Public Interest Litigation – Deaths in Beggars’ Home due to Cholera – Article 21 – Constitutional Violation Established – Appellant filed a PIL after media reports revealed deaths and illness of several beggars due to contamination in drinking water at Lampur Beggars’ Home – Authorities failed to ensure sanitary conditions and misrepresented facts – Held: Deaths amounted to violation of the right to life and dignity under Article 21 – Supreme Court recognized the need for judicial intervention and systemic reform [Paras 3-10, 18-20].

Institutional Negligence – Departmental Proceedings – Compliance Noted – Respondents submitted that departmental proceedings were concluded and penalties imposed – Court accepted compliance on that front – However, held that mere disciplinary actions were insufficient without sustained structural reforms and monitoring [Paras 21-22].

Beggars’ Homes – Paradigm Shift in Approach – From Penal to Protective Institutions – Constitutional Reframing – Court held that Beggars’ Homes must be viewed through a constitutional lens, aligned with Articles 38, 39(e), 41, and 47 – Emphasised shift from colonial punitive mindset to rehabilitation and dignity-based frameworks – Institutions must ensure health, freedom, privacy, and humane conditions [Paras 16-16.7].

Right to Life with Dignity – Expanded Interpretation – Article 21 – Applicability to Institutionalised Persons – Reaffirmed that all persons, including those in State custody, are entitled to humane treatment, adequate nutrition, healthcare, and dignity – Denial of such constitutes constitutional breach – Emphasised that beggars, unlike convicts, are not criminals and cannot be treated as such [Paras 15-16.6].

Anti-Begging Laws – Judicial Review – Validity and Purpose – The Bombay Prevention of Begging Act and similar laws in other States examined – Court acknowledged State’s interest in regulating begging but cautioned against criminalising poverty – Enforcement must balance public order with constitutional rights – Reiterated Delhi High Court’s earlier partial striking down of such laws [Paras 17-17.5].

Judicial Monitoring – Long-Term Oversight by Supreme Court – Compliance Recorded – From 2004 onwards, Supreme Court issued multiple detailed directions for improvement in Beggars’ Homes – Continuous monitoring led to structural changes, enhanced hygiene, staffing, vocational training, food quality, and medical care – Final reports showed significant compliance and nil complaints from inmates – Court stressed need for reforms to be sustained across India [Paras 22-22.18].

Final Directions – Nationwide Reform Mandated – Article 21 – Court Issued Model Framework – Directions issued to all States/UTs covering medical screening, disease control, hygiene, infrastructure audits, dietary standards, vocational training, legal aid, child and gender-sensitive provisions, and accountability mechanisms – Directed Union Ministry to issue model guidelines within 3 months – Held: Failure to maintain humane conditions in such institutions constitutes breach of fundamental rights [Paras 23-23.3].

Judgment – Appeal Disposed – Structural Reforms Ordered – Supreme Court partially allowed the appeal – Reiterated State's affirmative duty under Article 21 – Upheld PIL’s maintainability – Issued binding directions to State and Union authorities to overhaul Beggars’ Homes nationwide – Liberty granted to seek further directions if needed [Paras 24-25].

Criminal Law - Police Duty – Registration of FIR – Section 154 CrPC – Mandatory Nature – Police informed of MLC involving appellant (head injury from assault during riots) on 14.05.2023 but failed to register FIR – High Court erred in blaming victim’s family for not lodging report – Held: Once information of cognizable offence is received, FIR must be registered; dereliction of duty established [Paras 14–16, 18–19].

Constitutional Bench Precedent – Lalita Kumari v. Govt. of U.P. (2014) 2 SCC 1 – Applied – Registration of FIR mandatory if information discloses cognizable offence; no preliminary inquiry permissible except in limited categories – Police failure in present case contrary to binding law [Paras 16–17].

Eyewitness Testimony – Appellant as Victim and Eyewitness – Aged 17 years – Claimed he witnessed fatal assault on Vilas Mahadevrao Gaikwad and was himself attacked by same assailants – Police ignored testimony and did not investigate identification of assailants – Failure undermined rule of law [Paras 12, 22].

Dereliction of Duty – Superintendent of Police – Section 154(3) CrPC – Appellant’s complaint dated 01.06.2023 ignored by SP, Akola – Failure to act or inquire despite statutory duty – Cause for serious concern; departmental and disciplinary proceedings directed [Paras 20–21].

Police Impartiality – Duty to Act Without Bias – Officers must shed religious/casteist prejudices – Failure to investigate properly in riot context indicates bias or gross negligence – Police must act as neutral guardians of law [Para 23].

Relief/Orders – Appeal Allowed – Direction to Secretary, Home Ministry, Maharashtra to constitute SIT of senior police officers from both Hindu and Muslim communities – SIT to investigate appellant’s assault and related allegations by registering FIR – Disciplinary action against erring officers – Sensitization measures for police force mandated – SIT report to be filed before Supreme Court within 3 months [Paras 24–26].

Criminal Law - Sections 420, 468, 471 IPC - Forgery – Authorship and Chain of Custody – Sections 463, 464, 468 IPC – Conviction Unsustainable – Alleged tampered documents passed through hands of admission clerk, principal, and university before detection – Prosecution failed to prove appellant authored or had exclusive custody of forged documents – Suspicion, however grave, cannot substitute proof beyond reasonable doubt [Paras 8, 13–14].

Handwriting/Forensic Proof – Absence of Expert Opinion – Visual Overwriting Inference Unsafe – Courts below wrongly relied solely on apparent overwriting without handwriting expert corroboration – Held: When authorship is central to establish guilt, failure to examine expert or direct witness is fatal to prosecution [Paras 9–10].

Mens Rea – Sections 420, 471 IPC – Intention to Cheat Not Proved – Documents scrutinized and stamped by college authorities – No evidence that appellant knew of tampering or had dishonest intention to secure admission – Mental element not established [Para 11].

Section 313 CrPC – Compound and Omnibus Questions – Prejudice Caused – Incriminating circumstances not fairly and distinctly put to accused – Violated valuable statutory right of defence – Reliance on such defective examination impermissible [Para 12].

Benefit of Doubt – Where two reasonable views possible, benefit goes to accused – Prosecution failed to prove exclusive control or authorship of forged documents – Conviction set aside [Paras 13–15].

Decision – Appeal Allowed – Conviction under Sections 420 r/w 511, 468, and 471 IPC together with sentences set aside – Appellant acquitted [Para 15].

Tenancy Law - Landlord–Tenant – Challenge to Landlord’s Title – Estoppel against Tenant – Relinquishment Deed of 1953 (Exh. P-18) – Findings of Courts Below Perverse – Tenant inducted in 1953 by Ramji Das under a valid relinquishment deed executed by Sua Lal; rent paid to Ramji Das for decades and, after his death, to the landlady’s husband – Held: a tenant who entered under the landlord and paid rent for over half a century cannot dispute the landlord’s title; courts below ignored material evidence, warranting interference [Paras 5–7, 10–12].

Will/Probate – Production of Probate Order at Appellate Stage – Order 41 Rule 27 CPC – Proof of Ownership in Eviction Suits – High Court erred in refusing to take on record the 09.02.2018 probate order (Probate Case No. 8/2013) – Probate, though not mandatory, imparted legal sanctity to the Will bequeathing the shop to the plaintiff; in eviction suits, ownership need not be established as strictly as in a title suit – Rejection of additional evidence unsustainable [Paras 8–10].

Attornment/Notice – Registered Notice (Exhs. P-9 to P-11) – Presumption of Service – Trial court erred in discarding registered notice for want of acknowledgment – First appellate court (initial round) rightly noted presumption of receipt when sent to correct address; notice conveyed bequest and assertion of ownership – Attornment established; no rent shown paid from January 2000 – Default proved [Paras 11–12].

Bona Fide Requirement – Expansion of Existing Family Business – Adjacent Premises – Landlady intended to join and expand husband’s sweets and savouries business; sons also involved – Need genuine; not disputed – Requirement established [Para 13].

Appellate Interference – Concurrent Findings – Perversity – Where courts below ignore material evidence and proceed on conjectures (suspicion about Will; ignoring relinquishment deed; overlooking presumption on registered notice), interference justified – Orders of trial court, first appellate court (on remand), and High Court set aside [Paras 10, 12, 14].

Relief/Decree – Eviction and Arrears – Suit decreed for eviction on grounds of rent default and bona fide need; arrears payable from January 2000 till delivery – Conditional protection: tenants may remain for six months subject to (i) undertaking within two weeks to vacate in six months and (ii) payment of arrears within one month; failing which, summary eviction permissible [Para 14–15].

Criminal Law – Rape Conviction – Downgrade to Outraging Modesty – Appellant originally convicted under Section 376AB IPC and Section 6 of POCSO Act for allegedly sexually assaulting a girl under 12 – Victim’s consistent statements under Section 164 Cr.P.C., her deposition during trial, and medical evidence did not establish penetration – Allegations limited to touching of private parts – Held: Ingredients of penetrative sexual assault under Section 3(c) POCSO and Section 375 IPC not made out – Conviction under Section 376AB IPC and Section 6 POCSO set aside – Conviction modified to Section 354 IPC and Section 10 POCSO [Paras 3–9]

POCSO Act – Nature of Assault – Victim below 12 years – Where allegations and evidence prove non-penetrative touching with sexual intent, offence falls under Section 7 read with Section 9(m) of the POCSO Act – Section 3(c) not attracted in absence of penetration – Held: Alleged act amounts to aggravated sexual assault under Section 9(m) not penetrative sexual assault [Paras 6–8]

Sentencing – Modification of Sentence – Original sentence of 20 years RI under Section 6 POCSO Act modified to 5 years RI under Section 354 IPC and 7 years RI under Section 10 POCSO Act – Sentences to run concurrently – Fine of ₹50,000 retained as compensation to victim payable within two months [Para 9]

Decision: Appeal partly allowed – Conviction under Section 376AB IPC and Section 6 POCSO Act set aside – Conviction altered to Section 354 IPC and Section 10 POCSO Act – Sentence reduced accordingly.

Homicide – Murder vs. Culpable Homicide – Sections 302 & 304 Part I IPC – Conviction Modified – Appellant convicted under Section 302 IPC for killing his brother-in-law – Evidence showed prior incidents of harassment of appellant’s sister and parents by the deceased – On the day of incident, deceased allegedly attempted to assault appellant with stone outside hospital, triggering retaliation – Held: act not premeditated; chance encounter and grave provocation proved – Conviction altered from Section 302 IPC to Section 304 Part I IPC [Paras 16–20].

Grave and Sudden Provocation – Applicability – Test Applied – Court held that seeing the deceased immediately after assaults on sister (leading to her hospitalization) and on parents, coupled with sudden attack attempt, constituted grave and sudden provocation – Appellant’s loss of self-control justified conversion of conviction [Paras 17–19].

Confession and Admissions – Voluntariness – Sections 164 & 313 CrPC – Appellant consistently admitted killing in confessional and examination statements, but explained circumstances – Court relied on admissions along with corroborative evidence to accept provocation defence [Paras 8–9].

Sentencing – Young Age and Custody Undergone – Modification – Appellant had already undergone more than 12 years in custody – Sentence reduced to period already undergone – Appellant directed to be released forthwith if not required in other cases [Paras 21–22].

Decision – Appeal partly allowed – Conviction under Section 302 IPC modified to Section 304 Part I IPC – Sentence reduced to period already undergone – Release ordered [Paras 20–23].

Tenancy Protection – Section 3(2)(b), TN Cultivating Tenants Protection Act – Grounds of eviction – Allegations of felling trees, digging pits, constructing huts – Revenue Court relied on Commissioner’s report from earlier civil suit and ordered eviction – High Court affirmed – Held: No cogent evidence of destructive acts or negligence – Mere pruning of trees not sufficient – Eviction unsustainable [Paras 14, 17-20].

Beneficial Legislation – Interpretation – TN Cultivating Tenants Protection Act enacted to shield cultivating tenants from eviction – Courts must lean towards tenant protection unless gross violation proved – Beneficial construction requires widest interpretation favouring tenants – Eviction orders must rest on credible and reliable evidence, not mechanical reliance on reports [Paras 22-24].

Civil Court Decrees & Revenue Proceedings – Use of prior commissioner’s report – Revenue Court mechanically relied on report filed in O.S. No. 491/1994 – High Court in revision affirmed without independent scrutiny – Held improper – Revisional jurisdiction under Section 6-B read with Section 115 CPC demands careful review [Paras 14, 18-20].

Long Possession – Equitable considerations – Tenant family cultivating land since 1955–60 – Tenants have vital interest in protecting land and crops – Court held equities lie in favour of sustaining tenancy in absence of proven injurious acts [Para 20].

Connected Appeals – Civil Appeals 7467-7469/2011 by other heirs claiming ownership noted – Already subject matter of O.S. No. 302/2009 at Coimbatore – To be decided independently on merits – Not considered in present appeals [Para 13].

Decision – Appeals allowed – Impugned High Court judgment and Revenue Court eviction order set aside – Respondents restrained from interfering with appellants’ possession except in accordance with law – Connected appeals also disposed of [Paras 25-27].

Criminal Law – Cheating – Section 420 IPC – Quashment of Proceedings – Educational institution accused of using a forged Fire NOC to secure recognition – National Building Code and writ directions established no Fire NOC was required for buildings below 15 metres – Held: Essential ingredient of dishonest or fraudulent inducement absent since recognition/renewal was not contingent on Fire NOC – Proceedings under Section 420 IPC quashed [Paras 5-11, 12-13, 16, 21-22].

Cheating – Ingredients – Deception vis-à-vis Inducement – Mere deception insufficient unless coupled with dishonest inducement causing wrongful gain or loss – Court reiterates that intention is the gist and the false representation must be material to the grant – As the alleged NOC was not a condition precedent, causative link between representation and administrative action missing – Outcome: No offence under Section 420 IPC made out – Reasoning draws from statutory definitions and precedents [Paras 12-16].

Forgery – Sections 465, 468, 471 IPC – Requirement of “making” a false document and mens rea – No material connecting the appellant to the creation of the alleged forged NOC – Original fabricated document not recovered – Without proof of making (Section 464 IPC) and requisite dishonest intent to cause wrongful loss/gain, offences under Sections 465/468/471 not attracted – Outcome: Forgery-based allegations unsustainable [Paras 18-20].

Administrative/Regulatory Compliance – National Building Code, 2016 – Fire NOC not necessary for educational buildings below 15 m – Appellant’s building 14.20 m – Prior writ order directed renewal of affiliation without insistence on Fire NOC – This regulatory framework undercuts the prosecution’s case on materiality and inducement – Outcome: Supports quashment [Paras 5-11, 16, 21].

Appellate Intervention – Scope at Quashing Stage – High Court erred by overlooking that uncontroverted allegations, read with the writ order and NBC norms, do not disclose essential ingredients of cheating/forgery – Supreme Court sets aside High Court order and quashes proceedings – Decision: Appeal allowed, CC No. 303/2020 quashed [Paras 21-22].

Criminal Procedure – Registration of FIR – Article 226 & Section 482 Cr.P.C. – Writ petitions by complainants against CBI officers alleging intimidation and illegal seizures – High Court directed registration of FIRs – Supreme Court upheld orders, holding that once complaints disclose cognizable offences, FIR registration is mandatory – Preliminary inquiry report of CBI not conclusive – Alternative remedies not a bar to writ jurisdiction [Paras 14, 22-24, 27-32, 34-36, 40].

Delay – Appeals filed after 12 years – Explained by pendency of Letters Patent Appeals dismissed on maintainability – Supreme Court condoned delay noting appellants were vigilant, pursuing remedies in good faith – No deliberate laches [Paras 11-13].

Public Servants – Protection under Section 197 Cr.P.C. and Section 140 Delhi Police Act – Not applicable – Allegations of illegal seizure, coercion, and abuse of authority fall outside scope of official duty – Public servants not immune where actions are prima facie mala fide and criminal in nature [Paras 18, 26].

Scope of Judicial Review – High Court’s discretion – Constitutional Courts empowered to order FIR registration if material discloses cognizable offence – Supreme Court declined to interfere under Article 136, reiterating that justice requires accountability even for investigators – “Those who investigate must also be investigated” [Paras 29-30, 34-38].

Investigation – To be conducted by Delhi Police (not Special Cell) by an officer not below ACP rank – Preliminary inquiry report may be looked into but not treated as conclusive – Appellants directed to cooperate – No coercive steps unless custodial interrogation required – FIR and investigation to be completed within 3 months [Paras 39-41].

Decision – Appeals partly allowed with modification – High Court’s orders upheld regarding FIR registration and investigation, but investigation shifted to Delhi Police ACP – Appeal otherwise dismissed [Paras 38-42].