Dowry Death – Quashing of Chargesheet – FIR named multiple family members without specific allegations – Appellants (brother-in-law and mother-in-law of the deceased) had alibis, with the brother-in-law at work 40 km away at the time of the incident – Postmortem revealed asphyxia as cause of death with no external injuries except ligature mark – High Court's order directing appellants to seek bail set aside – Chargesheet quashed for lack of specific allegations and evidence [Paras 1-13].

Specific Allegations – Legal Requirement – Emphasis on need for specific allegations against accused in dowry death cases – Casual naming of family members without detailed involvement considered an abuse of judicial process – Citing Geeta Mehrotra and Anr. v. State of Uttar Pradesh and Anr. (2012) 10 SCC 741, court reiterated quashing of proceedings in absence of specific accusations [Paras 10-12].

Decision – Appeals allowed – High Court’s order set aside – Chargesheet and cognizance order quashed – Noting abuse of judicial process in implicating family members without substantial evidence [Paras 13].

Insolvency Resolution – Threshold for Admission – Adjudicating Authority's jurisdiction under Section 7 of IBC is limited to ascertaining the existence of default and admitting or rejecting the application accordingly – NCLT cannot dismiss the petition on the basis that the corporate debtor is exploring settlement possibilities without addressing the merits of the petition – Appeals allowed, orders set aside [Paras 1-36].

Jurisdiction of Adjudicating Authorities – Powers under IBC – NCLT and NCLAT overstepped their jurisdiction by directing parties to settle disputes and failing to admit the petition despite clear evidence of default – IBC provides a statutory framework where Adjudicating Authorities cannot act beyond their conferred powers – Petition restored to NCLT for fresh consideration [Paras 27-33].

Decision – Appeals allowed – NCLT and NCLAT orders set aside – Petition under Section 7 of IBC restored for disposal afresh by NCLT – Impleadment applications disposed of with liberty to applicants to adopt appropriate proceedings in accordance with law [Paras 34-36].

Criminal Breach of Trust by Public Servant – Proof of Entrustment – Section 409 IPC pertains to criminal breach of trust by a public servant – Prosecution must prove that the accused was entrusted with the property and dishonestly misappropriated or used it – Mere retention of property without misappropriation does not constitute criminal breach of trust – Essential ingredients: entrustment, dishonest misappropriation, and dishonest use [Paras 41-45].

Cheating and Dishonestly Inducing Delivery of Property – Section 420 IPC – Requires proof of deception, fraudulent inducement, and dishonest intention at the inception of the transaction – Mere breach of contract cannot give rise to criminal prosecution under Section 420 IPC unless fraudulent or dishonest intention is shown from the beginning [Paras 46-48].

Falsification of Accounts – Section 477-A IPC – Prosecution must prove destruction, alteration, or falsification of accounts by a clerk, officer, or servant with intent to defraud – Evidence must show wilful act and intent to defraud [Paras 49-50].

Evidence and Burden of Proof – Non-examination of key witness (B. Satyajit Reddy) materially fatal to prosecution – Handwriting expert’s testimony supported appellant’s version – No financial loss caused to the Bank or the depositor – Benefit of doubt given to appellant due to inconsistent and insufficient evidence [Paras 61-67].

Decision – Appeals allowed – Conviction and sentence under Sections 409, 420, 477-A of the IPC and Section 13(2) read with Section 13(1)(d) of the PC Act set aside – Appellant acquitted of all charges [Para 67].

Hindu Law – Karta’s Power to Alienate – A Karta may alienate joint family property for value either for legal necessity or for the benefit of the estate to bind the interests of all the undivided members of the family whether they are adults, minors, or widows – No specific grounds to prove legal necessity; it depends on the facts of each case – Karta’s discretion in fulfilling legal necessity, although not beyond challenge on the grounds of lack of existence of legal necessity or absence of benefit to the estate [Paras 1-30].

Limitation for Challenging Alienation – Suit for declaration and cancellation of the relinquishment deed filed nearly 24 years after execution – Governed by Article 109 of the Limitation Act, providing 12 years from the date the alienee takes possession – Suit barred by limitation as filed well beyond the prescribed period [Paras 31-34].

Decision – Appeal dismissed – High Court's judgment upheld – Suit barred by limitation [Paras 34].

Appeal in Case of Acquittal – Section 378 CrPC – State’s right to appeal against acquittal – Appellate Court's duty to consider whether the trial court’s decision is plausible and possible – Double presumption of innocence for acquitted persons – Importance of the trial court's advantage of observing witnesses in person – High Court must undertake deeper scrutiny and ensure the trial court's findings are not perverse before overturning acquittal [Paras 20-23].

Dying Declaration – Evidence – High Court erroneously relied on dying declaration not supported by credible witness testimony – Trial court correctly rejected the dying declaration based on inconsistencies and lack of corroboration – High Court’s approach critiqued for not addressing detailed trial court reasoning [Paras 24-32].

Merits of Evidence – High Court overlooked discrepancies in key witness testimonies and failed to consider trial court's detailed analysis – Importance of trial court’s advantage in evaluating witness credibility – Reversal of acquittal found unjustified [Paras 24-33].

Decision – Appeals allowed – High Court’s conviction set aside – Trial court's acquittal upheld – Orders of conviction by High Court overturned [Para 33].

NDPS Act – Bail – Recovery of psychotropic substances – Seizure of 137,665 tablets collectively weighing approximately 90 kg from four locations – Confessional statements recorded under Section 67 of NDPS Act held inadmissible in trial as per Tofan Singh v. State of Madras [2021] 4 SCC 1 – Absence of clarity on quantitative analysis of samples – Prosecution’s inability to establish possession of commercial quantity – Bail granted to A-4 and A-1 [Paras 1-12].

Evidentiary Standards – Reliance on Statements under Section 67 NDPS – Confessional statements alone insufficient for prosecution in absence of supporting evidence – Reliance on electronic communications (WhatsApp messages) and financial transactions insufficient without scientific analysis of devices – Bail granted due to lack of direct evidence linking appellants to the contraband [Paras 6-11].

Decision – Appeals allowed – Impugned order of the High Court quashed – Bail order of the Special Judge restored for Bharat Chaudhary (A-4) – Raja Chandrasekharan (A-1) granted bail as charge sheet filed and prolonged custody considered [Para 12].

Election Petition – Non-submission of Form 25 – Appellant contested 2019 elections from 16 Hassan (General) Parliamentary Constituency, alleging respondent no.1 filed a false affidavit and secured election by suppressing material facts – Respondent no.1 sought dismissal for non-compliance with Section 83(1) proviso of the RP Act, requiring Form 25 affidavit – High Court dismissed the petition – Supreme Court held non-submission of Form 25 is a curable defect – Election petition should not be dismissed at threshold – Appeal allowed, petitioner granted opportunity to file Form 25 affidavit [Paras 1-27].

Verification of Petition – Technical vs. Hyper-technical Compliance – Substantial compliance with Section 81(3) by verifying the petition and copies – Non-signing of index and synopsis not fatal – Allegations against respondent fall within broader ambit, requiring trial [Paras 20-25].

Opportunity to Cure Defects – Previous decisions support allowing petitioner to cure affidavit defect – High Court should permit filing of proper affidavit instead of dismissing petition summarily [Paras 22-24].

Decision – Appeal allowed – High Court's order set aside – Application under Order VII Rule 11 dismissed – Appellant granted 15 days to file Form 25 affidavit – Urgent trial of the election petition directed [Para 27].

Compassionate Appointment – Assessment of Family Pension – Appellant rejected respondent's application for compassionate appointment based on merit points, considering family pension of Rs 8265 per month – Tribunal and High Court directed reconsideration, stating pension would reduce to Rs 4959 after ten years – Supreme Court held pension on date of consideration is relevant – Policy mandates considering financial position at time of application – Compassionate appointment is to tide over immediate crisis, not a vested right – Appeal allowed, High Court's judgment set aside [Paras 1-14].

Evaluation Criteria – Pension is not an extraneous circumstance – Authorities must evaluate financial position per policy – Reassessment after ten years not a basis to discard current pension – Uniform criteria applied to all applicants – Granting appointment contrary to scheme's objective [Paras 10-13].

Decision – Appeals allowed – High Court’s judgment and order set aside – OA filed by respondent dismissed [Para 14].

Consumer Law – Limitation for Filing Complaint – Respondent's registration for house allotment under General Registration Scheme, 1985, was cancelled in 2000 for non-payment of seed money – Respondent filed consumer complaint in 2011 after Housing Board's 2009 policy decision on restoration of cancelled registrations – Supreme Court held complaint time-barred under Section 24A of Consumer Protection Act – Cause of action arose on cancellation date, not policy decision – Consumer forums must adhere to limitation period – Appeals allowed, NCDRC's order set aside [Paras 1-14].

Evaluation of Default and Restoration Policy – No formal allotment made – Respondent failed to pay seed money despite multiple notices – Registration cancellation in 2000 undisputed – 2009 policy not applicable as cancellation due to respondent's default – Complaint filed beyond two-year limitation period – Consumer forum's order erroneous [Paras 8-11].

Decision – Appeals allowed – NCDRC’s judgment set aside – Appellant to refund registration money if respondent unwilling to accept allotment at current rates [Para 14].