Criminal Law – Quashing of Complaint – Section 482 CrPC – The Supreme Court held that allowing the criminal proceeding to proceed for offences under Sections 494 and 495 of the IPC would constitute an abuse of process. The Family Court had conclusively determined that the appellant did not have a subsisting marriage when she entered into the second marriage with the respondent. This finding, having attained finality, precluded further criminal proceedings based on the same facts [Paras 15-16].

Jurisdiction of Family Court – Determination of Marital Status – The Family Court, vested with the jurisdiction to determine the matrimonial status of a person under Section 7(1) of the Family Courts Act, 1984, had adjudicated the issues and declared the purported divorce null and void. The High Court's conclusion that the matter was highly contentious and needed to be tried on evidence was erroneous [Para 15].

Decision – Appeal Allowed – The Supreme Court set aside the impugned judgment of the Gauhati High Court and allowed the appellant's petition to quash the complaint. The criminal complaint pending in the Court of SDJM(S) II Kamrup (M) Guwahati was quashed [Paras 16-17].

Consumer Law – Delay in Possession – Non-compliance with ABA – Appellant failed to deliver possession of apartments in the promised state and time – NCDRC ordered refund with interest – Supreme Court upheld NCDRC’s decision based on breach of representation by the developer [Paras 1-26].

Building Plan Approval – Fire NOC Requirement – Appellant argued possession date starts from Fire NOC receipt – Court referenced Abhishek Khanna case, confirming possession period starts post Fire NOC – Delay in possession justified refund [Paras 17-20].

Interim Orders – Compliance – NCDRC interim order for possession not adhered to by appellant due to incomplete construction – Supreme Court affirmed NCDRC's refund order given non-compliance [Paras 21-22].

Decision: Appeals dismissed – NCDRC's orders for refund with interest upheld – Appellant failed to comply with ABA and interim orders, justifying refund and interest.

Land Acquisition – Higher Compensation – BDA Act vs. 2013 Act – LA Act incorporated into BDA Act remains applicable – High Court erred in applying 2013 Act to BDA acquisitions – 2013 Act provisions not applicable where BDA Act governs acquisition – Repeal of LA Act does not affect ongoing BDA proceedings [Paras 1-24].

Legislation by Incorporation – Provisions of LA Act within BDA Act – Section 36 of BDA Act mandates that LA Act provisions as incorporated remain effective – Subsequent amendments to LA Act do not alter incorporated provisions – Consistent legal precedent upholding this principle [Paras 12-16].

Judicial Precedent – Misapplication of Offshore Holdings Private Limited Case – High Court misinterpreted principles of incorporation vs. reference – BDA Act remains self-contained code with selective incorporation of LA Act – Constitutional Bench’s findings in Offshore Holdings reaffirmed [Paras 22-23].

Decision: Applications allowed – High Court judgment in Sri Sudhakar Hegde case overruled – 2013 Act not applicable to acquisitions under BDA Act – LA Act provisions, as incorporated, continue to govern BDA acquisitions.

Specific Performance – Readiness and Willingness – Financial Capacity and Conduct – Court must assess both financial capacity and conduct of the plaintiff in determining readiness and willingness – Delay in performance, conduct inconsistent with agreement obligations, or inequitable benefit to plaintiff can bar specific performance – Contractual obligations, particularly regarding discharge of encumbrances, must be clear and adhered to by both parties [Paras 1-29].

Equitable Relief – Discretionary Nature – Section 20 of Specific Relief Act – Specific performance is discretionary – Court considers conduct of parties, escalation of property prices, and fairness in granting relief – Plaintiff’s failure to consistently demonstrate readiness and willingness impacts entitlement to specific performance [Paras 30-36].

Decision: Appeal allowed – High Court judgment set aside – Specific performance not granted due to respondent’s lack of demonstrated readiness and willingness – Appellants directed to refund advance amount with interest.

Hindu Law – Succession – Self-acquired Property – Inheritance Rights – Property of a male Hindu dying intestate – Daughter’s right to inherit – Property to devolve by inheritance, not survivorship – Daughter entitled to inherit father’s self-acquired property in preference to collaterals – Recognized under old customary Hindu Law and judicial pronouncements [Paras 1-79].

Hindu Succession Act, 1956 – Section 15 – Order of Succession – Female Hindu’s property – Scheme under Section 15 – Property to devolve on her own heirs, failing which, on heirs of her father – Distinction between property inherited from father/mother and husband/father-in-law – Ensuring inherited property of issueless female reverts to the source [Paras 66-76].

Decision: Appeal allowed – Judgment and decree of the Trial Court and High Court set aside – Suit decreed – Ramasamy Gounder's daughters entitled to 1/5th share each in the suit properties.

Service Law – Promotion Regulations – ESIC Recruitment Regulations 2015 vs. DACP Scheme – High Court erred in applying DACP Scheme over ESIC Recruitment Regulations 2015 for teaching cadre promotions – ESIC Recruitment Regulations 2015, being statutory, have precedence over DACP Scheme – Concession by appellant’s counsel before CAT irrelevant as legal position is clear [Paras 1-27].

Statutory Regulations – Precedence over Executive Instructions – DACP Scheme as executive instruction cannot override statutory ESIC Recruitment Regulations 2015 – Recruitment advertisements referencing DACP Scheme do not supersede statutory regulations – High Court’s reliance on DACP Scheme misplaced [Paras 10-25].

Estoppel and Concessions – No Estoppel against Statutory Provisions – Concession by appellant’s counsel before CAT not binding – Legal errors in concession do not affect statutory interpretation – Appeals court bound by correct legal position irrespective of lower court concessions [Paras 23-25].

Decision: Appeal allowed – High Court judgment set aside – Promotions to be governed by ESIC Recruitment Regulations 2015 – Revised seniority list to reflect promotions as per ESIC regulations, not DACP Scheme

Constitutional Law – Reservation in Education – Constitutional validity of OBC and EWS reservation in AIQ seats – Permissibility under Article 15(5) – Reservation in postgraduate medical courses not prohibited – Reservation as a means to ensure substantive equality and address structural barriers faced by disadvantaged classes – Constitutional amendment and legislative provisions upheld [Paras 1-29].

Merit and Reservation – Reconceptualization of Merit – Merit not solely based on exam scores – Structural inequalities and socio-economic factors influencing merit – Reservation ensuring equal opportunity and addressing historical disadvantages – Merit as a social good advancing equality [Paras 17-29].

Judicial Precedent – AIQ Reservation – Development of AIQ seats through judicial decisions – No prohibition on reservation in AIQ seats for OBCs and EWS – Analysis of relevant cases and constitutional provisions [Paras 30-31].

Decision: Writ petitions challenging the validity of OBC and EWS reservation in AIQ seats dismissed – Constitutional validity of reservation provisions upheld – Reservation to be implemented in the current and subsequent academic years as directed by the court.

Criminal Law – Murder vs. Grievous Hurt – IPC Sections 302 and 326 – Conviction converted by High Court – Deceased died due to head injury after six days – Head injury considered fatal and on a vital part of the body – Mere absence of fracture not sufficient to downgrade conviction – High Court’s conversion of conviction to Section 326 IPC erroneous – Appeal allowed [Paras 1-8].

Evidence – Medical Evidence – Post-Mortem Report – Cause of death due to head injury – Congestion and subdural hematoma over both temporal lobes – Internal injuries can be fatal despite absence of external fractures – High Court failed to consider full medical evidence [Para 7].

Judicial Review – Appellate Interference – High Court’s erroneous application of law – Reinstatement of trial court’s judgment – Conviction under Section 302 IPC for intentional causing of fatal head injury upheld [Paras 7-8].

Decision: Appeal allowed – High Court’s judgment set aside – Conviction under Section 302 IPC and Section 302/34 IPC restored – Respondents to undergo life imprisonment as ordered by the trial court.

Criminal Law – Rape and Murder of Minor Girl – Sentencing – Appellant convicted for the offences under IPC and POCSO Act, sentenced to death by the trial court and confirmed by the High Court – Supreme Court commuted death sentence to life imprisonment, taking into account restorative justice principles and mitigating circumstances – Sentence of imprisonment for a period of twenty years instead of life imprisonment for the remainder of the appellant's natural life for the offence under Section 376A IPC [Paras 36-45].

Restorative Justice – Opportunity for Rehabilitation – Supreme Court emphasized giving offenders an opportunity to repair the damage caused and become socially useful individuals – Balancing retributive and restorative justice principles in sentencing [Paras 43].

Circumstantial Evidence – Doctrine of Last Seen – Prosecution proved that the appellant was last seen with the victim, and there was no plausible explanation from the appellant for the victim's condition – DNA evidence confirmed appellant's involvement – Conviction upheld based on circumstantial evidence and corroborating medical reports [Paras 23-32].

Fair Trial – Right to Legal Representation – Supreme Court noted that the trial court provided legal assistance to the appellant, ensuring a fair trial – No evidence suggesting procedural unfairness or deprivation of legal rights [Paras 33-35].

Decision: Appeal partly allowed – Death sentence commuted to imprisonment for a period of twenty years for the offence under Section 376A IPC – Conviction and sentence for other offences under IPC and POCSO Act affirmed – All punishments to run concurrently [Paras 43-45].