Limitation Law – Filing of Subsequent Suit for Specific Performance – Article 113 and Order VII Rule 13 of the Code – Suit Barred – The second suit filed in 2007 for specific performance was barred under Article 113 of the Limitation Act – Held: The second suit must be filed within three years from the rejection of the earlier plaint in 1998; filing the suit beyond 2001 made it time-barred under Order VII Rule 11(d) [Paras 9.8-9.12].

Pleadings – Misuse of Extension Letter – Letter dated 15.07.1991 used in second suit not mentioned in first suit filed in 1993 – Attempt to misuse it for continuity of cause of action – Held: Such reliance was mischievous and inadmissible [Paras 9.9-9.11].

Law of Limitation – Nature and Scope – Doctrine of Continuous Running of Time – Once time starts running under limitation, it continues unless interrupted by statutory provisions – Held: Extension based on pending litigation irrelevant for computing limitation under Article 113 [Para 9.11].

Decision – Second Suit for Specific Performance Rejected – Application under Order VII Rule 11(d) allowed – Appeal allowed, setting aside trial court and High Court orders [Paras 9.12, 10].

Land Acquisition – Compensation Under 2013 Act – Supreme Court’s Powers Under Article 142 – The respondents, landowners, sought compensation for acquired lands – The Supreme Court, following K.L. Rathi Steels Ltd. (2024) 7 SCC 315, directed that compensation be paid under the 2013 Act – The time for fresh acquisition proceedings under Section 24(2) of the 2013 Act was extended by one year, from 01/08/2024 – Held: Respondents entitled to compensation under the 2013 Act, subject to procedural compliance as outlined in K.L. Rathi (2024) [Para 3].

Article 142 – Exercise of Inherent Powers – Balancing Public and Private Interests – The Court exercised Article 142 powers to ensure uniformity in compensation awards and to balance public interest with private rights – Provisions of Chapters II and III of the 2013 Act (Social Impact Assessment) were dispensed with, given the urban/semi-urban nature of the land – Held: Directions issued to expedite fresh acquisition proceedings, while waiving procedural requirements to ensure fairness and efficiency [Paras 3-4].

Land Acquisition – Procedural Directions – Expedited Compensation Payment – The Court issued specific directions:

a) Time limit for acquisition extended by one year (from 01/08/2024).

b) Status quo to be maintained on possession and land use.

c) Social Impact Assessment waived due to urban nature of land.

d) Pre-2014 notifications deemed preliminary notifications under Section 11 of the 2013 Act.

e) Compensation to be assessed as of 01/01/2014, with all monetary benefits except rehabilitation.

f) Collector to determine compensation as per Section 28, award solatium under Section 30 – Landowners may seek enhancement under Chapter VIII of the 2013 Act.

Held: Orders passed to ensure fair compensation while streamlining procedural requirements [Para 3].

Decision: Miscellaneous Applications Disposed of – Supreme Court extended the time for fresh acquisition proceedings and ordered compensation to be paid under the 2013 Act, with procedural waivers to ensure expeditious resolution – Pending interlocutory applications also disposed of [Paras 5-6].

Criminal Law – Rape and POCSO Act – Acquittal – Respondent accused of abducting and raping a 16-year-old prosecutrix under threat of a knife – FIR filed after two days of delay, with initial report by father alleging assault by three boys unrelated to the accused – Medical examination showed no injuries; contradictions in prosecutrix’s testimony regarding assault – Trial Court and High Court acquitted the accused for lack of credible evidence – Supreme Court upheld acquittal – Held: Sole testimony of prosecutrix must inspire confidence to convict; prosecutrix’s testimony contradictory and lacked corroboration – Appeal dismissed [Paras 4–12].

Delay in FIR – Unexplained Delay – Incident allegedly occurred on 16.09.2014; FIR lodged on 18.09.2014 – Trial Court found delay unexplained and raised doubts about the veracity of allegations – High Court and Supreme Court concurred that delay undermined prosecution’s case in the absence of corroborative evidence [Paras 5, 7, 12].

Testimony of Prosecutrix – Contradictions and Credibility – Prosecutrix’s testimony contradicted her earlier statements under Section 164 CrPC and her examination-in-chief – Allegations of hitting the accused with a danda varied in description, with no injuries found on the accused during surrender – Supreme Court emphasized that conviction based on sole testimony of prosecutrix requires absolute confidence in its reliability, which was absent in this case [Paras 9–10].

Absence of Resistance or Alarm – Credibility Questioned – Prosecutrix stated that accused, known to her, threatened her with a knife but raised no alarm while being taken through a public bazaar and into a shop – Supreme Court noted that prosecutrix’s explanation failed to inspire confidence, as circumstances contradicted normal behavior in such situations [Paras 11–12].

Medical Evidence – Lack of Injuries – Medical examination revealed torn hymen but no external injuries on prosecutrix – Supreme Court noted absence of corroborative medical evidence to support allegations of force or assault, further weakening prosecution’s case [Paras 9, 12].

Decision: Appeal dismissed – Orders of Trial Court and High Court acquitting the respondent upheld – Supreme Court reiterated caution in convicting based on sole testimony without corroboration in rape cases [Paras 12–13].

Property Law – Lease and Conveyance – Application for Conveyance – Municipal Corporation of Greater Mumbai (MCGM) denied conveyance of Block-A to Century Textiles & Industries Limited post lease expiration – High Court allowed writ petition directing conveyance – Supreme Court held: Neither statutory framework nor lease terms imposed any obligation on MCGM to convey the property – Absence of clear covenant in lease deed or statutory mandate precludes any claim for conveyance [Paras 44-53, 55].

Statutory Interpretation – Harmonious Construction – Sections 48(a) and 51(2) of Bombay Improvement Trust Transfer Act, 1925 – Conflict alleged between requirement to restore premises in good condition and entitlement to conveyance – Held: Provisions to be harmonized – Restoration duty remains intact unless lease or statutory framework permits conveyance – "Shall convey" in Section 51(2) interpreted as contingent, not absolute – Avoids rendering Section 48(a) otiose [Paras 45-52].

Delay and Laches – 61-Year Delay in Seeking Relief – Lease expired in 1955; writ petition filed in 2016 after 10-year delay post statutory notice in 2006 – High Court erred in ignoring delay – Supreme Court: Doctrine of laches bars such delayed claims – Respondent's conduct deemed deliberate and non-diligent – Writ petition ought to have been dismissed [Paras 56-63].

Public Welfare – Abuse of Beneficial Legislation – Lease for housing poorer classes under welfare scheme – Respondent sought commercial redevelopment contrary to lease terms – Held: Breach of lease purpose undermines legislative intent – Diverting public welfare objectives for private profit subverts statutory framework [Paras 64-69].

Decision: Appeal allowed – High Court judgment set aside – Writ petition dismissed – Pending applications disposed of.

NDPS Act – Interim Release of Seized Vehicle – Principles and Applicability – Appeal against Gauhati High Court judgment dismissing writ petition challenging the denial of interim release of a seized vehicle used in alleged drug transportation – Appellant sought interim custody under Sections 451 and 457 Cr.P.C. – Respondent contended NDPS Act precludes such interim release – Held: Interim release permissible under Cr.P.C. provisions unless inconsistent with NDPS Act – Appellant found not complicit in the crime – Vehicle's prolonged retention by police without valid purpose would cause unnecessary deterioration and loss – Appeal allowed, vehicle ordered to be released under strict conditions. [Paras 19-36].

NDPS Act – Confiscation of Vehicle – Scope of Section 60 – A vehicle used for transporting narcotics is liable for confiscation only after conclusion of trial and conviction – Owner can avoid confiscation by proving lack of knowledge or connivance in the illicit use – Interim release possible if no allegation against owner exists or owner shows due diligence to prevent misuse – Differentiation made between vehicles owned/used by accused and those owned by innocent parties – Present case involves the fourth scenario: contraband recovered from a third-party occupant without owner's knowledge or consent [Paras 29-32].

General Criminal Law Principles – Applicability of Sections 451 and 457 Cr.P.C. – No express bar under NDPS Act for invoking Cr.P.C. provisions regarding interim custody – Section 51 NDPS Act allows Cr.P.C. to supplement unless inconsistent – Trial Court empowered to order interim release of vehicles if factual circumstances justify such relief – Past rulings affirm discretion for interim custody in appropriate cases [Paras 19-23, 31-32].

Judicial Presumptions – Absurd or Unjust Results – Courts lean against interpretations leading to absurdity – State's interpretation would require indefinite retention of any vehicle used in drug transportation, including planes or buses, till trial conclusion – Judicial notice taken of practical concerns like weather damage to seized vehicles during prolonged storage – Beneficial release ensures utility, prevents waste, and serves wider societal and economic interests [Paras 24-28, 34-35].

Conditions for Interim Release – Safeguards to Ensure Availability for Trial – Vehicle's release contingent upon preparation of inventory (videography, photographs) authenticated by involved parties – Prohibition on sale or transfer of ownership during trial – Owner required to furnish bond and undertaking to produce vehicle on demand or compensate its value as determined by court – Released vehicle must remain accessible for trial proceedings [Paras 28, 36].

Decision: Appeal allowed – Trial Court directed to release the seized vehicle to the appellant (registered owner) on superdari with conditions – Appellant barred from transferring ownership or altering vehicle’s condition – Undertaking required to ensure vehicle's availability during trial and compliance with final court orders. [Paras 36].

Criminal Law – Compounding of Non-Compoundable Offenses – Exceptional Circumstances Warrant Relief – Applicant sought relief for compounding of offense under Section 326 IPC based on a voluntary settlement reached post-conviction – Supreme Court exercised inherent powers to recognize the compromise despite Section 326 being non-compoundable under CrPC – Held: Amicable settlement in exceptional circumstances justified invoking inherent powers to reduce the sentence to the period already undergone [Paras 4-5, 8].

Criminal Procedure – Inherent Powers of Supreme Court – Compromise Between Parties – Section 326 IPC Non-Compoundable – The Court noted the voluntary nature of the settlement, compensation of ₹5,80,000 paid by the applicant, and complainant’s unequivocal consent – Exercise of inherent powers warranted to promote peace and harmony and prevent future discord [Paras 5-6].

Sentencing – Reduction of Sentence – Based on Amicable Settlement – Sentence of one year reduced to the period already undergone considering exceptional facts, voluntary compromise, and applicant’s effort to resolve disputes [Paras 8-9].

Decision: Miscellaneous Application allowed – Conviction upheld – Sentence reduced to the period already undergone – Related I.A. disposed of .

Anticipatory Bail – Imposition of Maintenance Condition – High Court Exceeded Jurisdiction – Condition Set Aside – Held: Bail conditions under Section 438 CrPC should ensure that the accused does not abscond or evade trial – Imposing a condition to pay maintenance is irrelevant to the bail process and is beyond the scope of the court's power – Reference made to Munish Bhasin vs. State (Govt. of NCT of Delhi), (2009) 4 SCC 45 – The High Court’s imposition of a maintenance condition in its order dated 17.07.2023 is quashed – Trial Court directed to impose appropriate bail conditions ensuring the appellant's presence during trial [Paras 7-12].

Criminal - Appeal against Conviction – Murder - Credibility of Witness Testimony – Minor Contradictions Not Fatal – Conviction Upheld - The appellants argued inconsistencies in witness statements and alleged bias due to political rivalry. The Court held that minor contradictions do not impair the credibility of eyewitness accounts when corroborated by medical and circumstantial evidence. [Paras 14-15, 20-23].

Doctrine of Falsus in Uno, Falsus in Omnibus – Not Applicable in Indian Law - The Court reiterated that this doctrine is not a rule of evidence in Indian jurisprudence. Testimonies can be partly believed if they inspire confidence, even if some portions are found unreliable. [Paras 19, 25].

Investigation Lapses – Not Grounds for Acquittal if Core Evidence is Strong - The defense highlighted investigative lapses, including alleged tampering with FIR details. The Court observed that defects in investigation do not vitiate the prosecution's case if eyewitness and medical evidence remain consistent and credible. [Paras 17, 22].

Homicidal Death Established – Medical Evidence Corroborates Witness Accounts - Postmortem reports confirmed that the deaths of the victims resulted from injuries inflicted during the attack, validating the prosecution's narrative. [Paras 13-14].

Conviction Under Explosive Substances Act – A3's Role Affirmed - A3's use of a bomb during the incident was sufficient to sustain his conviction under Section 5 of the Explosive Substances Act. [Para 24].

Decision – Appeal Dismissed, Convictions Upheld - The Supreme Court found no fault in the High Court's judgment, maintaining the conviction of the appellants while dismissing the appeal. [Paras 26-27].

Criminal Law – Bail - Bail Conditions for Foreign Nationals – Applicability of Civil Authority Notification – Compliance Mandated - The appellant challenged the procedural requirements for notifying Civil Authorities when bail is granted to foreign nationals. The court noted that under Clause 5 of the Foreigners Order, 1948, a foreigner cannot leave India without the Civil Authority's permission if required to answer criminal charges. Directions were issued for prosecuting agencies to notify the concerned Registration Officer upon the grant of bail to ensure compliance with legal provisions and administrative efficacy. [Paras 6-8].

Non-Impleadment of Civil Authorities – Rationale Explained - The court declined to mandate impleadment of Civil Authorities in all bail applications involving foreigners, reasoning that such a requirement could delay judicial processes. Instead, authorities should be notified post-bail to take necessary legal steps under the Foreigners Act and associated orders. [Paras 5-7].

Powers under Foreigners Act vs. Criminal Courts’ Bail Jurisdiction – Distinct Yet Harmonized - The court clarified that the power to arrest or detain a foreigner under Clause (g) of Section 3(2) of the Foreigners Act is independent of the criminal court's jurisdiction to grant bail. Hence, bail does not preclude the enforcement of administrative orders under the Act. [Paras 5-6].

Decision – Directions Issued to Ensure Administrative Compliance Post-Bail - The Supreme Court issued directives to prosecuting agencies and Registration Officers for ensuring coordination between judicial orders and administrative requirements. Criminal appeals were disposed of accordingly. [Paras 8-9].