Criminal Law – Child Witness Testimony – The Supreme Court evaluated the reliability of a child witness in a case involving murder and dacoity. The Court held that while the testimony of a child witness must be scrutinized with care and caution, it is not to be rejected solely based on the age of the witness. However, in this case, due to inconsistencies and lack of corroboration, the testimony was deemed unreliable [Paras 22-26].

Evidence Act – Fingerprint Evidence – The Court discussed the admissibility and reliability of fingerprint evidence, emphasizing that such evidence must be supported by a clear chain of custody and proper procedural safeguards. In the absence of link evidence and proper methodology, the fingerprint evidence was not considered sufficient to sustain a conviction [Paras 30-32].

Criminal Law – Circumstantial Evidence – The Supreme Court reiterated that in cases relying on circumstantial evidence, all incriminating facts must be fully established and consistent only with the guilt of the accused. The presence of fingerprints on certain items was not deemed adequate to infer the accused's guilt beyond a reasonable doubt, especially when other substantive evidence was lacking [Paras 33-34].

Decision – Appeals allowed – Held – The convictions of the accused under Section 396 IPC and related provisions were overturned. The Court granted the benefit of doubt to the accused due to the unreliable child witness testimony and insufficient fingerprint evidence [Paras 27-29, 35].

Banking Conduct – Misappropriation and Integrity – The Supreme Court discussed the necessity for bank employees to exhibit absolute devotion, integrity, and honesty, especially given their responsibility for handling depositors' and customers' money. The Court highlighted that failure to observe these standards impairs public confidence in the banking system. The Supreme Court overturned the High Court's decision, which had set aside the respondent's dismissal for lack of procedural fairness and non-speaking orders by the disciplinary authority. The Court found that the disciplinary and appellate authorities had indeed considered the evidence and provided reasoned orders [Paras 1-15, 20-42].

Dismissal and Procedural Fairness – The Court considered whether the disciplinary authority’s disagreement with the enquiry officer’s findings was procedurally flawed and prejudiced the respondent. It held that although procedural fairness was essential, the respondent's other proven charges justified the dismissal. The Supreme Court emphasized that the High Court had erred in setting aside the dismissal solely based on procedural lapses related to one charge, while the other charges, which were severe, remained unchallenged and supported the dismissal [Paras 16-19, 35-38].

Judicial Review – Scope and Limitations – The Supreme Court reiterated the limits of judicial review in disciplinary matters, stating that it should focus on correcting errors of law, procedural errors, or violations of natural justice, rather than re-evaluating the merits of the decision. The Court found that the High Court overstepped these limits by reassessing the findings of the disciplinary proceedings [Paras 23-25, 39-41].

Decision – Appeal allowed – Held – The Supreme Court set aside the High Court’s judgment and restored the disciplinary authority's order of dismissal. The Court underscored the importance of maintaining integrity in banking and upheld the disciplinary action taken against the respondent [Paras 43-44].

Contract Law – Concluded Contract – The Supreme Court analyzed whether the acceptance of a conditional offer with a further condition results in a concluded contract. The Court held that acceptance must be absolute and unqualified to form a concluded contract. The acceptance of a conditional offer with an additional condition does not constitute a concluded contract unless the original proposer accepts the new condition without qualifications. This aligns with Section 7 of the Indian Contract Act, 1872, which mandates absolute and unqualified acceptance for the formation of a valid contract [Paras 1-19, 55-59].

Contract Law – Offer and Acceptance – The Court underscored the fundamental principles of offer and acceptance, stating that an acceptance with variations is essentially a counter-offer that must be accepted by the original proposer to result in a contract. It emphasized that mere agreement on some terms does not constitute a binding contract if essential terms are still under negotiation [Paras 20-24, 56-58].

Judicial Review – The Supreme Court criticized the High Court and Trial Court for overlooking the main point regarding the conditional acceptance of the tender offer. The Courts below failed to consider that the counter-proposal by the Respondent was not unconditionally accepted by the Appellant, thus, there was no concluded contract. The Supreme Court set aside the lower courts' decisions and ruled in favor of the Appellant, ordering the refund of the earnest money deposited [Paras 59-62].

Decision – Appeal allowed – Held – The appeal was allowed, and the judgment of the High Court and the Trial Court was set aside. The Court declared that there was no concluded contract between the parties, and therefore, no question of breach or damages. The Appellant was entitled to a refund of the earnest money deposited with interest [Paras 61-62].

Motor Accident – Compensation – Future Prospects – The Supreme Court held that future prospects could be granted even in cases pertaining to notional income. Once the victim is proven to be employed, the necessary corollary is that they would be earning an income, and future prospects must be considered to provide just compensation, taking into account inflation and the quest for better circumstances​​.

Motor Accident – Death of Married Couple – Assessment of Income – The Court noted that the claimants were unable to produce documents evidencing the deceased's income or employment. However, this does not justify adopting the lowest tier of minimum wage for computing income. The Court emphasized maintaining the deceased's family standard of living and applied the minimum wage for skilled workers​​.

Motor Accident – Compensation – Notional Income – The Court recognized that notional income determination must consider the effects of inflation and improvements in skills over time. Future prospects should be awarded on notional income, recognizing the homemaker's contributions to the household and society​​.

Compensation for Homemakers – The Court affirmed that compensation for homemakers on a pecuniary basis is a settled proposition. It highlighted the gendered nature of housework and the need to recognize homemakers' work and sacrifices, reflecting changing societal attitudes and international obligations​​.

Decision – Appeals allowed – Held – The total compensation awarded by the High Court was increased. The Court ordered the enhanced compensation amount to be paid within two months with interest from the date of filing the Detailed Accident Report. The Court also laid down general observations regarding notional income calculation for homemakers and future prospects​​.

Motor Vehicles Act – Hypothecation Entry and Fraudulent Documentation – The Supreme Court examined the validity of the High Court's order for the release of a vehicle based on a forged clearance certificate. The High Court failed to consider that the hypothecation entry in the original registration certificate was fraudulently removed by the original owner using a forged Form 35. The Regional Transport Officer (RTO) had cancelled the registration certificate upon discovering the forgery, rendering the subsequent transfer and registration null and void. The Court emphasized that the respondent had no right to claim the vehicle based on fraudulent documentation [Paras 1-23].

Procedural Aspects and Legal Implications – The Court detailed the procedural history, including the original owner's failure to repay the loan and the arbitration award in favor of the appellant. It highlighted the fraudulent actions taken to cancel the hypothecation entry and transfer the vehicle. The Court underscored that legal transfers and registrations must adhere to statutory requirements and cannot be based on fraudulent acts. The RTO's order, which nullified the fraudulent registration, was a crucial factor overlooked by the High Court [Paras 3-16, 20-21].

Decision – Appeal allowed – Held – The Supreme Court set aside the High Court's order and directed the release of the vehicle in favor of the appellant. The Court ordered the Chief Judicial Magistrate of Sitapur to ensure the vehicle's retrieval from the respondent and its release to the appellant on appropriate terms and conditions within four weeks [Para 23].

Service Law – Appointment of Warden – The Supreme Court held that the Governing Body of the College is the authority to appoint the Warden of the College Hostel. The Court emphasized that the Principal, being the Executive head of the College, is in a position to know the members of the staff. Thus, applications for the Warden's post should be invited through the Principal, who will then make recommendations to the Governing Body. The Governing Body, taking into account the Principal's recommendations, will decide the appointment [Paras 1-36].

Governing Body's Authority – The Court noted that the Governing Body has general supervision and control over the affairs of the College and is responsible for administrative appointments, including that of the Warden. The Division Bench's directions requiring the applications to be placed before the Staff Council were deemed unnecessary, as the Staff Council is not statutorily empowered to make recommendations for the Warden's appointment [Paras 20-32, 36-41].

University Grants Commission (UGC) Letter – The Court clarified that the UGC letter dated 19.02.1987 does not confer authority on the Principal to appoint the Warden. It merely suggests that the Warden should be appointed from among the senior teachers in the College, but it does not override the administrative authority of the Governing Body [Paras 20-26].

Decision – Appeal allowed – Held – The Supreme Court set aside the directions in paragraph 41 of the Division Bench's judgment. It affirmed that the Governing Body, with the recommendation of the Principal, should initiate the process for appointing the Warden of the College Hostel. The Court directed the Governing Body to commence the process for the appointment before the Hostel reopens [Paras 36-41].

Constitutional Law – Contempt of Court – Articles 129 and 142 of the Constitution – The Supreme Court has inherent powers as a Court of Record to punish for contempt – These powers cannot be abridged or taken away even by legislative enactment – Comparison of Articles 129 and 142 shows no restriction on the Supreme Court's powers to punish for contempt, unlike clause (2) of Article 142 which can be subject to any law made by Parliament [Paras 9-10, 31].

Contempt Proceedings – Scandalising the Court – The raison d'être of contempt jurisdiction is to maintain the dignity of judicial institutions – Not a vindictive exercise but necessary when persistent and unwarranted attacks are made against the judiciary – Repeated unjustified allegations and attempts to scandalise the court amount to contempt – Apologies, if not genuine, do not mitigate the offense [Paras 1, 20, 33].

Judicial Precedent – Roshan Lal Ahuja In Re – The Court reaffirmed the principles laid down in previous cases like Roshan Lal Ahuja In Re and others where motivated attempts to malign judiciary's reputation warranted strict action – Apologies must be sincere and demonstrate remorse, not serve as a tactic to avoid consequences [Paras 27-33].

Decision: Contemnor is found guilty of contempt – Conduct aimed at scandalising the court cannot be countenanced – Sentencing deferred to allow the contemnor a chance to be heard on the issue of final sentence [Paras 33-34].

Facts: The appellant, Bharati Reddy, was elected to the post of Adhyaksha of Zilla Panchayat. A writ petition was filed before the High Court alleging that Reddy played fraud on the government by submitting a false affidavit for the issuance of an Income and Caste Certificate.

Issues:

Whether the High Court was justified in issuing a writ of quo warranto directing Reddy to vacate the office of Adhyaksha.

Whether the Income and Caste Certificate issued to Reddy was valid.

Whether the discrepancies in Reddy's affidavits warranted her disqualification from holding the office.

Held:

The post of Adhyaksha of Zilla Panchayat is a public office for which a writ of quo warranto can be issued if the incumbent is ineligible or incurs disqualification (Para 13).

The High Court erred in issuing the writ of quo warranto without first determining the validity of the Income and Caste Certificate issued to Reddy. The certificate's validity was to be determined by the Caste Verification Committee (Para 22).

Discrepancies in Reddy's affidavits and the expedited issuance of the certificate did not automatically invalidate it. The Caste Verification Committee was tasked with investigating these matters (Para 20-21).

The High Court's decision to leave the question of the certificate's validity to the Caste Verification Committee was correct. The Committee should expedite its inquiry (Para 37).

Decision: The decisions of the Single Judge and the Division Bench of the High Court were set aside. The Caste Verification Committee was directed to expedite its inquiry into the validity of the Income and Caste Certificate issued to Reddy and conclude the same preferably within a stipulated period (Para 38).

Facts:

The appellant, Jagdish, was injured in a motor accident on November 24, 2011, resulting in severe injuries.

The accident occurred when Jagdish, riding a motorcycle, was hit by a dumper, causing 90% permanent disability.

Issues:

The appellant sought an enhancement of compensation on several grounds, including loss of future prospects, computation of disability, and increase in monthly income.

Held:

The Court determined that the appellant's claimed monthly income of Rs. 6,000/- was reasonable and allowed it for computation.

Considering the severity of disability, the Court held that the disability was 100% and increased the compensation accordingly.

The total compensation awarded to the appellant was Rs. 25,38,308/- along with interest at the rate of 9% per annum.

The Court directed the amount to be deposited before the Tribunal within a specified period.

The appeal was allowed, and no order was made regarding costs.