Prevention of Corruption – Extrajudicial Confession – Confession obtained from the respondent-officer deemed involuntary – Supreme Court emphasized that extrajudicial confessions are weak evidence and require corroboration – Conviction based solely on such confessions without corroboration is unjustified – The court held the findings of the Armed Forces Tribunal (AFT) that the confession was not voluntary were plausible and supported by the circumstances [Paras 30-45].

Reappreciation of Evidence – AFT's Jurisdiction – The court upheld the AFT's jurisdiction to reappreciate evidence to determine if court-martial findings are legally sustainable – The judgment emphasized that the AFT can interfere with court-martial decisions if findings involve wrong decisions on law, material irregularities, or result in miscarriage of justice [Paras 26-29].

Decision – Union of India's appeal dismissed – Respondent-officer's appeals allowed – Conviction under Section 63 of the Army Act set aside – Major R. Metri acquitted of all charges and directed to be reinstated with continuity of service but without back wages [Paras 54-55].

Probation – Sections 3 and 4 of the Probation of Offenders Act empower courts to release offenders on probation of good conduct in specific cases and circumstances. Similarly, Sections 360 and 361 of the Cr.P.C. also empower courts to release offenders on probation of good conduct. Considering the sentence imposed by the lower courts on the appellants for the offence under Section 379 read with Section 34 of IPC and the fact that there are no criminal antecedents against the appellants, the court is inclined to release them on probation of good conduct. The appellants shall be released on probation upon furnishing a personal bond of Rs. 25,000/- with surety of the like amount and undertaking to keep the peace and good behavior for three years to the satisfaction of the trial court. Failure to comply with these directions or breach of the undertaking will result in serving the sentence imposed by the trial court [Paras 1-7].

Decision – Appeal allowed – Conviction and sentence maintained, but appellants to be released on probation of good conduct [Para 7].

Security Cheque – Rejection of Plaint – Plaintiff sought a declaration that the cheque issued was only for security and not for consideration, aiming to prevent proceedings under the Negotiable Instruments Act – Supreme Court held that such a declaration cannot be granted as it would contravene the provisions of the N.I. Act, particularly Section 118(a), which presumes that every negotiable instrument was made for consideration – The right of the defendant to prosecute the plaintiff for dishonour of cheque cannot be frustrated by seeking such a declaration – High Court's order set aside, and trial court's order rejecting the plaint restored [Paras 1-39].

Order 7 Rule 11 – Principles – The plaint must be rejected if it does not disclose a cause of action or is barred by any law – Supreme Court reiterated that a meaningful reading of the plaint is required to ascertain whether it discloses a cause of action or is barred – Clever drafting cannot create a cause of action where none exists [Paras 25-27].

Decision – Appeal allowed – High Court's order set aside – Trial court's order rejecting the plaint under Order 7 Rule 11 CPC restored – Plaintiff's suit dismissed [Paras 39-40].

Eviction – Public Premises – Nationalisation Act – Respondent challenged eviction on grounds that property was private and not a "mine" – Supreme Court held that under Section 3(1) of the Nationalisation Act, properties falling under the definition of "mine" transferred to the Central Government – Definition under Section 2(h) includes lands and buildings used for management or residence of staff – Objections relying on a Court Commissioner’s report rejected as it lacked relevance to statutory definitions – Eviction order confirmed [Paras 1-19].

Definition of Mine – Wide Interpretation – Supreme Court emphasized broad scope of "mine" under Section 2(h) of the Nationalisation Act, including properties used for offices and staff residences regardless of their proximity to mining activities – Ownership immaterial, focus is on the nature of use [Paras 12-15].

Decision – Appeal allowed – High Court's order set aside – District Court's eviction order restored – No order as to costs [Paras 19-20].

Power of Attorney – Authorization to Sell – Supreme Court held that a power of attorney must explicitly confer the power to sell property for the agent to have such authority – The document in question only contained provisions for leasing and executing necessary documents if a security had to be offered for borrowal – No express power to sell the property was included, rendering the sales executed by the appellant's sister invalid – High Court's interpretation attributing constructive notice to the appellant under Section 3 of the Transfer of Property Act was incorrect [Paras 1-20].

Constructive Notice – Section 3 of the Transfer of Property Act – High Court incorrectly attributed constructive notice to the appellant, failing to appreciate that possession of an agent is also possession of the principal – Unauthorized sale by an agent does not equate to the principal parting with possession [Paras 13-14].

Decision – Appeal allowed – High Court's judgment set aside – Judgment and preliminary decree of the trial court restored – No order as to costs [Para 20].

Public Interest Litigation – Gandhi Ashram Redevelopment – Appellant challenged a Government Resolution for redevelopment of the Gandhi Ashram Memorial – Supreme Court held that the High Court erred in disposing of the writ petition without calling for a reply from the State of Gujarat – The High Court should have allowed the pleadings to be completed and afforded the State an opportunity to file a comprehensive affidavit [Paras 1-6].

Judicial Process – Summary Disposal – The High Court's summary disposal without completing pleadings deprived the parties of a fair hearing – Supreme Court emphasized the importance of a comprehensive judicial review in matters of public interest involving significant historical and cultural heritage [Para 5].

Decision – Appeal allowed – High Court's judgment set aside – Writ petition restored to the file of the High Court – High Court to allow pleadings to be completed and hear the parties afresh – All rights and contentions of the parties are kept open – High Court requested to expeditiously dispose of the proceedings [Paras 6-8].

Dying Declaration – Reliance on Evidence – Supreme Court held that the non-recovery of the weapon used in the crime does not invalidate reliance on a dying declaration – Conviction based on dying declaration upheld where it was recorded by a credible authority and established the respondent's participation in the unlawful assembly [Paras 6-7, 9].

Defective Framing of Charges – Section 464 CrPC – The court ruled that mere defects in the form or language of the charge do not render a conviction unsustainable if the accused is not prejudiced – Accused can be convicted under Section 302 IPC read with Section 149 IPC despite not being specifically charged under Section 149 if the ingredients of the offence are implicit in the charges framed [Paras 7.1-8].

Unlawful Assembly and Rioting – Sections 148 and 149 IPC – Supreme Court clarified that an accused can be convicted under Section 148 IPC even if fewer than five persons are tried, as long as the involvement of six to seven persons is established – Conviction under Section 148 upheld based on the unlawful assembly's use of force or violence [Paras 12-12.1].

Decision – Appeal partly allowed – High Court's acquittal of the respondent under Section 302 IPC quashed and set aside – Respondent convicted for the offence under Section 304 Part I read with Section 149 IPC and for the offence under Section 148 IPC – Sentenced to ten years RI for Section 304 Part I read with Section 149 IPC and three years RI for Section 148 IPC, with sentences to run concurrently – Respondent directed to surrender within four weeks to serve remaining sentence [Para 13].

Constitutional Law – Special Reservation – Tamil Nadu Special Reservation Act, 2021 providing 10.5% internal reservation for Vanniakula Kshatriyas within the MBCs and DNCs declared unconstitutional – No substantial basis for classifying Vanniakula Kshatriyas into a separate group from the remaining 115 communities within the MBCs and DNCs – Violation of Articles 14, 15, and 16 – [Paras 1-77].

Legislative Competence – Constitutional Amendments – The 105th Amendment Act is prospective – The 102nd Amendment Act held the field at the time of enactment of the 2021 Act – State's power to provide reservation and sub-classification within MBCs and DNCs affirmed, but such classification must be reasonable and not based solely on population – [Paras 17-48].

Consultation Requirement – Article 338-B(9) – State Government required to consult the National Commission for Backward Classes on major policy matters affecting SEBCs – Failure to consult does not void legislative competence but highlights procedural deficiency – [Paras 75-76].

Decision – Appeals allowed – Tamil Nadu Special Reservation Act, 2021 declared unconstitutional – No bar on legislative competence but classification found unreasonable – [Para 77].

Remanding of Case: An order of remand should not be passed merely to send the proceedings back to the lower court or Tribunal. The Appellate Court must decide the appeal on its merits, especially when both sides have presented oral and documentary evidence. Remanding is only justified if the lower court failed to consider crucial evidence or made significant legal errors [Paras 1-88]​​​​.

Occupancy Rights under Karnataka Land Reforms Act: Sections 45 and 137 and Rule 19 of the Karnataka Land Reforms Rules place the duty on the Tahsildar to verify the revenue records and other documents to record the name of the land owner accurately. The Karnataka Land Reforms Act is aimed at granting occupancy rights to cultivating tenants, and courts should interpret its provisions to further this objective. The Act aims to confer ownership on tenants, with Section 45 specifically providing for registration of occupancy rights in favour of tenants [Paras 1-88]​​.

Delay and Laches: The court emphasized that significant delays in challenging legal orders without adequate justification can result in the dismissal of the case due to laches. In this case, the writ petition was filed after 13 years of the Appellate Authority’s order, with reasons like financial problems and ill health not being considered sufficient to condone the delay [Paras 1-88]​​.

Fraud and Misrepresentation: Allegations of fraud must be supported by substantial evidence. In this case, the contention that the order of the Land Tribunal was obtained by fraud was not substantiated with sufficient evidence, and hence, could not be upheld [Paras 1-88]​​ .

Decision: Appeals allowed. The order of the Division Bench of the High Court of Karnataka in Writ Appeal No. 1950 of 2007 dated 30.12.2014 was set aside, and the order of the learned Single Judge in W.P. No. 27230/2002 dated 25.07.2007 was restored. The order in Writ Appeal No. 1563 of 2007 dated 30.12.2014 was also set aside, and the learned Single Judge’s order in W.P. No. 23034/2002 dated 25.07.2002 was restored. The Land Tribunal was directed to hold an inquiry on the notice dated 24.05.2002 and pass appropriate orders in accordance with the law expeditiously​​​​