Criminal Law – Cruelty – Appellant convicted under Section 498A IPC for subjecting his wife to cruelty, leading to her suicide – High Court acquitted appellant under Section 304B IPC but confirmed conviction under Section 498A IPC – Supreme Court examined admissibility of deceased’s statements under Section 32(1) of Evidence Act – Held, evidence of deceased wife regarding cruelty is admissible under Section 32(1) if cause of death comes into question and evidence relates to circumstances of death [Paras 1-28].

Evidence Law – Admissibility of Statements by Deceased – Section 32(1) of Evidence Act – Statements by deceased admissible if they pertain to cause of death or circumstances leading to death – Acquittal under death-related charges does not bar admissibility under Section 32(1) if death cause is in question – Supreme Court clarified scope and applicability, overruling limited extent of previous judgments [Paras 9-23].

Decision: Appeal dismissed – Conviction and sentence under Section 498A IPC upheld – Appellant to surrender within one week to serve remaining sentence [Para 27-28].

Criminal Law – Rape and Murder – Conviction based on circumstantial evidence – Appellant convicted for the offences punishable under Sections 302 and 376(2)(i) IPC and Section 6 of POCSO Act – Death sentence for the offence under Section 300 IPC punishable under Section 302 IPC commuted to life imprisonment without remission for 30 years – Failure to conduct DNA profiling under Section 53A CrPC not fatal if other evidence suffices to form a complete chain of circumstances pointing to the guilt of the accused [Paras 1-31].

Evidence Law – Last Seen Theory – Applicability – Victim last seen with the appellant – Recovery of the victim’s body at the appellant’s instance – Last seen theory strengthens the prosecution’s case when coupled with other incriminating circumstances – Conviction upheld based on credible witness testimonies and corroborative evidence [Paras 32-35].

Decision: Appeal dismissed – Conviction and sentences under Sections 302 and 376(2)(i) IPC and Section 6 of POCSO Act upheld – Death sentence commuted to life imprisonment with a stipulation of no premature release before 30 years [Para 43].

Property Law – Cancellation of Allotment – Default in Installment Payments – Appellant, a 55-year-old woman, allotted a plot under the Middle-Income Group Scheme – Made initial payments but defaulted on four installments due to husband's ill-health – Paid balance with interest before cancellation notice was served – High Court dismissed writ petition challenging cancellation – Supreme Court held that appellant's payments and willingness to pay additional compensation showed no willful delay – Cancellation order set aside on payment of additional Rs. 2 lakhs as compensation [Paras 1-6].

Decision: Appeal allowed – Cancellation order set aside on condition of appellant paying additional Rs. 2 lakhs within six weeks – Respondents to hand over possession and execute necessary documents thereafter [Para 6].

Service Law – Pay Scale – UGC Scale of Pay – Respondent appointed as Librarian-cum-Museum Assistant in an Ayurvedic college sought UGC pay scale as per 1990 Rules – State contended 1990 Rules not applicable as college under Ayush Department – Supreme Court held 1990 Rules applicable to institutions under Higher Education Department, not Ayush Department – Respondent governed by 1987 Rules at appointment and later by 2013 Rules – No parity with librarians under Higher Education Department – High Court orders set aside [Paras 6-23].

Service Law – Equal Pay for Equal Work – Doctrine applicable when employees are similarly circumstanced in every way – Differing eligibility criteria and governing rules preclude application of UGC scales to respondent – Policy decisions on pay scales not interfered with by courts unless discriminatory or arbitrary [Paras 18-20, 24].

Decision: Appeal allowed – High Court's orders set aside – Respondent not entitled to UGC scale of pay [Paras 26-27].

Electricity Law – Captive Generating Plants – Open Access – Appeal by power distribution company against the order of Electricity Regulatory Commission allowing captive power plant to supply electricity to its sister concern – Supreme Court held that the establishment of a captive power plant primarily for own use or for use by an association of persons (including corporate bodies) is permissible under the Electricity Act – Conditions of Rule 3 of the Electricity Rules, 2005 satisfied – No interference warranted with orders of the Regulatory Commission and Appellate Tribunal [Paras 1-26].

Regulatory Framework – Interpretation of Statutory Provisions – Sections 2(8), 9, and 42(2) of the Electricity Act and Rule 3 of the Electricity Rules – Liberal interpretation to promote establishment of captive power plants for reliable and cost-effective power, facilitating industrial growth and employment – Policy under Section 3 of the Electricity Act aligns with the provisions promoting captive power generation [Paras 20-23].

Decision: Appeals dismissed – Orders of the Chhattisgarh State Electricity Regulatory Commission and the Appellate Tribunal for Electricity upheld – No interference warranted [Paras 25-27].

Contempt of Court – Wilful Disobedience – Respondents found guilty of contempt for not complying with Supreme Court and High Court orders – Despite multiple opportunities to settle the dispute or comply, respondents failed – Supreme Court sentenced respondent No. 1 to seven days of simple imprisonment and imposed a fine of Rs. 5 lakhs – Fine to be deposited before the High Court with Rs. 4 lakhs to the petitioner and Rs. 1 lakh to the Maharashtra State Legal Services Authority – Sentence kept in abeyance for two weeks to allow compliance [Paras 1-5].

Decision: Respondent No. 1 sentenced to seven days simple imprisonment and fine of Rs. 5 lakhs imposed on respondents – Sentence suspended for two weeks for compliance [Para 4].

Civil Procedure – Appointment of Commissioner – Order 26 Rule 9 and Rule 11 CPC – Court has wide powers to appoint a commissioner for local investigations to elucidate any matter in dispute or to ascertain the market value of any property, mesne profits, damages, or annual net profits – Commissioners do not perform judicial acts but ministerial acts to aid the court – Court can confirm, vary, or set aside the commissioner's report [Paras 1-26].

Arbitration – Reference to Arbitration – Section 21 of the Arbitration Act, 1940 – For a matter to be referred to arbitration, all parties must agree in writing and apply to the court for an order of reference – Agreement must be explicit and reflect a meeting of minds – Court cannot refer a matter to arbitration based solely on the submission of one party without the explicit agreement of the other [Paras 15-26].

Decision: Appeal Disposed of – Orders of the lower courts set aside – Chartered Accountant’s report treated as a commissioner’s report under Order 26 Rule 11 CPC, not as an arbitration award – Case remanded to trial court for reconsideration of objections to the commissioner’s report [Paras 36-37].

Service Law – Selection – Posts of Constable (General) – Appellant’s application found with incorrect and incomplete information regarding criminal antecedents – Application liable to be rejected at any stage of selection process – Supreme Court held suppression of material information in application form as ground for rejection of candidature [Paras 2-4].

Criminal Antecedents – Disclosure – Misrepresentation – Appellant did not disclose pending FIRs and criminal cases in job application – Court emphasized necessity of honesty in uniformed services – Candidate’s suppression of facts and false statement justified rejection of application [Paras 6.1-6.3].

Judicial Precedents – Relevant Cases – Reference made to past judgments highlighting suppression of material facts and misrepresentation by candidates in service applications – Previous rulings supported the decision to reject candidature based on suppression and dishonesty [Paras 6.4-6.11].

Decision: Appeal allowed – Judgment and order of the High Court quashed and set aside – Rejection of respondent’s candidature for the post of constable upheld [Para 9].

Constitutional Law – Education – Regulation of Fees – Section 87 of Punjab Reorganisation Act, 1966 – Notification requiring unaided educational institutions to disclose income expenditure accounts and balance sheets on their websites and prohibiting them from charging any costs from parents – Supreme Court held clause (a) of the notification as substantive and not peripheral, thus ultra vires Section 87 – Clause (b) held consistent with legislative intent and valid [Paras 1-18].

Administrative Law – Power of Government – Notification under Section 87 of Punjab Reorganisation Act, 1966 – Government's power to make peripheral or insubstantial changes – Substantive changes require legislative action – Enhancement of penalty amounts under Section 14 of the 2016 Act struck down as it constituted a substantive change [Paras 9-17].

Decision: Appeals partly allowed – Clause (a) of the notification struck down – Clause (b) upheld – Enhancement of penalty amounts under Section 14 struck down [Paras 21-23].