Criminal Law – Dowry Death – Acquittal Reversed – Reinstatement of Conviction – Young bride burned to death within a year of marriage due to repeated dowry demands for TV, motorcycle, and ₹15,000 – Trial Court convicted husband (Ajmal) and mother-in-law (Jamila) under Sections 304-B, 498-A IPC and Sections 3/4 of the Dowry Prohibition Act – High Court acquitted both citing unreliability of prosecution witnesses and socio-economic improbability of the dowry demand – Supreme Court finds High Court reasoning erroneous and restores conviction – Held: Demand for dowry proved; presumption under Section 113B Evidence Act applies and remains unrebutted – Inconsistencies in witness testimonies immaterial where core allegations remain unshaken – High Court failed to assign valid reasons for reversing trial court findings [Paras 16, 17, 20–24].

Witness Testimony – Credibility – PW1 (father), PW2 (maternal uncle), and PW6 (mother) deposed consistent dowry demands and harassment – High Court erred in rejecting PW2’s evidence based on minor contradictions – PW2 did not claim to witness the act of setting deceased ablaze, only saw accused fleeing and informed PW1 – Contradiction between PW1 and PW2 regarding eyewitness claim not material – PW6’s statement that deceased lived ‘happily’ in matrimonial home held to be outlier and cannot override consistent evidence of harassment – Held: Minor contradictions do not justify wholesale rejection of testimony; core prosecution case remains intact [Paras 16.1–16.4, 18–22].

Circumstantial Evidence – Dowry Demand – Consistent evidence of dowry demand and threats by accused a day before death – Presumption of dowry death under Section 113B attracted – Deceased subjected to cruelty “soon before her death” – Trial Court correctly found guilt established – High Court erred in holding that demand could not have been made as accused were too poor to maintain the demanded items – Supreme Court rejects reasoning as fallacious and legally unsustainable – Dowry demand does not require financial capability to maintain articles [Paras 20, 23].

Dowry Prohibition Act – Scope of Dowry – Section 2 DPA covers demands before, at or after marriage – High Court wrongly disbelieved prosecution version due to alleged absence of dowry demand prior to marriage – Held: Section 2 does not restrict timing of demand – Demand made post-marriage also constitutes dowry – Items demanded (TV, motorcycle, cash) clearly fall within the definition [Paras 23].

Sentencing – Consideration of Age – While conviction of both accused restored, Court refrains from sending 94-year-old Jamila (mother-in-law) to prison considering age and frailty – Ajmal (husband) directed to surrender within four weeks to serve sentence of life imprisonment under Section 304-B IPC – Humanitarian considerations and dignity of the elderly convict weighed while refraining from incarceration [Para 24].

Directions – Dowry Prohibition – Systemic and Preventive Measures – Supreme Court issued comprehensive directions to strengthen enforcement of dowry-related laws – Directed State Governments to ensure strict implementation of Dowry Prohibition Act, 1961 – Mandated appointment and effective functioning of Dowry Prohibition Officers under Section 8-B of the Act – Emphasised sensitisation and regular training of police officers, prosecutors and judicial officers dealing with dowry death cases – Directed police authorities to promptly register FIRs and conduct time-bound investigations in cases under Sections 304-B and 498-A IPC – Ordered High Courts to periodically monitor pendency and disposal of dowry death trials to avoid delays – Called for community-level awareness programmes to educate families about legal consequences of dowry demands – Directed circulation of judgment to Chief Secretaries and Directors General of Police of all States and Union Territories for compliance and follow-up action [Paras 25–27].

Decision – Appeals Allowed – Acquittal Set Aside – Appeals allowed – Judgment of High Court set aside – Conviction restored with modification on sentence – Matter concluded with binding directions to curb dowry-related offences [Paras 24–27].

Contract – Sale Agreement – Suppression of Encumbrance – Breach by Vendor – Respondent entered agreement to sell land for ₹4.45 crores but failed to disclose existing mortgage – Appellant paid ₹55 lakhs as advance – On discovering the mortgage, appellant withheld further payment – Held: Vendor's failure to disclose encumbrance constituted fraud and breach of contract – Appellant entitled to refund with interest [Paras 4–8, 12, 31].

Set-Off – Claim by Vendor for Alleged Loss – Respondent claimed to have sold property at lower price due to appellant’s breach and sought set-off – Trial Court rejected claim as barred by limitation and lacking merit – High Court reversed and remanded case to examine damages – Supreme Court held remand unwarranted – Plea of set-off was an afterthought and not legally sustainable [Paras 11, 16–18, 30].

Evidence – Admission in Cross-Examination – Weight and Reliability – High Court relied on one stray statement in appellant’s cross-examination claiming prior knowledge of mortgage – Supreme Court held such isolated admission unreliable and contradicted by evidence – High Court ignored material admissions by respondent accepting concealment and non-reply to legal notice [Paras 13–15, 23–24, 29].

Conduct of Parties – Vendor’s Admissions – Respondent admitted he accepted money after contract period and used none to repay bank – Also admitted receiving notice from appellant alleging concealment but gave no reply – Supreme Court held this conduct proved fraudulent intent and justified refund [Paras 23–24, 31].

Practice and Procedure – Remand – High Court remanded case to trial court to assess limited issue of damages – Supreme Court held remand unjustified as findings were perverse and contrary to record – Trial Court’s decree restoring refund claim reinstated [Paras 17–18, 32–33].

Decision: Appeal allowed – High Court judgment set aside – Trial Court’s decree restored – Appellant entitled to ₹65,43,750 with 13% interest per annum from date of suit till realization – No costs.

Motor Accident Claim – Compensation – Estimation of Income – Tribunal computed Rs.95,000/month as income of deceased based on EMI payments for two trucks owned – No income tax returns filed by claimants – Held: Tribunal and High Court erred in assuming income based on EMI alone – Such inference is speculative and unsupported by documentary evidence – Computation revised [Paras 2–3, 6–7].

Compensation – Income of Deceased – Ownership of Vehicles – Deceased was owner of two trucks and allegedly a reputed transporter – No independent evidence produced to establish actual income – Claim that deceased also drove other trucks for extra income was unsubstantiated – Mere ownership of trucks does not imply high personal income – Held: Trucks could have continued generating income after death – Dependency loss not absolute [Paras 6–7].

Motor Vehicle Claims – Just Compensation – Principle in Pranay Sethi applied – Compensation should not be windfall nor pittance – SC held Rs.50 lakhs (already deposited) sufficient for loss of dependency – Additional Rs.1.6 lakhs awarded for consortium, estate, and funeral expenses – Interest at 9% p.a. awarded from date of claim petition [Paras 8–9].

Filial Consortium – Entitlement of Children – Following Magma Insurance v. Nanu Ram, Court reiterated that not only wife but also children of deceased entitled to filial consortium – Additional compensation granted accordingly [Para 9].

Decision: Appeal allowed – Tribunal’s computation of income set aside – Total compensation fixed at Rs.50,00,000 plus Rs.1,60,000 towards conventional heads – Interest @9% p.a. from date of claim petition – Balance to be paid within one month.

Motor Accident Compensation – Death of Minor Child – Enhancement of Compensation – Notional Income – Multiplier – Appeal arose from claim filed by parents of a 14-year-old boy who died in a road accident caused by rash and negligent driving of a truck – Tribunal awarded meagre compensation of Rs.1,29,500/- – High Court enhanced compensation to Rs.4,70,000/- – Parents sought further enhancement before Supreme Court [Paras 2–4].

Notional Income – Minimum Wages – Applicability – Court held that monthly notional income of deceased minor can be determined on basis of Minimum Wages Act, 1948 – For a Class B city, minimum wages fixed at Rs.5,400/- per month – Contention regarding income of contemporaries rejected as speculative [Para 7].

Future Prospects – Minor Deceased – Addition of 40% – Court allowed addition of 40% towards future prospects even in case of deceased minor child – Consistent with settled principles governing motor accident compensation [Para 7].

Multiplier – Selection – Reshma Kumari Principle Applied – Multiplier of 15 held applicable relying on Reshma Kumari v. Madan Mohan – Judgment in Baby Sakshi Greola distinguished as applicable to permanent disability cases and not death of minor child [Paras 4–6, 7].

Personal Expenses – Deduction – One-half deduction towards personal and living expenses of deceased minor upheld as appropriate in claim by parents [Para 7].

Conventional Heads – Consortium – Estate – Funeral Expenses – Parents held entitled to loss of estate and funeral expenses at Rs.15,000/- each – Loss of filial consortium awarded at Rs.40,000/- each to both parents [Para 7].

Pain and Suffering – Minor Deceased – Award to Legal Heirs – Since deceased child survived for one day after accident, parents entitled to compensation for pain and suffering endured by child – Amount of Rs.25,000/- awarded under this head [Para 8].

Quantum of Compensation – Recalculation – Total compensation recalculated at Rs.8,65,400/- comprising loss of dependency, consortium, medical expenses, funeral expenses, loss of estate and pain and suffering – Earlier amounts awarded to be deducted [Paras 7–8].

Interest – Rate Enhanced – Compensation directed to be paid with interest at rate of 7.5% per annum within two months from date of judgment [Para 9].

Decision – Appeal Allowed – Appeal allowed – Compensation enhanced and modified – Judgment of High Court modified accordingly – Pending applications disposed of [Paras 9–11].

Criminal Law – Circumstantial Evidence – POCSO/rape of minor – Last seen theory and recoveries disbelieved – FIR omissions and witness conduct found highly suspicious – Chain of circumstances not proved – Conviction set aside and accused acquitted [Paras 21-22, 31-33, 49-52, 68-77, 78-79].

Circumstantial Evidence – Governing principles – Five golden principles reiterated – Circumstances must be fully established by reliable evidence – Must be consistent only with hypothesis of guilt – Must exclude every possible hypothesis of innocence – Chain must be complete and incapable of explanation on any other theory – Suspicion however strong cannot take place of proof – Sharad Birdhichand Sharda principles reaffirmed and strictly applied [Paras 21-23].

FIR – Evidentiary value – FIR is not encyclopaedia but must disclose basic prosecution story – Non-mention of crucial facts admittedly within knowledge of informant held fatal – Omission of names of alleged last-seen witnesses and alleged act of accused “pushing out” the child found inexplicable – FIR lodged after medical examination yet silent on material developments – Such omissions treated as serious infirmities affecting prosecution credibility [Paras 29-35].

Last Seen Together – Doctrine – Weak type of circumstantial evidence – Requires proximity of time and place and corroboration – Alleged last-seen witnesses introduced belatedly – Names surfaced only on following day – Two witnesses turned hostile – Remaining witnesses contradicted each other and prosecution case – Unnatural conduct noted in not helping naked bleeding child or confronting accused – Evidence found unreliable and incapable of forming incriminating circumstance [Paras 37-52].

Witness Conduct – Natural behaviour test – Courts must examine human probabilities – Conduct of complainant, journalist witness and others found abnormal and suspicious – Failure to disclose crucial information at earliest point – Possibility of afterthought and tutoring could not be ruled out – Prosecution version rendered doubtful on cumulative assessment [Paras 44-45, 52].

Victim Testimony – Child witness – Identification – Victim unable to identify accused in court – Stated she was tutored by her mother – No corroborative evidence to link accused – Trial court erred in overlooking this significant circumstance – Benefit of doubt extended to accused [Para 67].

Investigation – Quality and fairness – Duty of Investigating Officer to act fairly and objectively – Serious lapses and casual approach noticed – Failure to promptly identify, examine and medically test alleged last-seen witnesses – No explanation for delay and omissions – Investigation found pedantic, negligent and biased – Such lapses struck at root of prosecution case [Paras 55-66].

Recoveries – Section 27 Evidence Act – Strict proof required – Alleged recoveries from accused’s house not proved beyond doubt – Contradictions regarding arrest date and recovery sequence – Panch evidence inconsistent – IO silent on crucial alleged recovery – Ownership and exclusive possession of premises not established – Chain of custody of seized articles not proved – Parents did not identify child’s clothes – Possibility of planting evidence could not be ruled out – FSL report rendered inconsequential [Paras 68-75].

Forensic Evidence – Evidentiary value – FSL report cannot be read in isolation – Must be supported by reliable seizure, custody and linkage evidence – In absence of proved recovery and chain of custody, forensic findings lose probative force – Courts below erred in relying mechanically on FSL results [Paras 71-75].

Appreciation of Evidence – Duty of courts – Courts dealing with heinous offences must remain cautious – Emotional response cannot replace legal scrutiny – Trial Court and High Court failed to critically analyse glaring inconsistencies and investigative lapses – Findings found perverse and unsustainable in law [Paras 66, 76-77].

Practice Directions – Criminal Trials – Need for structured judgments – Supreme Court issued comprehensive directions to streamline criminal trial records – Trial courts directed to append standardized tabulated charts containing (i) list of prosecution witnesses with role and examination dates, (ii) list of exhibits with description and proof, (iii) list of material objects with seizure and identification details – Objective to ensure clarity, transparency and ease of appellate scrutiny – Directions aimed at reducing miscarriage of justice due to poor record management – Registry directed to circulate judgment to all High Courts for implementation and compliance – Directions declared prospective and mandatory in nature [Paras 81-91].

Criminal Appeal – Result – Prosecution failed to establish guilt beyond reasonable doubt – Benefit of doubt must go to accused – Conviction and sentence under IPC and POCSO Act set aside – Accused acquitted – Directed to be released forthwith if not required in any other case [Paras 78-80].

Accident Claim - Motor Vehicles Act – Compensation Claim – Involvement of Vehicle Not Proved – Appellants, legal heirs of two deceased victims of a road accident, filed claim petitions which were dismissed by the Tribunal and High Court – Both courts held that the appellants failed to prove the involvement of the offending vehicle beyond preponderance of probabilities – Supreme Court upheld the concurrent findings and dismissed the appeals [Paras 2, 11, 20].

Evidence – Credibility of Witnesses – Testimonies of P.W.1 and P.W.2 found to be inconsistent and contradictory – P.W.3 and P.W.4’s claim that driver confessed to accident found improbable – No eyewitness account directly proving the identity or involvement of the vehicle – Evidence found to lack credibility – No error in lower courts’ appreciation [Paras 13–15].

Motor Vehicles Act – Chargesheet and MVI Report – Mere filing of chargesheet held insufficient without corroborative evidence – Motor Vehicle Inspector’s report showed no damage to the alleged vehicle despite alleged fatal collision – Court found this inconsistent with the nature of the accident – Doubts raised on reliability of vehicle’s involvement [Paras 9, 18].

Standard of Proof – Preponderance of Probabilities – Court reiterated that in accident claims, preponderance of probabilities is sufficient – However, in present case, even that standard not met – FIR lacked registration number – Spot mahazar prepared days later – Multiple evidentiary gaps noted [Paras 16–17].

Sympathy vs Legal Proof – Though the Court acknowledged the tragic loss of life, it reiterated that compensation under MV Act cannot be granted on sympathy alone – Liability must be proved with credible evidence – Appeals dismissed [Para 19].

Decision: Appeals dismissed – No costs.

PIL - Maternity Benefits – Adoptive Mothers – Constitutionality of Section 5(4), Maternity Benefit Act, 1961 – Provision granted 12 weeks’ maternity benefit only if adopted child is below three months of age – Petitioner challenged this as discriminatory and violative of Articles 14, 19(1)(g) and 21 – Court noted that the Maternity Benefit Act, 1961 was repealed on 21.11.2025 by notification under the Code on Social Security, 2020 – Section 60(4) of the 2020 Code is pari materia to the repealed provision – Held: Petition need not be withdrawn – Petitioner permitted to amend the petition within six weeks to challenge Section 60(4) of the 2020 Code – Union of India raised no objection – Judgment to be pronounced after amended petition is filed [Paras 2–11].

Decision: Petitioner permitted to amend the writ petition to challenge Section 60(4) of the Code on Social Security, 2020 within six weeks – Judgment to follow upon submission of amended petition.

Accident Claim - Motor Vehicles Act – Compensation – Section 166 – Essential Ingredients – Claimants must establish (i) occurrence of accident (ii) involvement of offending vehicle and (iii) rash and negligent act – Mere proof of occurrence of accident insufficient to fasten liability – Failure to establish involvement of specific vehicle fatal to claim [Paras 8, 16–19] .

Evidence – Standard of Proof – Preponderance of Probabilities – Though strict proof beyond reasonable doubt not required in motor accident claims – Claimants must still adduce cogent and reliable evidence connecting the accident with the alleged offending vehicle – FIR omissions not fatal per se but must be examined cumulatively with other evidence [Paras 16–17] .

Witness Testimony – Credibility – Contradictory and Unreliable Evidence – P.W.1 and P.W.2 not eyewitnesses and had no personal knowledge of the accident – Their versions based on hearsay and police information – Held: Star witnesses unreliable and incapable of proving involvement of offending vehicle [Paras 13–14] .

Eyewitness Evidence – Improbable Conduct – P.W.3 and P.W.4 claimed confession by driver revealing registration numbers – Such conduct contrary to normal human behaviour – Material contradictions during cross-examination – Held: Evidence does not inspire confidence [Para 15] .

Police Records – Chargesheet – Evidentiary Value – Filing of chargesheet not conclusive proof of involvement of vehicle – Chargesheet filed after recovery of vehicle one and a half months post-accident – To be treated only as one circumstance in assessing probability [Paras 9–10, 18] .

Motor Vehicle Inspector’s Report – No Damage to Vehicle – Report dated 05.10.2013 showing no damage to alleged offending vehicle – Inconsistent with collision resulting in death of two persons – Held: Strong circumstance negating involvement of vehicle [Para 18] .

Supreme Court – Article 136 – Interference with Concurrent Findings – Tribunal and High Court recorded concurrent findings of fact after proper appreciation of evidence – Interference permissible only if findings are perverse or wholly unsatisfactory – Held: No perversity or exceptional circumstance shown [Paras 12, 19] .

Decision: Civil Appeals dismissed – Judgments of the Motor Accident Claims Tribunal, Shimoga and Karnataka High Court affirmed – Claimants failed to prove involvement of offending vehicle – No order as to costs.

Service Law – Compassionate Appointment – Not a Matter of Right – Respondents appointed as sweepers on compassionate basis after their fathers' deaths – Later sought appointment as Junior Assistants based on eligibility – Supreme Court held compassionate employment is a concession, not a vested right – Intended solely to mitigate sudden financial distress of the family – No entitlement to specific or higher post [Paras 7–10].

Compassionate Appointment – Once Exercised, Cannot Be Re-exercised – Court held that once appointment on compassionate grounds is accepted and acted upon, the right stands consummated – Subsequent claims for higher post unsustainable – Recognized risk of creating ‘endless compassion’ if such claims allowed [Paras 9–10].

Eligibility vs. Entitlement – Possession of qualifications for a higher post does not grant automatic right to such appointment under compassionate grounds – The objective is survival support, not career advancement – Requests for upgrades contrary to scheme’s purpose [Paras 11–12].

Delay and Laches – Delay of 3 and 9 years respectively in seeking higher post – Held fatal – Court reiterated that compassionate appointments address immediate financial need – Prolonged delay indicates absence of urgency and breaks causal link with intended relief [Paras 13–15].

Negative Discrimination – Claim for parity with others who were allegedly granted similar benefit – Rejected – Court reaffirmed that illegal or mistaken reliefs granted to others cannot form basis for equal treatment – Article 14 does not sanction negative equality [Paras 16–19].

Final Decision – Appeals allowed – High Court judgment set aside – Writ petitions seeking higher posts dismissed – Compassionate appointment as sweepers held to have fulfilled intended purpose – No further relief warranted.

Decision: Appeals allowed – High Court directions granting Junior Assistant posts quashed – Writ petitions dismissed – No costs.