Ex-Parte Decree – Setting Aside – When an ex-parte decree is set aside and the suit is restored, the defendants cannot be relegated to the position prior to the date of hearing of the suit – Defendants are debarred from filing any written statement but can participate in the hearing of the suit, cross-examine the plaintiff's witnesses, and address arguments [Paras 6, 7].

High Court's Scope – Beyond Jurisdiction – The High Court's observation that defendants cannot file their written statement after setting aside the ex-parte decree was beyond the scope and ambit of the matter before it – The Trial Court should consider the prayer of the defendants to file their written statement [Paras 3.2, 6].

Remand to Trial Court – The issue of whether the defendants may be allowed to file their written statement should be remanded to the Trial Court – The Trial Court should decide this issue based on law and its merits, allowing the original plaintiff to resist the application [Paras 6, 7].

Decision: Appeals allowed in part – High Court's order quashed to the extent it barred defendants from filing their written statement – Matter remanded to the Trial Court to decide the issue within three months from the first date of hearing – No order as to costs [Paras 7-8].

Criminal Law – Cruelty – Appellant convicted under Section 498A IPC for subjecting his wife to cruelty, leading to her suicide – High Court acquitted appellant under Section 304B IPC but confirmed conviction under Section 498A IPC – Supreme Court examined admissibility of deceased’s statements under Section 32(1) of Evidence Act – Held, evidence of deceased wife regarding cruelty is admissible under Section 32(1) if cause of death comes into question and evidence relates to circumstances of death [Paras 1-28].

Evidence Law – Admissibility of Statements by Deceased – Section 32(1) of Evidence Act – Statements by deceased admissible if they pertain to cause of death or circumstances leading to death – Acquittal under death-related charges does not bar admissibility under Section 32(1) if death cause is in question – Supreme Court clarified scope and applicability, overruling limited extent of previous judgments [Paras 9-23].

Decision: Appeal dismissed – Conviction and sentence under Section 498A IPC upheld – Appellant to surrender within one week to serve remaining sentence [Para 27-28].

Constitutional Law – Writ Petition – Maintainability – High Court's jurisdiction under Article 227 of the Constitution of India to entertain writ petitions against orders passed by the NCDRC in appeals under Section 58(1)(a)(iii) of the Consumer Protection Act, 2019 – Supreme Court held such writ petitions maintainable – Emphasized that while exercising jurisdiction under Article 227, High Court must adhere to its parameters [Paras 1-17].

Consumer Protection – National Consumer Disputes Redressal Commission (NCDRC) – Writ Petition – High Court jurisdiction under Article 227 – High Court’s interim orders must respect the limited jurisdiction of superintendence – Orders by NCDRC in appeals under Section 58(1)(a)(iii) not subject to further appeal to Supreme Court under Section 67, Consumer Protection Act, 2019 [Paras 10-16].

Decision: Appeal dismissed – High Court’s jurisdiction under Article 227 upheld – Matter remanded to High Court for consideration on merits without expressing opinion on merits [Para 17].

Criminal Law – Rape and Murder – Conviction based on circumstantial evidence – Appellant convicted for the offences punishable under Sections 302 and 376(2)(i) IPC and Section 6 of POCSO Act – Death sentence for the offence under Section 300 IPC punishable under Section 302 IPC commuted to life imprisonment without remission for 30 years – Failure to conduct DNA profiling under Section 53A CrPC not fatal if other evidence suffices to form a complete chain of circumstances pointing to the guilt of the accused [Paras 1-31].

Evidence Law – Last Seen Theory – Applicability – Victim last seen with the appellant – Recovery of the victim’s body at the appellant’s instance – Last seen theory strengthens the prosecution’s case when coupled with other incriminating circumstances – Conviction upheld based on credible witness testimonies and corroborative evidence [Paras 32-35].

Decision: Appeal dismissed – Conviction and sentences under Sections 302 and 376(2)(i) IPC and Section 6 of POCSO Act upheld – Death sentence commuted to life imprisonment with a stipulation of no premature release before 30 years [Para 43].

Constitutional Law – Writ Petition – Postponement of NEET-PG Examination – Petitioners sought postponement of NEET-PG 2022 scheduled for May 21, 2022, due to ongoing counselling process for NEET-PG 2021 – Court held that postponement would cause chaos, uncertainty, and disturb the sanctity of medical education – Highlighted the impact on patient care and availability of resident doctors if the exam is postponed – Reiterated that policy decisions regarding exam schedules are within the executive's domain and not for courts to interfere unless arbitrary or without application of mind [Paras 1-15].

Decision: Petition dismissed – Reliefs sought for postponement of NEET-PG 2022 examination not granted – Emphasized importance of adhering to scheduled timelines for medical examinations and the executive’s role in balancing priorities [Para 15].

Constitutional Law – Contempt of Court – Compensation for Endosulfan Victims – Petitioners affected by Endosulfan sought enforcement of the Supreme Court's order dated January 10, 2017, directing the State Government to compensate affected persons and provide medical facilities – State Government's inordinate delay in compliance exacerbates the violation of fundamental rights under Article 21 – Right to health integral to the right to life – State directed to disburse compensation and provide medical facilities promptly [Paras 1-5].

Contempt of Court – Enforcement of Court Orders – Directions issued for monthly meetings by the Chief Secretary to ensure diligent implementation of the Court's judgment – Costs awarded to petitioners for delayed compensation – Compliance report to be filed indicating progress [Para 5].

Decision: Petition partially allowed – State Government directed to compensate victims and provide medical facilities – Compliance to be monitored through monthly meetings and reports [Paras 5-6].

Criminal Law – Bail – Grant of Bail – Respondent accused granted bail by the High Court – Appellant, wife of the deceased, challenged the bail order – Supreme Court held that the High Court failed to consider the gravity of the offense, the criminal antecedents of the accused, and the threat to witnesses – Order granting bail was unreasoned and showed non-application of mind – Bail order set aside and respondent directed to surrender forthwith [Paras 1-34].

Criminal Procedure – Section 439 CrPC – Discretion in Granting Bail – Courts must exercise discretion judiciously and consider factors such as the nature of the accusation, the severity of the punishment, and potential threats to witnesses – High Court's order lacked proper reasoning and assessment of these factors [Para 16-19, 24].

Decision: Appeal allowed – Bail granted to the respondent by the High Court set aside – Respondent directed to surrender forthwith – High Court's judgment in bail matters to be detailed and reasoned [Para 32-34].

Electricity Law – Captive Generating Plants – Open Access – Appeal by power distribution company against the order of Electricity Regulatory Commission allowing captive power plant to supply electricity to its sister concern – Supreme Court held that the establishment of a captive power plant primarily for own use or for use by an association of persons (including corporate bodies) is permissible under the Electricity Act – Conditions of Rule 3 of the Electricity Rules, 2005 satisfied – No interference warranted with orders of the Regulatory Commission and Appellate Tribunal [Paras 1-26].

Regulatory Framework – Interpretation of Statutory Provisions – Sections 2(8), 9, and 42(2) of the Electricity Act and Rule 3 of the Electricity Rules – Liberal interpretation to promote establishment of captive power plants for reliable and cost-effective power, facilitating industrial growth and employment – Policy under Section 3 of the Electricity Act aligns with the provisions promoting captive power generation [Paras 20-23].

Decision: Appeals dismissed – Orders of the Chhattisgarh State Electricity Regulatory Commission and the Appellate Tribunal for Electricity upheld – No interference warranted [Paras 25-27].

Service Law – Pay Scale – UGC Scale of Pay – Respondent appointed as Librarian-cum-Museum Assistant in an Ayurvedic college sought UGC pay scale as per 1990 Rules – State contended 1990 Rules not applicable as college under Ayush Department – Supreme Court held 1990 Rules applicable to institutions under Higher Education Department, not Ayush Department – Respondent governed by 1987 Rules at appointment and later by 2013 Rules – No parity with librarians under Higher Education Department – High Court orders set aside [Paras 6-23].

Service Law – Equal Pay for Equal Work – Doctrine applicable when employees are similarly circumstanced in every way – Differing eligibility criteria and governing rules preclude application of UGC scales to respondent – Policy decisions on pay scales not interfered with by courts unless discriminatory or arbitrary [Paras 18-20, 24].

Decision: Appeal allowed – High Court's orders set aside – Respondent not entitled to UGC scale of pay [Paras 26-27].