Property Law - Land Transfer – SC/ST Land Protection – Delay and Laches – Karnataka Act of 1978 – Section 4 – Original grantee received land in 1977 with grant certificate issued in 1981 under Schedule E of the Land Revenue Code, which prohibited alienation for 15 years – First transfer effected in 1997, after expiry of the 15-year prohibition period – Appellant purchased the land in 2003 – Proceedings initiated in 2006-07 under the Act of 1978, nine years after the first transfer – Authorities and High Court annulled the sale holding any transfer without prior Government permission to be null and void under Section 4 – Held: The proceedings were initiated by Respondent Nos. 4 and 5, sons of the original grantee, who were themselves parties to the first transfer in 1997 and were aged approximately 35 and 25 years respectively at the time — this distinguishing fact takes the case outside the protective ambit of the beneficial legislation invoked – Orders of authorities and High Court set aside [Paras 2–8].

Beneficial Legislation – Laches – Distinction from Precedents – While the Act of 1978 is a beneficial legislation designed to protect SC/ST grantees from being enticed into parting with their lands, the protection cannot be invoked by persons who were themselves knowing and willing parties to the alienation – Satyan v. Deputy Commissioner held an 8-year delay not fatal where villagers initiated proceedings against illegal transfers; Shakuntala recognised that even where no limitation is prescribed, proceedings must be initiated within a reasonable time – Present case distinguishable as the initiators of proceedings were adult parties to the very transfer sought to be annulled, not uninformed legal representatives or the village community [Paras 6–7].

Decision: Appeal allowed – Impugned orders of the authorities and the High Court set aside – Pending applications disposed of [Paras 8–9].

Electricity Law – Tariff Determination – Depreciation – Recovery of Capital Cost – Consumer Interest – Rithala Combined Cycle Power Plant – Section 61(d) of the Electricity Act, 2003 – Regulation 6.32 of DERC (Terms and Conditions for Determination of Generation Tariff) Regulations, 2011 – TPDDL established a 108-MW gas-based power plant at Rithala, Delhi as a short-term measure for a limited operational period of 5 to 6 years – Commission by order dated 31.08.2017 fixed capital cost at Rs.197.70 crores, determined technical useful life at 15 years, but restricted operational and recovery period to six years up to March 2018 under the PPA – Said order attained finality as it was not challenged by TPDDL – Commission by order dated 11.11.2019 allowed depreciation only for six years amounting to Rs.83.34 crores – APTEL set aside the Commission's order directing depreciation over entire 15-year useful life – Supreme Court allowed appeal, restored Commission's order, and answered all three substantial questions of law in favour of the Commission [Paras 1, 19, 23, 24].

Electricity Law – Depreciation – Useful Life vs. Regulatory Recovery Period – Distinction – Whether depreciation must be allowed over entire technical useful life irrespective of period of actual supply – Plant ceased to supply electricity after March 2018 – Consumers cannot be required to pay for a service they no longer received – TPDDL had obligation to supply electricity only for six years under the PPA – Commission had clarified that TPDDL was free to sell power as a merchant generator or sell the Plant itself after March 2018 – No legal impediment existed to such sale – Held: Depreciation cannot be allowed beyond the regulatory recovery period; first substantial question of law answered in the negative [Para 20].

Electricity Law – Regulation 6.32 of 2011 Regulations – Harmonious Construction – Absolute Right to Recover Depreciation – No provision can be read in isolation – Regulation 6.32 prescribing depreciation over useful life must be construed harmoniously with Regulation 4.1 which confines tariff entitlement to the period approved under the PPA – 2011 Regulations must be read in conjunction with Section 61(d) of the 2003 Act which places consumer interest at the centre of tariff regulation – Regulation 6.32 does not confer an absolute and unconditional right to recover depreciation from consumers even for a period when the asset is free to supply electricity but is not doing so – Held: Second substantial question of law answered in the negative [Para 21].

Electricity Law – APTEL – True-Up Proceedings – Regulatory Framework – Finality of Orders – Distinction between technical useful life of 15 years and regulatory recovery period of 6 years is not merely semantic but is clearly drawn by the tariff framework – True-up proceedings are intended to give effect to the tariff framework and not to reopen or reconfigure it – APTEL erred in disregarding the regulatory framework and approval conditions which had attained finality – Held: Third substantial question of law answered in the affirmative [Para 22].

Decision: Appeal allowed – Impugned judgment dated 10.02.2025 of APTEL set aside – Order dated 11.11.2019 of the Commission restored – No order as to costs.

Motor Accident Compensation – Enhancement – 100% Permanent Disability – Minor Claimant – Notional Income – Appellant aged fourteen years suffered 100% permanent disability in a motor accident on 08.11.2016 when the motorcycle he was riding pillion was driven negligently and struck a tractor trolley – Claims Tribunal awarded ₹7,76,543/- – High Court partially enhanced compensation to ₹12,17,543/- taking notional annual income at ₹30,000/- – Supreme Court finds notional income determined by the High Court to be on the lower side – Held: Notional income to be fixed on the basis of minimum wages of a skilled workman in Rajasthan in 2016 at ₹5,800/- per month (annual ₹69,600/-); future prospects at 40% added; multiplier of 18 applied; loss of income computed at ₹17,53,920/- [Paras 2–8].

Attendant Charges – Two Attendants – Round the Clock Assistance – Multiplier Applied – High Court awarded ₹1,21,800/- under attendant charges, which the Supreme Court found grossly inadequate given the nature of permanent disability – Held: Appellant requires services of two attendants round the clock for the rest of his life; minimum wages of a semi-skilled workman at ₹5,000/- per month taken as attendant charges; applying multiplier of 18 for two attendants, total attendant charges computed at ₹21,60,000/-; 25% of attendant charges to be immediately released; remaining 75% to be placed in fixed deposit with annual release of ₹1,50,000/- to enable future needs [Paras 9, 11].

Compensation – Various Heads – Enhancement – Mental Pain, Suffering and Loss of Amenities – Future Medical Expenses – Loss of Marriage Prospects – Supreme Court enhanced amounts under non-pecuniary and other heads – Held: Mental pain, suffering and loss of amenities enhanced to ₹10,00,000/-; future medical expenses enhanced to ₹3,00,000/-; loss of marriage prospects enhanced to ₹3,00,000/-; special diet and transportation awarded at ₹1,00,000/-; medical bills and operation charges retained as awarded by High Court at ₹69,743/- – Total compensation determined at ₹56,83,663/- with interest at 6% per annum from date of filing of claim petition till actual payment [Paras 10, 11].

Decision: Appeal allowed – Judgment of Rajasthan High Court dated 09.04.2024 in Civil Miscellaneous Appeal No. 1334 of 2022 modified – Total compensation of ₹56,83,663/- awarded with interest at 6% per annum from date of filing of claim petition – Amounts already paid to be taken into account – Parties to bear their own costs – Pending interim application disposed of.

Specific Performance – Decree – Conditional Decree – Inexecutability – Non-Deposit of Balance Sale Consideration – Plaintiff-respondent obtained decree of specific performance on 31.10.2012 directing defendant to execute sale deed upon receiving balance sale consideration within three months – Balance sale consideration was not deposited within the stipulated period nor was any application for extension of time moved within that period – Execution petition filed on 08.01.2015 was resisted by defendant on ground of inexecutability – Executing Court and Revisional Court dismissed the objections; High Court upheld the same – Held: Decree for specific performance is conditional in nature imposing reciprocal obligations; non-compliance of the condition to deposit balance sale consideration within the stipulated time renders the suit automatically dismissed and the decree inexecutable; appeal allowed [Paras 3, 16–35, 52].

Specific Performance – Nature of Decree – Preliminary Decree – Court Not Functus Officio – A decree passed in a suit for specific performance is in the nature of a preliminary decree and the court passing the same does not become functus officio upon its passing – The court retains control and jurisdiction over the decree till the sale deed is actually executed or the decree is rendered inexecutable – Section 28(1) of the Specific Relief Act, 1963 confers discretionary power on the court to extend time for compliance or to rescind the contract in the event of default [Paras 36, 39(i)–39(iii)].

Conditional Decree – Automatic Dismissal – No Extension Without Application – A decree of specific performance is self-operative and conditional – Where the balance sale consideration is not deposited within the time stipulated and no application for extension of time is moved within the said period, the suit for specific performance stands automatically dismissed and the decree ceases to exist in the eyes of law – Mere permission to deposit granted subsequently by the executing court, or actual deposit thereafter, does not ipso facto amount to deemed extension of time or condonation of delay – Interim order restraining alienation of suit property does not prohibit deposit of balance sale consideration [Paras 25–30, 35].

Section 28 – Rescission – Application Not Mandatory – The filing of an application under Section 28 of the Specific Relief Act, 1963 for rescinding the contract is not mandatory but optional – The court in appropriate circumstances is not powerless to treat the contract as rescinded for non-compliance of the condition without such an application being moved – Failure of the judgment debtor to seek rescission under Section 28 does not revive an inexecutable decree or make it executable when deposits were not made in time [Paras 31–34, 39(vii)].

Specific Performance – Equitable Relief – Readiness and Willingness – Conduct of Decree Holder – Relief of specific performance under Sections 16(C) and 20 of the Act is equitable and discretionary and the court is not bound to grant it merely because there was a valid agreement – Court must examine conduct of the plaintiff both prior to and subsequent to filing of the suit – Plaintiff who obtained decree of specific performance is obliged to establish continuous readiness and willingness to perform his obligations; failure to deposit balance sale consideration within stipulated time and failure to move any application for extension indicates absence of genuine readiness and willingness – He who seeks equity must do equity [Paras 43–48].

Limitation – Second Execution Petition – Maintainability – Dismissal of First Execution for Want of Prosecution – Article 136 of the Limitation Act, 1963 provides twelve years from the date of decree or when it becomes enforceable for filing an execution application – Dismissal of first execution petition on default/want of prosecution is not a decision on merits and does not preclude the decree holder from filing a fresh execution petition within limitation – Second execution filed on 08.01.2015 against decree dated 31.10.2012 held to be within time [Paras 21–24].

Decision: Appeal allowed – Decree of specific performance dated 31.10.2012 rendered inexecutable – Contract rescinded under Section 28 of the Specific Relief Act, 1963 – Execution proceedings directed to be closed – Defendant-appellant directed to refund earnest money of Rs. 80,000/- with simple interest at 8% per annum from 19.10.2005 till refund; in default, liberty to sell half acre of suit land within three months to make payment – Orders of High Court and Executing Court set aside – Pending applications disposed of.

Environmental Law – Environmental Clearance – Formaldehyde Manufacturing Units – Ex-Post Facto EC – Consent to Establish and Consent to Operate – NGT Order of Closure Set Aside – Appellants are formaldehyde and resin manufacturing units in Rajasthan and Haryana, established and operated pursuant to valid CTE and CTO granted by the respective State PCBs – NGT, by order dated 03.06.2021 in Dastak N.G.O., directed that such units cannot operate without prior EC; the other two original applications involving the appellant-units were decided by relying upon the said NGT order – Held: The NGT judgment in Dastak N.G.O. having been set aside by this Court in Pahwa Plastics (supra), and the factual matrix of the appellant-units being similar to Pahwa Plastics, the impugned closure directions stand set aside; ratio of Pahwa Plastics applied mutatis mutandis [Paras 3–4, 17, 20, 23, 26–27].

Precedent – Pahwa Plastics – Applicability – PCBs Unaware of EC Requirement – Bona Fide Establishment – The PCBs of Rajasthan and Haryana were themselves unaware of the applicability of the EIA 2006 Notification to formaldehyde units at the time CTE and CTO were granted; upon realising the requirement, the PCBs issued notices directing appellant-units to apply for EC within sixty days, which was duly complied with – Screening, Scoping and TOR completed; Public Consultation exempted for most units as they are situated in notified industrial areas; two units (Guruji Overseas and Chemwood Industries) have completed Public Consultation and only Appraisal remains; two units have already been granted EC – Held: The case is not one of deliberate non-compliance; the judgment of Pahwa Plastics squarely applies [Paras 7–13, 20, 24–26].

Argument Repelled – 8000 Workers – Applicability of Pahwa Plastics Not Confined to Large Units – Respondents contended that Pahwa Plastics was decided to protect approximately 8000 workers and cannot apply to appellant-units employing only 10–15 workers – Held: The figure of 8000 workers referred to in Pahwa Plastics encompassed all formaldehyde manufacturing units, including the present appellant-units, and was not confined to the units in Pahwa Plastics alone; argument repelled [Para 22].

Ex-Post Facto Environmental Clearance – Vanashakti Judgment and Review – Effect – The Vanashakti judgment dated 16.11.2025 struck down OMs dated 14.03.2017 and 07.07.2021 as being illegal; the Vanashakti Review judgment dated 18.11.2025 by a three-Judge Bench allowed the review petition and acknowledged the ratio of Pahwa Plastics – Held: The delay in grant of EC to the appellant-units was attributable to the pendency of the Vanashakti litigation; Pahwa Plastics continues to hold the field and the challenge based on OM dated 07.07.2021 is not sustainable [Paras 5–6, 12–13].

Decision: Appeals allowed – Closure orders passed by NGT set aside – Appellant-units permitted to function and operate – Respondents directed to decide pending EC applications within one month – Electricity, if disconnected, to be restored subject to payment of charges – Union of India to inform appellant-units within three working days of any further steps required – Pending applications disposed of.

Forest Law – Revenue Records – Title to Land – Reserve Forest Notification – Writ Jurisdiction – Appellants claimed ownership of 600 acres in Survey No. 81, Kalvalanagaram Village, Pinapaka Mandal, Khammam District, based on pattas allegedly granted in 1931-32 by the Nizam of Hyderabad – Joint Collector rejected the claim in 2003 for failure to produce original patta certificates and proof of possession – Single Judge allowed the writ petition, declared the 1950 Notification ultra vires as issued under a repealed Act, and declared appellants' title – Division Bench reversed, holding the Notification not invalidated merely by reference to the wrong enactment and that revenue entries without original title documents cannot establish ownership – Held: Civil Appeal dismissed, Division Bench judgment upheld [Paras 2–21].

Revenue Records – Evidentiary Value – Fiscal Purpose – It is well settled that entries in Revenue Records, Faisal Patti, Vasool Baqi and Pahanies serve only a fiscal purpose enabling payment of land revenue – Revenue records do not confer or prove title, mutation neither creates nor extinguishes title and carries no presumptive value regarding ownership – Stray or solitary entries for a single year cannot be relied upon to establish rights – Appellants failed to produce the foundational patta document and the revenue entries relied upon were contradictory and unauthorised, with Survey No. 81 consistently recorded as "Jungle" in Pahanies – Held: Revenue entries insufficient to establish title to the Subject Matter [Paras 15–18].

Writ Jurisdiction – Article 226 – Scope of Judicial Review – Certiorari – A writ of certiorari lies only on limited grounds, namely, want of jurisdiction, excess of jurisdiction, violation of natural justice, or error of law apparent on the face of the record – Proceedings under Article 226 of the Constitution are not the appropriate forum for resolving serious disputes concerning questions of fact and title to property, which are the proper function of a civil court in a regularly constituted suit – Held: Single Judge exceeded the scope of judicial review by effectively declaring appellants' title to the Subject Matter in writ proceedings; such course is unavailable and was rightly corrected by the Division Bench [Paras 17, 19–20].

Forest Notification – Validity – Wrong Enactment – A notification is not rendered invalid merely because it references a repealed enactment, provided it is not inconsistent with the provisions of the new Act and the purpose for which it was issued is apparent – Held: 1950 Gazette Notification proposing reservation of Survey No. 81 as reserve forest cannot be declared ultra vires solely on the ground that it was issued under the Hyderabad Forest Act, 1326 Fasli rather than 1355 Fasli [Para 10].

Decision: Civil Appeal dismissed – Order of Division Bench upheld – No order as to costs – Pending applications disposed of.

Medical Law – Professional Misconduct – MCI Ethics Committee – Natural Justice – Declaration Form – Appellant, a senior paediatrician, appeared as faculty at SSSMC, Dehradun during MCI inspection on 22.01.2015 and subsequently joined PMC, Patna on contract – Declaration Form signed by him on 21.04.2015 for PMC assessment did not disclose his earlier appearance at SSSMC in the same academic year – MCI Ethics Committee initially exonerated him as he was abroad attending ESPGHAN conference at Amsterdam on the date of PMC inspection (05.05.2015) – Executive Committee referred matter back, whereupon Ethics Committee found him guilty of serious misconduct for non-disclosure and directed removal of his name from Indian Medical Register for three months – Single Judge allowed writ petition; Division Bench reversed and restored penalty – Held: Civil appeal allowed in part; punishment modified by exercise of power under Article 142 [Paras 2–17].

Natural Justice – Charge Framing – Change of Charge Without Notice – Once a delinquent successfully defends the original charge framed against him, the disciplinary authority cannot, without issuing a fresh show cause notice, hold him guilty of a different and new charge not originally framed – Show cause notice dated 09.12.2015 charged appellant with appearing as fake faculty at two institutions; having successfully defended this charge by proving absence from India on the inspection date, the Ethics Committee proceeded to hold him guilty of the separate charge of non-disclosure in the Declaration Form without affording him any opportunity to respond – Held: This constitutes a clear breach of principles of natural justice and the Executive Committee could not have imposed punishment on the new charge without a fresh show cause notice [Paras 10–12].

Misconduct – Mis-declaration – Quantum of Punishment – Article 142 – Despite the procedural infirmity, the appellant failed to satisfactorily explain the mis-declaration in the Declaration Form, wherein he had affirmed that he had not presented himself to any other institution as faculty in the current academic year for purposes of MCI assessment – Such brazen mis-declaration, unexplained, constitutes misconduct that could not be condoned – However, considering that the Executive Committee's decision dates back to 21.07.2016 and nearly a decade has elapsed, and that the appellant is now 76 years of age with the matter hanging over him for ten years – Held: In the interest of complete justice, penalty of removal from Indian Medical Register for three months modified to issuance of a censure/warning by NMC in exercise of powers under Article 142 of the Constitution [Paras 13–16].

Decision: Civil appeal allowed in part – Punishment modified from removal from Indian Medical Register for three months to issuance of censure/warning by NMC – NMC directed to issue order accordingly – Interim orders vacated.

Insolvency and Bankruptcy – CIRP of Holding Company – Assets of Subsidiary Companies – Corporate Veil – Lifting Justified – Corporate debtor EIL had three subsidiary companies holding leasehold lands allotted by GNIDA on which EIL itself undertook development of projects Earth Towne, Earth TechOne and Earth Sapphire Court – NCLAT held that assets of subsidiaries could not be treated as assets of the corporate debtor and set aside NCLT orders approving the resolution plans – Held: Where subsidiary companies are inextricably connected to the holding company, share common directors, have no independent business of their own, and exist only as a front for the holding company's operations, the corporate veil ought to be lifted – EIL was the main driving force in development of all three projects and in payment of GNIDA's dues; the subsidiary companies were merely a front – This was an eminently fit case for lifting the corporate veil and treating the project lands as effectively forming part of the CIRP proceedings against EIL [Paras 53–56].

Resolution Plan – Scope – Development Rights vs. Title – Leasehold Lands – Resolution plans of Alpha and Roma unequivocally recorded that only development rights in relation to the projects were included and not the title to the underlying lands – GNIDA's ownership of the land would not stand transferred; what was contemplated was merely transfer of possession to the successful resolution applicants to enable completion of projects and delivery of units to allottees as sub-lessees – Held: Transfer of possession of leasehold lands to resolution applicants for project completion is permissible and does not amount to transfer of title [Paras 44–46, 56].

GNIDA – Inaction and Ineptitude – Disentitlement to Penal Interest – GNIDA failed to monitor development on leased lands, issued only sporadic and intermittent default notices, was aware that EIL was executing the projects but failed to take coercive steps, did not participate in CIRP proceedings despite being informed by both the IRP in December 2018 and the RP in May 2019, and filed its claims belatedly before the already-displaced IRP – Held: GNIDA contributed greatly to the present imbroglio by persistent inaction and ineptitude and is, therefore, not entitled to penal interest, penal charges or time-extension penalties; dues are to be recalculated excluding such charges and communicated to Alpha and Roma within two weeks [Paras 48–51, 67].

Payment of Dues – Schedule – Interest Waiver – Successful resolution applicants Alpha and Roma directed to clear the recalculated principal dues of GNIDA (excluding penal interest and penalties) in equated monthly instalments over twenty-four months, commencing with the first payment on or before 7th July 2026 – GNIDA not entitled to any interest on principal amounts for the extended payment period of twenty-four months, owing to its own failure in monitoring and timely recovery – Alpha and Roma to bear dues entirely without burdening the home/office space buyers – Registration of units in favour of allottees to be undertaken only after GNIDA's dues are paid in full with its active participation [Paras 67–68].

Project-Specific CIRP – Real Estate Insolvency – CIRP in real estate cases can be project-specific, limiting the insolvency process to projects in default so as to protect homebuyers in viable projects – As per Regulation 36A(1) of the IBBI Regulations (as clarified with effect from 15.02.2024), a Resolution Professional, after CoC approval, may invite resolution plans project-wise – Supreme Court's earlier decisions affirming project-specific resolution in real estate cases referred to with approval [Para 12].

Earth Copia – Freehold Project – NCLAT's Error – Alpha's resolution plan also covered Earth Copia, a project on freehold land in Gurugram having no connection whatsoever with GNIDA – NCLAT erred in setting aside Alpha's entire resolution plan without noticing that the NCLT's order dated 08.06.2021 also included approval of the plan in relation to Earth Copia – GNIDA had no grievance in relation to this project and ought to have clarified this in its appeal – Held: Setting aside of Alpha's resolution plan, insofar as it pertains to Earth Copia, was erroneous [Paras 29, 50].

Limitation – Appeals before NCLAT – Delay Condonation – Section 62(2) of the Code – Civil Appeal (Diary) No. 19132 of 2023 filed with a delay of 34 days against the NCLAT judgment dated 30.01.2023 – Section 62(2) empowers the Supreme Court to condone delay in filing up to 15 days but not beyond – Held: Appeals barred by time and dismissed on this short ground [Para 4].

Dissenting Homebuyers – Authorised Representative – Section 25A(3A) of the Code – Individual homebuyers who did not vote in favour of the resolution plan cannot maintain a separate voice of dissent once the authorised representative has cast his vote in accordance with the decision of more than 50% of the voting share of the financial creditors he represents – A few persons within a class cannot dissent against the majority vote in favour of the resolution plan [Paras 30–31].

Decision: Civil Appeal Nos. 1526, 1743, 2491, 2466, 3438 and 4619 of 2023 allowed – Resolution plans of Alpha and Roma restored – Civil Appeal Nos. 2406-2407 of 2023 disposed of in terms of the judgment – Civil Appeal Nos. 3435-3437 of 2023 and Civil Appeal (Diary) No. 19132 of 2023 dismissed – Civil Appeal Nos. 2756 and 2763 of 2023 filed by GNIDA dismissed – GNIDA to recalculate dues excluding penal interest and penalties and communicate to resolution applicants within two weeks – Resolution applicants to pay dues over twenty-four monthly instalments commencing 7th July 2026 – Time frames for project completion to commence from 1st June 2026.

Criminal Law – Dowry Death – Section 498A IPC – Cruelty – Acquittal of Father-in-Law – No Direct Evidence of Individual Role – Conviction of appellant Narendra Singh (father-in-law) under Section 498A upheld by High Court challenged – Prosecution case: deceased died of 55% burn injuries on 22.04.2001, within nine months of marriage; first dying declaration recorded by Executive Magistrate (PW-18) on 16.04.2001 stated husband, father-in-law and mother-in-law poured kerosene and set her on fire after stuffed cloth in mouth; second dying declaration recorded by DSP (PW-22) on 17.04.2001 stated deceased poured kerosene herself and set herself on fire – Held: No direct evidence implicating Narendra Singh in mental cruelty or dowry demand; allegations against him generic; prosecution failed to establish charge under Section 498A IPC beyond reasonable doubt; conviction set aside [Paras 25–29].

Dying Declaration – Evidentiary Value – Conflicting Declarations – Second Declaration Preferred – First dying declaration recorded by PW-18 (Tehsildar/Executive Magistrate) found doubtful as PW-18 deposed in cross-examination that a person present with the deceased in hospital had tutored her to depose in a particular manner – Second dying declaration recorded by PW-22 (DSP) wherein deceased stated she poured kerosene herself, held more reliable – Variation in the two declarations on the manner of death casts doubt on their veracity – Held: First declaration falls foul of settled principles governing dying declarations; conviction cannot safely be sustained on the basis of the same [Paras 23–25].

Witness Testimony – Family Witnesses – Interested Witnesses – Improvements in Examination-in-Chief – PW-1 (father), PW-2 (mother), PW-3 (uncle) and PW-5 (brother) all deposed to dowry demands and cruelty in examination-in-chief, but none of them had disclosed the factum of dowry demand in their statements under Section 161 CrPC before the police – Witnesses attributed omissions to the police but offered no credible explanation – Testimonies marked by uniform improvements across all witnesses suggesting afterthought; not corroborated by any independent witness – Neighbours (PW-7, PW-8, PW-9) turned hostile; PW-10 (neighbour) stated deceased complained of disliking small-town life and that accused Narendra Singh and Leela Singh were on a walk with her husband at the time of the incident – Held: Testimonies of interested witnesses, riddled with contradictions and improvements, unsafe to rely upon in absence of corroboration [Paras 17–18, 20, 22, 27–28].

Dying Declaration – Principles Governing – Law Summarised – Dying declaration can form the sole basis of conviction but need not be corroborated as an absolute rule of law; each case to be determined on its own facts; declaration recorded by a competent Magistrate in proper form stands on a higher footing; court must consider whether statement was made at the earliest opportunity and was not the result of tutoring by interested parties [Para 24] — Relied upon: Khushal Rao v. State of Bombay, 1957 SCC OnLine SC 20.

Circumstantial Evidence – Panchsheel Principles – In criminal trial two inferences possible, the one favouring accused to be accepted – Circumstances must be fully established, consistent only with guilt, conclusive in nature, excluding every other hypothesis, and forming a complete chain leaving no reasonable ground for innocence – Held: Prosecution failed to establish a complete chain; benefit of doubt to accrue to accused [Para 25] — Relied upon: Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116; State of U.P. v. Ashok Kumar Srivastava, (1992) 2 SCC 86.

Misuse of Section 498A IPC – Courts to Guard Against Roping in All Family Members Without Specific Role – Observations made that father-in-law appears to have been roped into proceedings by extension of the case against the husband, without any specific allegation or evidence of individual role – This Court has repeatedly cautioned against misuse of Section 498A IPC against family members in the absence of any role attributable to them [Para 27].

Decision: Criminal Appeal No. 302 of 2014 (filed by Narendra Singh) allowed – Conviction under Section 498A IPC set aside – Criminal Appeal Nos. 307 of 2014 (filed by State) and 309 of 2014 (filed by brother of deceased) dismissed.