Murder – Dying Declaration – The Supreme Court emphasized that a dying declaration can form the sole basis for conviction if it is found to be genuine and voluntary. However, the Court must ensure the declaration is free from tutoring, prompting, or imagination. In this case, the victim, who had 80% burn injuries, was found to be in no position to talk or give a statement. The son's testimony that his mother committed suicide and the lack of corroborative evidence from other prosecution witnesses weakened the prosecution's case [Paras 1-28].

Witness Credibility – Hostile Witnesses – Several key prosecution witnesses, including the victim's son and daughter-in-law, turned hostile and contradicted the prosecution's version of events. Their testimonies did not support the claim that the victim made a dying declaration implicating the appellants. This inconsistency further cast doubt on the reliability of the dying declaration [Paras 9-20].

Judicial Scrutiny – High Court's Duty – The Court reiterated that while reversing an acquittal, the High Court must thoroughly scrutinize the evidence on record and provide cogent reasons for overturning the trial court's findings. The High Court failed to do so in this case, leading to an erroneous conviction [Paras 23-24].

Decision – Appeal Allowed – The Supreme Court set aside the High Court's order convicting the appellants under Section 302 read with Section 34 IPC. The appellants were acquitted, and their bail bonds were discharged. The lack of credible evidence and the unreliable dying declaration could not justify the conviction [Paras 27-28]. Appeal Allowed.

Murder – Acquittal Justified – The Supreme Court emphasized that the evidence of the appellant running away from the scene of the crime was too thin to justify a conviction under Section 302 IPC. The principle of res gestae could not be applied to convict based on such insubstantial evidence. The Court upheld the acquittal by the trial court, stating that the witness statements and evidence were contradictory and did not inspire confidence [Paras 9-13].

Witness Credibility – Contradictions – The Court found significant contradictions in the testimonies of key witnesses (PW-3, PW-5, and PW-6). The inconsistencies regarding the exact location and actions of the accused weakened the prosecution's case. The evidence of PW-5, in particular, was found to be unreliable due to her contradictory statements about witnessing the assault and the presence of the accused [Paras 9-11].

Evidence of Assault – Lack of Corroboration – The prosecution's attempt to establish the weapon of assault (a club) as linked to the accused failed due to insufficient corroboration. The club seized from the accused's house was not proven to match the one used in the crime. The autopsy surgeon was not shown the club, and there was no conclusive evidence to connect the seized club to the injury sustained by the deceased [Paras 12-13].

Decision – Appeal Allowed – The Supreme Court set aside the judgment of the High Court of Karnataka that had convicted the appellant. The trial court's acquittal was restored, and the appellant was directed to be discharged from his bail bonds. Appeal Allowed.

Murder – Eyewitness Testimony – The Supreme Court upheld the High Court's decision to reverse the acquittal based on the reliability and trustworthiness of eyewitnesses. The absence of motive was deemed insignificant when direct evidence from reliable eyewitnesses is available. The non-examination of independent witnesses was not considered fatal to the prosecution's case [Paras 1-22].

Reversal of Acquittal – Judicial Standards – The High Court was justified in reappreciating the entire evidence independently and coming to its own conclusion. The rule that the High Court should ordinarily give due importance to the opinion of the Sessions Judge does not apply when the Sessions Judge makes erroneous assumptions about crucial evidence. The appellate court has full power to review and reconsider evidence upon which the order of acquittal is based [Paras 7-20].

Injured Eyewitnesses – Reliable evidence from injured eyewitnesses cannot be discarded merely because no independent witness was examined. The presence of trustworthy and consistent testimonies from eyewitnesses, even if they are related or interested parties, holds substantial weight in the judicial process [Paras 10-11].

Place of Incident – Proven by Prosecution – The prosecution successfully established the place of the incident through credible evidence, including the recovery of the dead body and blood-stained items from the scene. The High Court found no error in the prosecution's presentation of the place of the incident as stated in the FIR [Paras 13-14].

Decision – Appeal Dismissed – The Supreme Court dismissed the appeal, affirming the High Court's order convicting the appellant. The conviction was based on reliable eyewitness testimony and proper reappreciation of evidence. The appellant was directed to surrender and serve the sentence [Paras 18-19]. Appeal Dismissed.

Constitution of India – Media Reporting on Judicial Proceedings – The Supreme Court of India ruled that freedom of speech and expression extends to reporting the proceedings of judicial institutions. This includes the right of the media to comment on and write about ongoing litigation, subject to certain limitations to ensure justice is not derailed. The Court emphasized that oral remarks made by judges during hearings do not form part of the judicial record and are not binding​​.

Freedom of Expression – Media Rights – Article 19(1)(a) of the Constitution guarantees every citizen the right to freedom of speech and expression, which includes the freedom of the press to report on judicial proceedings. The Court stated that media reporting serves a crucial role in promoting transparency, accountability, and public confidence in the judicial system. The evolution of media from print to digital platforms necessitates the judiciary to adapt and engage with new forms of technology, ensuring that court processes remain open and accessible​​.

Judicial Conduct – Oral Remarks by Judges – The Court noted that oral observations made by judges during proceedings should be seen as part of the judicial dialogue and not as formal judicial opinions. Such remarks, though significant for understanding the judges' thought process, do not hold the same weight as written judgments. Judges are advised to exercise caution in making off-the-cuff remarks to avoid misinterpretation and to maintain judicial propriety​​.

Decision – Appeal Disposed of – The Supreme Court set aside the High Court’s remarks attributing responsibility for the COVID-19 surge to the Election Commission. The Court emphasized that such oral remarks were inappropriate and did not constitute part of the judicial record. The appeal was disposed of with the clarification that the media's right to report on court proceedings is integral to the freedom of speech and expression. Appeal Disposed of​​.

School Fees Regulation – Autonomy of Private Schools – Constitutional Validity – Appeals challenging the validity of the Rajasthan Schools (Regulation of Fee) Act 2016 and Rules 2017 dismissed – Supreme Court upheld High Court's ruling that the provisions are intra vires the Constitution – Court emphasized that while private schools have autonomy to fix fees, this can be regulated to prevent profiteering and commercialization [Paras 1-52, 119] .

COVID-19 Pandemic – Fee Reduction – Judicial Intervention – Supreme Court directed that private unaided schools in Rajasthan can collect annual school fees fixed for 2019-20 with a 15% deduction due to unutilized facilities during the pandemic – Collection to be made in six monthly installments – Schools not to debar students from classes or withhold results due to non-payment of fees [Paras 118-121] .

Disaster Management Act – Powers of State – State's directions to defer and reduce school fees under the Disaster Management Act challenged – Supreme Court held that State Government’s power under the Act does not extend to altering school fee structure fixed under the Rajasthan Schools (Regulation of Fee) Act 2016 [Paras 54-71] .

Decision- Appeal Dismissed – First set of appeals challenging the validity of the Rajasthan Schools (Regulation of Fee) Act 2016 and the Rules framed thereunder dismissed – Second set of appeals allowed – High Court's order dated 18.12.2020 quashed – School fees for academic year 2020-21 to be determined with a 15% deduction due to unutilized facilities during the pandemic – Specific directions issued regarding the collection of fees and protection of students’ rights [Paras 118-121] .

Land Acquisition – Specific Performance – Compensation – The appellant executed an agreement to sell land to the respondent, which was later acquired by the state. The courts below granted specific performance. The High Court modified this to grant compensation awarded under the Land Acquisition Act, with deductions for expenses incurred by the original landowner. The Supreme Court upheld this modification, emphasizing that compensation under the Land Acquisition Act may be deemed an appropriate substitute for specific performance when the contract becomes impossible to fulfill through no fault of the plaintiff. [Paras 1-12].

Specific Relief Act, 1963 – Section 21 – Award of Compensation – When specific performance of a contract becomes impossible due to land acquisition, the court is empowered to award compensation in lieu of specific performance. The compensation amount determined under the Land Acquisition Act is to be taken as the measure of damages, subject to deductions for the landowner's litigation costs. [Paras 7-11].

Decision – Appeal Partly Allowed – The appellant is entitled to Rs. 300,000 from the compensation deposited by the acquiring body, with the balance amount, including interest and solatium, payable to the respondent. The decision of the High Court was modified to this extent, confirming the entitlement of the respondent to the compensation awarded under the Land Acquisition Act, less the specified deductions. [Paras 12-13].

Electricity Supply – Contract Load Reduction – The respondent, a small-scale industry, requested a reduction in its sanctioned electricity load from 4000 KVA to 1325 KVA due to issues such as frequent trippings and load shedding. The Jharkhand State Electricity Board (JSEB) rejected the request, citing an agreement clause preventing load reduction within three years of a fresh agreement. The Supreme Court held that agreements for load enhancement are mere extensions or amendments of the initial agreement. Thus, the respondent's application for load reduction, filed three years after the initial agreement, should have been allowed under Regulation 9.2 of the 2005 Regulations. [Paras 1-21].

Electricity Supply Code – Interpretation of Agreement – The Court emphasized that fresh agreements for enhanced loads are not to be treated as new agreements but as amendments to the initial agreement, in line with the Jharkhand State Electricity Regulatory Commission (Electricity Supply Code) Regulations 2005. This ensures fairness and compliance with regulatory provisions favoring the consumer. [Paras 14-16].

Decision – Appeal Dismissed – The Supreme Court dismissed the appeal, stating that the respondent's application for reduction of load must be deemed allowed under Regulation 9.2, entitling the respondent to all consequential benefits. [Paras 19-21].

Land Acquisition – Specific Performance – Compensation – The appellant executed an agreement to sell land to the respondent, which was later acquired by the state. The courts below granted specific performance. The High Court modified this to grant compensation awarded under the Land Acquisition Act, with deductions for expenses incurred by the original landowner. The Supreme Court upheld this modification, emphasizing that compensation under the Land Acquisition Act may be deemed an appropriate substitute for specific performance when the contract becomes impossible to fulfill through no fault of the plaintiff. [Paras 1-12].

Specific Relief Act, 1963 – Section 21 – Award of Compensation – When specific performance of a contract becomes impossible due to land acquisition, the court is empowered to award compensation in lieu of specific performance. The compensation amount determined under the Land Acquisition Act is to be taken as the measure of damages, subject to deductions for the landowner's litigation costs. [Paras 7-11].

Decision – Appeal Partly Allowed – The appellant is entitled to Rs. 300,000 from the compensation deposited by the acquiring body, with the balance amount, including interest and solatium, payable to the respondent. The decision of the High Court was modified to this extent, confirming the entitlement of the respondent to the compensation awarded under the Land Acquisition Act, less the specified deductions. [Paras 12-13].

Income Tax – Section 80-IA(5) – Deduction – The scope of sub-section (5) of Section 80-IA is limited to the determination of the quantum of deduction under sub-section (1) by treating the eligible business as the only source of income. Sub-section (5) cannot be interpreted to limit the deduction to business income alone. The deduction is computed on the basis of net income from the eligible business, but it is allowed against the gross total income, including income from other sources, subject to the ceiling of the gross total income. [Paras 1-15].

Income Tax Act – Section 80AB – Computation of Deduction – Section 80AB pertains to the computation of the quantum of deductible income in the gross total income. It cannot curtail the width of Section 80-IA. Section 80A(2) stipulates that the aggregate amount of deductions under Chapter VI-A shall not exceed the gross total income of the assessee. [Paras 9-10].

Decision – Appeals Dismissed – The Supreme Court dismissed the appeals, holding that the deduction under Section 80-IA of the Act is not limited to business income. The deduction computed on the profits and gains from the eligible business can be set off against the gross total income, including income from other sources, subject to the ceiling of gross total income. [Para 15].