Criminal Law – Remission of Sentence – Judicial Review – The Court has the power to review the government's decision regarding the acceptance or rejection of an application for remission under Section 432 of the CrPC to determine whether the decision is arbitrary in nature. While the government has discretion to suspend or remit sentences, it cannot exercise this power arbitrarily. In this case, the presiding judge's opinion lacked adequate reasoning and failed to consider relevant factors for remission, such as the potential for re-offense and socio-economic conditions of the convict's family. The Court directed a re-evaluation of the remission application with proper consideration of these factors [Paras 1-25].

Principle of Fairness – Executive Discretion – Emphasized that executive power must be exercised in a fair, informed, and reasonable manner. The opinion of the presiding judge should guide the executive's decision but should not be followed mechanically if it lacks adequate reasoning. A well-reasoned opinion is necessary to ensure fairness in the remission process [Paras 11-24].

Decision- Petition allowed – Directed the Special Judge to provide a fresh opinion on the remission application within one month, with adequate reasoning considering all relevant factors. The State of Chhattisgarh must take a final decision on the application within one month of receiving the opinion.

Service Law – Dismissal – Submission of False Certificate – The respondent secured employment by submitting a forged SSLC, which was proved in a departmental inquiry. The High Court substituted the punishment of dismissal with reinstatement without back wages. The Supreme Court held that producing a fake certificate is a grave misconduct that justifies dismissal. Interference by the High Court in the disciplinary authority's decision was unwarranted unless the punishment was shockingly disproportionate or there was procedural irregularity, neither of which was found in this case. The Supreme Court restored the disciplinary authority's decision to dismiss the respondent [Paras 1-8].

Judicial Review – Proportionality of Punishment – Reiterated that judicial review of disciplinary actions is limited. Courts should not interfere with the quantum of punishment unless it is shockingly disproportionate. The disciplinary authority's decision is based on maintaining trust and integrity, which is paramount in employment, particularly in cases involving forged documents [Paras 7-7.5].

Decision- Appeal allowed – High Court's order quashed – Order of dismissal by the disciplinary authority restored. No costs awarded.

Criminal Law – Dowry Death – Presumption under Section 113B – The presumption under Section 304B IPC, read with Section 113B of the Indian Evidence Act, comes into play once it is shown that the woman was subjected to cruelty or harassment for dowry soon before her death. This presumption can be rebutted by the accused by demonstrating that the ingredients of Section 304B IPC have not been satisfied. The main ingredients to establish an offence under Section 304B IPC include: unnatural death within seven years of marriage, cruelty or harassment related to dowry demands, and such cruelty or harassment occurring soon before the death. The appellants failed to rebut the presumption against them [Paras 1-23].

Analysis of Evidence – Harassment and Dowry Demands – Evidence presented showed repeated dowry demands and harassment of the deceased by the husband and in-laws. The deceased's mother (PW-1) and other family members (PW-2 to PW-4) provided consistent testimonies about the dowry demands and harassment. The medical evidence indicated the death was not due to drowning, further supporting the case of dowry death [Paras 13-21].

Decision- Appeal partly allowed – Conviction and sentence of appellant No.1 (husband of the deceased) upheld – Conviction and sentence of appellants No.2 and 3 (sister-in-law and mother-in-law) set aside – Appellants No.2 and 3 to be released, and bail bonds cancelled – Appellant No.1 to surrender within two weeks to serve the remaining sentence.

Arbitration – Interim Measures – Scope of Section 37 – The appeals challenge the High Court's interim orders issued in the context of Section 37 of the Arbitration and Conciliation Act, 1996, which should focus on examining the Commercial Court's decision regarding interim relief under Section 9. The High Court's orders directed a status report on the FIR, summoned the investigating officer, and transferred the investigation, actions deemed beyond the scope of Section 37 [Paras 1-9].

Judicial Overreach – Investigation Proceedings – The Supreme Court held that the High Court exceeded its jurisdiction by engaging in supervising the criminal investigation and issuing orders that should have been confined to the merits of the Commercial Court's order on interim relief. Such actions are inappropriate under arbitration proceedings and should be addressed through criminal proceedings if necessary [Paras 7-8].

Decision- Appeals allowed – High Court's orders dated February 24, 2022, March 11, 2022, and March 29, 2022, quashed – High Court directed to decide the appeal under Section 37 of the Arbitration and Conciliation Act strictly in accordance with the law. Interim order restraining the appellants from alienating the property remains unaffected.

Service Law – Enhanced Age of Superannuation – The appellant, serving in a government-aided private institution, claimed entitlement to the enhanced retirement age of 65 years. The Supreme Court noted the earlier Full Bench decision in Dr. S.C. Jain was overruled in Dr. R.S. Sohane, confirming that teachers in such institutions are entitled to the enhanced retirement age. The appellant was therefore entitled to retire at 65 years with all consequential and monetary benefits, including arrears of salaries and allowances, notwithstanding the principle of 'no work, no pay' due to his non-continuation of service till 65 [Paras 1-6].

Judicial Precedent – Consistency in Application – Emphasized the need for consistency in the application of judicial decisions. The Court noted similar cases where teachers were granted benefits for the intervening period between 62 and 65 years, setting a precedent that should be uniformly applied. The appellant's case could not be distinguished from similarly situated teachers who were granted benefits following the Sohane ruling [Paras 4-5].

Decision- Appeal allowed – High Court's order quashed – Appellant entitled to the enhanced age of superannuation of 65 years and all consequential benefits, including arrears of salaries and allowances, to be paid within six weeks. No interest on arrears for the delay period from the High Court's dismissal to the appeal filing was granted due to the significant delay in filing the appeal.

Consumer Protection – Manufacturer Defect – Punitive Damages – The appeal arises from a complaint regarding a defect in a Hyundai Creta vehicle, particularly its safety features. The respondent purchased the vehicle based on its advertised safety features, including airbags. During a collision, the airbags did not deploy, resulting in injuries to the respondent. Both the State and National Commissions upheld the claim of defect and awarded punitive damages. The Supreme Court affirmed the decision, holding that a consumer would reasonably expect airbags to deploy in a frontal collision, and failure to meet this expectation justifies punitive damages [Paras 1-17].

Fit for Purpose – Implied Conditions – Vehicles, as goods under Section 2(7) of the Sale of Goods Act, carry implied conditions of fitness for their purpose. The failure of the airbags to deploy during a collision indicated the vehicle was not fit for its intended purpose. The manufacturer is strictly liable for ensuring safety features meet reasonable consumer expectations. The Court emphasized that punitive damages should serve as a deterrent and reflect the capacity of the manufacturing enterprise [Paras 7-15].

Relief and Jurisdiction – Consumer Forum Powers – The consumer forums have the power to award reliefs under Section 14(1) of the Consumer Protection Act, including punitive damages. Even if specific reliefs are not claimed, the forums can mould reliefs to do effective justice within the statutory framework. The Court upheld the relief granted by the forums, including the direction to replace the vehicle and the compensation awarded [Paras 11-15].

Decision- Appeal dismissed – The Supreme Court upheld the compensation and punitive damages awarded by the State and National Commissions. The failure to deploy airbags in a significant collision justified the punitive damages. The interim order is dissolved, and there is no order as to costs.

Labour Law – Voluntary Retirement Scheme (VRS) – Appellant contested the employer's order treating his date of birth as 21st September 1945 instead of 21st September 1949 – Supreme Court observed inconsistencies in records maintained by the employer and failure to provide the appellant an opportunity of hearing before altering the date of birth in his service book – Court emphasized the importance of uniformity and accuracy in service records maintained by the employer [Paras 1-18].

Service Record Discrepancies – Evidence and Estoppel – Discrepancies in appellant's date of birth recorded in various documents including service book, Form "B", and LIC policy – Supreme Court held the employer’s action of unilaterally altering the date of birth at the end of appellant’s career without proper procedure and adequate proof as unjustified – Reiterated that entries in Form "B" are not conclusive proof and should be verified by a medical board if disputed – Appellant's consistent reliance on service book and pay slips showing date of birth as 21st September 1949 accepted [Paras 13-16, 22].

Natural Justice – Procedural Fairness – Employer's failure to follow principles of natural justice by not providing the appellant an opportunity to be heard before changing his recorded date of birth – Supreme Court set aside the High Court's acceptance of the employer’s "mistake" rationale for different entries in different documents – Directed reinstatement of the original date of birth as per service book [Paras 12, 21].

Decision: Appeal allowed – Judgment of the Division Bench and Single Judge of the High Court set aside – Rejection order dated 13th October 2008 quashed – Respondents directed to extend VRS benefits to appellant treating his date of birth as 21st September 1949 with interest on differential amount at 7% per annum [Paras 23-24].

Criminal Law – Quashing of Criminal Proceedings – Political Vendetta – Appellants argued that the complaint was initiated out of political animosity – Supreme Court reiterated that political vendetta alone is not a ground for quashing proceedings if the complaint otherwise makes out a prima facie case – Allegations in the complaint, if established, would result in conviction – Complaint cannot be quashed at the inception without trial [Paras 2, 24-25, 39].

Jurisdiction – Special Court under Atrocities Act – Contention that only Special Court could take cognizance of offences under the Atrocities Act – Supreme Court held that even if the Magistrate took cognizance and then committed the case to the Special Court, proceedings are not vitiated – Complaint disclosed offence under Atrocities Act, and jurisdiction was proper [Paras 22-23].

Inherent Powers of High Court – Section 482 CrPC – Powers to be exercised sparingly – Not to be used to interfere with criminal proceedings unless no offence is disclosed, or the proceedings are patently frivolous – Court should not embark on enquiry into reliability of allegations at this stage – Criminal proceedings should not be nipped in the bud on the basis of possible political vendetta alone [Paras 27-28, 30, 39].

Decision: Special leave petition dismissed – High Court's decision upheld – Trial to proceed to determine truth of allegations – Trial Court may consider exempting personal appearance of appellant due to his health condition [Paras 40-41].

Public Law – Legitimate Expectation – FPS vacancies canceled by State in light of 2013 Act – Respondent claimed legitimate expectation based on prior selection – Supreme Court held legitimate expectation cannot prevail over statutory reforms required by the 2013 Act – Decision in public interest to implement statutory mandate upheld [Paras 9-22].

Estoppel – Against Statute – State's cancellation of vacancies justified by need to comply with 2013 Act – Supreme Court reiterated principle that there can be no estoppel against statute – State's decision to reform Public Distribution System as per statutory requirements cannot be challenged on grounds of promissory estoppel or legitimate expectation [Paras 25-27].

Public Interest – Policy Decisions – State's cancellation of vacancies a bona fide decision in public interest to implement 2013 Act – Court emphasized need for public policy decisions to conform with statutory mandates – Reforms in Public Distribution System aimed at ensuring food security and legal entitlements to beneficiaries prioritized over individual expectations [Paras 15-20, 30].

Decision: Appeal allowed – Division Bench's judgment set aside – Single Judge's judgment restored – State's cancellation of FPS vacancies upheld as necessary for implementing National Food Security Act, 2013 [Paras 31-32].