Criminal Law - Murder - Indian Penal Code 1860 - Sections 302, 307 and 498A - Appellant-husband convicted for murder of wife who died of acute burn injuries - Trial Court convicted and sentenced to life imprisonment which was affirmed by High Court - Supreme Court noted severe discrepancies in dying declarations and suspicious delay in registering FIR - Post-mortem showed 96 percent burns creating doubt on homicidal nature and victim fitness to give statements - Close relatives turned hostile and supported suicide theory due to ailments - Held - prosecution failed to prove a single incriminating circumstance and reasonable doubt exists regarding homicidal death - appeal allowed and appellant acquitted - [Paras 1-14].

Evidence Law - Dying Declaration - Indian Evidence Act 1872 - Section 32 - Reliability - Two inconsistent dying declarations recorded - First dying declaration recorded by a Head Constable whose signature was not proved by the Sub-Inspector and registered as FIR after an unexplained delay of 15 hours - Second dying declaration recorded by Executive Magistrate while medical evidence showed 96 percent burns casting doubt on consciousness and fitness of deceased - Held - dying declarations are highly suspicious and unreliable - [Paras 10-13].

Evidence Law - Hostile Witness - Indian Evidence Act 1872 - Section 154 - Testimony of close relatives - Sister, cousin, and mother of the deceased deposed in cross-examination that deceased committed suicide due to ailments and denied any marital discord - High Court brushed aside testimony assuming witnesses were won over without declaring them hostile or confronting them with Section 161 statements through the Investigating Officer - Held - testimony in court must be relied upon and High Court erred in rejecting their version - [Paras 7-9].

Criminal Law - Burden of Proof - Indian Evidence Act 1872 - Section 106 - Applicability - Death by burns occurring in the marital home - Prosecution relied on absence of explanation by husband under Section 106 - Held - burden under Section 106 does not shift until prosecution discharges initial burden of establishing foundational facts and circumstances proving guilt beyond reasonable doubt - [Paras 1-13].

Decision: Appeal allowed – Conviction and sentence set aside – Appellant acquitted of all charges and directed to be set free forthwith if not required in any other case.

Securities Law - Insider Trading - Securities and Exchange Board of India Act 1992 - Sections 11, 11B, 12A, 15G, 15J, 15Z - Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations 2015 - Regulation 4(1) and Note thereto - Legitimate Corporate Purpose - Avoided Loss - Appeal challenging SAT's quashing of WTM's order finding respondents guilty of insider trading - Respondents, including the Chairman and Managing Director and his daughters (promoters/VPs) of Tara Jewels Limited (TJL), sold substantial shareholdings during the Unpublished Price Sensitive Information (UPSI) period (02.10.2017 to 29.11.2017) when TJL faced significant losses and entered liquidation, thereby avoiding approximately Rs.1.38 crores in losses - WTM imposed market bans, disgorgement with interest, and monetary penalties under Section 15G and 15HB SEBI Act - SAT allowed respondents' appeal, holding their explanation that TJL was at risk of being downgraded to a non-performing asset was a sufficient defence under the proviso to Regulation 4(1) of PIT Regulations 2015, and noted minimal price difference after trades - Supreme Court found that respondents were undisputedly in possession of UPSI and sold shares while possessing it - The 'note' appended to Regulation 4(1) of PIT Regulations 2015 explicitly states that "the reasons for which he trades or the purposes to which he applies the proceeds of the transactions are not intended to be relevant for determining whether a person has violated the regulation" - This note distinguishes the 2015 Regulations from the predecessor 1992 Regulations (under which SEBI v. Abhijit Rajan was decided), where such intent could be considered - The argument of legitimate corporate purpose or rerouting funds for the company, even if true, is irrelevant under the 2015 Regulations - Lack of profit or even less profit is inconsequential - The disgorgement order by WTM for loss avoided was justified under Section 11B of the SEBI Act - Held - SAT erred in quashing the WTM's order; the WTM's findings of insider trading and disgorgement order are restored - [Paras 2.3, 3, 4, 10, 11, 14, 16, 19].

Securities Law - Insider Trading - Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations 2015 - Regulation 4(1) - Note thereto - Irrelevance of motive - Once possession of Unpublished Price Sensitive Information (UPSI) and trading while in its possession is established, the 'note' to Regulation 4(1) renders the reasons for trading or the application of proceeds irrelevant for determining a violation - This principle marks a significant departure from the position under the 1992 PIT Regulations, which allowed consideration of intent or purpose for trades - Held - The purpose for which proceeds are employed is an irrelevant consideration in determining insider trading under the 2015 Regulations - [Paras 9.7, 11, 14, 15, 18, 19].

Interpretation of Statutes - Ejusdem Generis - Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations 2015 - Regulation 4(1) - "Including" - The word "including" preceding the list of defences in Regulation 4(1) of the PIT Regulations 2015 indicates that the listed defences are not exhaustive - However, applying the rule of ejusdem generis, any other potential defences must be of the "same and similar nature" as those explicitly provided - Held - The six defences provided in Regulation 4(1) are illustrative, but any other acceptable defences must align with their nature - [Paras 12, 13].

Securities Law - Penalty - Securities and Exchange Board of India Act 1992 - Section 15G - Quantum of penalty - While upholding the findings of insider trading and disgorgement, the Supreme Court reviewed the monetary penalty imposed by the WTM - Taking a cumulative view of facts and circumstances, the penalty of Rs.25 Lakhs under Section 15G for Respondent No.1 was found excessive compared to Rs.10 Lakhs imposed on Respondents No.2 and 3 - Held - The penalty under Section 15G for Respondent No.1 is reduced from Rs.25 Lakhs to Rs.10 Lakhs, aligning it with the penalty for other respondents - [Para 18].

Decision: Appeal allowed – SAT's order set aside – WTM's order restored with modification – Penalty under Section 15G for Respondent No.1 reduced from Rs.25 Lakhs to Rs.10 Lakhs – Penalties to be paid within three months.

Civil Law - Maintenance - Hindu Marriage Act 1955 - Sections 24 and 26 - Enhancement of interim and child maintenance - Appellant-wife instituted divorce proceedings and sought maintenance - Family Court awarded interim maintenance for minor children - High Court enhanced child maintenance to Rs 1,25,000 per month and closed contempt proceedings against respondent-husband - Supreme Court on further appeal evaluated husband's net disposable income and voluntary nature of certain deductions like ESPPs and Provident Funds - Supreme Court enhanced monthly maintenance for both children to Rs 1,50,000 and enhanced appellant-wife's personal maintenance to Rs 30,000 per month considering medical expenses for aggressive breast cancer - Held - quantum of maintenance further enhanced - appeal disposed of - [Paras 1-25].

Civil Law - Deduction Analysis - Hindu Marriage Act 1955 - Section 24 - Determination of net disposable income - Voluntary versus mandatory deductions - Husband claimed deductions towards Provident Fund and Employee Stock Purchase Plans - Supreme Court held that Provident Funds and ESPPs are ultimately benefits that accrue to the husband and can be withdrawn in the future unlike mandatory income tax and professional taxes - Held - voluntary deductions cannot be used to reduce monthly income for maintenance calculations - [Paras 19-20].

Civil Law - Medical Expenses and Personal Maintenance - Hindu Marriage Act 1955 - Section 24 - Interim maintenance for spouse - Appellant-wife diagnosed with aggressive breast cancer during pendency of proceedings - High Court earlier granted personal maintenance which was omitted in final order - Supreme Court restored and enhanced personal maintenance to Rs 30,000 per month keeping in mind treatment expenses and care of children - Held - medical condition of spouse is a vital factor in determining quantum of maintenance - [Paras 21-22].

Decision: Civil appeals disposed of – Monthly maintenance for both children enhanced to a total of Rs 1,50,000 effective from 1st January 2025 – Personal maintenance for the appellant-wife enhanced to Rs 30,000 per month – Respondent-husband directed to comply with all undertakings and directions within three months.

Criminal Law - Culpable homicide not amounting to murder - Indian Penal Code 1860 - Sections 302, 304 Part II and 34 - State appeal against High Court judgment altering respondents conviction from murder to culpable homicide not amounting to murder and reducing sentence to six years rigorous imprisonment - Trial Court convicted respondents under Section 302 read with Section 34 IPC and sentenced them to life imprisonment - High Court altered conviction to Section 304 Part II IPC based on surmises and conjectures while noting material inconsistencies in prosecution evidence - Supreme Court observed that High Court findings were based on surmises but held that evidence on record including doubtful dying declaration and major inconsistencies regarding scene of occurrence and presence of witnesses was insufficient to restore conviction under Section 302 IPC - Held - appeal dismissed as respondents served sentence and modified conviction remained unchallenged - [Paras 1-18].

Evidence Law - Dying Declaration - Indian Evidence Act 1872 - Section 32 - Reliability - Detailed blow by blow account by seriously injured victim with twenty-two injuries - Doctor admitting likelihood of tranquilizers and loss of consciousness - Overwriting in police records and medical intimation times creating serious doubt - Held - detailed narration by severely injured victim under treatment raises serious doubt as to voluntary nature and physical fitness - [Paras 11-14].

Evidence Law - Witness Testimony - Indian Evidence Act 1872 - Section 3 - Material inconsistencies - Eyewitness turning hostile - Discrepancies between witnesses regarding scene of occurrence and mode of shifting victim to hospital - Held - inconsistencies in prosecution evidence do not warrant interference with modified conviction - [Paras 8-15].

Decision: Criminal appeal dismissed – High Court judgment altering conviction to Section 304 Part II IPC and sentence of rigorous imprisonment for six years maintained.

Civil Law - Sale of Immovable Property - Transfer of Property Act 1882 - Section 54 - Execution of sale deeds for part consideration with balance retained to clear vendor debts - Plaintiffs filing suit for declaration of sale deeds as void and inoperative instead of seeking recovery of balance consideration - Trial Court and Appellate Court dismissing suit - High Court reversing in second appeal - Supreme Court holding that actual payment of entire sale price at the time of execution is not a sine qua non for completion of sale - title passes upon registration even on part payment - remedy lies in recovery of balance consideration and not cancellation of sale deed - Held - High Court judgment set aside and Trial Court decree restored - [Paras 1-18].

Civil Law - Second Appeal - Code of Civil Procedure 1908 - Section 100 - Scope of interference - High Court reversing concurrent findings of fact regarding validity of sale deeds - Supreme Court holding that High Court arrived at a wrong conclusion on available facts by treating sale as void for non-payment of balance consideration - Held - conclusion of High Court on available facts was erroneous - [Paras 6-14].

Decision: Appeal allowed - Judgment of the High Court reversed and that of the Trial Court as affirmed by the First Appellate Court restored - [Paras 1-18].

Environmental Law - Riverine Pollution - Environmental Protection - Rajasthan - Suo Moto Writ Petition (Civil) No. 8 of 2025 and connected appeals - State-wide environmental degradation including Jojari-Bandi-Luni river ecosystem contamination, untreated industrial effluent discharge, groundwater degradation, and systemic regulatory enforcement failures, revealed through reports of High-Level Ecosystem Oversight Committee and Special Investigation Team (SIT) - Court's previous interim directions included invocation of graver penal provisions under Bhartiya Nyaya Sanhita, 2023 Sections 272, 326(a), 326(c) and Prevention of Damage to Public Property Act, 1984 - State of Rajasthan submitted compliance reports detailing SIT's review of criminal cases, arrests, and preventive measures - SIT report indicated prima facie connivance amongst CETP officials and industrial units, but Court expressed concern over delayed promptness in invoking graver offences, mandating deeper probe into conspiracy and involvement of all persons including public servants - State's remedial actions noted for Jojari River, Sanganer-Dravyavati-Nevta textile units, and Morel Dam, alongside acceptance of recommendations for wastewater treatment at Ambey Valley and Khed HRTS/SEP sites and Nehda Dam - Court found severe degradation necessitated coordinated, multidisciplinary institutional response - Held - Supreme Court directed the State of Rajasthan to constitute an "Integrated Coordination Group" headed by the Chief Secretary within seven days and an independent "River Commission/River Rejuvenation Authority" under the Chief Secretary's chairmanship for integrated river management, including scientific determination of High Flood Line and protection of riverine ecosystems - Integrated Coordination Group to prepare a Comprehensive Resolution Plan within three weeks - SIT to intensify investigation; Committee to pass orders on White Category Industries' representations within seven days; State to establish Integrated Public Reporting and Environmental Grievance Redressal Mechanism using a QR Code-based digital platform; Chief Secretary to personally monitor compliance; details of action against RSPCB officers to be submitted - [Paras 1-33].

Environmental Law - Constitutional Law - Article 32 Constitution of India - Environmental Degradation - Suo Moto cognizance - Systemic failures - Inter-departmental coordination - Complex environmental issues necessitating integrated institutional response - Held - Supreme Court directed constitution of Integrated Coordination Group and an independent River Commission/Rejuvenation Authority - [Paras 18-19, 22, 33(A)-(G)].

Environmental Law - River Protection - High Flood Line - Ecological Buffer Zones - Indiscriminate industrial development - Encroachments on riverbeds and floodplains - Degradation of river ecosystem - Held - State directed to undertake comprehensive scientific exercise for determination and demarcation of High Flood Line and requisite ecological buffer zones for all river systems - No fresh permissions for industrial/commercial/residential development within identified river corridors until exercise completed - [Para 20].

Environmental Law - Hazardous Waste Management - Effluent Treatment Plants - HRTS facilities - Ambey Valley and Khed - Temporary arrangements used as repositories for accumulated industrial wastewater - Held - Entire accumulated wastewater to be scientifically treated and disposed of - All RCC storage tanks and associated infrastructure at HRTS sites to be dismantled and land restored through ecological restoration measures under Committee's supervision, developed as green ecological zone/urban forest - [Para 21].

Environmental Law - River Basin Management - Institutional Framework - Rajasthan River Basin and Water Resources Planning Authority - Became largely defunct and failed to discharge functions - Held - State directed to constitute an independent and adequately empowered River Commission/River Rejuvenation Authority for integrated management of rivers and river basins, including scientific determination of High Flood Line - Commission to function under chairmanship of Chief Secretary - [Para 22, 33(G)].

Environmental Law - Industrial Effluents - Centralized Effluent Treatment Plants (CETPs) - Operational overload - Transportation risks - Need for decentralized treatment - Held - State Government to examine feasibility of encouraging Captive Effluent Treatment Plants (ETPs) for industries generating 100 KLD or more - Expedite pending applications - Formulate policy to incentivize ETPs for smaller units - Maximize capacity utilization of existing CETPs - Establish additional CETPs - [Paras 23-24].

Environmental Law - Industrial Development - Proximity to River - RIICO Industrial Area, Kakani - Developed in close proximity to Luni River - Portions falling within apparent High Flood Area - Absence of scientifically determined ecological buffer - Risk of river contamination - Held - Integrated Coordination Group to review layout after scientific determination of High Flood Line and buffer - Corrective measures including modification/relocation of plots if within High Flood Line/floodplains/buffer - No untreated effluent discharge into river system - [Paras 25-26].

Environmental Law - Land Use Regulation - Industrial Parks - Ambey Valley Industrial Park - Irregularities concerning conversion of agricultural land, deviation from Master Plan, issuance of pattas for industrial purposes in residential area, development of plots within riverbed/high flood area - Serious deficiencies in official records - Held - Chief Secretary to undertake inquiry into legality of land-use conversions/approvals/allotments and direct remedial/corrective measures - [Para 27].

Environmental Law - Groundwater Resources - Sustainable Management - Excessive dependence on groundwater for industrial purposes - Contamination of surface water - Depletion of water table - Held - State Government to formulate comprehensive strategy for sustainable groundwater management including regulation of extraction, reuse/recycling, augmentation of recharge, monitoring levels and quality - No water-intensive industries in dark zones (over-exploited zones) - [Para 28].

Criminal Law - Environmental Offences - Enforcement - Bhartiya Nyaya Sanhita 2023 - Sections 272, 326(a), 326(c) - Prevention of Damage to Public Property Act 1984 - Non-invocation of graver penal provisions - SIT investigation - Connivance amongst CETP officials and industrial units - Held - SIT to intensify investigation process comprehensively examining role of all persons including public servants, industrial units, office-bearers of CETPs - Appropriate action strictly in accordance with law - Details of action against responsible RSPCB officers to be placed before Committee - [Paras 2, 4-6, 33(H), 33(N)].

Environmental Law - Public Grievance Redressal - Environmental Violations - Lack of effective mechanism - Held - State of Rajasthan to establish an Integrated Public Reporting and Environmental Grievance Redressal Mechanism using a QR Code-based digital platform - Platform to facilitate confidential reporting of violations with geo-tagged information, photos, videos - Immediate electronic transmission to jurisdictional authorities - Examine feasibility of incentive scheme for credible information - [Para 33(J)].

Decision: Suo Moto Writ Petition and connected appeals disposed of with comprehensive directions – State of Rajasthan directed to constitute an Integrated Coordination Group and an independent River Commission/Rejuvenation Authority, formulate a Comprehensive Resolution Plan, intensify SIT investigation, address industrial pollution, groundwater management, and establish a public grievance redressal mechanism – Chief Secretary to personally monitor compliance.

Civil Law - Land Acquisition - Land Acquisition Act 1894 - Sections 4(1), 18(1) - Compensation enhancement - Challenge against High Court's dismissal of review petition seeking compensation parity for lands acquired under same notification - Notification issued on 11.02.1999 - Reference Court enhanced compensation to Rs. 3,00,000/- per acre on 27.03.2001 - High Court further enhanced to Rs. 5,00,000/- per acre on 23.06.2011 - For other lands under the same notification, compensation was determined at Rs. 6,50,000/- per acre (Ravindra case) - Appellants' review petition seeking parity was dismissed by High Court on 07.09.2015 due to delay - Supreme Court condoned delay in Special Leave Petitions - Exercised powers under Article 142 of the Constitution - Held - Appellants entitled to compensation of Rs. 6,50,000/- per acre with statutory benefits, but not entitled to interest for two periods of delay aggregating 4,427 days - [Paras 3-11].

Writ Law - Constitutional Powers - Constitution of India 1950 - Article 142 - Doing complete justice - Land acquisition compensation parity - Despite abnormal delay and High Court's dismissal of review petition, Supreme Court invoked Article 142 to extend compensation determined in a similar case for lands under the same notification to the appellants - Held - to do complete justice, the appellants are entitled to compensation of Rs. 6,50,000/- per acre with statutory benefits - [Paras 10].

Civil Law - Land Acquisition - Interest entitlement - Land Acquisition Act 1894 - Delay in pursuing claim - Appellants' claim for enhanced compensation suffered from abnormal delay between Reference Court judgment and High Court appeal, and between High Court judgment and refiling of SLPs - Total delay of 4,427 days - Held - Appellants not entitled to interest for the period of delay - [Para 11].

Decision: Civil Appeals allowed – Appellants entitled to Rs. 6,50,000/- per acre with statutory benefits – Appellants not entitled to interest for the period from 28.03.2001 to 2008 and from 24.06.2011 to 27.01.2017.

Writ Law - Child Custody - Constitution of India - Article 226 - Custody of minor child - Maternal grandparents filed contempt petition against father for non-compliance with previous order directing transfer of child's custody to father - Earlier order based on father's natural guardianship and financial provisions - Grandparents alleged child not sent to them for visitation post-transfer of custody - Father contended grandparents also did not visit - Court interacted with minor child - Found child's welfare best served with maternal grandparents, considering their care and child's admission in prestigious institution while with them - Held - Custody of child returned to maternal grandparents - Contempt case closed with directions - [Paras 1-9].

Family Law - Child Welfare - Parens Patriae Jurisdiction - Best interest of child - Supreme Court while dealing with contempt petition for non-compliance of custody order - Interacted with minor child and exercised parens patriae jurisdiction - Found that despite previous order handing over custody to father - Child's welfare and interest would be best served if allowed to be looked after by maternal grandparents - Held - Child's welfare is paramount consideration - [Paras 6-8].

Family Law - Child Custody - Visitation Rights - Following change of custody from father to maternal grandparents - Court directed father to build confidence in child - Father allowed to visit child once in three months - Visitation to be under strict supervision of maternal grandparents or maternal uncles and only if child desires - Held - Visitation rights subject to child's welfare and desire - [Para 7].

Decision: Contempt case closed – Custody of minor child directed to be handed over to maternal grandparents – Maternal uncle allowed to take child from Court – Grandparents entitled to pursue maintenance claim as per law – Father granted visitation rights once in three months under strict supervision of grandparents if child desires.

Civil Law - Trademark Infringement - Trade Marks Act 1999 - Sections 2 and 11 - Appellant-defendant asked plaintiff in cross-examination whether there were documents showing since when the mark BABA was being used - High Court expunged the question holding it to be a purely factual question beyond permissible cross-examination since the written statement was not on record - Supreme Court held that when the plaintiff affirms trademark infringement, the defendant is entitled to question the plaintiff on documents substantiating the time from which the brand name was used, even if the written statement is not on record - Held - High Court order reversed and trial directed to proceed after recalling the plaintiff and recording his answer - appeal allowed - [Paras 1-12].

Decision: Appeal allowed - Impugned order of the High Court reversed - Trial directed to proceed after recalling the plaintiff and recording his answer - Pending applications disposed of.