations of facilitation through appellant's company did not suffice to implicate him personally in criminal conspiracy [Paras 4-6, 15].

Failure to Array Necessary Accused Parties – Absence of Direct Involvement of Appellant – The prosecution failed to array companies involved in the transaction as accused parties, including companies that routed funds ultimately reaching Accused No. 14 – Appellant argued that he could not be charged individually without his company being implicated – Supreme Court accepted this contention, noting the lack of material evidence showing appellant’s direct involvement in the alleged transactions – Held: Without implicating the primary entities involved in the transaction, it was improper to prosecute the appellant individually [Paras 7, 11].

No Material Linking Appellant to Conspiracy – Role of Primary Accused – The prosecution primarily accused Accused Nos. 1, 3, and 14 of conspiracy and corruption; however, no substantial evidence was presented to link the appellant with the core conspiracy – The Supreme Court ruled that continuation of proceedings would be a "travesty of justice" given the absence of material to implicate the appellant – Held: Appeal allowed, and proceedings against the appellant were quashed [Paras 12, 13, 16].

Decision – Appeal Allowed – Proceedings Quashed – The Supreme Court set aside the impugned High Court judgment and quashed the proceedings against the appellant alone – This decision does not impact the trial against other accused, which is allowed to proceed independently.

Criminal Law – Abetment of Suicide – Appeal Allowed – Appellants, senior employees of Hindustan Lever Ltd, were accused of abetting the suicide of their colleague, Rajeev Jain, by allegedly harassing and humiliating him due to his refusal to accept a Voluntary Retirement Scheme (VRS) – High Court dismissed their plea to quash the criminal proceedings under Section 306 of the IPC – Supreme Court evaluated the standards for abetment of suicide, referencing previous rulings on instigation under Section 107 IPC and found insufficient grounds to conclude that the appellants’ actions constituted abetment to suicide – Held: Proceedings against the appellants quashed as an abuse of process, allowing the appeal [Paras 1-26].

Evidence and Witness Testimony – Credibility and Relevance of Statements – High Court relied heavily on statements from colleagues of the deceased, Sudhir Kumar Ojha and Jayant Kumar Ghatak, who alleged that the appellants humiliated Jain in a meeting, pressuring him to accept a lower position – Supreme Court observed that mere allegations of workplace harassment without a direct intent to provoke suicide do not satisfy the legal criteria for abetment under Section 306 – Statements of the colleagues did not sufficiently establish that appellants’ conduct amounted to instigation or compelling pressure as required by law [Paras 10, 13-16, 22].

Legal Interpretation – Abetment Under Section 306 IPC – Necessary Mens Rea and Direct Instigation – Supreme Court reiterated that for an abetment charge to hold, there must be a clear intention to incite suicide, with direct or indirect incitement – Citing Geo Varghese v. State of Rajasthan and S.S. Cheena v. Vijay Kumar Mahajan, Court emphasized that mere workplace dissatisfaction or frustration does not constitute abetment, requiring proof of an unequivocal act by the accused to create an unbearable situation for the victim – Court found no direct instigation or evidence of unbearable harassment compelling Jain to commit suicide [Paras 17-20, 23-24].

Decision – Appeal Allowed, Proceedings Quashed – Supreme Court concluded that the High Court erred in dismissing the appellants' plea for quashing proceedings – No prima facie case of abetment under Section 306 IPC was established, as the appellants’ actions did not meet the threshold of instigation – Held: High Court order set aside, and proceedings in Criminal Case No. 11428 of 2007 quashed – Appellants exonerated from charges under Section 306 IPC [Paras 25-26].

Bail Application – Grant of Bail – Sections 377, 498A IPC and Sections 66E, 67A IT Act – Bail Granted - The appellant, who had been incarcerated for nearly one year, was involved in a case filed after a divorce petition, with allegations related to electronic files disputed by him. He sought bail pending trial on charges under Sections 377, 498A, 506, and 34 of the IPC and Sections 66E and 67A of the Information Technology Act. Considering the period of incarceration, the court allowed the bail with conditions, including passport submission and a prohibition on contacting the informant/complainant. Violation of any conditions would result in bail cancellation [Paras 2-5].

Identity Protection – Suppression of Informant's Name – Granted - The identity of the informant/complainant, who is respondent No. 2, will be protected, and her name will be deleted from all court documents, with the original record kept in a sealed cover. The application for identity suppression was allowed [Paras 1, 6].

Appeal Outcome – Bail Granted - The appeal was allowed in terms of the signed order, and the appellant was released on bail pending the trial, with specific conditions related to contact restrictions, social media activity, and submission of travel documents [Para 8].