Double Jeopardy – Section 300(1) CrPC – Whether an accused can be tried for an offense under the Negotiable Instruments Act (NI Act) and also for offenses under IPC based on the same set of facts – High Court quashed IPC proceedings citing Section 300(1) CrPC – Supreme Court holds conflicting views on the application of double jeopardy in such cases – Matter referred to a larger bench for clarity [Paras 1-13].

Negotiable Instruments Act – Offense under Section 138 – Cheque issued by respondent dishonored due to insufficient funds – Proceedings initiated under Section 138 of the NI Act – High Court observed overlapping of facts with IPC offenses but quashed IPC proceedings [Paras 2-5].

Ingredients of Offenses – Distinction between IPC and NI Act offenses – Supreme Court examines previous judgments with conflicting views on whether similar facts can lead to prosecution under both statutes – Need for consistent legal interpretation emphasized [Paras 6-12].

Decision: Appeal referred to a larger bench – Legal questions formulated regarding applicability of Section 300(1) CrPC and double jeopardy principles in cases involving both IPC and NI Act offenses [Para 13].

Quashing of FIR – Section 482 CrPC – Appeal against High Court's dismissal of petition to quash FIR – FIR registered based on private complaint alleging offenses under IPC including cheating and breach of trust – Supreme Court finds no ingredients of alleged offenses made out in the complaint – FIR and charge-sheet quashed [Paras 1-19].

Commercial Dispute – Allegations of cheating and breach of trust – Private complaint leading to FIR and charge-sheet – Supreme Court observes complaint reflects a commercial relationship that went sour – No criminal intent or actions substantiating IPC offenses evident – Complaint does not disclose commission of any offense [Paras 14-15].

Judicial Precedents – Importance of judicial scrutiny – Emphasis on the need for courts to carefully examine if complaints make out any offenses – Supreme Court underscores established principle that if no offense is made out, the complaint should be quashed [Para 18].

Decision: Appeal allowed – High Court order set aside – FIR and charge-sheet against appellants quashed – No order as to costs [Para 19].

Public Interest Litigation – Temple Management – Appeal against High Court’s disposal of PIL regarding temple management without hearing appellant’s impleadment application – Supreme Court finds inter se disputes between family members over temple management – High Court rightly left questions of shebait rights to civil courts – Appeals dismissed, judgment and order upheld [Paras 1-47].

Management of Religious Institutions – Shebait Rights – Disputes among heirs regarding temple management – Appellant claimed shebait rights based on lineage – High Court held such disputes should be resolved through civil suits – State intervention justified for regulating non-religious affairs of public temples [Paras 36-40].

Judicial Review – Necessity of Complete Hearing – Importance of hearing all affected parties in PILs – Supreme Court notes pending impleadment application not highlighted during High Court proceedings – Despite this, other family members participated, and substantive rights protected [Paras 46-47].

Decision: Appeals dismissed – High Court’s order affirmed – Parties directed to resolve shebait rights disputes in appropriate civil courts [Para 47].

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].