Maternity Leave – Central Civil Services (Leave) Rules, 1972 – Rule 43 – The appellant, a government employee, applied for maternity leave for her first biological child – Leave was denied on the ground that she had two stepchildren from her husband's previous marriage, thereby exceeding the limit of two surviving children stipulated under Rule 43 – Tribunal and High Court upheld the denial – Supreme Court allowed the appeal, holding that the appellant’s entitlement to maternity leave for her first biological child is independent of her prior availing of child care leave for her stepchildren [Paras 1-30].

Purposeful Interpretation – Beneficial Legislation – The court emphasized that maternity leave provisions must be construed to support the continuance of women in the workplace, recognizing child birth as a natural incident of life – Rejected a literal interpretation that would disadvantage families not conforming to traditional structures – Affirmed the purposive approach to extend benefits under social welfare legislation to non-traditional families [Paras 15-26].

Constitutional Rights – Articles 15(3), 21, and 42 – The court reinforced that beneficial provisions for women under Article 15(3) and the right to privacy and dignity under Article 21 support the appellant's claim – Emphasized the State's duty under Article 42 to provide just and humane work conditions, including maternity relief [Paras 21-26].

Decision – Appeal allowed – Judgments of the High Court and Central Administrative Tribunal set aside – Appellant entitled to maternity leave under Rule 43 – Directed release of benefits within two months [Paras 28-30].

Contract Law – Tender Process – Uniform Bidding – GST Rates – High Court directed the appellant to clarify GST rates and HSN codes in the tender document to ensure fair competition – Supreme Court held that no statutory or public duty exists requiring the appellants to indicate the HSN code – Bidder's responsibility to quote correct GST rate [Paras 1-48].

Mandamus – Scope and Application – The High Court's issuance of mandamus to compel the appellant to seek clarification from GST authorities was deemed impractical and beyond legal requirements – Appellants not bound to provide HSN code in tender documents under current statutory framework [Paras 15-49].

GST Regime – Supplier's Tax Liability – The GST Act places the tax liability on the supplier, not the purchaser – Suppliers must self-assess and quote accurate tax rates – High Court's directions to the appellant were inconsistent with GST provisions [Paras 33-47].

Decision – Appeal allowed – High Court's judgment set aside – No mandatory duty for appellants to specify HSN codes in tender documents – Bidders responsible for quoting correct GST rates [Paras 28-49].

Judgment Writing – Incomprehensible Language – The High Court's judgment affirming the CGIT's order was found to be incomprehensible – Supreme Court emphasized the importance of clarity and accessibility in judgment writing – Highlighted the need for judgments to be written in a manner that is understandable to all stakeholders, including the parties involved and the public [Paras 10-14].

Judicial Review – Disciplinary Proceedings – Misconduct – The respondent was charged with gross misconduct and dismissed from service – The CGIT found the penalty of dismissal harsh and disproportionate, modifying it to compulsory retirement – High Court affirmed CGIT's decision – Supreme Court remanded the case to the High Court for reconsideration in clear and comprehensible language [Paras 1-31].

Accessibility – Digital Signatures – Courts and tribunals must ensure judgments and orders are accessible and signed using digital signatures – Avoid scanned versions of printed copies to ensure accessibility for persons with disabilities using screen readers [Paras 21-22].

Decision – Appeal allowed – High Court's judgment set aside – Case remanded to the High Court for fresh consideration – All rights and contentions of the parties on merits kept open – High Court requested to expedite disposal of the writ petitions [Paras 29-31].

Negotiable Instruments Act – Sections 138 and 139 – Dishonour of Cheque – The drawer's admission of signing a cheque raises a presumption of liability – This presumption cannot be rebutted merely by proving that the cheque details were filled in by someone other than the drawer – Handwriting expert's report on whether the drawer filled in the cheque details is irrelevant to determining the purpose of the cheque issuance [Paras 1-17].

Presumption of Liability – Section 139 NI Act – Once a cheque is signed and handed over, it is presumed to be for the discharge of debt or liability – The burden shifts to the drawer to rebut this presumption with evidence to the contrary – Reports from handwriting experts do not suffice to rebut the statutory presumption of liability [Paras 13-17].

Decision – Appeal allowed – High Court's order permitting the engagement of a handwriting expert set aside – Handwriting expert's report not to be considered in trial – Respondents may raise other legitimate defenses during trial [Paras 19-20].

Dowry Death – IPC Section 304B – The trial court convicted the appellant based on the second dying declaration implicating him, despite acquitting his parents on the same evidence – High Court reduced the sentence but upheld the conviction – Supreme Court found the first dying declaration more reliable as it was made voluntarily without any external influence, unlike the second declaration recorded in the presence of the deceased's relatives, which could have been influenced – Benefit of doubt given to the appellant similar to that given to his parents by the trial court [Paras 1-20].

Dying Declaration – Reliability – The court must ensure the dying declaration is true, reliable, voluntary, and made in a fit state of mind – When multiple dying declarations exist, the one recorded by a higher authority like a Magistrate, without suspicion, is more reliable – Inconsistencies and lack of corroboration necessitate careful scrutiny of each case's facts [Paras 8-10].

Decision – Appeal allowed – High Court and trial court judgments set aside – Appellant acquitted of all charges – Bail bonds discharged [Paras 22-23].

Criminal Law – Conviction Reversal – High Court convicted the appellant under Section 302 read with Section 34 IPC after reversing the trial court's acquittal – Appellant's appeal to Supreme Court dismissed in limine without recording reasons – Supreme Court emphasized the need for notice and recording reasons when disposing of appeals under Article 134(1)(a) or (b) or Section 2 of the Enlargement of Jurisdiction Act [Paras 1-38].

Constitutional Law – Right to Appeal – Supreme Court upheld that the deletion of Rule 15(1)(c) of Order XXI by the Amendment Rules, 1981, does not violate the principles laid out in the Constitution Bench decision in Sita Ram v. State of Uttar Pradesh – Emphasized procedural fairness and the necessity of recording reasons in appeal dismissals [Paras 19-37].

Judgment – Fairness in Judicial Process – The necessity of recording reasons for dismissal of appeals to ensure transparency and fairness – The decision aligns with Article 21 of the Constitution guaranteeing the right to life and personal liberty [Paras 24-27].

Decision – Writ Petition disposed of – No relief granted due to the finality of the previous judgment and dismissal of the review petition – Principles from the Constitution Bench's decision in Sita Ram to guide future procedures in preliminary hearings of criminal appeals [Paras 38-40].

Mutual Funds – Winding Up – SEBI Regulations – FIFA sought commission for mutual fund distributors from the date of winding-up notices – Court held that Regulation 52 applies only when the scheme is in operation and not after the winding-up notice – Commission payment is not an expense connected with winding up under Regulation 41(2)(b) [Paras 1-9].

Regulatory Interpretation – Recurring Expenses – Court clarified that recurring expenses under Regulation 52, including distributor commission, are applicable during the scheme's operation – Post-winding-up, such expenses are not permissible – Transparency regulations do not confer additional rights to claim expenses during winding up [Paras 3-9].

Order – Application dismissed – FIFA's claim rejected – Franklin Templeton's statement on bearing liquidation expenses recorded [Paras 10-11].

Criminal Law – Charge Framing – High Court set aside the trial court's order framing charges of rape and POCSO Act offenses against the accused – Supreme Court found the High Court's reasoning, particularly on delay in lodging FIR, incomprehensible and erroneous – Reiterated that charges should be framed based on prima facie evidence and strong suspicion, not proof [Paras 20-31].

Revisional Jurisdiction – Scope – Emphasized that the revisional jurisdiction should be invoked sparingly, primarily to correct gross errors or jurisdictional issues – Interference at the charge-framing stage should be minimal, allowing the trial to proceed unless there's clear abuse of process [Paras 21-27].

Delay in FIR – Not a Ground for Discharge – Supreme Court held that delay in lodging FIR cannot be a sole ground for discharging the accused – The truthfulness and sufficiency of evidence are to be tested during the trial [Para 20].

Decision – Appeal allowed – High Court's order set aside – Trial court directed to proceed with the trial based on the original charges framed – Observations made for deciding the appeal not to influence the trial court's final judgment on the merits [Paras 31-32].

Criminal Law – Quashing of Proceedings – Section 482 CrPC – High Court dismissed the appellant's application to quash criminal proceedings related to an offense under Section 376 IPC – Supreme Court allowed the appeal, holding that the allegations did not prima facie constitute the offense of rape – Consensual relationship between the parties negated the essential ingredients of Section 376 IPC [Paras 3-15].

Consent and Misconception of Fact – Sections 375, 376 IPC – The complainant and appellant were in a consensual relationship from 2013 to 2017 – The complainant's marriage and subsequent divorce were acknowledged – Allegations did not establish that the appellant's promise to marry was false at inception and intended to induce a sexual relationship – Supreme Court emphasized the need for a clear distinction between breach of a promise and a false promise made with dishonest intent [Paras 10-14].

Revisional Jurisdiction – Scope – Supreme Court reiterated the cautious exercise of powers under Section 482 CrPC – Interference warranted only when the FIR or charge-sheet does not disclose any cognizable offense or is manifestly attended with mala fide intentions [Paras 7-9].

Decision – Appeal allowed – High Court's order set aside – Application under Section 482 CrPC allowed – Case Crime No. 11 of 2018, charge-sheet dated 23 April 2018, and the order taking cognizance dated 24 May 2018 quashed [Paras 15-16].