Criminal Law – Conviction and Sentencing – Appellant convicted for murdering his uncle by striking him with a wooden cot leg ('Bahi') – Incident followed a quarrel the previous day – Trial Court acquitted appellant due to inconsistencies in evidence and delay in FIR – High Court reversed acquittal, emphasizing credibility of eye witnesses and medical evidence – Supreme Court re-evaluated the intention and knowledge, concluding it was culpable homicide not amounting to murder [Paras 1-19]​​.

Criminal Law – Evidence and Testimony – High Court erred in dismissing Trial Court's findings on delay in FIR and credibility of witnesses – Supreme Court noted the complainant's priority to save the victim justified delay – Minor inconsistencies in site plan and bed head ticket not sufficient to overturn otherwise credible eye witness and medical evidence [Paras 10-12]​​.

Criminal Law – Culpable Homicide vs. Murder – Distinction between Section 302 and Section 304 IPC – Absence of intention to kill deduced from circumstances – Single blow with a non-dangerous weapon – Lack of premeditation – Conduct of appellant indicated culpable homicide not amounting to murder (Section 304 Part-II IPC) rather than murder (Section 302 IPC) [Paras 13-17]​​.

Decision – Appeals Partly Allowed – Conviction under Section 302 IPC set aside – Conviction under Section 304 Part-II IPC imposed – Sentence reduced to period already undergone – Appellant to be released if not required in any other case [Paras 18-19]​​.

Service Law – Selection Criteria – The Board of Examiners altered the selection criteria by introducing interviews and merit-based assessments not prescribed by the statutory rules. The eligibility and procedure for promotion from Class-IV to Class-III positions, as per the Executive Council’s rules, emphasized seniority and passing departmental tests without mandating interviews. The Board's unauthorized changes were deemed illegal [Paras 1-12, 14-20]​​.

Service Law – Estoppel and Acquiescence – The Division Bench erred in applying the principles of estoppel and acquiescence over statutory service rules. Statutory rules take precedence over any principle of estoppel. The participation of the appellants in the selection process did not bar them from challenging the unauthorized changes as it violated statutory rules [Paras 22-23, 30-31]​​.

Decision – Appeals Allowed – The judgment of the Division Bench was set aside, and the judgment of the learned Single Judge was restored. BHU was directed to conduct fresh selections for promotion in accordance with the existing rules, ensuring all eligible appellants receive due promotions and consequential benefits. Benefits to be extended to legal heirs of deceased appellants [Paras 32-34]​​.

Court Fees – Suit Valuation – Nature of relief decisive for suit valuation – Market value of property involved in litigation not decisive for suit valuation – Plaintiff entitled to value the relief of injunctions and damages separately – High Court erred in considering market value for determining suit valuation [Paras 1-15]​​.

Injunctions – Suit for Mandatory and Prohibitory Injunctions – Suit for mandatory injunction to remove defendants from property after termination of license maintainable – Valuation for mandatory injunction not required to be at market value of property – Plaintiff valued reliefs appropriately under Section 7(iv)(d) of the Court Fees Act [Paras 9-10, 13-15]​​.

Decision – Appeal Allowed – High Court's order returning plaint for re-filing based on market value set aside – Trial Court's order rejecting defendant's application under Order VII Rule 11 CPC restored – No observations on merits of the case, left open for pending appeal [Paras 14-15]​​.

Constitutional Law – Double Jeopardy – Accused having undergone trial and acquitted of offences under Sections 504 and 506 IPC cannot be subjected to another trial for the same charges on the same facts – Re-trial would violate Article 20(2) of the Constitution and Section 300 CrPC [Para 24.2]​​.

Criminal Procedure – Territorial Jurisdiction – Offences under Section 376 IPC occurred in Delhi and were separate from those under Sections 504 and 506 IPC which occurred in Chamoli – Charges under Sections 504 and 506 IPC, already tried and concluded, do not form the same transaction as Section 376 IPC – Sessions Judge rightly discharged the accused for lack of territorial jurisdiction for Section 376 IPC [Paras 1-26]​​.

Criminal Procedure – Separate Charges – Offences under Sections 504, 506, and 376 IPC not forming part of the same transaction cannot be tried together under Section 220 CrPC – Alleged rape (Section 376 IPC) distinct and separate from alleged insults and threats (Sections 504 and 506 IPC) [Paras 20-22.2]​​.

Decision – Appeal Dismissed – Discharge of the accused under Section 376 IPC by the Sessions Judge upheld – No re-trial for offences under Sections 504 and 506 IPC due to acquittal and bar of double jeopardy [Paras 25-26]​​.

Criminal Law – Private Defense – Appellant, a BSF constable, fired at intruders in self-defense – Right of private defense extends to causing death if there is reasonable apprehension of danger to life – Incident occurred in a high-risk area near the Bangladesh border with history of smuggling and attacks on BSF personnel – Court held that actions were in exercise of the right of private defense as the appellant was confronted by armed intruders and had no recourse to State aid – Conviction for murder altered to culpable homicide not amounting to murder under Section 300 Exception 2 IPC [Paras 1-27]​​.

Evidence – Testimonies and Circumstances – Court relied on testimonies of witnesses and the specific topography of the crime scene – Discrepancies in witness statements regarding the positioning of the deceased and the appellant explained by the uneven terrain – Right of private defense supported by the presence of immediate threat and absence of malice [Paras 8-25]​​.

Decision – Appeal Partly Allowed – Conviction under Section 302 IPC set aside – Conviction altered to culpable homicide not amounting to murder under Section 304 IPC – Considering the appellant had already served over eleven years in prison, sentence deemed sufficient – Appellant released for time served, and bail bonds discharged [Paras 26-27]​​.

Civil Law – Presumption of Marriage – Long cohabitation between a man and a woman raises a presumption of marriage under Section 114 of the Evidence Act – The High Court erred in denying partition of property based on the legitimacy of the plaintiff – Sufficient evidence of long cohabitation and recognition of the relationship by society supports the presumption of marriage and legitimacy of the offspring [Paras 1-27]​​.

Civil Procedure – Final Decree Proceedings – Trial Courts should not adjourn matters sine die after passing a preliminary decree for partition – Courts must proceed suo motu for drawing up the final decree under Order 20 Rule 18 CPC to avoid undue delay in the realization of the decree’s benefits – Separate final decree proceedings are discouraged to streamline the process and ensure timely relief [Paras 29-33]​​.

Decision – Appeals Allowed – The High Court's judgment set aside – Trial Court's decree for partition restored – Directive issued to Trial Courts to automatically proceed with final decree steps after a preliminary decree without requiring separate proceedings [Paras 28, 34]​​.

Civil Procedure – First Appeal – Scope and Duty of First Appellate Court – Section 96 CPC provides for filing an appeal from a decree passed by a court of original jurisdiction – Order 41 Rule 31 mandates that the judgment of the appellate court must state points for determination, decisions thereon, and reasons for decisions – Appellate court’s failure to comply with these requirements leads to infirmity in the judgment – High Court erred by not considering evidence and reasoning provided by the Trial Court, and by failing to form points for determination [Paras 26-30]​​.

Property Law – Ancestral and Self-Acquired Property – Appellant and respondent, as children of deceased Puttanna, were entitled to shares in the property acquired by their father – Property cultivated by Puttanna and granted occupancy rights posthumously is heritable – Appellant entitled to 1/2 share, not 1/4 share as modified by the High Court – High Court's judgment set aside, Trial Court’s decree restored [Paras 9-25, 31]​​.

Decision – Appeal Allowed – High Court’s judgment set aside – Trial Court’s decree restored, affirming appellant’s 1/2 share in property described at item no. 3 of Schedule 'A' – Final decree proceedings to be conducted accordingly – No order as to costs [Paras 31-32]​​.

NEET-PG Counselling – Conduct of Special Stray Round – Petitioners sought a Special Stray Round of counselling for the remaining 1456 vacant seats after NEET-PG-2021 counselling rounds – Supreme Court held that the admission process must have an endpoint and must adhere to a strict schedule – Emphasized that any deviation could compromise medical education standards and public health – Found that non-clinical seats typically remain vacant annually and re-affirmed no scope for mid-session admissions [Paras 1-12].

Procedural Adherence – Adherence to Time Schedule – Court noted the existing nine rounds of counselling already conducted, fulfilling the mandated procedure – Further round was deemed unnecessary and impractical, as it could interfere with NEET-PG-2022 admissions – Affirmed previous decisions highlighting the importance of maintaining the time schedule for medical admissions to ensure academic and professional integrity [Paras 10.1-10.7].

Public Interest and Education Quality – Balancing Seats and Quality – Court recognized the need to balance seat occupancy with quality education – Determined that endless counselling rounds would disrupt educational timelines and lower the standard of medical education – Emphasized that maintaining a strict schedule is crucial for the credibility and functionality of medical education systems [Paras 10.4-10.6].

Decision – Petitions Dismissed – Held – Petitions for conducting a Special Stray Round of counselling for NEET-PG-2021 dismissed – No order as to costs – Reiterated that adherence to established counselling schedules is essential for maintaining order and standards in medical education [Paras 11-12].

Custody of Child – Welfare of Minor – The paternal grandparents sought custody of their minor grandson, whose parents passed away during the Covid-19 pandemic – High Court had handed over custody to the maternal aunt – Supreme Court reversed this decision, emphasizing the emotional and loving care provided by paternal grandparents – Grandparents' ability to provide a stable environment and the minor's expressed preference to stay with them were significant factors – Court directed that custody remain with the paternal grandparents while granting visitation rights to the maternal aunt [Paras 1-12].

Guardianship – Emotional Bond and Stability – The Court highlighted that grandparents often provide deep emotional support and stability to grandchildren – Rejected the notion that age and financial independence alone could determine the best interest of the child – Court acknowledged that the minor showed a willingness to stay with grandparents during the interim custody period [Paras 7.1-7.2].

Decision – Appeal Allowed – Held – High Court's order to give custody to the maternal aunt was set aside – Custody granted to paternal grandparents with visitation rights to the maternal aunt – Directed both families to act jointly and cordially for the child's welfare – Emphasized the need to consider the minor's emotional and educational well-being, ensuring regular contact with both families [Paras 8-12].