Criminal Law – Burden of Proof – Alibi – Appeal against conviction for murder – Plea of alibi by appellant – Trial court and High Court concurrently found plea of alibi unconvincing – Supreme Court reiterates heavy burden on accused to prove alibi with certainty – Evidence adduced by appellant sketchy and insufficient to exclude presence at crime scene – Appeal dismissed on grounds of failure to discharge burden of proof [Paras 16-20].

Inquest and Post-Mortem Reports – Discrepancies – Discrepancies between inquest and post-mortem reports – Inquest report not substantive evidence but serves to ascertain cause of death – Post-mortem report by medical expert given more weight – Supreme Court finds no merit in claims of ante-dated FIR and discrepancies impacting prosecution case [Paras 28-32].

Judicial Review – Concurrent Findings – Supreme Court emphasizes limited scope of judicial review in criminal appeals – Interference warranted only in cases of manifest error or miscarriage of justice – Concurrent findings of fact by lower courts not disturbed unless clearly perverse – Appellant's arguments on defective investigation and absence of independent witnesses found unpersuasive [Paras 36-37].

Decision- Appeals dismissed – Conviction and sentences upheld – Directions for compliance with procedural mandates regarding evidence and investigation reiterated – Parties to bear their own costs [Para 38].

Constitutional Law – Reservation in Promotions – Quantifiable Data Requirement – The Supreme Court emphasized that states must collect quantifiable data to show the inadequacy of representation of SCs and STs in public employment before providing reservations in promotions. The yardstick for determining the adequacy of representation and the unit for collecting such data must be related to the specific grade/category of posts to which promotion is sought [Paras 1-10].

Constitutional Amendments – Enabling Provisions – The Court upheld the constitutional amendments enabling reservation in promotions (Articles 16(4-A) and 16(4-B)) but reiterated that they are enabling provisions, not mandatory. States have the discretion to implement these provisions based on collected data demonstrating inadequacy of representation and backwardness [Paras 11-20].

Application of Roster System – Cadre-Based Approach – The Court clarified that the roster system for reservation must be post-based rather than vacancy-based. Cadre strength should be used as the unit for the operation of the roster, ensuring that reservation does not exceed 50% of the total cadre strength [Paras 21-29].

Efficiency in Administration – Compliance with Article 335 – Any reservation in promotions must ensure that the overall administrative efficiency as stipulated under Article 335 of the Constitution is maintained. The states must balance the need for reservation with the requirement of maintaining efficiency in public administration [Paras 30-34].

Decision – Appeals Disposed – The Supreme Court directed the states to follow the principles laid down in the judgment, ensuring that reservation in promotions is based on adequate quantifiable data. The states must periodically review the representation of SCs and STs in promotional posts to assess the need for continuation or adjustment of reservation policies [Para 35].

Central Civil Services – Grade Pay under MACP Scheme – Appeal against the High Court’s decision to grant grade pay of Rs. 6600/- – Supreme Court holds that as per Clause 8.1 of the MACP Scheme, grade pay of Rs. 5400/- in PB-2 and PB-3 are to be treated as separate grade pays – High Court’s allowance of grade pay of Rs. 6600/- was erroneous and contrary to MACP Scheme – Appeal allowed, High Court judgment set aside [Paras 1-26].

Government Policies – Judicial Interference – Supreme Court reiterates limited scope of judicial interference in government policies, especially pay commissions – High Court’s modification of MACP Scheme beyond its guidelines was incorrect – Court emphasizes that policy framed by expert bodies like pay commissions should not be interfered with unless patently unreasonable [Paras 7-13].

Decision- Appeal allowed – High Court judgment dated 23.10.2019 set aside – Central Administrative Tribunal’s order restored – Respondents entitled to grade pay of Rs. 5400/- as per Clause 8.1 of MACP Scheme – No recovery of excess pension paid till December 2021 – Pension to be refixed accordingly from January 2022 onwards [Paras 32-33].

Legislative Procedure – Suspension of MLAs – Challenge to the suspension of 12 MLAs for disorderly behavior – Supreme Court emphasizes that long-term suspension impacts the representation of the constituency more severely than expulsion, disqualification, or resignation – Held that the suspension for one year is unreasonable, irrational, and arbitrary – Impugned resolution quashed as it goes beyond the permissible period of suspension, impacting the democratic process and the rights of the constituency to be represented [Paras 1-14].

Rule 53 of Maharashtra Legislative Assembly Rules – Procedural Requirement – Suspension beyond the remainder of the ongoing Session violates Rule 53, which allows for suspension only for the remainder of the Session – Supreme Court highlights that any extension of suspension beyond the session period would be illegal, irrational, and unconstitutional – The Court stresses the need for a rational and objective standard in disciplinary measures within legislative procedures [Paras 7-13].

Democratic Values – Right to Representation – Long-term suspension undermines democratic values by unrepresenting constituencies and enabling manipulation by the ruling party – Such actions deter meaningful debates and participation by the Opposition due to the fear of suspension – The Court underscores the importance of balancing disciplinary measures with democratic principles and representation rights [Paras 14-15].

Decision- Writ petitions allowed – Suspension beyond the remainder of the Monsoon Session of July 2021 declared null and void – Petitioners entitled to all consequential benefits of being members of the Legislative Assembly post the remainder of the concerned Session in July 2021 – Orders for quashing the resolution passed by the Maharashtra Legislative Assembly suspending the petitioners for one year [Para 16].

Registration Act – Original Power of Attorney – Appeal against High Court's decision concerning the requirement of producing the original power of attorney – Supreme Court clarifies that Sections 32(c), 33, and 34(2)(c) do not necessitate the production of the original power of attorney if the power of attorney holder presenting the document is also the executant – The inquiry under the Registration Act does not extend to verifying the validity of the power of attorney – Appeal allowed, High Court judgment set aside [Paras 1-26].

Execution of Documents – Competence and Authority – Examines the competence of a power of attorney holder to execute a sale deed – The original power of attorney not required for registration if the executant is presenting the document – Emphasizes that the authority of the power of attorney holder must be evident from the power of attorney itself and the registration authority's role is to ensure the executant's identity and competence [Paras 24-26].

Decision- Appeal allowed – High Court judgment reversed – Trial court's findings restored – No need for original power of attorney if executant presents the document – Plaintiff's ownership and possession upheld [Paras 32-33].

Bail – Judicial Discretion – Appeal against High Court's order granting bail to an accused charged with serious financial offences – Supreme Court emphasizes that bail decisions must consider the nature and gravity of the accusations, the modus operandi, and the evidence collected during the investigation – High Court's failure to consider these factors renders its decision unsustainable – Appeal allowed, bail order set aside, and respondent directed to surrender [Paras 1-14].

Financial Fraud – Consideration of Evidence – Accusations involve misappropriation and siphoning of Rs. 25 crores through shell companies using false documents – High Court did not consider the status report and evidence showing the systematic fraud committed – Supreme Court highlights the necessity of considering all relevant factors and evidence in bail decisions [Paras 9-13].

Decision- Appeal allowed – High Court judgment and order dated September 14, 2020, granting bail quashed and set aside – Respondent to surrender immediately – Respondent allowed to apply for bail afresh after three months, with High Court to consider the application based on relevant material and factors [Paras 13-14].

Execution of Foreign Decrees – Jurisdiction – Appeal against the High Court's decision on the execution of a foreign money decree – Foreign decree from a superior court of a reciprocating territory (United Kingdom) – Supreme Court clarifies that the High Court of Delhi has jurisdiction to entertain execution petitions for foreign decrees if the decree amount exceeds the pecuniary limits set under Section 5(2) of the Delhi High Court Act – High Court of Delhi considered a "principal civil Court of original jurisdiction" when pecuniary limits are exceeded – Appeal allowed, Division Bench judgment set aside, matter remanded to High Court for expedited hearing [Paras 1-32].

Interpretation of "District Court" – Section 44A CPC – "District Court" under Section 44A of the CPC includes courts with ordinary original civil jurisdiction based on pecuniary limits – High Court of Delhi, exercising such jurisdiction, competent to execute foreign decrees when pecuniary limits are met – Division Bench erred in excluding High Court from jurisdiction over foreign decree execution – Execution proceedings are a continuation of the original suit, thus falling within the jurisdiction of the High Court when pecuniary limits are exceeded [Paras 24-30].

Decision- Appeal allowed – Division Bench judgment dated July 1, 2014, quashed and set aside – Execution First Appeal (EFA) No. 3 of 2014 restored to the file of the Division Bench of the High Court of Delhi – High Court directed to expedite the hearing and decide on merits within four months [Paras 31-32].

Landlord-Tenant Law – Statutory Tenancy – Jurisdiction of Civil Courts – The Supreme Court held that the jurisdiction of Civil Courts is barred in matters covered by the Haryana (Control of Rent & Eviction) Act 1973, which provides a complete code for determining the rights of tenants and landlords. The appropriate remedy for eviction in such cases lies with the Rent Controller under the Act 1973, not with the Civil Court [Paras 1-11, 25].

Effect of Special Legislation – Burmah Shell Act – The Burmah Shell (Acquisition of Undertakings) Act 1976 confers tenancy rights to BPCL and overrides other inconsistent laws. The tenants under this Act are considered statutory tenants, and their eviction must be pursued under the specific provisions of the Rent Control Act applicable to the region [Paras 17-19, 21].

Decision – Appeal Dismissed – The Supreme Court dismissed the appeal, upholding the High Court's judgment that the Civil Court has no jurisdiction to entertain the suit for possession. The remedy for the appellants lies in initiating eviction proceedings under the Haryana (Control of Rent & Eviction) Act 1973 [Paras 25-26].

Trust Law – Disposal of Trust Property – Registrar's Authority – The Supreme Court held that the Registrar of Public Trusts cannot impose conditions beyond those stipulated in the trust deed or by law. The Registrar's authority to refuse sanction for the disposal of trust property is limited to situations where such disposal would be prejudicial to the interests of the trust as defined by law or the trust deed. The Registrar must base decisions on objective criteria provided in the trust instrument or law, rather than personal notions of what is beneficial or prejudicial [Paras 1-10, 20-28].

Autonomy of Trusts – Principle of Democratic Decision-Making – The Court emphasized the importance of maintaining the autonomy and democratic decision-making of self-governed organizations. Public control over trusts is intended to ensure efficient administration without overriding the decisions made by the trust's members. Any measure of public control should not undermine the right to freedom of association under Article 19(1)(c) of the Constitution [Paras 27-28].

Decision – Appeal Allowed – The Supreme Court set aside the impugned judgment and the Registrar's decision, allowing the trust to proceed with the sale of its properties subject to fresh valuation and public tender to ensure transparency and fairness [Para 29-30].