Criminal Law – Murder Conviction – Benefit of Doubt – Appellants convicted under Section 302 read with 149 IPC – Prosecution evidence found with vital discrepancies and inconsistencies – Independent witnesses not examined – Recoveries of weapons used in the crime not corroborated – Appellants granted benefit of doubt – Appeals allowed, convictions set aside [Paras 1-30].

Evidentiary Discrepancies – Inconsistencies in Witness Testimony – Court found significant discrepancies in the testimonies of prosecution witnesses – Injured witness’s medical examination timing inconsistent with other evidence – Court finds these inconsistencies undermine the prosecution’s case [Paras 12-19].

Judicial Review – Concurrent Findings – Reappraisal of Evidence – Supreme Court reappraised evidence due to vital errors in lower courts’ appreciation – Exceptional circumstances warranted intervention – Convictions overturned based on detailed review [Paras 26-29].

Decision: Appeals allowed – High Court and trial court judgments quashed – Appellants acquitted – Orders for release of the appellants unless required in other cases [Para 30].

Service Law – Promotion Guidelines – Difference between Backlog Vacancies and Regular Promotions – Appeals challenge High Court orders requiring separate zones of consideration for SC/ST promotions – Supreme Court distinguishes special drives for backlog vacancies from regular promotions – Regular promotions involve DPC evaluation; backlog promotions focus solely on reserved category candidates – Tribunal and High Court misapplied ad-hoc promotion criteria to regular promotions – Orders for regular promotions by extending zone of consideration set aside [Paras 1-30].

Promotion Criteria – Separate Zone of Consideration – High Court orders for separate zone of consideration for SC/ST candidates in promotions challenged – Supreme Court holds Office Memorandum for backlog vacancies distinct from regular promotion procedures – Regular promotions guided by seniority and merit; backlog vacancies follow special drive policies [Paras 25-28].

Judicial Review – Misapplication of Promotion Rules – Tribunal and High Court erred by not addressing special recruitment drive and misapplying ad-hoc promotion rules – Supreme Court sets aside erroneous orders, upholding structured promotion guidelines [Paras 28-29].

Decision: Appeals allowed – High Court orders set aside – Regular promotion criteria upheld, special drive guidelines for backlog vacancies distinguished [Para 30].

Environmental Law – Closure Order – Environmental Clearance – Appeal against closure of Cold Steel Rolling Mill lacking prior Environmental Clearance – National Green Tribunal (NGT) granted one-year period for compliance – Supreme Court upholds NGT’s decision citing ambiguity in EIA notifications and subsequent amendment – Closure order quashed, unit allowed time for compliance [Paras 1-25].

Environmental Clearance – EIA Notification Ambiguity – Numerous Cold Steel Rolling Mills operated under Consent to Establish (CTE) and Consent to Operate (CTO) without prior EC due to notification ambiguity – NGT granted one-year grace period for compliance – Supreme Court supports this approach to avoid economic and social disruptions [Paras 11-18].

Judicial Review – Tribunal Powers – Sustainable Development – NGT’s power to issue compliance periods under Section 21 of the NGT Act recognized – Supreme Court cites suo moto jurisdiction and need for pragmatic environmental governance balancing development and compliance [Paras 19-23].

Decision: Civil Appeal No. 3116 of 2020 dismissed – Closure notice issued by Gujarat State Pollution Control Board quashed – Civil Appeal No. 3576 of 2020 disposed of accordingly [Para 25].

Motor Vehicle Laws – Accident Compensation – Appeal against High Court’s reversal of MACT’s compensation award – High Court erred in doubting the link between the accident and the offending vehicle – Tribunal’s findings based on credible witness testimony – Supreme Court reinstates compensation with recalculations in line with Pranay Sethi judgment [Paras 1-16].

Motor Vehicles Act – Section 166 – Application for Compensation – Evidentiary standards for criminal trials not applicable to summary proceedings under Section 166 – Supreme Court emphasizes reliance on evidence presented, not potential criminal trial evidence – Compensation recalculated to include spousal and parental consortium but excludes loss of love and affection [Paras 10-13].

Judicial Review – Recalculation of Compensation – Supreme Court recalculates compensation considering future prospects and other damages per Pranay Sethi – Enhanced compensation awarded using judicial discretion under Article 142 of the Constitution [Paras 12-15].

Decision: High Court order set aside – Compensation recalculated and awarded with 7% interest p.a. from the claim application date till realization [Para 16].

Contempt of Court – Summary Proceedings – Denial of Trial – Appeal against CAT’s conviction for contempt under Section 14 of the Contempt of Courts Act, 1971 – Appellant denied charges and sought trial – CAT proceeded without trial, relying on behavior observed in court – Supreme Court finds denial of trial improper under Section 14 and Rule 15 of the CAT Rules – Conviction set aside, direction to forward case to Bar Council of India quashed [Paras 1-28].

Judicial Process – Right to Trial – Contempt in the Face of Court – Supreme Court emphasizes necessity of trial when charges are denied – Distinguishes from cases where contemptuous behavior is admitted or incontrovertible – Ensures procedural fairness in contempt proceedings [Paras 14-28].

Decision: Appeal allowed – Impugned order set aside – Conviction and directions to Bar Council quashed – Case underscores procedural fairness in contempt adjudications [Paras 28-29].

Criminal Law – Murder – Life Imprisonment – Appeal against High Court’s reversal of acquittal under Section 302 IPC – Prosecution charged 22 accused with forming an unlawful assembly and committing murder – High Court acquitted 20 accused but convicted appellants (A1 and A2) under Section 302 – Supreme Court finds inconsistencies in prosecution's evidence and contradictions in witness testimonies – Acquittal by Trial Court was based on detailed assessment of evidence – High Court's conviction of appellants not sustained due to lack of cogent reasons to overturn acquittal [Paras 1-27].

Penal Code 1860 (IPC) – Section 302 – Conviction for Murder – Analysis of evidence by Trial Court versus High Court – Importance of consistent witness testimonies and reliable evidence – Supreme Court emphasizes need for stronger rationale to reverse acquittal [Paras 17-25].

Principle of Falsus in Uno, Falsus in Omnibus – Application in criminal jurisprudence – Supreme Court acknowledges principle does not strictly apply but emphasizes need to separate credible evidence from falsehoods – High Court's selective reliance on inconsistent witness testimony criticized [Para 23].

Decision: Appeal allowed – High Court order set aside – Acquittal by Sessions Court restored – Appellants to be released unless required in other cases [Para 27].

Criminal Procedure – Summoning Witnesses – Section 311 CrPC – Appeal against High Court’s rejection of application to summon cellular nodal officers – Power under Section 311 CrPC to summon, examine, recall, or re-examine any material witness at any stage – Closing of prosecution evidence not an absolute bar – Essentiality of evidence for just decision of the case is crucial – High Court and trial court orders set aside – Application allowed, directing trial court to conclude proceedings expeditiously [Paras 1-44].

Criminal Jurisprudence – Just Decision – Role of Courts – Emphasis on court's active role in discovering truth and ensuring justice – Statutory provisions to be interpreted purposively to aid in uncovering facts essential to the case – Denial of application under Section 311 CrPC found unjustified due to its importance in linking accused’s location with crime [Paras 28-43].

Judicial Discretion – Exercise of Power – Section 311 CrPC – Courts must exercise power judiciously and not arbitrarily – Importance of obtaining material evidence that could influence the outcome of the case – Court’s decision guided by need for justice and truth [Paras 30-32].

Decision: Appeal allowed – High Court order set aside – Application to summon cellular nodal officers and decoding registers granted – Trial court directed to conclude trial by October 31, 2022 [Para 44].

Consumer Protection – Deficiency in Service – Banking Services – Appeals against NCDRC orders dismissing appeal and review application – Appellant's complaint regarding deficiency in service by HDFC Bank in prematurely encashing a joint Fixed Deposit (FD) without joint instructions – SCDRC wrongly relegated appellant to civil court – NCDRC erred in not entertaining review application – Consumer complaint restored to NCDRC for merit-based resolution – Orders of NCDRC set aside, case remanded for fresh adjudication [Paras 1-22].

Consumer Definition – Joint FD Holders – Appellant and father as joint FD holders – Consumer status under Section 2(1)(d)(ii) of Consumer Protection Act, 1986 – Deficiency of service claim valid under Section 2(1)(g) – FD encashment issue pertains to deficiency in banking service, not a personal dispute [Paras 9-20].

Judicial Review – Reinstatement of Appeal – NCDRC's procedural failure – Appellant's affidavit denying withdrawal instructions – Review application justified – Appeal reinstated with directions for expedited resolution [Paras 21-23].

Decision: Appeals allowed – Orders of NCDRC set aside – Consumer complaint restored for merit-based resolution – NCDRC directed to dispose of the appeal within four months – All rights and contentions of parties kept open [Para 21-23].

Service Law – Age Relaxation – Recruitment – Appeal against High Court's direction for age relaxation under Uttar Pradesh Public Services (Relaxation of the Age Limits for Recruitment) Rules, 1992 – Respondent sought age relaxation for appointment as Mukhya Sevika – High Court's decision overturned by Supreme Court – State's uniform application of age limit of 50 years upheld – No vested right to age relaxation – Eligibility criteria should be uniformly applicable to avoid arbitrary selection [Paras 1-16].

Public Services – Age Limit – Discretionary Power – Governor's discretion under Rule 3 of Age Relaxation Rules – Applicable to candidates recruited from open category through competitive examination – Respondent’s claim for relaxation as Anganwadi worker not justified under Rules – Uniform age criteria necessary for fair selection process [Paras 12-15].

Decision: Appeal allowed – High Court judgment set aside – Respondent’s writ petition dismissed – Uniform application of age criteria upheld – No arbitrary exceptions permitted in recruitment [Para 16].