Civil Law – Land Allocation for School Construction – the legality of land allocation for constructing a school in a village in Azamgarh, previously demolished for a National Highway project. The Court examined the authority of the Land Management Committee and State in deciding land allocation. [Para 3-6, 11-12]

Public Interest Litigation – Misuse and Concealment of Facts – The Court criticized the misuse of Public Interest Litigation by the respondents for personal gains and concealing previous similar petitions, highlighting the need for honesty in legal proceedings. [Para 6-7, 16]

Principles of Natural Justice – Violation by High Court – Held – The Supreme Court found the High Court’s decision to be in violation of the principles of natural justice, as it was made without proper notice to the affected parties and without considering all relevant facts. [Para 11-12, 18]

Judicial Process – Hasty Decisions and Lack of Fair Hearing – Criticized – The Court criticized the High Court's approach in hastily deciding the case and not providing a fair hearing to all parties involved. [Para 11-12, 16-18]

Land Management – Authority and Jurisdiction – The Court examined the scope of authority and jurisdiction of the Land Management Committee and Sub-Divisional Officer in allocating land for public purposes, emphasizing the proper procedure to be followed. [Para 4-5, 11, 18]

Decision – Quashing of High Court Order – The Supreme Court quashed the High Court's order due to its illegality, perversity, and violation of natural justice principles, reinforcing the importance of a fair and unbiased judicial process. [Para 18-19]

Decision – Appeal Allowed – The Court allowed the appeal, emphasizing the significance of adhering to legal standards and the proper administration of justice in public interest cases. [Para 19-20]

Criminal Law – Culpable Homicide – Section 304 Part II of IPC – The Supreme Court modified the conviction of the appellant from Section 302 (murder) to Section 304 Part II (culpable homicide not amounting to murder) of the Indian Penal Code. The Court held that the appellant's act of firing a gun in a crowded place without taking reasonable safety measures, which led to the death of a person, constitutes culpable homicide under Section 299 IPC and is punishable under Section 304 Part II of the IPC. [Para 13-17, 18]

Criminal Law – Culpable Homicide – Distinction between Sections 302 and 304 Part II of IPC – The Supreme Court modified the conviction of the appellant from Section 302 (murder) to Section 304 Part II (culpable homicide not amounting to murder) of the Indian Penal Code (IPC), in a case involving celebratory firing during a marriage ceremony. The court observed the absence of intention to kill and lack of prior enmity, while acknowledging the negligence and recklessness of the appellant in firing a gun in a crowded place. [Para 13-18]

Criminal Procedure – Evidence – Hostile Witnesses – The evidence of multiple eyewitnesses, who were initially supportive of the prosecution's case but later turned hostile during the trial, was considered. Despite their change in testimony, the Court found sufficient grounds to convict the appellant under Section 304 Part II of the IPC based on the totality of circumstances and existing jurisprudence. [Para 8-10, 16-17]

Judicial Precedent – Reliance on Earlier Judgments – The Court referred to its previous decisions in Kunwar Pal Singh v. State of Uttarakhand and Bhagwan Singh v. State of Uttarakhand to establish the legal principles applicable to cases of death resulting from negligent handling of firearms in public gatherings. These precedents were instrumental in determining the appropriate section of the IPC under which the appellant was convicted. [Para 14, 15, 17]Decision – Conviction under Section 302 IPC set aside, conviction for offense under Section 304 Part II IPC established, with a sentence equivalent to the period already undergone; the conviction and sentence under the Arms Act remain unaltered [Para 18-19].

Quashing of FIR – Supreme Court quashed the FIR against the appellants, holding the dispute to be essentially civil in nature and an abuse of criminal process. [Para 10, 14-15, 17-18]

Civil vs. Criminal Proceedings – Distinguished – Emphasized the distinction between civil disputes and criminal proceedings. Observed that a civil dispute should not be disguised as a criminal complaint if a civil remedy is already being pursued. [Para 15-17]

Abuse of Process of Law – Held – Concluded that the initiation of criminal proceedings in a matter predominantly of civil nature constituted an abuse of the process of law. Directed the quashing of the FIR to prevent misuse of the criminal justice system. [Para 16-17]

Validity of Sale Deed – Civil Matter – Recognized that the core issue concerning the validity of the sale deed was a civil matter and thus not justiciable in criminal proceedings. Directed the matter to be resolved through civil litigation. [Para 14, 18]

Direction – Quashing of Criminal Proceedings – Directed the quashing of all criminal proceedings arising out of the FIR, reaffirming that the outcome of this order shall not influence the pending civil suit, which shall be adjudicated as per law. [Para 18-19]

Decision – Appeal Allowed – The appeal was allowed, and all pending applications related to the case were disposed of accordingly. [Para 19-20]

Misbranded Food Articles – Conviction under Prevention of Food Adulteration Act for selling sugar boiled confectioneries without proper labeling as per Rule 32(c) and (f) of the Prevention of Food Adulteration Rules, 1955 – Contention of non-manufacture by appellants rejected due to lack of evidence. [Paras 2, 4-5]

Legal Argument – Appellants' counsel contended that provisions under Rule 32 (c) and (f) were not applicable, but the court affirmed their relevance at the time of the offense. [Paras 6-7]

Constitutional Application – Reference to Article 20(1) of the Constitution – Court emphasized that no person can be subjected to a greater penalty than that applicable at the time of the offense but can benefit from a lesser penalty under new legislation. [Para 8]

Sentence Reduction – Consideration under the Food Safety and Standards Act, 2006, which replaced the Prevention of Food Adulteration Act, 1954, and provides for a maximum penalty of Rs.3,00,000 for misbranded food without imprisonment. [Para 9]

Application of Beneficial Amendment – Precedent established in T. Barai v. Henry Ah Hoe and subsequent cases allowed applying amendments beneficial to the accused even retrospectively. [Para 9]

Modified Sentence – Appellant no.2's sentence modified from three months' imprisonment and Rs.1,000 fine to solely a fine of Rs.50,000. The fine of Rs.2,000 for appellant no.1 upheld. [Para 10]

Criminal Law – Section 153-A IPC – Quashing of FIR - Background and Allegations – FIR registered against appellant, a professor, for promoting enmity under Section 153-A IPC based on his WhatsApp status about Jammu & Kashmir and Pakistan Independence Day – High Court dismissed writ petition to quash FIR. [Paras 1-2]

High Court Judgment – Upheld FIR for potentially attracting Section 153-A due to the part of the status related to Jammu & Kashmir – Dismissed writ petition. [Para 3]

Legal Interpretation – Section 153-A IPC requires intent to promote enmity or disharmony – Expression of views on abrogation of Article 370 and Independence Day of Pakistan not sufficient to attract offence under Section 153-A – Relied on prior Supreme Court decisions emphasizing the importance of intention and the effect of words on reasonable minds. [Paras 5-7, 9-12]

Freedom of Speech – Criticism of State action and expression of dissent within constitutional limits permissible – Expression of unhappiness over abrogation of Article 370 and extending Independence Day wishes to Pakistan considered within bounds of free speech. [Paras 9-10, 12]

Police Machinery and Free Speech – Emphasis on educating police about democratic values and reasonable restrictions on free speech – Need to understand the distinction between permissible dissent and punishable speech. [Para 13]

Dismissal of Case – Prosecution for offence under Section 153-A IPC deemed abuse of law – Impugned judgment and FIR quashed – Upholds the right to dissent and freedom of speech. [Paras 14-15]

Criminal Law – Murder and Dowry Death – Appeal Against Conviction – Court examined the appeal against the conviction for the murder of the appellant's wife and related dowry death charges. The appeal challenged the findings of the High Court and trial court, focusing on the reliability of circumstantial evidence and the validity of the charges under Sections 302, 304B, and 498A of the IPC. [Para 1-3, 9-11]

Conviction Based on Circumstantial Evidence – Analyzed – The Court discussed the principles governing conviction based on circumstantial evidence, emphasizing the need for the circumstances to form a coherent chain pointing unequivocally towards the guilt of the accused and excluding all other hypotheses. [Para 8, 12-13, 17]

Acquittal under Section 302 IPC – Reasoned – The Court found that the prosecution failed to establish beyond reasonable doubt the circumstances implicating the appellant in the murder of his wife. Notably, the evidence, such as the recovery of bloodstained clothes and certain documents, was deemed unreliable. The Court distinguished between mere suspicion and proof beyond reasonable doubt, leading to the acquittal of the appellant under Section 302 IPC. [Para 13-17]

Conviction under Section 304B and 498A IPC – Restored – Despite the acquittal for murder, the Court restored the conviction and sentence for dowry death and cruelty towards the wife. It held that these charges were proven and upheld in related appeals against co-accused. [Para 18]

Direction for Release – Given the period already served (over fifteen years), the Court waived the fine and ordered the immediate release of the appellant, conditional on his not being required in any other case. [Para 19]

Decision – Appeal partly allowed with a set-aside conviction for murder under Section 302 IPC, but the convictions under Sections 304B and 498A IPC were restored. [Para 18-20]

Criminal Law – Grant of Anticipatory Bail – Police Officer Misconduct –Bail Overturned – High Court's decision granting pre-arrest bail to respondent, a police officer accused of manipulating investigation and wrongful arrest in Dhanwar PS Case No. 296 of 2021, set aside – Serious allegations against the police officer necessitated careful consideration [Paras 1-2, 9-11]

Role and Conduct of Police in Investigations – emphasized the heightened responsibility of police officers in maintaining the integrity of investigations. The Court underscored the serious implications of a police officer, particularly an Investigating Officer, abusing their authority to manipulate investigations. [Para 6, 8, 10]

Criteria for Granting Bail – outlined – The Court reiterated the considerations for granting bail, including the nature and seriousness of the offence, evidence character, peculiar circumstances of the accused, and potential risk of the accused tampering with evidence or witnesses. It was held that these considerations also apply to anticipatory bail, with additional emphasis on public interest and state security in cases involving police officers. [Para 7]

Judicial Discretion in Bail Matters – stressed – The Court noted that the exercise of judicial discretion in bail matters must be judicious and supported by cogent reasons, especially in cases involving law enforcement officers where public interest and the integrity of the criminal justice system are at stake. [Para 5, 9]

Decision – Revocation of Anticipatory Bail – The Supreme Court set aside the High Court's order granting anticipatory bail to the accused police officer, observing that the High Court failed to consider the serious allegations and the potential impact on public trust in law enforcement.

Accident Compensation – Motor Accident – Appeal against reduced compensation awarded by High Court – Original claim for ₹1,00,00,000/- by dependants of deceased Ravisankar – Tribunal awarded ₹51,64,550/- – High Court reduced to ₹22,48,000/- – Supreme Court reassessed compensation to ₹38,81,500/-. [Paras 1, 5-6, 17]

Income Assessment of Deceased – Multi-tasking deceased involved in agriculture, dairy farming, and government contracting – Initial Tribunal assessment at ₹50,000/- monthly – High Court revised to ₹20,000/- – Supreme Court reassessed at ₹35,000/- monthly considering various sources of income and evidence. [Paras 2, 11-14, 16]

Compensation Calculation – Methodology – Based on Motor Vehicles Act, 1988 – Consideration of age, future prospects, personal expenses, multiplier of 11 as per Sarla Verma case – Additional compensation for loss of estate, funeral expenses, and loss of consortium. [Paras 15-16]

Decision: The Supreme Court modified the High Court's judgment, increasing the compensation to ₹38,81,500/- with 8% interest from the date of filing the claim petition till realization. [Para 17]      

Quashing of FIR for Rape on False Promise to Marry -  FIR and subsequent proceedings under Sections 376(2)(n) and 506 IPC were quashed due to inconsistencies and improbabilities in the complainant's allegations, demonstrating that the relationship was consensual and not based on a false promise to marry - Discrepancies noted between FIR, complainant's statement under Section 164 Cr.P.C., and actual facts concerning the complainant's marital status. [Paras 1-2, 6-8, 10]

Consent and Misconception – Analysis – The Court highlighted the nature of the relationship between the appellant and the complainant, noting that the complainant was not under any misconception at the time of giving consent. The Court observed that the allegations did not constitute rape as defined under Section 375 of the IPC. [Paras 6.3, 8, 9]

Evaluation of Evidence – Discrepancies in Complainant’s Testimony – The Court pointed out inconsistencies in the complainant's statements regarding the divorce from her first husband and subsequent relations with the appellant. It was observed that the complainant's actions did not align with her allegations of being deceived into a physical relationship. [Paras 6.2, 7, 9]

Decision – The appeal was allowed, and the FIR and subsequent proceedings against the appellant were quashed due to the lack of credibility in the allegations and the consensual nature of the relationship. [Para 10]