Criminal Law – Private Defense – Appellant, a BSF constable, fired at intruders in self-defense – Right of private defense extends to causing death if there is reasonable apprehension of danger to life – Incident occurred in a high-risk area near the Bangladesh border with history of smuggling and attacks on BSF personnel – Court held that actions were in exercise of the right of private defense as the appellant was confronted by armed intruders and had no recourse to State aid – Conviction for murder altered to culpable homicide not amounting to murder under Section 300 Exception 2 IPC [Paras 1-27]​​.

Evidence – Testimonies and Circumstances – Court relied on testimonies of witnesses and the specific topography of the crime scene – Discrepancies in witness statements regarding the positioning of the deceased and the appellant explained by the uneven terrain – Right of private defense supported by the presence of immediate threat and absence of malice [Paras 8-25]​​.

Decision – Appeal Partly Allowed – Conviction under Section 302 IPC set aside – Conviction altered to culpable homicide not amounting to murder under Section 304 IPC – Considering the appellant had already served over eleven years in prison, sentence deemed sufficient – Appellant released for time served, and bail bonds discharged [Paras 26-27]​​.

Civil Law – Presumption of Marriage – Long cohabitation between a man and a woman raises a presumption of marriage under Section 114 of the Evidence Act – The High Court erred in denying partition of property based on the legitimacy of the plaintiff – Sufficient evidence of long cohabitation and recognition of the relationship by society supports the presumption of marriage and legitimacy of the offspring [Paras 1-27]​​.

Civil Procedure – Final Decree Proceedings – Trial Courts should not adjourn matters sine die after passing a preliminary decree for partition – Courts must proceed suo motu for drawing up the final decree under Order 20 Rule 18 CPC to avoid undue delay in the realization of the decree’s benefits – Separate final decree proceedings are discouraged to streamline the process and ensure timely relief [Paras 29-33]​​.

Decision – Appeals Allowed – The High Court's judgment set aside – Trial Court's decree for partition restored – Directive issued to Trial Courts to automatically proceed with final decree steps after a preliminary decree without requiring separate proceedings [Paras 28, 34]​​.

Civil Procedure – First Appeal – Scope and Duty of First Appellate Court – Section 96 CPC provides for filing an appeal from a decree passed by a court of original jurisdiction – Order 41 Rule 31 mandates that the judgment of the appellate court must state points for determination, decisions thereon, and reasons for decisions – Appellate court’s failure to comply with these requirements leads to infirmity in the judgment – High Court erred by not considering evidence and reasoning provided by the Trial Court, and by failing to form points for determination [Paras 26-30]​​.

Property Law – Ancestral and Self-Acquired Property – Appellant and respondent, as children of deceased Puttanna, were entitled to shares in the property acquired by their father – Property cultivated by Puttanna and granted occupancy rights posthumously is heritable – Appellant entitled to 1/2 share, not 1/4 share as modified by the High Court – High Court's judgment set aside, Trial Court’s decree restored [Paras 9-25, 31]​​.

Decision – Appeal Allowed – High Court’s judgment set aside – Trial Court’s decree restored, affirming appellant’s 1/2 share in property described at item no. 3 of Schedule 'A' – Final decree proceedings to be conducted accordingly – No order as to costs [Paras 31-32]​​.

NEET-PG Counselling – Conduct of Special Stray Round – Petitioners sought a Special Stray Round of counselling for the remaining 1456 vacant seats after NEET-PG-2021 counselling rounds – Supreme Court held that the admission process must have an endpoint and must adhere to a strict schedule – Emphasized that any deviation could compromise medical education standards and public health – Found that non-clinical seats typically remain vacant annually and re-affirmed no scope for mid-session admissions [Paras 1-12].

Procedural Adherence – Adherence to Time Schedule – Court noted the existing nine rounds of counselling already conducted, fulfilling the mandated procedure – Further round was deemed unnecessary and impractical, as it could interfere with NEET-PG-2022 admissions – Affirmed previous decisions highlighting the importance of maintaining the time schedule for medical admissions to ensure academic and professional integrity [Paras 10.1-10.7].

Public Interest and Education Quality – Balancing Seats and Quality – Court recognized the need to balance seat occupancy with quality education – Determined that endless counselling rounds would disrupt educational timelines and lower the standard of medical education – Emphasized that maintaining a strict schedule is crucial for the credibility and functionality of medical education systems [Paras 10.4-10.6].

Decision – Petitions Dismissed – Held – Petitions for conducting a Special Stray Round of counselling for NEET-PG-2021 dismissed – No order as to costs – Reiterated that adherence to established counselling schedules is essential for maintaining order and standards in medical education [Paras 11-12].

Custody of Child – Welfare of Minor – The paternal grandparents sought custody of their minor grandson, whose parents passed away during the Covid-19 pandemic – High Court had handed over custody to the maternal aunt – Supreme Court reversed this decision, emphasizing the emotional and loving care provided by paternal grandparents – Grandparents' ability to provide a stable environment and the minor's expressed preference to stay with them were significant factors – Court directed that custody remain with the paternal grandparents while granting visitation rights to the maternal aunt [Paras 1-12].

Guardianship – Emotional Bond and Stability – The Court highlighted that grandparents often provide deep emotional support and stability to grandchildren – Rejected the notion that age and financial independence alone could determine the best interest of the child – Court acknowledged that the minor showed a willingness to stay with grandparents during the interim custody period [Paras 7.1-7.2].

Decision – Appeal Allowed – Held – High Court's order to give custody to the maternal aunt was set aside – Custody granted to paternal grandparents with visitation rights to the maternal aunt – Directed both families to act jointly and cordially for the child's welfare – Emphasized the need to consider the minor's emotional and educational well-being, ensuring regular contact with both families [Paras 8-12].

Insolvency Law – Withdrawal of CIRP – The appellant sought to withdraw the Corporate Insolvency Resolution Process (CIRP) of Siva Industries under Section 12A of the IBC after the Committee of Creditors (CoC) approved a settlement plan with a 94.23% majority – NCLT and NCLAT rejected the withdrawal application and directed liquidation – Supreme Court emphasized the paramount importance of the commercial wisdom of the CoC in such decisions, stating that adjudicating and appellate authorities should not interfere unless the decision is capricious or irrational [Paras 1-28].

Commercial Wisdom of CoC – Paramount Status – The Court reiterated that the commercial decisions of the CoC should not be subject to judicial review unless found to be arbitrary, capricious, or de hors the law – The Court upheld the decision of the CoC to approve the settlement plan and allowed the withdrawal of CIRP, aligning with the principles of minimizing judicial intervention in commercial decisions under the IBC framework [Paras 21-28].

Decision – Appeals Allowed – Held – Orders of NCLT and NCLAT set aside – Application for withdrawal of CIRP allowed – Emphasized the importance of adhering to the commercial wisdom of CoC and reducing judicial intervention in insolvency proceedings [Paras 28-29].

Environmental Protection – Ecologically Sensitive Zones (ESZ) – Supreme Court directed a minimum ESZ of 1 kilometer around all protected forests, national parks, and wildlife sanctuaries, with existing activities allowed to continue subject to guidelines – Emphasized the importance of a buffer zone to protect wildlife and forest ecosystems – For Jamua Ramgarh sanctuary, subsisting activities allowed within 500 meters, but new activities require adherence to the 1-kilometer ESZ norm [Paras 1-20].

Prohibited and Regulated Activities – Guidelines Adherence – The Court mandated strict compliance with the Guidelines of 9th February 2011 for activities within the ESZ – Prohibited activities include commercial mining, setting up of industries causing pollution, and major hydro-electric projects – Certain activities like tree felling, commercial use of water resources, and establishment of hotels to be regulated [Paras 6-7, 9, 32].

Role of State – Public Trust Doctrine – The Court highlighted the State's role as a trustee of natural resources, emphasizing sustainable development – Reiterated the need for States to protect forests while balancing economic activities – Directed State and Union Territories' authorities to ensure compliance and report on subsisting structures within ESZs [Paras 25, 28-29].

Decision – Applications Allowed/Dismissed – Held – Directions issued for maintaining ESZ and regulating activities within these zones – Rejected claims for resuming mining activities within prohibited areas of the Jamua Ramgarh sanctuary – Allowed implementation of the Guidelines for ESZ across all protected areas – Emphasized the need for compliance with environmental protection laws and sustainable development principles [Paras 34-35, 42].

Ancient Monuments and Archaeological Sites – Permissible Construction – The construction activities undertaken by the State of Odisha within the prohibited area of Shree Jagannath Temple for providing basic amenities like toilets, cloak rooms, and electricity rooms – Supreme Court upheld these constructions, stating that they do not fall under the definition of "construction" as per Section 2(dc) of the Act and are necessary for public convenience – Court emphasized the harmony between Section 2(dc) and Sections 20C and 20D, permitting essential public facilities even within the prohibited area [Paras 30-43].

Interpretation of Statutes – Legislative Intent – The Court highlighted that legislative intent behind excluding certain constructions from the definition of "construction" under Section 2(dc) was to allow essential services for public convenience – Emphasized that statutory provisions should be read harmoniously to avoid rendering any section otiose or redundant [Paras 41-42].

Public Interest – Development of Heritage Sites – Supreme Court reiterated its previous directions from the Mrinalini Padhi case for providing modern amenities like toilets and cloak rooms in the vicinity of Shree Jagannath Temple – The Court recognized the necessity of such facilities for the welfare of devotees and aligned with the broader goal of developing Puri as a world heritage city [Paras 21-28].

Decision – Appeals Dismissed – Held – The construction activities challenged by the appellants were found to be in accordance with the statutory provisions and necessary for public welfare – Appeals dismissed with costs – The Court criticized the misuse of public interest litigations for personal or publicity interests, emphasizing the need to curb such practices [Paras 57-60].

Criminal Law – Sole Witness Testimony – The conviction of the appellants was based on the sole testimony of Amol Singh (P.W.6) – Supreme Court held that when a witness is "wholly reliable," conviction or acquittal can be based on such testimony – Conversely, if a witness is "wholly unreliable," neither conviction nor acquittal can be based on their testimony – The evidence of Amol Singh (P.W.6) was found to be "wholly unreliable" due to contradictions and the testimonies of other witnesses – The Court emphasized that corroboration is necessary when the testimony falls in the third category of being neither wholly reliable nor wholly unreliable [Paras 12-22].

Medical Evidence and Motive – The Court noted that medical evidence only established that the death was homicidal and could not corroborate the witness’s claim of having witnessed the incident – It also reiterated that establishing motive alone is insufficient for conviction if the primary evidence is unreliable [Paras 22-23].

Decision – Appeals Allowed – Held – The convictions and sentences imposed by the High Court and the Trial Court were set aside – The appellants were acquitted of all charges and ordered to be released forthwith if not required in any other case [Paras 24-25].