Criminal Procedure Code 1973 (CrPC) – Section 482 – Quashing of criminal complaint – Unexplained inordinate delay must be taken into consideration as a crucial factor for quashing a criminal complaint – Over four-year gap between initial investigation and complaint filing, with no evidence provided to sustain the claims – High Court must detail cases to prevent miscarriage of justice – Criminal complaint quashed – Appeal allowed [Paras 1-29].

Decision – Appeal allowed – Criminal complaint quashed – High Court order set aside [Para 29

Criminal Procedure Code 1973 (CrPC) – Section 427 – Sentence on offender already sentenced for another offence – Theft of electricity – Sentences in nine cases – If a person already undergoing a sentence of imprisonment is sentenced on a subsequent conviction to imprisonment, such subsequent term of imprisonment would normally commence at the expiration of the imprisonment to which he was previously sentenced – Ordinarily the subsequent sentence would commence at the expiration of the first term of imprisonment unless the court directs the subsequent sentence to run concurrently with the previous sentence – The general rule is that where there are different transactions, different crime numbers and cases decided by different judgments, concurrent sentence cannot be awarded under Section 427 CrPC – Under Section 427(1) of CrPC, the court has the power and discretion to issue a direction that all the subsequent sentences run concurrently with the previous sentence; however, discretion has to be exercised judiciously depending upon the nature of the offence or offences committed and the facts in situation – Specific direction or order by the court is required for the subsequent sentence to run concurrently with the previous sentence – This Court orders and directs that the sentences imposed on the appellant in the nine sessions trials shall run concurrently [Paras 1-16].

Decision – Appeal allowed – High Court judgment set aside – Sentences in nine cases to run concurrently [Para 14].

Evidence – Multiple dying declarations – Legal position summarized – If the court concludes a dying declaration is true and reliable, made without tutoring, duress, or prompting, and when the declarant was physically and mentally fit, it can be the sole basis for conviction – In case of inconsistencies, the declaration by a higher officer (e.g., Magistrate) can be relied upon if no circumstances cast doubt on its truthfulness – Scrutiny required when declarations are not voluntary or are unsupported by other evidence [Paras 1-15].

Penal Code 1860 (IPC) – Section 498A – Cruelty – Multiple dying declarations – Second declaration rejected by the High Court – Appellant's conviction examined based on cumulative evidence – First declaration did not name the appellant – Second declaration was the only evidence of cruelty, deemed unreliable by the High Court – Conviction and sentence set aside [Paras 16-21].

Section 32 of the Indian Evidence Act – Relevance of dying declarations – Statements concerning the cause of death or related circumstances are relevant – Test of credibility based on overall facts and evidence – Multiple dying declarations require careful assessment of consistency and truthfulness [Paras 11-14].

Decision – Appeal allowed – Conviction and sentence under Section 498A IPC set aside – Appellant to be released unless required in another case [Para 21].

Land Acquisition Act 1894 – Section 4 – Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act 2013 – Section 24(2) – Lapse of land acquisition proceedings – High Court's declaration of deemed lapse under Section 24(2) due to non-tendering of compensation found unsustainable – Constitution Bench decision in Indore Development Authority v. Manoharlal [2020 (8) SCC 129] overruled Pune Municipal Corporation and Anr. v. Harakchand Misirimal Solanki and Ors. [2014 (3) SCC 183] relied upon by the High Court – Acquisition proceedings do not lapse if possession has been taken even if compensation has not been tendered [Paras 1-4].

Decision – Appeal allowed – High Court judgment set aside – Acquisition proceedings with respect to the land in question not deemed to have lapsed [Para 4].

Motor Vehicles Act 1988 – Section 166 – Death in accident – Enhancement of compensation – High Court increased the level of income but did not address the issue in the correct perspective – Documentary evidence showed the deceased was cultivating 66 acres and entitled to a third of the value of produce from income of those agricultural lands – Income computed at Rs. 150000/- per annum – Applying 40% towards future prospects, total annual income (Rs. 150000 + Rs. 60000) amounts to Rs. 210000 – With a 1/4th deduction (4 dependents), annual loss of dependency (Rs. 210000 - Rs. 52500) is Rs. 157500 – Applying a multiplier of 16, total loss of dependency (i.e. Rs. 157500 x 16) is Rs. 2520000 – Filial and parental consortium increased – Each of the children and the mother of the deceased entitled to Rs. 40000/- – Total amount payable towards filial and parental consortium is Rs. 120000/- – Appeal allowed [Paras 9-14].

Decision – Appeal allowed – Compensation enhanced to Rs. 2520000/- for loss of dependency, and Rs. 40000/- each for filial and parental consortium for the three appellants [Para 14].

Land Acquisition Act 1894 – Section 4 – Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act 2013 – Section 24(2) – Lapse of acquisition proceedings – High Court's declaration of deemed lapse under Section 24(2) due to non-tendering of compensation found unsustainable – Acquisition proceedings do not lapse if possession has been taken even if compensation has not been tendered – High Court's reliance on earlier decisions overturned by the Constitution Bench in Indore Development Authority v. Manoharlal [Paras 1-6].

Decision – Appeals allowed – Impugned judgment and order of the High Court set aside – Acquisition proceedings with respect to the land in question not deemed to have lapsed [Para 6].

Service Law – Appointment – If it is found that there is no lapse/delay on the part of the applicant, he cannot be punished for no fault attributable to him – Respondents directed to appoint the appellants to the post of Health Worker (Female) within six weeks if found meritorious and meeting other eligibility criteria – Appellants entitled to benefits from the date of actual appointments [Paras 2-6].

Decision – Appeal allowed – High Court judgment set aside – Respondents directed to appoint the appellants to the post of Health Worker (Female) within six weeks if found meritorious and meeting other eligibility criteria [Para 6].

Land Acquisition Act 1894 – Section 4 – Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 – Section 24(2) – Lapse of acquisition proceedings – Twin conditions of not taking over possession and not tendering/paying the compensation are required to be satisfied – If one of the conditions is not satisfied there shall not be lapse of the acquisition proceedings under Section 24(2) of the Act 2013 [Paras 3-4].

Decision – Appeal allowed – Impugned judgment and order of the High Court set aside – Acquisition proceedings with respect to the land in question are not deemed to have lapsed [Para 4].

Land Acquisition Act 1894 – Section 4 – Acquisition of land – Compensation – Claimants not entitled to the same compensation as awarded for lands acquired after 5 years from the date of acquisition – High Court awarding compensation at Rs.297/- per sq. yard unsustainable – Compensation rate revised to Rs.120/- per sq. yard [Paras 1-6].

Decision – Appeal allowed in part – Compensation revised to Rs.120/- per sq. yard – Statutory benefits and interest to be provided excluding the delayed period in preferring the appeal [Para 6].