Criminal Law – Abetment of Suicide – Conviction based on circumstantial evidence – Appellant convicted under Section 306 IPC for the murder of Kamalamma – High Court reversed trial court's acquittal, convicting appellant based on circumstantial evidence including alleged motive, extra-judicial confession, and discovery of the weapon and body – Supreme Court affirmed High Court’s decision, emphasizing suspicion cannot substitute for proof beyond reasonable doubt – Conviction upheld [Paras 1-11, 12-19].

Section 106 of the Indian Evidence Act – Applicability – Burden of proof – When a death occurs within the privacy of the home and the accused is the only person with the deceased, the burden shifts to the accused to explain the circumstances leading to death – Appellant's failure to offer a satisfactory explanation strengthens the prosecution case – Court affirmed principle that false or no explanation can be an additional link in the chain of circumstances [Paras 12-13, 18-19].

Concurrent Findings – Judicial Review – Supreme Court reiterated the principle that it would not interfere with concurrent findings of fact unless there is a manifest illegality or error resulting in grave injustice – High Court and Trial Court had concurrent findings establishing guilt of the appellant – No ground for interference found [Paras 11, 19].

Decision – Appeal dismissed – Conviction and sentence of life imprisonment upheld – No interference with concurrent findings of lower courts [Para 19].

Civil Procedure – Counter-Claim – Late Filing – Counter-claim filed 13 years after written statement – Single Judge allowed counter-claim to avoid multiplicity of proceedings – Division Bench set aside order for lack of opportunity to plaintiffs – Supreme Court restored Single Judge’s order, emphasizing counter-claim filed before issues framed – Late counter-claim permitted in exceptional circumstances before commencement of plaintiff’s evidence – Procedural laws should aid justice, not obstruct it [Paras 1-19].

Principles from Ashok Kumar Kalra Case – Timeliness – Counter-claim generally filed with written statement – Court discretion to allow late counter-claim considering factors like period of delay, reason for delay, and prejudice to opposite party – Not typically allowed after issues framed – Supreme Court found no prejudice or undue delay here, counter-claim necessary for comprehensive adjudication [Paras 13-13.1].

Decision – Appeal allowed – Division Bench order set aside – Single Judge order restored – Suit to proceed from current stage with counter-claim on record – No costs [Paras 18-19].

Specific Performance – Readiness and Willingness – Compliance of "readiness and willingness" under Section 16(c) to be in spirit and substance, not merely in form – High Court's finding of compliance affirmed – Plaintiff had made specific pleadings and provided evidence of readiness and willingness to perform contractual obligations [Paras 1-88].

Limitation Act – Article 54 – Suit filed within prescribed limitation period – Time for performance not essence of contract in immovable property cases – Equity principle of delay not applicable if suit within limitation period – High Court's conclusion on limitation upheld [Paras 9-12].

Discretion under Section 20 of Specific Relief Act – Grant of specific performance is discretionary – Consideration of readiness and willingness, conduct of parties, hardship to defendant – High Court's decision to grant specific performance justified – Directions for additional payment to respondent in light of substantial increase in property value since agreement [Paras 13-24].

Decision – Appeal dismissed – High Court's decree for specific performance confirmed with additional payment directions – Respondent to deposit additional amount within eight weeks, appellant to execute sale deed upon deposit [Para 24].

Criminal Law – Quashing of Cognizance – Misappropriation of stocks worth Rs. 16,99,648/- – High Court directed further investigation into the role of the appellant, a District Manager, despite his exoneration in departmental proceedings – Supreme Court upheld the High Court's order for further investigation but expunged remarks prejudicial to the appellant – Investigation to be concluded impartially and independently [Paras 1-24].

Section 482 CrPC – Inherent Powers of High Court – High Court justified in exercising inherent powers to direct further investigation – Such powers to be used sparingly, with circumspection, and in exceptional cases – Observations prejudicial to appellant's case deleted to ensure fair investigation [Paras 11-21].

Right to Fair Investigation – Article 21 of the Constitution – Ensuring fair and just investigation is fundamental – High Court's order for further investigation deemed necessary to secure the ends of justice – Investigation to be conducted impartially, without influence from expunged remarks [Paras 13-19].

Decision – Appeal dismissed with modifications – Further investigation ordered by High Court to continue without prejudice from specific observations – Matter left open for examination by investigating agency, sanctioning authority, and concerned court at relevant stages [Para 21-22].

Income Tax – Employee Contribution – Deduction of Employees' Contributions to PF/ESI – Section 36(1)(va) vs. Section 43B – Contributions must be deposited on or before the due date specified in the respective acts for deduction eligibility – Distinction between employer's contribution (Section 36(1)(iv)) and employees' contribution (Section 36(1)(va)) upheld – Non-obstante clause of Section 43B does not override the specific condition in Section 36(1)(va) – High Court's interpretation upheld [Paras 30-54].

Principles of Interpretation – Strict Construction of Tax Statutes – Deduction provisions in tax statutes must be strictly complied with – No equitable considerations in tax statutes – Parliament's intent in distinguishing employer's and employees' contributions in the IT Act emphasized [Paras 46-50].

Decision – Appeals dismissed – High Court's decision that employees' contributions to PF/ESI must be deposited by the due date under the respective acts for the amounts to be deductible under Section 36(1)(va) affirmed [Para 54].

Land Acquisition – Compensation – Jammu and Kashmir State Land Acquisition Act, 1990 – Acquisition proceedings initiated under the State Act of 1990 – High Court directed compensation as per the Act, 2013 – Supreme Court held Act, 2013 not applicable to State Act of 1990 – Compensation to be determined under the State Act of 1990 – High Court's order set aside [Paras 5-6].

General Clauses Act – Section 6 – Saving of rights, liabilities, and obligations under repealed laws – Order 2019 issued post-Act 2013 – Rights and liabilities under State Act of 1990 continue under General Clauses Act – No application of Section 24(1)(a) of Act, 2013 to State Act of 1990 [Para 5.3].

Order of Status Quo – Impact on Award Declaration – Award not declared due to High Court's stay order – High Court's reliance on non-declaration of award for compensation under Act, 2013, erroneous – Period of stay to be excluded in determining applicability of Act, 2013 [Para 5.4].

Decision – Appeals allowed – High Court's judgment directing compensation under Act, 2013 quashed – Matter remanded to High Court to decide writ petitions on other grounds challenging land acquisition proceedings under State Act of 1990 – Applicability of Act, 2013 concluded and not to be reopened [Para 7].

Land Acquisition – Public Purpose – Karnataka Industrial Areas Development Act, 1966 – Land acquisition for private companies – Acquisition upheld when for public purpose and in furtherance of Act's objectives – Regulations permit land allotment to single company for industrial development with State Government's consultation – Acquisition for MSPL and AISL upheld as consistent with statutory requirements [Paras 28-41].

Environmental Clearance – Acquisition Validity – Karnataka Industrial Areas Development Act, 1966 – Environmental clearance obtained subsequently validates acquisition – Absence of clearance at acquisition time not fatal when eventual clearance granted – Clearance from MOEF and KSPCB considered [Paras 25-33].

Procedural Compliance – Notification Validity – Simultaneous issue of notifications under Sections 1(3), 3(1), and 28(1) of 1966 Act upheld – Procedure under Section 28, including objection consideration, complied – No evidence of undue haste or non-application of mind [Paras 33-35].

Single Company Acquisition – Public Purpose – Acquisition for a single company's industrial project valid under 1966 Act – Board empowered to allot land to individual companies with State Government approval – Allotment to MSPL and AISL in furtherance of industrial development objectives [Paras 37-41].

Judicial Review – High Court Overreach – Division Bench’s inclusion of value judgments on policy views criticized – High Court’s quashing of notifications overturned – Emphasis on statutory interpretation and procedural adherence [Paras 42-44].

Decision – Appeals allowed – High Court's quashing of acquisition notifications reversed – Acquisition proceedings for MSPL and AISL validated – Environmental and procedural compliance confirmed [Para 24-44].

Criminal Law – Issuance of Process – Section 204 CrPC – Requirement for reasoned order – Magistrate must provide reasons for concluding prima facie case against accused – Issuance of process is not an empty formality – Order of Magistrate set aside for lack of reasons [Paras 28-30].

Vicarious Liability – Section 34 of Drugs and Cosmetics Act – Specific Averments Required – Directors' liability for company's offence requires specific averments of their role in conduct of business – Merely being a director insufficient for prosecution – Detailed role and responsibility must be specified in complaint – Complaint against directors lacking such details quashed [Paras 13-24].

Procedural Compliance – Drug Manufacturing – Compliance with Rule 76 of Drugs and Cosmetics Rules – Active direction and supervision by approved competent technical staff – Directors not responsible for day-to-day supervision unless specified – Letters from technical staff confirming compliance [Paras 6-10].

Decision – Appeal allowed – High Court and CJM's orders quashed – Complaint against appellants dismissed for lack of specific averments and procedural irregularity – Complaint to proceed against other accused as per law [Paras 31-32].

Service Law – Seniority Determination – Officiating Period Exclusion – Seniority calculation must exclude period spent in a promotional post on officiating basis unless specified otherwise in rules – Officiating service cannot count towards length of service in a particular post for seniority purposes – Appellants' seniority claim based on officiating service rejected [Paras 12-14].

Nagaland SCERT Service Rules, 2003 – Eligibility Criteria – Five years continuous service in feeder grade required for promotion – Appellants failed to meet eligibility criterion of continuous service in feeder grade as per 2003 Rules – Regularization of service after 2003 Rules' operationalization must comply with rule stipulations [Paras 13-15].

Judicial Review – DPC Recommendations – Limited judicial interference with Departmental Promotion Committee (DPC) recommendations unless exceptional circumstances – Previous High Court remand for fresh DPC consideration complied with – Fresh DPC recommendation favoring appellants overturned due to non-compliance with eligibility criteria [Paras 7-9].

Decision – Appeal dismissed – Seniority of appellants cannot be computed including officiating period – Respondent No. 4's seniority maintained as per valid regularization date – Authorities to re-compute seniority based on this judgment [Paras 16-18].