Passive Euthanasia - Constitution of India – Article 21 – Right to Die with Dignity – Distinction between Active and Passive Euthanasia – Terminology – Held: The "right to live with dignity" inherently includes the "right to die with dignity" as an integral part of Article 21. A robust distinction between active and passive euthanasia lies in the source of the harm; active euthanasia introduces an external agency of harm ("causing death"), whereas passive euthanasia involves the withdrawal or withholding of medical treatment, allowing the underlying fatal condition to take its natural course ("allowing death to occur"). The Court observed that the term "passive euthanasia" is obsolete and confusing, and directed that it be replaced with the phrase "Withdrawing or Withholding of Medical Treatment" (WMT). Euthanasia (active) remains strictly impermissible and constitutes a penal offence unless authorized by explicit legislative enactment. [Paras 33-45, 111, 293-295]

Medical Law and Ethics – Clinically Assisted Nutrition and Hydration (CANH) – Classification as Medical Treatment – Administration of nutrition and hydration through Percutaneous Endoscopic Gastrostomy (PEG) or nasogastric tubes – Held: CANH is a technologically mediated medical intervention prescribed and supervised by trained healthcare professionals. It involves protocols and clinical judgment regarding dosage, materials, and complication management, distinguishing it from basic primary care or oral feeding. Merely because CANH can be administered at home by a lay person does not relegate it to non-medical status, as it still requires regular medical supervision. Consequently, CANH constitutes "medical treatment" and is amenable to being lawfully withheld or withdrawn subject to the Best Interest Principle and procedural safeguards. [Paras 114-129, 301-305]

Medical Jurisprudence – Best Interest Principle – Scope and Application – Incompetent patients in Persistent Vegetative State (PVS) – Held: Any decision to withdraw or withhold medical treatment for an incompetent patient must be rooted in their "best interests." This is not a narrow or formulaic test but a holistic evaluation of medical and non-medical considerations. Medical considerations include the futility of treatment (absence of any therapeutic benefit), irreversibility, and the indignity of prolonging life in a state devoid of awareness. Non-medical considerations involve the "Substituted Judgment" standard, where decision-makers must consider what the patient would have wanted if they had capacity, based on their past wishes, values, and lifestyle. The "Balance Sheet Approach" must be utilized to weigh the potential benefits of continued treatment against the burdens of physical suffering, invasiveness, and loss of dignity. [Paras 209-233, 306-318]

Procedural Law – Streamlining Common Cause (2018) Guidelines – Implementation Challenges – Held: To bridge the legislative vacuum and address medical practitioners' hesitation, the Court streamlined existing guidelines. (i) Chief Medical Officers (CMOs) must maintain panels of qualified medical practitioners and nominate a member for the Secondary Medical Board within 48 hours of a hospital's request. (ii) For patients in home settings, the next of kin may admit them to any hospital for the purpose of triggering the medical board process. (iii) A 30-day "Reconsideration Period" is mandatory after the concurrence of the two medical boards to allow aggrieved parties to approach the High Court, though it may be waived in cases of unanimous consensus among all stakeholders. (iv) Judicial intervention should be minimal and serves only as a safeguard or when the medical process reaches an impasse. [Paras 255-278, 322]

Constitution of India – Article 142 – Directions to High Courts and Union Government – Legislative Inaction – Held: Guidelines framed by the Court are interim measures to fill a legislative void. The Court urged the Union Government to consider enacting comprehensive legislation on end-of-life care to provide clarity and certainty. Directions issued to State High Courts to ensure Judicial Magistrates of First Class (JMFC) are apprised of their role in receiving intimations regarding the withdrawal of medical treatment. [Paras 279-291, 323, 327]

Decision: The Miscellaneous Application is allowed. The Court permitted the withdrawal/withholding of CANH for the applicant, noting he had been in PVS for 13 years with no hope of recovery. The 30-day reconsideration period was waived due to the unanimous consensus of the parents and medical boards. AIIMS was directed to admit the applicant to its Palliative Care department to ensure the withdrawal process is humane and managed under a robust End-of-Life (EOL) care plan.

Reservation – OBC Non-Creamy Layer – Determination of Creamy Layer – Respondent candidates qualified in Civil Services Examination and claimed benefit of OBC (Non-Creamy Layer) status – Authorities denied benefit by treating parental salary from private/PSU employment as falling within creamy layer criteria – High Courts set aside the exclusion – Held: The 1993 Office Memorandum contemplated consideration of income from “other sources” under the Income/Wealth Test where equivalence of posts was not determined – Introduction of salary income as a decisive factor through later clarificatory communication lacked rational basis and was unsustainable [Paras 5–7].

Reservation Policy – Objective of Creamy Layer Principle – The doctrine aims to exclude socially advanced members within backward classes so that reservation benefits reach genuinely backward sections – However, exclusion must strictly follow criteria prescribed under governing policy and constitutional principles – Arbitrary expansion of creamy layer criteria without rational classification violates equality principles under Articles 14 and 16 [Paras 17, 41].

Public Sector Employees – OBC Status – Treatment of children of PSU employees – Denial of OBC Non-Creamy Layer status to wards of PSU employees while granting similar benefit to wards of government employees occupying comparable posts amounts to hostile discrimination – Such unequal treatment cannot be sustained under constitutional equality principles [Paras 40–41].

Service Allocation – Civil Services Examination – Determination of eligibility for reservation benefits must be based on the applicable rules and certificates valid as on the relevant cut-off date – Authorities must apply reservation policy consistently with governing Office Memoranda and constitutional mandates [Paras 6–8].

Relief – Creation of Supernumerary Posts – Considering that several similarly placed candidates were affected, the Court directed the authorities to create supernumerary posts wherever necessary to accommodate candidates found eligible under the clarified creamy layer criteria, subject to fulfillment of other eligibility conditions [Para 43].

Decision: All Civil Appeals dismissed – Union of India directed to reconsider claims of the candidates in accordance with the principles laid down in the judgment and implement the same within six months.

Criminal Law – Murder by Arson – Parricide Allegation – Parents allegedly killed when their hut was set ablaze – Trial Court convicted son and daughter-in-law relying mainly on motive and dying declarations – High Court acquitted accused – Supreme Court held prosecution failed to establish a complete chain of circumstances proving guilt beyond reasonable doubt – Investigation found selective and deficient – Acquittal affirmed [Paras 26-28, 31].

Evidence – Dying Declaration – Principles Governing Reliability – Court reiterated that a dying declaration is an important exception to hearsay under Section 32 Evidence Act and can form sole basis of conviction if it inspires full confidence of the Court – However Court must ensure it is voluntary, truthful and not the result of tutoring, prompting or imagination – Where declaration appears doubtful or suspicious, corroboration becomes necessary [Paras 7, 13-14].

Multiple Dying Declarations – Suspicion and Inconsistencies – Case involved two written declarations and several alleged oral declarations – First declaration (FIS) recorded in hospital without medical certification and in presence of villagers and relatives – Second declaration recorded by Executive Magistrate with conflicting testimony regarding authorship and without medical certification – Held: Surrounding circumstances created serious doubt about voluntariness and authenticity – Declarations did not inspire confidence [Paras 17-18].

Oral Dying Declarations – Credibility of Witnesses – Several witnesses claimed that deceased made oral statements implicating accused immediately after incident – However testimonies inconsistent and witnesses closely related or interested in property dispute – Independent witnesses who first noticed the fire not examined – Held: Oral declarations unreliable and unsafe to rely upon [Paras 19-22].

Criminal Investigation – Defective Investigation – Investigating Officer failed to prepare scene mahazar, conduct forensic examination, investigate possible accidental fire from gas cylinder, or examine independent witnesses – Arrest circumstances and presence of accused near scene not established – Held: Investigation appeared predetermined and selective, undermining prosecution case [Paras 24, 28, 31].

Witness Testimony – Interested Witnesses and Motive – Prosecution relied largely on relatives allegedly hostile to accused due to property dispute – Independent villagers and first witnesses to incident not examined – Evidence of motive also weakened by testimony that accused was entitled to share in property – Held: Prosecution evidence insufficient to sustain conviction [Paras 21-22, 26].

Criminal Procedure – Examination of Accused – Section 313 CrPC – Trial court asked only four general questions without putting incriminating circumstances such as motive, dying declarations and medical evidence – Supreme Court held such casual examination violates statutory duty and causes serious prejudice to accused – Courts and prosecutors must ensure every incriminating circumstance is put to the accused [Paras 29-30].

Standard of Proof – Suspicion Cannot Replace Proof – Criminal conviction must rest on proof beyond reasonable doubt and not on conjectures, suspicion or perceived motive – Where evidence fails to exclude other hypotheses, benefit of doubt must go to the accused [Para 30].

Decision: Appeal dismissed – Supreme Court affirmed judgment of High Court acquitting the accused – Prosecution case found unreliable due to doubtful dying declarations, interested witnesses and defective investigation – Pending applications disposed of.

Company Law - Oppression and Mismanagement - Interim Relief - Appellants claiming 40% shareholding in holding company alleged illegal removal of their shareholding, fabricated statutory filings, unlawful induction of directors and asset-stripping of valuable redevelopment project - NCLT declined interim relief - NCLAT set aside that order but confined protection to restraint against taking “perceptive steps” for one month - Held: Since the substantive Company Petition under Sections 241, 242, 244 and 59 of the Companies Act, 2013 remained pending, paramount consideration was preservation of the subject matter till final adjudication by NCLT - Interim arrangement earlier operating before Supreme Court directed to continue [Paras 20, 27-30].

Interlocutory Stage - Scope of Supreme Court Consideration - Court clarified that at this stage it was not examining merits of oppression and mismanagement allegations or rival claims regarding shareholding and control - Controversy before Court confined to nature and scope of interim protection necessary to preserve subject matter of dispute pending adjudication before NCLT [Paras 20, 32].

Preservation of Subject Matter - Project Land - Where project land constituted principal asset connected with dispute and allegations were made regarding conveyance, mortgage, transfer of development rights and alteration of management structure, status quo protection was necessary to ensure that proceedings do not become infructuous and parties are not left with shell entities [Paras 15-19, 27-29].

Insolvency Proceedings - Effect on Interim Protection - During pendency of appeals, entity in whose favour project land had been conveyed was admitted into corporate insolvency resolution process under Section 7 IBC - Supreme Court took note of these developments and continued restraint so that no irreversible changes were made to the property while underlying dispute as to corporate control and transactions remained unresolved [Paras 23, 28-29].

Limited Protective Works - No Creation of Equity - On complaints regarding excavation pits and safety of adjoining structures, Supreme Court permitted only limited protective works such as laying foundation in excavated pits, retaining walls, backfilling and barricading, subject to approvals - Held: Such permission was only to secure neighbouring structures and would not create any equity in favour of applicant [Paras 24-25].

Contempt Jurisdiction - Disputed Facts - Appellants alleged violation of interim directions by construction activity, registration with regulatory authorities and marketing of units - Respondents controverted allegations - Held: At this stage it was not necessary to enter into merits of contempt allegations since they involved factual disputes - focus remained on preserving subject matter pending final adjudication [Para 26].

Expeditious Disposal - NCLT Directed to Decide Main Petition - Supreme Court modified NCLAT order and directed continuation of status quo till disposal of Company Petition - Parties directed to appear before NCLT, Mumbai Bench on 19.03.2026 and Company Petition No.159(MB) of 2021 directed to be decided preferably within two months - All merits left open [Paras 29-30].

Decision: Appeals and Contempt Petitions disposed of - Impugned order dated 11.10.2022 modified - Parties directed to maintain status quo in terms of earlier orders of Supreme Court - No steps to be taken altering nature of property or creating third-party interests - NCLT directed to decide Company Petition expeditiously - Observations not to be treated as expression on merits [Paras 29-34].

Criminal Procedure – Quashing of FIR – Section 482 CrPC – Sine Qua Non – Dispute arising from a Collaboration Agreement of 2012 led the appellant to lodge a complaint with the Commissioner of Police – FIR not registered on complaint, whereupon appellant filed an application under Section 156(3) CrPC before the Magistrate along with a complaint under Sections 420, 406 and 120-B IPC – Magistrate by order dated 05.04.2023 directed the police to register an FIR under Section 156(3) CrPC – Respondents challenged the Magistrate's order and FIR under Section 482 CrPC before the High Court – High Court quashed the Magistrate's order and the FIR on the grounds of suppression of facts in the Section 156(3) application, non-conduct of preliminary inquiry by the Magistrate and absence of reasoning and application of mind – High Court further quashed the complaint and all subsequent proceedings and characterised the complaint as based on false, malicious and vague allegations without any foundation – Held: The sine qua non for exercise of power under Section 482 CrPC to quash an FIR is a finding that the complaint, on its face, does not disclose commission of a cognizable offence – No such finding recorded by the High Court – Impugned order set aside – Matter remitted for fresh consideration [Paras 7-9].

Section 482 CrPC – Scope – Before embarking on quashment of an FIR, the High Court must record a conclusion that the complaint does not disclose a cognizable offence – Labelling a complaint as false, malicious or vague without any foundation in the order is not sufficient to quash the FIR – High Court must pass a detailed reasoned order [Para 8].

Decision: Appeal disposed of – Impugned order of the High Court set aside – Matter remitted to the High Court for fresh consideration on all grounds under Section 482 CrPC – Interim order operating in favour of the respondents to continue subject to further orders by the High Court – High Court directed to decide the petition expeditiously.

Specific Performance – Sale Agreement as Security for Loan – Sham and Nominal Document – Plaintiff filed suit for specific performance of registered sale agreement dated 04.06.2002 for property for consideration Rs.13,00,000 with advance Rs.6,00,000 – Defendants contended plaintiff was unlicensed money lender who advanced loan with understanding defendants would repay within 12 months and plaintiff would return title deeds and cancel agreement – Understanding reduced to Memorandum of Understanding dated 04.06.2002 signed same day as sale agreement – MoU and no objection letter executed on consecutive stamp papers from same vendor with same witnesses – Plaintiff withheld MoU from plaint – Held: Circumstances probablise defense that agreement executed as security for loan not genuine sale transaction – Conduct of parties significant in evaluating bona fides – Plaintiff approaching court with unclean hands having withheld material document – Equitable discretionary relief rightly denied – Appeal dismissed [Paras 2-13].

Equitable Relief – Clean Hands Doctrine – Material Document Withheld – Plaintiff sought specific performance but did not disclose Memorandum of Understanding executed same day as sale agreement – MoU came on record through defendants clearly reciting loan transaction – Held: Even slight doubt that plaintiff not acting bonafidely and material facts withheld sufficient to deny equitable relief – Plaintiff with unclean hands not entitled to discretionary relief of specific performance [Paras 6, 12].

Evidence – Contemporaneous Documents – Probative Value – MoU on stamp paper bearing document no.47663 and no objection letter on stamp paper no.47662 both dated 04.06.2002 from same vendor with same witnesses – Held: Consecutive document numbers, same date, same vendor, same witnesses probablise defense that sale agreement was security for loan transaction – Execution of MoU makes strong probable case proving agreement was sham and nominal document [Paras 10-11].

Decision: Appeal dismissed – High Court judgment setting aside Trial Court decree upheld – Sale agreement found sham document executed as security for loan – Memorandum of Understanding established loan nature of transaction – Plaintiff withheld material document approaching court with unclean hands – Equitable discretionary relief rightly denied.

Cooperative Societies - State Reorganisation - Multi-State Cooperative Society - Section 103 of Multi-State Cooperative Societies Act, 2002 - Deeming Fiction - Scope and Applicability - Sugarcane Growers Cooperative Societies, Bajpur and Gadarpur, originally registered under the U.P. Cooperative Societies Act, 1965, had their area of operations spanning across the newly formed States of Uttar Pradesh and Uttarakhand upon bifurcation of erstwhile State of U.P. under the Reorganisation Act, 2000 - High Court held both societies to be Multi-State Cooperative Societies under Section 103 of 2002 Act and directed elections to be conducted by the Central Registrar - Held: Section 103 of the 2002 Act does not operate automatically or universally - Deeming fiction is conditional upon factual determination that the objects of the Society, as reflected in bye-laws, extend to more than one State - Conceptual distinction between 'objects' and 'area of operation' is fundamental - Mere geographical spread of membership or activity cannot substitute the requirement that principal objects must themselves be multi-state in character - Bye-laws of both societies disclosed objects confined to promoting interests of local canegrowers within a single State - Impugned judgment of High Court quashed [Paras 1, 22-24, 26].

State Reorganisation Act - Sections 87 and 93 - Overriding Effect - Harmonious Construction - Section 87 of Reorganisation Act embodies the doctrine of legislative continuity, ensuring that statutory regimes governing cooperative societies remain operational during the transitional period - Section 93 contains a non-obstante clause giving the Reorganisation Act overriding effect over any inconsistent law - Both States took necessary steps for reorganisation of the societies under the transitional framework before the 2002 Act came into force - Deeming fiction under Section 103 of 2002 Act cannot retrospectively unsettle completed statutory action for reorganisation - Held: Provisions of two statutes must be harmoniously construed to give effect to both - Operation of legal fiction under Section 103 must be restricted in cases where reorganisation of societies has already been completed under Sections 87 and 93 of the Reorganisation Act [Paras 13-14, 21-24].

Legal Fiction - Strict Construction - Deeming Provision - Section 103 of 2002 Act - A legal fiction must be strictly confined to the purpose for which it is created and cannot be extended beyond its legitimate field - Deeming provision under Section 103 of 2002 Act cannot be construed in isolation to override the express statutory scheme of the Reorganisation Act - Held: In absence of multi-state objects in bye-laws, statutory pre-conditions for invoking Section 103 of 2002 Act are absent and societies cannot be treated as Multi-State Cooperative Societies [Para 22].

Decision: Civil Appeal Nos. 8743, 8744 and 8745 of 2013 allowed - Judgment and order dated 14.03.2007 of the High Court quashed and set aside - Civil Appeal No. 8746 of 2013 dismissed - Judgment and order dated 05.09.2006 upheld - Authorities under State Cooperative law directed to conduct elections of the Societies expeditiously - No order as to costs [Paras 26-27].

Election Law – Disqualification – More than Two Children Norm – Section 45(1)(v) – Respondent gave birth to third child after cut-off date – Statutory disqualification attracted – Election rightly declared void – Concurrent findings of Tribunal, Appellate Tribunal and High Court upheld [Paras 19–20]

Election Petition – Evidence – Non-cross-examination – Effect – Respondent failed to cross-examine petitioner’s witnesses despite repeated opportunities – Evidence remained uncontroverted – Tribunal justified in accepting petitioner’s case – Adverse inference drawn against respondent [Paras 7, 19–20]

Election Disputes – Burden of Proof – Discharge by Petitioner – Petitioner led cogent documentary and oral evidence proving disqualification – In absence of rebuttal, Tribunal bound to accept unrebutted evidence – Finding of disqualification inevitable [Paras 7, 20]

Election Tribunal – Jurisdiction – Challenge rejected – Objection to jurisdiction not substantiated on legal grounds – Issue not meriting interference [Para 18]

Relief in Election Petition – Declaration of Returned Candidate’s Election as Void – Section 44-E – Petitioner entitled not only to challenge election but also seek declaration of self as duly elected – Statutory right recognised [Para 22]

Consequential Relief – Declaration of Election Petitioner as Winner – Section 44-J(2)(b) – Where only two candidates contested and returned candidate is disqualified, remaining candidate entitled to be declared elected – Fresh election unwarranted [Paras 23–25]

Election Law – Avoidance of Unnecessary Elections – Legislative Intent – Scheme of Sections 44-E and 44-J aims to avoid re-election where result is determinable from existing votes – Tribunal must grant effective relief [Paras 14, 22–24]

Fresh Election – When Not Required – Only Two Candidates in Fray – Setting aside election of returned candidate leaves sole valid candidate – Direction for re-election erroneous – Appellate Tribunal and High Court erred [Paras 23, 25–26]

Delay in Election Litigation – Impact – Election held in 2022 – Litigation consumed over 3 years – Denial of consequential relief would defeat justice – Court must ensure fruits of litigation are not lost [Para 24]

Equitable Relief – Successful Election Petitioner – Denial of office after successful challenge amounts to travesty of justice – Restoration of Tribunal’s order justified [Paras 24–25]

Election Law – Principle – “Next Highest Votes” – In limited candidate scenario, candidate securing next highest valid votes entitled to be declared elected upon disqualification of returned candidate [Paras 9, 23]

Scope of Interference – Supreme Court – Concurrent findings on disqualification not interfered with – Interference limited to erroneous denial of consequential relief [Paras 19–20, 27]

Decision: Appeal allowed – Judgments of High Court and Election Appellate Tribunal set aside to extent of denying consequential relief – Order of Election Tribunal restored – Appellant declared elected as Chairman of Delang Panchayat Samiti – Directions for fresh election quashed – Compliance directed within two weeks – Connected SLP dismissed.

Anticipatory Bail – Spurious Liquor Manufacturing Case – Supplier of Bottles and Caps – Appellant not initially named in FIR – Added as accused based on custodial interrogation of co-accused who stated that appellant supplied plastic bottles and caps with Government labels for manufacturing spurious liquor – No raid conducted at appellant's business establishment – Appellant granted interim protection by Supreme Court and cooperated with investigation – Appellant previously arraigned in two successive cases with similar allegations and released on bail – Held: Appellant entitled to anticipatory bail as not initially named in FIR, no raid at his premises, already cooperated with investigation, and no allegation of misuse of interim protection [Paras 2-10].

Investigation – Custodial Interrogation – Necessity – Prosecution contended that appellant's custodial interrogation required to uncover larger conspiracy and money trail involving manufacture and supply of spurious liquor – Investigation revealed 400 calls between appellant and accused no.23 who coordinated supply of fake bottles and caps – Financial transactions discovered between appellant and accused no.2 – Court observed that appellant already appeared before Investigating Officer during interim protection and cooperated with investigation – No material to show custodial interrogation indispensable at this stage [Paras 5-9].

Identity Confusion – Addition of Accused – Initially memo dated 30.10.2025 filed to add Manoj Kotaria as accused no.20 – Subsequently memo dated 11.11.2025 filed to change name to Mutta Manoj Kumar @ Manoj Kotaria – Witnesses referred to appellant variously as Manoj Kothariya, Manoj Kumar, owner of Mishramal Heerachand Plastic Dealers – Defence contended confusion about identity – Prosecution relied on witness statements ascribing role of supply of bottles and caps to appellant – Court noted appellant not initially named and confusion regarding identity exists [Paras 5-7].

Criminal Procedure – Successive Prosecution – Appellant arraigned as accused in two successive criminal cases (Crime Nos. 69 of 2025 and 115 of 2025) registered in quick succession with same set of allegations unsupported by material – In each instance appellant arrested, remanded and ultimately released on bail – Court considered pattern of successive prosecution while granting anticipatory bail [Para 7].

Decision: Appeal allowed – Impugned order dated 05.12.2025 of Andhra Pradesh High Court refusing anticipatory bail set aside – Interim protection granted vide order dated 06.01.2026 made absolute – Appellant to be released on anticipatory bail in Crime No. 171 of 2025 on terms and conditions imposed by arresting officer or Trial Court – Conditions imposed: appellant shall cooperate with investigation and trial and shall not influence witnesses.