Murder and Concealment of Evidence – Conviction Affirmed by Supreme Court – Appellant Perumal Raja @ Perumal convicted for murder of Rajini @ Rajinikanth under Section 302 and Section 201 of the IPC – High Court's judgment affirming conviction upheld – Conviction based on circumstantial evidence including recovery of deceased’s body parts and belongings, and superimposition report confirming identity. [Para 2, 3, 31]

Circumstantial Evidence – Principles for Conviction – Conviction based on circumstantial evidence requires satisfaction of the 'panchsheel' principles – Circumstances must point only towards the guilt of the accused, forming a conclusive chain that excludes every hypothesis except guilt. [Para 37]

Section 27 of the Evidence Act – Admissibility of Statements Leading to Discovery – Statements made by the appellant leading to recovery of evidence admissible under Section 27 of the Evidence Act – Statements must directly relate to and lead to discovery of a fact. [Para 19, 20, 22, 25, 30]

Absence of Direct Eyewitnesses – Reliance on Recovery and Forensic Evidence – In absence of eyewitnesses, conviction based on recoveries made from appellant's disclosure, forensic evidence, and superimposition report – Recovery of body parts and belongings crucial in establishing guilt. [Para 32, 33, 34, 35, 36]

False Explanation by Accused – Consideration as an Additional Link in Circumstantial Evidence – Appellant's false explanation considered as an additional link in the chain of circumstantial evidence, reinforcing the conclusion of guilt. [Para 38, 39, 40]

Acquittal of Co-accused – Different Evidentiary Standards – Acquittal of co-accused not impacting appellant's conviction – Co-accused acquitted due to lack of direct evidence implicating them. [Para 43]

Decision – Supreme Court Upholds High Court’s Judgment – Appellant Perumal Raja @ Perumal’s conviction for murder and concealment of evidence affirmed – Appeal dismissed, maintaining life imprisonment and fines as sentenced. [Para 45]

Property Dispute – Suit for Declaration and Injunction – Dismissal of suit by Trial Court and First Appellate Court upheld; High Court's decision reversing their findings set aside – Plaintiffs failed to prove oral partition and will as per statutory requirements – Appeal allowed. [Paras 2, 3, 6-8, 12-15]

Evidence – Burden of Proof – Plaintiffs unable to substantiate claim of oral partition and execution of will in favor of plaintiffs – Reliance on unconnected documents insufficient to establish oral partition or plaintiffs' ownership. [Paras 6, 12, 13]

Partition – Oral Partition – Requirement of Proof – Oral partition not established through credible evidence – High Court's reliance on unrelated sale and mortgage deeds to conclude oral partition erroneous. [Para 10, 12, 13]

Will – Execution and Proof – Plaintiffs' claim based on will not established as per Section 68 of Indian Evidence Act, 1872 and Section 63 of Indian Succession Act, 1956 – Trial Court and First Appellate Court's findings on lack of proof upheld. [Para 6]

Civil Procedure – Second Appeal – High Court's interference in factual findings of lower courts found unwarranted – High Court's judgment set aside for not conforming to the scope of Section 100 of CPC and for being perverse in appreciating evidence. [Paras 10, 14]

Decision – High Court's judgment in favor of plaintiffs set aside – Trial Court and First Appellate Court's dismissal of suit confirmed – Appeal allowed with no order as to costs. [Para 15]

Insurance Policy – Commencement Date Determination – Interpretation of insurance policy terms to ascertain the effective date of policy commencement – Focus on the dates of policy issuance, premium payment, and risk acceptance in determining policy start date. [Para 2-4, 9-11]

Suicide Clause in Insurance Policy – Application of suicide clause in life insurance policies – Analysis of policy terms regarding suicide within 12 months of policy issue or reinstatement – Importance of policy reinstatement date in determining the applicability of the suicide clause. [Para 5, 6, 8]

Policy Reinstatement – Impact on Suicide Clause – Consideration of policy reinstatement in the context of suicide clause enforcement – Determination of policy effectiveness from the reinstatement date in cases of lapsed and subsequently reinstated policies. [Para 6, 8]

Judicial Interpretation of Insurance Contracts – Adherence to Contractual Terms – Emphasis on strict interpretation of insurance policy terms and conditions – Importance of honoring specific expressions and dates mentioned in the policy contract. [Para 12-14]

Decision – Setting Aside Lower Forum Orders – Supreme Court's decision to set aside orders of the District Forum, State Commission, and National Commission based on misinterpretation of policy commencement and suicide clause – Appeals allowed, rejecting the claims of the respondents. [Para 15-16]

Negotiable Instruments Act – Section 138 – Conviction and Sentence – Appellant and intervenor convicted under Section 138 of the Negotiable Instruments Act – Sentenced to ten months of simple imprisonment and directed to pay a total of Rs. 5 crores in three cases – Conviction and sentence affirmed by the Sessions Court and High Court [Paras 1-5, 7].

Bail and Suspension of Sentence – Violation of Undertaking – High Court cancelled bail and suspension of sentence due to non-compliance with financial obligations under an undertaking – Appellant and intervenor failed to pay the agreed amount of Rs. 4.63 crores as per the payment schedule – High Court's order upheld by Supreme Court [Paras 4, 9-12, 17, 19].

Inter Se Agreement – Payment Proportions – Appellant and intervenor's internal agreement on payment proportions (60:40) not binding on the complainant – Dispute over the outstanding amount to be settled between appellant and intervenor – Supreme Court refrains from adjudicating on inter se payment dispute [Paras 13-16].

High Court's Discretion – Enforcement of Undertaking – Supreme Court emphasizes High Court's discretion in enforcing compliance with the undertaking – Orders compliance with original terms of settlement and directs coercive measures if necessary [Paras 18-20].

Decision – Appeal Dismissed – Supreme Court dismisses the appeal with costs of Rs. 5 lakhs payable to respondent No. 2 (complainant) – Appellant and intervenor directed to surrender within four weeks – High Court to proceed with pending revisions and applications ensuring full compliance with the undertaking [Paras 19-21].

Separation of Powers – High Court’s Power to Direct Notification of Rules Proposed by Chief Justice – Inadequate power under Article 229 to frame rules for post-retiral benefits of former judges – High Court, acting on judicial side, cannot compel the executive to exercise rule-making power as directed. [Para 24-30]

Criminal Contempt – Inappropriateness of Initiating Criminal Contempt for Legal Challenges – Recall application by State Government not contemptuous – Distinction between civil and criminal contempt – High Court's action in hastily invoking criminal contempt and custody of officials not justified. [Para 31-37]

Summoning Government Officials – Guidelines and Limitations – Inappropriate frequent summoning of government officials – Reliance on law officers instead of direct summoning – Framing of Standard Operating Procedure for appearance of government officials in court. [Para 38-45]

Decision – Impugned Orders Set Aside – Appeals allowed – High Court directed to reconsider the writ petition in light of observations made – Communication of judgment to all High Courts for framing rules based on SOP. [Para 46-49]

Criminal Appeal – Default Bail – Misapplication of Default Bail Provision by High Court – Supreme Court reverses the High Court's decision granting default bail to the respondent under Section 167(2) of CrPC – High Court's error in applying provisions of TADA instead of UAPA noted. [Paras 2, 4-5, 9, 14]

Unlawful Activities (Prevention) Act (UAPA) – Distinct Provisions for Extension of Investigation Period – Section 43D(2)(b) of UAPA allows extension of investigation period under specific conditions – High Court failed to apply these specific provisions in granting default bail. [Paras 5-7, 10]

Investigation Extension – Valid Reasons Required – Importance of specific reasons like pending sanctions and FSL report for extending investigation period beyond 90 days under UAPA – High Court's oversight in assessing the validity of reasons for extension. [Paras 3.3, 8, 10-11]

Terrorism – Seriousness of Offences Involving Terrorism – Supreme Court emphasizes the gravity of offences involving terrorism with national and international implications – Necessity of careful judicial consideration in such cases. [Para 13]

Decision – Reversal of High Court's Order – High Court's order granting default bail set aside due to misapplication of legal provisions and oversight of critical facts – Respondent to be taken into custody. [Para 14]

IBC - Corporate Insolvency Resolution – Jurisdiction under Article 226 – High Court’s Interference Improper – High Court set aside a resolution plan citing principles of natural justice violations due to alleged insufficient notice – Held: IBC provides a complete code with ample remedies; High Court intervention was unwarranted and delayed, especially as respondent had availed IBC remedies before – Appeal allowed, High Court’s decision set aside [Paras 9-14].

Principles of Natural Justice – Notice Requirement in CIRP – Notice Contentious – Respondent claimed lack of notice before the 19th CoC meeting; records showed notice was issued – Held: No procedural infirmity established; mere assertions insufficient to invoke principles of natural justice to invalidate the CIRP [Paras 7-8].

Adherence to IBC Framework – CIRP Finality – Delay Impacting IBC Spirit – The CIRP had been ongoing since 2018, with resolution plan approval in 2020 – High Court's interference disrupted finality, breaching IBC’s discipline and objectives – Process restored to Adjudicating Authority for completion [Paras 13-16].

Decision:

Appeals allowed, High Court judgment in Writ Petition No. 483 of 2023 set aside – Adjudicating Authority to resume CIRP and complete proceedings expeditiously [Para 16].

Sale Deed Dispute – Land ownership dispute involving land measuring 71 kanals 8 marlas – Discrepancy between original and interpolated sale deed – Original sale deed showing sale of entire land, while interpolated version showing sale of only 1/3rd of the land. [Paras 1, 11]

Interpretation of Registered Document – Application of Section 47 of the Registration Act, 1908 – Emphasis on the operation of a registered document from the time it would have commenced if no registration was required – In this case, the registered sale deed operates from the date of its execution. [Paras 5, 6, 11]

Legal Position of Sale Completion – Reference to the Constitution Bench decision in Ram Saran Lall v. Domini Kuer – Section 47 of the Registration Act does not determine the completion of sale but the operation date of the registered document. [Paras 7, 8]

Role of Consideration in Sale Deeds – Consideration fully paid on date of execution of sale deed – Sale deed operates from date of execution as per Section 47, Registration Act. [Paras 10, 11]

Invalidity of Unilateral Interpolation – Interpolation made by the seller after execution but before registration, without the buyer’s consent, deemed invalid – Sale deed to be considered in its original form at the time of execution. [Paras 11, 12]

High Court’s Decision Upheld – Supreme Court finds no error in High Court's decision restoring the Trial Court's decree – Dismissal of appeal with no order as to costs. [Paras 12, 13, 14]

Error in Date of Birth on Application – Minor Discrepancy – Appellant's candidature for Police Constable was rejected due to a mismatch in the date of birth in the application form (08.12.1997) and educational certificates (18.12.1997). The appellant contended the error was inadvertent, with no advantage gained, as he met the age criteria regardless. [Paras 2-4, 11, 18]

High Court Decision – Dismissal of Writ Petition – The High Court dismissed the appellant's writ petition, agreeing with the respondents that the error constituted misleading information, warranting rejection of the candidature per the terms of the advertisement. [Paras 6-7]

Supreme Court Analysis – Trivial Error – The Supreme Court found the error to be trivial and not impacting the selection process. The appellant's lack of awareness about the error and success in all stages of selection were noted. The principle 'De minimis non curat lex' (law does not concern itself with trifles) was applied. [Paras 14, 19, 20]

Precedents Considered – The Supreme Court considered various precedents where similar trivial errors in application forms were condoned. [Paras 16-17]

Supreme Court Decision – Candidature Restoration – The Court set aside the High Court's judgment, directing the State to consider the appellant as having passed the selection process and issue an appointment letter, if otherwise qualified. In case of no vacancy, an appointment letter is still to be issued, with the possibility of adjusting the vacancy in future recruitments. [Paras 25-26]