Criminal Law – Discharge Application – Appellant challenged the dismissal of his application for discharge under Section 227 of the Cr.P.C. – Alleged possession of disproportionate assets during his tenure at BSFC and ONGC – Initial investigation found allegations false but FIR registered 12 years later – Charge sheet filed seven years after FIR registration – Application for discharge dismissed by Special Judge (Vigilance) and High Court – Supreme Court conducted a limited inquiry, found calculation errors in the charge sheet, and ruled that no prima facie case was made out [Paras 1-20].

Procedural Delay – Extended Litigation – Allegations from 1974-1988 led to FIR in 2000, charge sheet in 2007, and protracted litigation – Appellant superannuated in 2010 and continued to contest the case – Supreme Court noted the prolonged duration and deemed the continuation of prosecution unjust apart from being illegal [Paras 19-20].

Legal Principles – Scope of Section 227 of Cr.P.C. – Supreme Court emphasized the necessity of sifting through evidence at the discharge stage – Reiterated that discharge should be granted if there is no sufficient ground for proceeding against the accused based on the material on record [Paras 13-18].

Decision:

Criminal Appeal allowed – Judgments of the High Court of Patna and the Special Judge (Vigilance) set aside – Appellant discharged from the case – No order as to costs.

Criminal Law – Murder of Father – Appellant convicted under Section 302 IPC for patricide committed under the influence of alcohol – Appellant inflicted multiple fatal injuries on the deceased using a wooden piece – Appellant claimed the act was unintentional and due to intoxication – Supreme Court rejected plea for reduction to Section 304 Part-I, upholding conviction under Section 302 IPC, emphasizing brutality and cruelty of the act despite lack of premeditation [Paras 1-24].

Evidence – Nature of Injuries – Eleven injuries inflicted on vital parts of the body, including multiple head injuries, broken sternum and ribs, and severe contusions – Court held that injuries indicated intent to cause death or grievous harm, not protected under Exception 4 of Section 300 IPC [Paras 3, 20-22].

Sentencing – Remission of Sentence – Appellant had already served 12 years of sentence – Supreme Court directed State to consider appellant's case for remission upon completion of mandatory sentence period as per policy [Para 23].

Decision:

Appeal disposed of – Conviction under Section 302 IPC upheld – State directed to consider appellant’s case for remission upon completion of mandatory sentence period – No order as to costs.

Charitable and Religious Endowments – Lease of Agricultural Lands – Appellant challenged the eviction order and sought lease consideration under Rule 15 of the 2003 Rules – High Court upheld statutory cancellation of leases under Section 82 of the 1987 Act – Supreme Court affirmed High Court's decision, finding land to be agricultural and not subject to the 2003 Rules [Paras 1-73].

Statutory Interpretation – Section 82 of 1987 Act – Supreme Court clarified that Section 82(3) and (4) apply only to non-agricultural land – Agricultural lands are subject to automatic lease cancellation under Section 82(1) – Rule 15 of 2003 Rules inapplicable to agricultural lands [Paras 52-56, 72].

Land Use and Classification – Evidence and Findings – Supreme Court examined reports and records, affirming agricultural classification of the land – Reiterated that use for non-agricultural purposes does not alter inherent classification [Paras 29-36, 57-60].

Decision: Appeals dismissed – High Court’s judgments and orders upheld – Leases found statutorily cancelled under Section 82(1) of the 1987 Act – Directions to consider lease under Rule 15 of the 2003 Rules deemed untenable – No order as to costs.

Civil Procedure – Second Appeal – Re-appreciation of Evidence – The High Court's jurisdiction under Section 41 of the Punjab Courts Act does not permit re-appreciation of evidence – Interference is warranted only if the decision is contrary to law, custom, or involves a substantial error or defect in procedure – High Court erred in re-examining findings of fact settled by trial and Appellate Courts [Paras 13-17, 26-33].

Specific Performance – Agreement to Sell – Appellant entered into agreements to sell with respondents, paid a significant portion of the sale price, and was in possession of the property – Respondents attempted to create third-party rights leading to the appellant filing suit – Trial court and Appellate Court decreed specific performance, but High Court erroneously interfered [Paras 18-24, 32].

Legal Principles – Jurisdiction under Section 41 – Supreme Court emphasized the limited scope of interference in second appeals under Section 41 – Findings of fact by lower courts should not be disturbed unless there is a substantial error of law or procedure – High Court's judgment set aside for exceeding this jurisdiction [Paras 15-17, 30].

Decision:

Appeals allowed – High Court's judgments and orders set aside – Judgments and decrees of the trial court and the Appellate Court upheld – Pending applications disposed of – No order as to costs.

Civil Procedure – Suppression of Material Facts – Appellant challenged the Appellate Court’s decree for specific performance on grounds of suppression of earlier suit – Respondents did not disclose the previous suit in the plaint, which was material to the case – Supreme Court held non-disclosure amounted to fraud on the court, rendering the decree void [Paras 1-34].

Specific Performance – Agreement to Sell – Trial court dismissed the suit for specific performance due to suppression of material facts – Appellate Court reversed this decision, decreeing specific performance – High Court upheld the Appellate Court’s decree without addressing the suppression issue – Supreme Court set aside High Court’s judgment, reinstating trial court’s dismissal [Paras 12-34].

Legal Principles – Fraud and Clean Hands – Supreme Court reiterated that parties must approach the court with clean hands and disclose all material facts – Non-disclosure of earlier suit filed and withdrawn without liberty constitutes fraud, vitiating the entire proceedings [Paras 23-25].

Decision: Appeal allowed – Judgment and decree of the High Court and Appellate Court set aside – Judgment of the trial court dismissing the suit for specific performance upheld – No order as to costs.

Constitutional Law – Article 136 – Plea of juvenility under Section 7A of the Juvenile Justice Act, 2000 can be raised at any stage, even after final disposal of the case – Supreme Court emphasized the significance of juvenility claims and the need for appropriate verification, given the potential for juveniles to be wrongfully tried as adults [Paras 1-30].

Juvenile Justice – Determination of Age – Evidence and Procedure – Supreme Court held that while determining the age of the accused, the Court must consider documentary evidence like birth certificates, school records, and in their absence, medical tests – Preference should be given to documents over opinions and medical evidence unless documents are proven fabricated or manipulated [Paras 45-50].

Plea of Juvenility – Importance of Documentary Evidence – The Court highlighted that documentary evidence plays a crucial role in establishing the age of the accused – In cases of conflicting evidence, courts should lean towards recognizing juvenility in borderline cases to uphold the best interests of the child [Paras 45-50].

Decision: Writ Petition allowed – Supreme Court directed the Sessions Court to verify the appellant's age based on documentary evidence and medical examination if necessary – The Sessions Court to determine the appellant's claim of juvenility at the time of the commission of the offence.

Constitutional Law – Right to Dignity – Article 21 of the Constitution guarantees the right to dignity and fair treatment to a living person and also extends this right to their body after death – Supreme Court emphasized that this right includes treating the body with respect and allowing family members to perform last rites according to religious traditions [Paras 36, 54].

Exhumation – Public Order and Health – Supreme Court acknowledged that exhumation of a body buried for over eight months could pose public health risks and disturb public order – Court emphasized that disinterment should be considered only in exceptional circumstances and with strong necessity [Paras 53-56].

Judicial Discretion – Exercise of Power – Supreme Court stressed the importance of judicial discretion and the need to balance individual rights with public order and health – Affirmed High Court’s decision to allow family members to perform prayers at the grave without exhuming the body [Paras 56-60].

Decision:

Appeal dismissed – High Court's order allowing family to perform prayers at the grave upheld – No order as to costs.

Medical Negligence – Reduction of Compensation – National Commission enhanced the compensation from Rs. 1 lakh awarded by the District Forum to Rs. 10 lakhs – Supreme Court found enhancement unjustified in absence of appeal or revision by the complainant – National Commission did not exercise suo moto revisional power properly – Supreme Court reduced the enhanced compensation to Rs. 4 lakhs to do substantial justice under Article 142 [Paras 1-8].

Consumer Protection – Suo Moto Revision – National Commission has suo moto revisional jurisdiction under Section 21(b) of the Consumer Protection Act – However, in this case, the National Commission did not put appellants on notice for enhancement, rendering the order unsustainable – Proper exercise of suo moto powers requires notification to parties [Paras 5-7].

Compensation – Factors for Determination – Amount of compensation varies based on individual damages and disabilities – Enhancement should not be automatic based on precedents without considering specific suffering and trauma of the complainant – Supreme Court adjusted compensation to balance justice and reasonable relief [Paras 7-8].

Decision: Appeal partly allowed – National Commission's order enhancing compensation to Rs. 10 lakhs quashed – Compensation enhanced to Rs. 4 lakhs under Article 142 – Appellants directed to pay balance amount within six weeks – Interest at 7.5% for delayed payment – Respondent allowed to withdraw deposited amount with accrued interest [Paras 8].

Criminal Law – Cancellation of Bail – Grounds for cancellation of bail for the co-accused were identical to those for the present respondents – Supreme Court held that once bail for the co-accused was cancelled, bail for the present respondents also required cancellation – High Court failed to consider the gravity of the offence and eyewitness identification in its bail order [Paras 1-6].

Penal Code – Sections 120(B), 302, 201 read with Section 34 – High Court's failure to consider the gravity of the offence and the identification of the respondents by two eyewitnesses – Supreme Court emphasized the necessity of considering these factors in bail decisions, especially in severe cases involving murder [Paras 2-3].

Legal Principles – Eyewitness Testimony and Bail – Supreme Court noted that the High Court's observations about the possibility of witness tampering before the Test Identification Parade were speculative – Supreme Court reiterated that proper weight must be given to eyewitness testimony in bail considerations [Paras 4-5].

Decision:

Appeals allowed – Bail orders passed by the High Court releasing the respondents Subrahmanya and Rajesh on bail were quashed and set aside – Respondents directed to surrender within two weeks – If they fail to surrender, the concerned police authority to arrest them and the Trial Court to issue non-bailable warrants [Paras 6-7].