Definition of "Teacher" – Sports Officer/PTI in JNKVV – PTI/Sports Officer falling within the definition of “teacher” under the JNKVV Act and Statute – Appellant entitled to retire at 62 years like other teachers – Impugned order setting aside the single judge's decision reversed – Appellant's premature retirement at 60 years deemed improper. [Paras 3, 4, 5, 8, 9, 12]

Interpretation of Statutes and Regulations – Examination of the JNKVV Act, Statute, and Regulations – No specific mention of duties of PTI/Sports Officer – Decision based on inclusive definition of “teacher” in the Act – PTI/Sports Officer’s role in imparting sports education and training considered equivalent to teaching. [Paras 3, 4, 10]

Reliance on Precedents – Division Bench of High Court misapplied the decision of “State of Madhya Pradesh and Others v. Ramesh Chandra Bajpai” – Appropriate reliance on “P.S. Ramamohana Rao v. A.P. Agricultural University and Another” for interpreting the term “teacher” expansively. [Paras 6, 7, 9, 11]

Decision - Appeals allowed – Appellant P.C. Modi recognized as a “teacher”, entitled to retirement benefits as if retired at age 62 – Benefits to be paid within six weeks from the date of the order. [Para 12]

Conviction of Appellants under Sections 302 and 34, and Section 325 and 34 of IPC – Life imprisonment for offence under Section 302/34 and three years of rigorous imprisonment for offence under Section 325/34 – Patna High Court upheld the convictions – Accused no.3 (Paro Yadav) convicted only under Section 302 IPC; no Section 34 applied [Paras 1, 6]

Incident Details – PW4, the first informant, with PW5 and the deceased (Gholti Yadav) attacked by appellants and accused no.3 – Accused no.3 fired a bullet from a musket, causing the deceased's death – Assault on PW4 and PW5 by the accused [Paras 2, 9]

Motive – Previous altercation between accused no.3 and the deceased over a horse theft – Prosecution established the motive and involvement of the accused [Paras 3, 8-10]

Common Intention – Section 34 IPC applied due to appellants' presence and involvement in the assault with accused no.3 – Vicarious liability established despite lack of overt act by appellants in the fatal injury [Paras 6-7, 12]

Eyewitnesses' Testimony – Reliability of PW1 to PW5, despite being relatives of the deceased – High quality and consistent testimonies, corroborating prosecution's case [Paras 8-11]

No Adverse Inference – Non-examination of two potential eye-witnesses not detrimental to prosecution's case due to the strength of available testimonies [Para 8]

Dismissal of Appeal – Supreme Court finds no merit in the appeal – Appellants directed to surrender to serve the remainder of their sentence [Paras 13-14]

Withdrawal of Petition – Petitioner seeks withdrawal of the special leave petition after initial arguments – Petition dismissed as withdrawn with observations on the need for uniformity in handling bail applications. [Para 1]

Bail and Parity among Co-Accused – Case founded on claim of parity in bail, contrasting petitioner’s denial of bail with co-accused’s grant by High Court of Judicature for Rajasthan – Importance of considering Supreme Court judgments in similar cases highlighted. [Para 2]

Observations on Consistent Handling of Cases – Court’s concern over inconsistent decisions in bail matters from the same FIR – Emphasis on avoiding conflicting decisions and considering relevant factors for co-accused bail parity. [Para 3]

Precedent for Consistency – Reference to a three-Judge Bench order in SLP (Crl.) No. 7203 of 2023 on similar issues – Direction for listing FIR-related matters before the same judge for consistent orders. [Paras 4-5]

Directive to High Courts – Order to communicate this decision and SLP (Crl.) No. 7203 of 2023 order to all High Courts for implementation – Aimed at ensuring uniformity and consistency in judicial decisions across similar cases. [Para 6]

Civil Appeals - Challenge to High Court's judgment upholding merger of cadres in Education Department - Appellants sought quashing of the merger order - Policy decision of merger generally not interfered with - Examination of posts, responsibilities, and pay scales found them to be at the same level - No grounds to interfere with High Court's judgment - Appeals dismissed. [Para 4-6]

Personal Liberty - The appellants challenged the merger order affecting their seniority in the Education Department - However, the delay in raising the issue, promotions, and retirements over 24 years since the merger, show that immediate aggrieved officers did not challenge the merger - No violation of personal liberty found in the merger decision. [Para 5-6]

Decision - The Supreme Court upheld the High Court's judgment dismissing the appeals challenging the merger of cadres in the Education Department. [Para 7]

Criminal Appeal – Conviction for Culpable Homicide Not Amounting to Murder – Appellant challenging High Court's judgment modifying conviction from murder to culpable homicide under Section 304 Part II, IPC – review the evidence and High Court's findings. [Para 1, 8]

Prosecution Case – Incident of Assault and Subsequent Death – Prosecution alleging appellant assaulted the victim, leading to his death – Initial conviction for murder by Sessions Court, later modified to culpable homicide by High Court. [Para 2, 3]

Appellant’s Arguments – Allegations of Misinterpretation of Evidence and False Implication – Appellant's counsel arguing about misinterpretation of evidence by High Court and withholding of key witnesses by prosecution, raising questions about the actual cause of victim's death. [Para 4, 5]

Respondent’s Arguments – Support for High Court's Reasoning and Judgment – Respondent's counsel defending the High Court's judgment, emphasizing the credibility of eyewitnesses and medical evidence linking the death to the assault. [Para 6, 7]

Analysis of Evidence – Scrutiny of Witnesses and Circumstances – Supreme Court meticulously examining FIR, witness testimonies, medical evidence, and other circumstances, especially focusing on inconsistencies and missing evidence. [Para 9-24]

Acquittal of Appellant – Supreme Court finding the evidence insufficient to establish culpable homicide beyond reasonable doubt, leading to appellant's acquittal and discharge from bail bonds. [Para 25, 26]

Decision – High Court’s Judgment Set Aside – Supreme Court setting aside the High Court’s judgment, leading to the appellant's release unless required in other cases. [Para 26]

Trial Court Conviction and High Court Acquittal – Six accused convicted under IPC Sections 148, 201/149, and 302/149 for murder, sentenced to life imprisonment and fine by the Court of Sessions – High Court set aside this conviction and sentence, leading to the present appeal by the appellant/complainant Chhote Lal. [Paras 2-3]

Disputed Incident Details – Incident dated 04.11.2000 involving the murder of Kishan Sarup, allegedly by the six accused – FIR lodged by appellant/complainant Chhote Lal, an eyewitness to the initial assault but not to the murder or burning of the body. [Paras 5-6, 8-9]

Questionable Eyewitness Testimony – Appellant/complainant, the sole eyewitness and father of the deceased, did not witness the actual killing or burning of Kishan Sarup – His presence during the incident and credibility of testimony brought into question due to the long-standing enmity with the accused group. [Paras 9-13]

Evidence Insufficiency and Reasonable Doubt – Prosecution failed to establish the guilt of the accused beyond reasonable doubt – Lack of complete circumstantial evidence chain and doubts about the presence and testimony of the sole eyewitness. [Paras 14]

Decision – The Supreme Court concurred with the High Court's view, extending the benefit of doubt to the accused persons – Appeal dismissed as lacking merit. [Paras 14-16]

Writ Petition (Criminal) – Consolidation of FIRs – Petitioner seeking consolidation of multiple FIRs registered in different states – Contention that cases are unrelated and should be consolidated for a fair and speedy trial – Disagreement by Respondents – Examination of pending cases – Decision to consolidate FIRs registered in the State of Madhya Pradesh – Transfer of cases to the District of Devas, Madhya Pradesh – Jurisdictional courts directed to take immediate steps for consolidation and adjudication by one trial – Rejection of transfer of cases from Karnataka and Jharkhand to Madhya Pradesh. [Para 1-7]

Limitation Act – Applicability to proceedings under the Jogighopa (Assam) Unit of Ashok Paper Mills Limited (Acquisition Transfer of Undertaking) Act, 1990 – Whether Article 116 of the Limitation Act 1963 applies – Held that the Jogighopa Act is not governed by the prescription of limitation under Article 116 of the Limitation Act, 1963, as the appeal thereunder, from an order of the Commissioner of payments cannot be said to be an appeal under the Code of Civil Procedure, 1908 for the Legislature of the State of Assam has been categorical in limiting the application of the code to certain aspects of the Act only. Given that the Jogighopa Act allows for a Judge of the High Court to be the Commissioner of Payments and then categorically provides for an appeal to lie therefrom, Division Bench of the High Court further evidences the sui generis nature of the appeal procedure provided therein. [Para 30.1]

Maintainability of Appeal – In the absence of a prescribed period of time for filing an appeal – Governed by the principle of ‘reasonable time’ – Held that the appeal is not barred by time as it was filed within a reasonable time, considering the sequence of events and the absence of a specific period of limitation. [Para 30.2]

Decision – The appeal is allowed, and the file is restored to the docket of the concerned District Judge for further proceedings. The District Judge is directed to decide the matter possibly within a period of three months from the date of this judgment and order. [Para 31]

Caste Certificate Cancellation – Challenge to High Court’s decision – High Court upheld the cancellation of the caste certificate of respondent No. 15 and related land sale transactions under the West Bengal Land Reforms Act, 1955 – Supreme Court examined the legality of High Court’s decision. [Para 1-2, 21-22]

Land Sale Transactions – Scheduled Tribes Land Protection Under West Bengal Land Reforms Act, 1955 – Dispute regarding whether respondent No. 15, belonging to Scheduled Tribe community, required permission for land sales – Examination of various land transactions by late father of respondent No. 15 and subsequent sales by respondent No. 15. [Para 3-8, 26-28]

Caste Certificate Authenticity and Misrepresentation – Respondent No. 15’s caste certificate as ‘Chik Baraik’ (Scheduled Tribe) and subsequent affidavits claiming belonging to general caste – Investigation into the validity of caste certificate and related land sales. [Para 4-6, 11, 31-33]

Judicial Review of Caste Certificate Cancellation – Examination of the procedure followed for cancellation of respondent No. 15’s caste certificate – Actions by various authorities including SDO, District Magistrate, and Committee in handling the caste certificate issue. [Para 10-11, 13-18, 33-35]

Committee Jurisdiction and Retrospective Amendment – Analysis of Committee’s jurisdiction in caste certificate cancellation matters under Section 8A of the West Bengal Scheduled Castes and Scheduled Tribes (Identification) Act, 1994 – Consideration of whether the 2017 amendment to the Act is retrospective. [Para 38]

Final Decision and Rationale – Supreme Court’s decision allowing the appeal, setting aside High Court’s judgment – Detailed reasoning considering the conduct of respondents and undisputed facts about respondent No. 15’s late father not belonging to Scheduled Tribe community. [Para 39-41]