Criminal Procedure – Joint vs. Separate Trial – Sections 218–223 Cr.P.C. – Segregation of MLA’s trial quashed – The trial court, affirmed by the High Court, ordered a separate charge-sheet and segregated trial for the appellant (a sitting MLA) to facilitate “day-to-day” hearing relying on Ashwini Kumar Upadhyay – Held: Segregation solely due to MLA status, without notice or legal necessity, misapplies law; impugned orders set aside; joint trial directed [Paras 7, 10–12.1, 16.1, 21, 24–25].

Natural Justice – Audi Alteram Partem – Suo motu segregation without notice – Unfair procedure vitiates order – The trial court acted suo motu without prior notice or hearing to the appellant; mere presence of counsel is not equivalent to meaningful opportunity – Such departure from fair procedure infringes Article 21 and cannot be cured by subsequent progress of trial [Paras 12.1, 17–19].

Criminal Procedure – Scope of Sections 218–223 Cr.P.C. – When joint trial is the norm – Where prosecution alleges one transaction/overarching conspiracy, with common witnesses and interlinked evidence, joint trial is warranted to avoid multiplicity, inconsistent findings and duplication – Separate trial requires cogent reasons such as demonstrable prejudice or distinct transactions; absent here [Paras 9, 13–14, 16, 22].

Precedents – Ashwini Kumar Upadhyay directions – Purpose is expedition, not derogation – Directions to prioritise MPs/MLAs’ cases do not authorise deviation from Cr.P.C. scheme or confer any procedural disadvantage upon an accused legislator – Equality before law under Article 14 forbids preferential segregation based on office held [Paras 15, 21, 23–23.1].

Case Management – Dealing with delay by co-accused – Proper course is to proceed against absconding or defaulting accused, not to sever a compliant accused – The trial court inverted the principle; no finding that joint trial would prejudice defence or cause delay; evidence from one trial cannot be imported into another, risking procedural complications [Paras 10, 16, 16.1, 18].

Investigative Discretion – Direction to file separate charge-sheet – Ultra vires – The discretion to file a charge-sheet lies with the investigating agency; court exceeded jurisdiction in directing a separate challan; even multiple charge-sheets in same transaction must ordinarily be tried together [Para 20].

Decision – Appeals allowed – Impugned trial-court orders dated 28.08.2024 and 02.09.2024 and High Court judgment dated 12.12.2024 set aside – Direction to file separate charge-sheet and to segregate appellant’s trial quashed – Matter remitted for joint trial with co-accused; trial court to ensure expedition consistent with procedural safeguards after hearing all parties [Paras 24–26].

Civil Law – Limitation – Validity of Sale Deed – Plaintiffs claimed 1/3rd share in agricultural land – Alleged that sale deed dated 14.06.1973 executed in favour of defendant was fraudulent and without consideration – Trial Court dismissed the suit as time-barred – First Appellate Court decreed the suit holding that the sale deed was void and suit filed within 12 years under Article 65 Limitation Act, 1963 – High Court affirmed the decree but held Article 59 applied, though suit was still within limitation – Supreme Court clarified that since sale deed was void ab initio, Article 65 (12 years) applied, not Article 59 (3 years) – Appeal dismissed [Paras 3–15, 24–41].

Limitation Act – Article 65 vs Article 59 – Court distinguished between void and voidable instruments – Article 59 applies only to voidable instruments requiring cancellation (fraudulent misrepresentation as to contents) – Article 65 applies to suits for possession based on title where the impugned document is void/void ab initio (fraud as to character or want of consideration) – Plaintiff, not being party to the void transaction, need not seek cancellation – Merely seeking joint possession suffices [Paras 25–29, 31–33].

Evidence – Proof of Fraudulent Sale Deed – Plaintiffs proved that thumb impressions on sale deed were not theirs – Expert testimony unchallenged – Defendant failed to produce original sale deed or prove payment of sale consideration of ₹15,000 – Husband of defendant, alleged to have paid balance ₹6,000, not examined – Attesting witness (brother of defendant) considered biased – Sarpanch attesting witness deceased – Courts held absence of valid execution and want of consideration rendered deed void [Paras 27, 35–38].

Transfer of Property Act, 1882 – Section 54 – Essential element of sale is transfer of ownership for a price – Sale without consideration is void – In present case, defendant failed to prove payment of consideration – Sale deed therefore void, conferring no title [Paras 34–38].

Principles Restated – (i) Void documents need not be cancelled; possession can be claimed under Article 65 – (ii) Burden lies on party relying on sale deed to prove valid execution and consideration – (iii) Limitation runs from date possession becomes adverse, not from date of void deed – (iv) Courts must distinguish between fraudulent misrepresentation as to character (void) and contents (voidable) of document [Paras 28–29, 31–33, 39–40].

Decision – Supreme Court dismissed appeal – Held that sale deed dated 14.06.1973 was void ab initio – Suit filed on 28.02.1984 within 12 years of sale deed was within limitation under Article 65 – High Court erred in applying Article 59 but rightly upheld maintainability of suit – Plaintiffs entitled to joint possession – Appeal dismissed [Paras 40–41].

PIL - Disability Rights – Constitutional Interpretation – RPwD Act – Judicial Directions – Court Declares Accessibility a Constitutional Mandate – The Court held that disability is not a deficit but a form of diversity – Failure to provide accessible systems is a constitutional violation – Courts must uphold inclusive frameworks to ensure dignity, autonomy, and equality for persons with disabilities [Paras 1–5, 27–35].

Institutional Care – Systemic Reforms – State Failure in Compliance – Directions Issued – The Court noted longstanding non-compliance by several States and UTs with orders concerning implementation of the RPwD Act – Directed nationwide monitoring through National Law Universities under “Project Ability Empowerment” to audit care institutions and recommend systemic reforms [Paras 6–11, 36–47].

Care Institutions – Monitoring Mechanism – Project Ability Empowerment – Eight National Law Universities assigned regional jurisdiction to inspect institutions housing persons with cognitive disabilities – Detailed thematic parameters outlined including resident profiling, health care, rehabilitation, education, infrastructure, and grievance redressal – Directions given for detailed report within six months [Paras 36–38, 47].

International Law – UNCRPD and Other Treaties – Interpretation and Application – The Court relied heavily on the UNCRPD and international human rights conventions to affirm the dignity and autonomy of persons with disabilities – Recognised the obligation of State parties to ensure community-based care, deinstitutionalisation, and accessibility [Paras 25–34].

Reservation Policy – Section 34 RPwD Act – Upward Migration for Meritorious PwD Candidates – Discriminatory Practice Condemned – The Court highlighted denial of “upward migration” to meritorious PwD candidates in employment, calling it hostile discrimination – Directed Union of India to explain if corrective action has been taken – Held: Reservations must reach the genuinely disadvantaged, and merit-based PwD candidates should not be counted against reserved seats [Paras 48–54].

Final Decision – Monitoring Mandated – Central and State Authorities Directed to Cooperate – Court directed constitution of “Project Ability Empowerment” and ordered all stakeholders including District Magistrates, Social Welfare Departments, and Ministry of Social Justice to fully support the monitoring – Directed interim funding of ₹25 lakhs per NLU and fixed deadline for report submission – Matters listed for further monitoring on 13th March, 2026 [Paras 44–47, 55–57].

Cruelty – Decree of Divorce – Section 13(1)(ia) of Hindu Marriage Act – Divorce Affirmed – The husband filed for divorce on grounds of mental cruelty; the wife filed counter-allegations including domestic violence – Family Court granted divorce which was upheld by the High Court – Supreme Court observed long-standing acrimony and prolonged separation since 2009, holding that false complaints constituted cruelty – Decree of divorce upheld [Paras 3.2–3.7, 7].

Domestic Violence – Compensation – DV Act Proceedings – Wife Entitled – Though initial complaint under DV Act was dismissed, appellate courts found the husband guilty of domestic violence and directed compensation of ₹2,00,000/-, later enhanced to ₹7,00,000/- – SLP against this enhancement was dismissed by Supreme Court – Proceedings under DV Act thus culminated in favour of wife [Paras 3.3–3.5].

Child Marriage Expenses – Contribution by Father – Reasonable Demand – Appellant-wife sought ₹10,00,000/- for daughter’s marriage – Despite husband’s denial of income, Court held he was capable of contributing – Directed to pay ₹10,00,000/- by 15th October 2025 – Held: Contributing to child’s marriage is a natural parental duty irrespective of spousal disputes [Paras 5–10].

Final Decision – Appeals Partly Allowed – Divorce decree affirmed – Supreme Court directed husband to pay ₹10,00,000/- towards daughter’s marriage expenses, failing which the appeals would be revived – Appeals accordingly disposed of [Paras 10–13].

Legal Metrology – Search and Seizure – Procedural Violations – Quashing of Notices – Appeal Allowed.

Search and Seizure – Legal Metrology Act, 2009 – Appellant (ITC Limited) challenged seizure of 7,600 pre-packed notebooks from its warehouse by Legal Metrology officials for alleged violation of Rule 24(a) of the Legal Metrology (Packaged Commodities) Rules, 2011 – Seizure conducted under Section 15 of the 2009 Act without obtaining warrant or recording “reasons to believe” – High Court’s Division Bench upheld seizure, reversing Single Judge’s quashing order – Held: Seizure was illegal – Officials failed to comply with mandatory safeguards under Section 15 of the 2009 Act and Sections 100(4), 165 of the Cr.P.C – No warrant obtained – No reasons to believe recorded – Single witness (driver) not independent – No urgency or exigency pleaded – Procedural violations vitiated entire action [Paras 11-23].

Criminal Procedure – Application of Cr.P.C to Special Acts – Section 15(4) of the Legal Metrology Act mandates compliance with Cr.P.C for search and seizure – Search requires “reasons to believe” and warrant unless exigency shown – Presence of two independent witnesses mandatory under Section 100(4) Cr.P.C – Held: Procedural safeguards under Cr.P.C applicable unless explicitly excluded – Respondent’s claim of “inspection” without warrant unsustainable – Premises, though commercial, not “public” for warrant exemption – CFC packages stored in warehouse do not constitute “wholesale packages” merely due to bulk [Paras 14-20].

Natural Justice – Violation of Principles – Simultaneous issuance of seizure and compounding notices deprived appellant of opportunity to be heard – No hearing granted – No opportunity for objections – Held: Violation of natural justice evident – Division Bench erred in not appreciating legal necessity of procedural compliance [Paras 7.5, 20.1].

Technical Violation – Rule 24 of 2011 Rules – Packages had declarations affixed as labels instead of being printed – Held: Declarations existed – At best, violation was technical – Supported by Supreme Court’s earlier ruling in State of Maharashtra v. Raj Marketing (2011) 15 SCC 525 – Seizure not justified in absence of material inconsistency in declared particulars [Para 22].

Decision: Appeal allowed – Search and seizure held illegal – Orders passed by Division Bench of High Court and impugned notices/quasi-criminal proceedings quashed – Order of Single Judge restored – No costs [Paras 23-24].

Advocates Act – Professional Misconduct – Bar Council of India – Suspension for Three Years – Supreme Court dismisses statutory appeal; imposes ₹1,00,000 costs; directs Collector to attach properties for recovery; Bar Council not to renew licence without prior permission; compliance report to Supreme Court upon completion of sentence [Paras 2-6].

Professional Misconduct – Scope of Appellate Interference – Serious, scandalous allegations by advocate – No leniency – Appeal dismissed with costs – The appellant-advocate, found guilty of professional misconduct and suspended for three years by BCI, had made scandalous allegations against the complainant; the Court, noting the serious nature of misconduct and obstinate conduct, refused to interfere or extend leniency; appeal dismissed with cost of ₹1 lakh [Paras 2-3].

Costs – Mode of Recovery – Attachment of Properties – Compensation to Complainant – Direction to Collector – Court directed the Collector, Agra, to attach appellant’s properties to recover ₹1 lakh cost to be paid to respondent within three months – Ensures effective enforcement and compensation to the complainant [Para 4].

Bar Council – Regulatory Consequence – Non-renewal of Licence Without Court’s Permission – To prevent circumvention of disciplinary penalty, the Bar Council was directed not to renew the appellant’s licence without prior permission of the Supreme Court [Para 4].

Post-Sentence Compliance – Reporting Requirement – After the appellant undergoes the sentence already awarded, a report shall be supplied to the Secretary General of the Supreme Court – Ensures oversight and compliance closure [Para 5].

Decision – Appeal Dismissed – Costs and Directions Affirmed – Statutory appeal dismissed; costs of ₹1 lakh imposed; attachment and non-renewal directions issued; matter disposed of accordingly [Paras 3-6].

Anticipatory Bail – Delay in FIR – Allegations of Mutation on Forged Documents – FIR lodged in 2019 regarding mutation entries based on sale deed dated 18.05.1996 executed on forged powers of attorney in names of deceased landowners – Appellants (A5 and A6), Circle Officer and Talathi at the time, certified mutation entries Nos. 15177 and 15180 in 1996, which were later cancelled by Sub-Divisional Officer in 1998 – FIR lodged after more than 20 years – Supreme Court held that long delay cannot by itself efface allegations of misuse of official position in facilitating fraudulent transfer of immovable property [Paras 3–4, 7–9, 11, 13–14].

Official Capacity – Scope of Criminal Liability – Appellants contended that certification of mutation entries was done in discharge of official duty on the basis of facially valid registered sale deed – No role in preparation of forged documents, no dishonest intention, and no personal gain alleged – Supreme Court held that whether appellants shared criminal intent or colluded with beneficiary (A1) is a matter for trial and cannot be conclusively decided at anticipatory bail stage [Paras 5.1–5.2, 9, 12].

Custodial Interrogation – Necessity – Appellants argued case is based on existing documentary evidence and custodial interrogation unnecessary – Court held that even in documentary fraud cases, custodial interrogation may be required to trace the chain of transactions, ascertain complicity, and prevent tampering of records – Appellants had interim protection for nearly six years but did not fully cooperate with investigation – Justification for custodial interrogation upheld [Paras 5.5, 10, 14].

Delay in Bail Adjudication – Constitutional Concerns – Anticipatory bail applications filed in 2019 remained pending in High Court for nearly six years – Interim protection granted continuously until final rejection on 04.07.2025 – Supreme Court strongly disapproved indefinite pendency of bail applications affecting personal liberty – Reiterated earlier rulings (Nikesh Tarachand Shah, Siddharam Satlingappa Mehtre, Satendra Kumar Antil, Rajesh Seth, Sanjay, Rajanti Devi, Kavish Gupta, Amol Vitthal Vahile, etc.) – Directed High Courts and subordinate courts to decide bail/anticipatory bail applications expeditiously, preferably within two months [Paras 15–18.1].

Principles Restated – Anticipatory bail under Section 438 CrPC is a statutory right, not a fundamental right – Courts must balance personal liberty with fair investigation – Prolonged pendency of bail applications amounts to denial of justice – Administrative directions must be issued by High Courts to prioritise bail matters [Paras 16, 16.9, 17–18.1].

Decision – Appeals dismissed – Rejection of anticipatory bail by Bombay High Court upheld – Appellants at liberty to apply for regular bail, which shall be considered on its own merits, uninfluenced by observations in this judgment – Registrar (Judicial) directed to circulate judgment to all High Courts for compliance [Paras 19–20].

Public Interest Litigation – Deaths in Beggars’ Home due to Cholera – Article 21 – Constitutional Violation Established – Appellant filed a PIL after media reports revealed deaths and illness of several beggars due to contamination in drinking water at Lampur Beggars’ Home – Authorities failed to ensure sanitary conditions and misrepresented facts – Held: Deaths amounted to violation of the right to life and dignity under Article 21 – Supreme Court recognized the need for judicial intervention and systemic reform [Paras 3-10, 18-20].

Institutional Negligence – Departmental Proceedings – Compliance Noted – Respondents submitted that departmental proceedings were concluded and penalties imposed – Court accepted compliance on that front – However, held that mere disciplinary actions were insufficient without sustained structural reforms and monitoring [Paras 21-22].

Beggars’ Homes – Paradigm Shift in Approach – From Penal to Protective Institutions – Constitutional Reframing – Court held that Beggars’ Homes must be viewed through a constitutional lens, aligned with Articles 38, 39(e), 41, and 47 – Emphasised shift from colonial punitive mindset to rehabilitation and dignity-based frameworks – Institutions must ensure health, freedom, privacy, and humane conditions [Paras 16-16.7].

Right to Life with Dignity – Expanded Interpretation – Article 21 – Applicability to Institutionalised Persons – Reaffirmed that all persons, including those in State custody, are entitled to humane treatment, adequate nutrition, healthcare, and dignity – Denial of such constitutes constitutional breach – Emphasised that beggars, unlike convicts, are not criminals and cannot be treated as such [Paras 15-16.6].

Anti-Begging Laws – Judicial Review – Validity and Purpose – The Bombay Prevention of Begging Act and similar laws in other States examined – Court acknowledged State’s interest in regulating begging but cautioned against criminalising poverty – Enforcement must balance public order with constitutional rights – Reiterated Delhi High Court’s earlier partial striking down of such laws [Paras 17-17.5].

Judicial Monitoring – Long-Term Oversight by Supreme Court – Compliance Recorded – From 2004 onwards, Supreme Court issued multiple detailed directions for improvement in Beggars’ Homes – Continuous monitoring led to structural changes, enhanced hygiene, staffing, vocational training, food quality, and medical care – Final reports showed significant compliance and nil complaints from inmates – Court stressed need for reforms to be sustained across India [Paras 22-22.18].

Final Directions – Nationwide Reform Mandated – Article 21 – Court Issued Model Framework – Directions issued to all States/UTs covering medical screening, disease control, hygiene, infrastructure audits, dietary standards, vocational training, legal aid, child and gender-sensitive provisions, and accountability mechanisms – Directed Union Ministry to issue model guidelines within 3 months – Held: Failure to maintain humane conditions in such institutions constitutes breach of fundamental rights [Paras 23-23.3].

Judgment – Appeal Disposed – Structural Reforms Ordered – Supreme Court partially allowed the appeal – Reiterated State's affirmative duty under Article 21 – Upheld PIL’s maintainability – Issued binding directions to State and Union authorities to overhaul Beggars’ Homes nationwide – Liberty granted to seek further directions if needed [Paras 24-25].

Criminal Law – Murder Conviction – Delay in Death – Appellant along with three co-accused dragged the deceased to the terrace, flung him down, and assaulted him with sticks and fists – Victim survived for about nine months before dying of septicemia, pneumonia, and paraplegia caused by spinal cord injury – Trial Court convicted under Section 302 IPC – High Court altered conviction to Section 307 IPC on the ground that death ensued after nine months due to lack of proper treatment – Supreme Court held that injuries were sufficient in the ordinary course of nature to cause death and supervening causes (septicemia, pneumonia) did not break the chain of causation – Conviction under Section 302 IPC restored [Paras 1–7, 19–22, 67–70].

Eyewitness Testimony – Credibility – PW-1 (brother), PW-11 (brother), and PW-12 (mother) were eyewitnesses – Their version consistent and corroborated by medical evidence – Court found no reason to discard their testimonies – Dying declarations of deceased also named the appellant and co-accused [Paras 3, 13, 21].

Medical Evidence – Cause of Death – PW-9 Dr. Kaushal recorded severe head injury and possibility of spinal cord fracture – PW-24 Dr. Chandrakar confirmed paraplegia, infected bedsores, septicemia, and pneumonia arising from spinal cord injury – PW-28 Dr. Shrivastava opined death was due to cardiorespiratory arrest caused by septic shock from infection of injuries – All three doctors ruled injuries as proximate cause of death – Cross-examination failed to shake their testimony [Paras 15–17, 18–21].

Section 307 IPC – Applicability – High Court erred in invoking Section 307 IPC solely because death occurred nine months later – Supreme Court clarified that intention, nature of injuries, and their sufficiency in the ordinary course of nature to cause death determine liability – Delay in death or adequacy of medical treatment irrelevant under Explanation 2 to Section 299 IPC [Paras 23–39, 67–70].

Causation – Supervening Causes – Death due to septicemia, pneumonia, or secondary infections does not absolve accused if such complications flow naturally from the original injury – Court reiterated that an injury sufficient to cause death remains culpable homicide even if death occurs after prolonged medical treatment – No evidence that improper treatment was cause of death – High Court’s reasoning rejected [Paras 40–66, 68–69].

Principles Restated – If injuries are fatal or sufficient in the ordinary course of nature to cause death, subsequent complications do not reduce liability – Delay in death does not diminish culpability – Courts must distinguish between remote, improbable consequences and natural/probable consequences of the injury – In present case, injuries were sufficient to cause death and thus fall under Section 302 IPC [Paras 69–70].

Decision – Appeal dismissed – Supreme Court held High Court committed grave error in reducing conviction to Section 307 IPC – Conviction under Section 302 IPC stands – Appellant liable for murder – No relief granted [Paras 70–71].