Criminal Law – Culpable Homicide – Sentence – Appellant convicted under Section 304 Part-II IPC for causing death of intervenor S by axe blow to the neck – Trial court sentenced him to 10 years’ RI – High Court reduced sentence to 8 years – Appellant sought further reduction on ground of young age (20 years) and absence of intention – Supreme Court held that deceased S was an innocent peacekeeper who suffered fatal injury without provocation – Act of appellant found not to be covered by Exception 1 to Section 300 IPC – Sentence of 8 years not excessive in the circumstances – Held: Sentence imposed by High Court appropriate and does not warrant interference [Paras 8–10, 22–23, 27–28].

Sentencing – Proportionality – Deterrence – Supreme Court emphasized balancing judicial discretion with societal interests and victim’s rights – Reiterated principles from Raj Bala v. State of Haryana and Shailesh Jasvantbhai v. State of Gujarat – Undue sympathy and disproportionate leniency undermine faith in justice system – Sentence must reflect gravity of offence and protect social order – Held: No compelling reason to further reduce sentence in absence of mitigating circumstances [Paras 24–25, 27–28].

Premature Release – Remission – Appellant permitted to seek premature release under applicable State remission policy – Court noted that such statutory remedies remain open and independent of judicial sentence review [Paras 17, 30].

Decision: Appeal dismissed – Sentence of 8 years’ rigorous imprisonment under Section 304 Part-II IPC upheld – Appellant entitled to seek premature release as per remission policy of State of Karnataka.

Trademark Law – Interim Injunction – Intra-group Licensing – Scope of Restraint – Suit filed by respondent sought to restrain petitioner from creating third-party interest including license or assignment of ‘Kirloskar’ trademarks – Trial Court granted injunction on 09.01.2025 – High Court stayed the injunction on 25.07.2025 permitting limited licensing to group companies – Later, by order dated 10.10.2025, High Court modified earlier order to prohibit even such licensing – Held: Prima facie, modified order expanded restraint without proper consideration of earlier licensing practices and despite pendency of appeal – Operation of 10.10.2025 order stayed [Paras 2–10].

Trademark Ownership – Difference between Assignment and Licensing – Petitioner argued that licensing does not amount to transfer of ownership and is distinguishable from assignment – Court noted there was no dispute over ownership of the mark and no prior adjudication on internal licensing history – Modified restraint seen as excessive at interlocutory stage [Paras 5–8].

Judicial Discretion – Modification of Interim Orders – Supreme Court observed that expanding the scope of an interim injunction during pendency of appeal and without full factual analysis was not warranted – Ordered interim stay on modified order [Paras 8–10].

Decision: Notice issued returnable on 04.11.2025 – Effect and operation of High Court order dated 10.10.2025 stayed – Parties allowed to exchange affidavits/written submissions in the meantime

Criminal Law – Murder – Conviction Reversed – Appellant convicted under Section 302 read with Section 34 IPC along with three others – FIR stated incident occurred when accused tried to destroy hut of one Jagya, and deceased Ramesh intervened – Alleged eyewitnesses Madho Singh (PW-5) and Puniya (PW-12) gave materially contradictory accounts regarding place and sequence of incident – Court found contradictions regarding location (hut, Gopya’s field, Bholiya’s field) and number of assailants with sharp weapons – Doubt raised on presence of eyewitnesses due to improbabilities, contradictions, and omissions – Medical evidence confirmed homicidal death but lacked independent corroboration of witness accounts [Paras 26-40, 41-52].

Witness Testimony – Credibility – Madho Singh (PW-5) and Puniya (PW-12) contradicted each other on key aspects – Each denied other’s presence – Madho Singh admitted political rivalry with accused and stated no one came to rescue despite hue and cry – Puniya claimed to have witnessed the assault but made no attempt to assist the deceased – Their testimonies found unreliable and lacking corroboration – Court classified Puniya as “wholly unreliable” and Madho Singh as “partially reliable” – No corroborative evidence to support their testimonies [Paras 40, 55].

FIR and Investigation – Omission of key eyewitness name in FIR – FIR failed to mention presence of Puniya despite being relative and allegedly witnessing incident – Site inspection plan contradicted witness statements – No source of light recorded at scene – Seized weapons not proven to be linked with specific injuries – FIR filed next morning – Held: Prosecution suppressed genesis of incident and shifted scene of crime – Entire narrative doubtful [Paras 29, 36, 49, 56-57].

Benefit of Doubt – Other co-accused not before Court – However, in exercise of powers under Article 142, Court extended benefit of doubt to similarly situated co-convicts Govardhan, Raja Ram, and Bhima – All four accused acquitted – Conviction and sentence set aside [Paras 61-64].

Decision: Appeal allowed – Conviction and sentence under Section 302 IPC and Section 302 read with Section 34 IPC set aside – Appellant and co-accused acquitted – To be released forthwith if not wanted in any other case.

Constitutional Law – Power of High Court – Direction for CBI Investigation – Limits of Jurisdiction – High Court, while hearing an intra-court appeal against a Single Judge’s order in recruitment matters, converted the appeal into suo motu PIL and directed CBI to conduct a preliminary inquiry – Held: High Court exceeded its jurisdiction – Exercise of power to order CBI inquiry under Article 226 permissible only where sufficient material exists disclosing prima facie commission of offence – Power to be exercised sparingly, cautiously, and in exceptional circumstances where fairness of investigation or public confidence is at stake – No such material existed here – Directions unsustainable [Paras 9–14, 18–24].

Public Employment – Recruitment Irregularities – Challenge to selection process for various posts in Legislative Council and Assembly Secretariat of U.P. – Allegations of favoritism and manipulation by private recruiting agencies – Writ petitions contained no prayer for CBI inquiry – Division Bench acted suo motu without foundation or pleading – Held: Ordering CBI inquiry based on “doubts” or “assumptions” violates settled principles – Directions quashed [Paras 15–21, 23].

Judicial Review – Suo Motu Public Interest Litigation – Scope – High Court, while exercising appellate jurisdiction, could not convert pending special appeal into suo motu PIL – Such action not in consonance with rules or judicial propriety – Matter left to Chief Justice of High Court to examine procedure and registry’s action in this regard [Paras 18–19, 25].

CBI Inquiry – Principles Reiterated – Direction for CBI investigation to be last resort – Permissible only when: (i) prima facie material discloses cognizable offence, (ii) local police incapable of impartial probe, (iii) involvement of high-ranking officials or systemic failure, or (iv) case has national ramifications – Mere allegations or administrative irregularities do not justify CBI inquiry – High Court’s assumption-based approach deprecated [Paras 10–14, 21–23].

Recruitment Process – Role of Specialized Agency – Following Sachin Kumar v. DSSSB (2021) 4 SCC 631, Single Judge directed future Class III recruitments in U.P. Legislative Assembly/Council to be conducted by U.P. Subordinate Services Selection Commission and not private agencies – Division Bench should have confined adjudication to legality of that direction – CBI inquiry beyond pleadings and scope of appeal [Paras 3–5, 17, 24–25].

Decision – Appeals allowed – High Court’s orders dated 18.09.2023 and 03.10.2023 set aside – Direction for CBI preliminary inquiry and registration of suo motu PIL quashed – Division Bench requested to hear Special Appeal Defective No. 485 of 2023 on merits in accordance with law – No opinion on merits expressed – Pending applications disposed of [Paras 24–25].

Service Law – Recruitment to Public Posts – Writ Jurisdiction – Maintainability – Dispute relating to recruitment of Graduate Primary Teachers in Karnataka – Challenge raised by married women candidates regarding rejection of caste-cum-income certificates issued in the name of parents instead of husbands – Held: High Court erred in entertaining writ petitions directly when efficacious alternative remedy before the Karnataka State Administrative Tribunal (KSAT) was available – KSAT is the competent forum for adjudication of service and recruitment disputes under the Administrative Tribunals Act, 1985 – Constitution Bench ruling in L. Chandra Kumar v. Union of India applied – T.K. Rangarajan v. State of T.N. distinguished as an exceptional case invoking Article 142 – Division Bench rightly set aside Single Judge’s order and relegated parties to KSAT – Appeals dismissed – Interim orders made absolute [Paras 26-33, 35-39, 40-47, 49-50].

Maintainability – Writ under Articles 226 and 227 – When not maintainable – Availability of effective alternative remedy – Exceptions reiterated, namely (i) violation of fundamental rights, (ii) breach of natural justice, (iii) lack of jurisdiction, and (iv) challenge to vires of statute – None of these exceptions attracted in the present case, as the dispute concerns rejection of documents in a recruitment process – High Court not to act as court of first instance in such service matters [Paras 32-37].

Administrative Tribunals – Powers and Efficacy – KSAT vested with powers akin to High Court under the Administrative Tribunals Act, 1985 – Empowered to grant interim relief including ex parte orders, review its decisions, punish for contempt, and regulate its own procedure – Karnataka Administrative Tribunal Rules prescribe six-month period for disposal – Hence, remedy before KSAT held to be effective, efficacious, and expeditious [Paras 38-46].

Public Employment – Provisional and Final Select Lists – Provisional list confers no vested right – Direction to act upon provisional list dated 18.11.2022 would create administrative uncertainty – Validity of final select list dated 08.03.2023 to be decided by KSAT – State’s refusal to revive provisional list upheld [Para 48].

Interim Protection – Supreme Court’s prior interim orders noticed – (i) 03.01.2024: Stay of High Court’s directions and keeping appointments under 08.03.2023 list in abeyance; (ii) 22.01.2024: Permitting 11,494 appointees to continue subject to outcome; 481 posts reserved for married women candidates; (iii) 04.10.2024: State allowed to fill remaining vacancies while keeping 500 posts reserved – All interim directions made absolute – 500 reserved posts to be filled as per KSAT’s final verdict [Paras 21(A)-(C), 49].

Recruitment – Facts and Background – Notification dated 21.03.2022 for 15,000 Graduate Primary Teacher posts; exams held on 21–22.05.2022; results declared 17.08.2022; provisional list issued 18.11.2022; dispute arose over validity of certificates of married women candidates – Single Judge’s order dated 30.01.2023 directing inclusion of such candidates – Division Bench judgment dated 12.10.2023 setting aside Single Judge’s order and relegating parties to KSAT – Supreme Court upholds Division Bench view and directs expeditious disposal [Paras 3-20, 47, 49-51].

Decision – Appeals dismissed – Division Bench judgment affirmed – Matters relegated to Karnataka State Administrative Tribunal for final adjudication – Interim orders dated 03.01.2024, 22.01.2024, and 04.10.2024 made absolute – 500 reserved posts to abide KSAT’s final decision – Tribunal requested to decide within six months – Merits of eligibility and certificate issues left open [Paras 47, 49-51].

Property Law – Agreement to Sell – Transfer of Property Act, 1882 – Whether agreement to sell executed during lifetime of deceased transfers ownership – Held: No – Agreement to sell does not create interest or title in immovable property; ownership transfers only upon execution and registration of sale deed – As no conveyance existed during lifetime, the property remained vested in deceased and formed part of matruka property – Reliance placed on Suraj Lamp & Industries (P) Ltd. (2) v. State of Haryana, (2012) 1 SCC 656, and Rambhau Namdeo Gajre v. Narayan Bapuji Dhotra, (2004) 8 SCC 614 [Paras 7–10].

Mohammedan Law – Matruka Property – Definition and Devolution – “Matruka” means property (movable or immovable) left behind by a deceased Muslim – Held: Such property devolves first to satisfy debts and legacies (limited to one-third of estate) and remainder distributed among heirs as per Quranic injunctions and Mulla’s Principles – Wife being a sharer entitled to one-fourth share in absence of child or grandchild; balance devolves on residuaries – Cited Jamil Ahmad v. Vth ADJ, Moradabad, (2001) 8 SCC 599 and Trinity Infraventures Ltd. v. M.S. Murthy, 2023 SCC OnLine SC 738 [Paras 8–15].

Inheritance – Nemo Dat Quod Non Habet – Principle – Held: A person cannot transfer a better title than he possesses – Widow who held only one-fourth share could not convey ownership of entire estate – Sale deed executed beyond her legal share invalid to that extent [Para 15].

Civil Procedure – Second Appeal – Section 100 CPC – When no substantial question of law arises, High Court must dismiss appeal in limine with reasons – Though High Court examined merits after so finding, no prejudice caused as conclusion consistent with law – Referred Surat Singh v. Siri Bhagwan, (2018) 4 SCC 562; Hasmat Ali v. Ameena Bibi, 2021 SCC OnLine SC 1142 [Para 5].

Language of Judgments – Translation Quality – Observed with concern the poor translation of trial court judgment from vernacular to English – Emphasized need for accuracy since words and punctuation bear decisive legal implications – Concern earlier echoed in Chairman, Managing Committee v. Bhaveshkumar Manubhai Parakhia (Order dated 18.03.2025) [Para 17].

Decision: Appeals dismissed – View taken by First Appellate Court and High Court upheld – Property in question forms part of matruka property – Wife entitled to 1/4th share; remaining 3/4th to devolve per Mohammedan inheritance law – No interference warranted – No order as to costs [Paras 15–18].

Environmental Law – Firecrackers in Delhi–NCR – Temporary relaxation on “test case” basis – Supreme Court permits sale and use of only NEERI-approved green crackers at designated locations for a limited window (sale: 18–20 Oct 2025 – use: 6–7 AM & 8–10 PM on the day before and on Diwali) – Ban on barium-containing crackers, series/laris, e-commerce sales and inflow from outside NCR – Strict patrols, QR-code verification, random sampling, licence renewals for the limited period, and AQI/soil/water monitoring directed – Rationale: balance right to life and health with livelihood/festive interests; prior Delhi–NCR ban in 2024 distinguished as both GNCTD and Union now seek calibrated relaxation – Directions modelled on Arjun Gopal (2018) regime – Test-case relaxation only for specified period [Paras 1–4, 12–14, 18–24].

Right to Life vs. Profession – Court reiterates primacy of health and environment over commercial/festive considerations – While acknowledging cultural practice of bursting crackers, uncontrolled use cannot be permitted to cause short/long-term health damage – Balance struck via narrow relaxation with strict compliance and enforcement [Paras 1–3, 16–20].

Green Crackers – NEERI formulations – Court notes NEERI/CSIR work cutting particulate emissions by 30–80% through zeolites, water-releasing molecules, and metallic composites; barium banned in India and replaced by strontium/potassium – NEERI SOP for manufacturer registration, product-wise approvals, QR codes; concern over QR misuse flagged – Enforcement directed via testing and penal action for violations [Paras 12–13, 14(A)(i), 14(C)(iii)-(v), (vi)-(vii)].

Operational Directions – Sale only 18–20 Oct 2025 at locations identified by District Collectors/Commissioners with police/SPCB patrols – Use only two time slots on two days (pre-Diwali and Diwali) – Confiscation of non-approved products; prohibition on e-commerce; no series/laris; no inflow from outside NCR; renewal of expired/cancelled trader licences for stipulated period – CPCB/SPCBs to monitor AQI 14–25 Oct 2025 and collect soil/water samples; report to Court – Relaxation expressly on “test case” basis [Para 24(A)–(M)].

Earlier Ban & Data – 2024 complete ban by GNCTD (14.10.2024 to 01.01.2025) and its expansion to entire NCR (19.12.2024) noted; present relaxation sought by GNCTD and Union distinguishes current context – Court records that AQI differences between 2018 and 2024 were not substantial (except Covid period), supporting calibrated approach with stringent safeguards [Paras 11, 21, 23–24].

Decision: Limited, strictly regulated relaxation granted – Only NEERI-approved green crackers – Detailed enforcement, monitoring, and reporting mandated – Relaxation confined to specified days/hours and expressly on test-case basis; IAs to be listed after three weeks for further directions [Paras 24–25].

Service Law – Waiting List/Reserved Panel – Counsel’s Concession – High Court directed absorption on future SC vacancy relying on 15.01.1999 assurance – Held: Wait list is not a source of recruitment and operates only if a selected candidate does not join – A concession contrary to statutory Recruitment Rules is not binding; cannot be enforced to extend life of wait list or fill future vacancies – Appeal allowed; High Court judgment set aside [Paras 12–13, 15–18; 1997 process closed].

Waiting List – Nature and Operative Period – The Court reiterates that mere placement in a wait list/“Reserved Panel” confers no vested right; it operates only if a selected candidate does not join and cannot continue indefinitely or after a fresh recruitment begins – Reliance placed on Gujarat State Dy. Executive Engineers’ Assn. v. State of Gujarat (three-Judge Bench) – Held, respondent’s right as a waitlisted candidate extinguished when all three selected candidates joined in 1997 [Para 12].

Concession by Counsel – Not Binding if Contrary to Law/Rules – The 15.01.1999 statement that respondent would be “absorbed” against next SC vacancy could not override Recruitment Rules or revive a closed selection – Wrong concession on law by counsel is not binding on the client; Court refers to Uptron India Ltd. v. Shammi Bhan and Central Council for Research in Ayurveda & Siddha v. K. Santhakumari – Held, State can place correct legal position and decline to act on an erroneous concession that violates statutory Rules [Paras 15–16, 17].

Future Vacancies & Prejudice to Fresh Candidates – Giving effect to the 1999 concession would fill posts in subsequent recruitment from an earlier list, prejudicing new aspirants and impermissibly extending the life of the wait list – Hence, the High Court’s absorption direction is unsustainable [Para 17].

Facts – 1997 selection for three SC Technician posts; respondent placed first in Reserved Panel; all three selectees joined; multiple rounds before CAT/High Court; 2013 recruitment and interim “one post to be kept vacant” order; ultimate HC (25.06.2024) direction to absorb with notional effect from 19.07.2013 set aside [Paras 3–11].

Decision: Appeal allowed – Calcutta High Court’s judgment dated 25.06.2024 set aside – Writ petition dismissed – No order as to costs [Para 18].

Motor Vehicles Act, 1988 – Compensation – Computation – Inclusion of allowances and perks – Future prospects @ 50% for age 27 – Deduction of income tax to follow slab rates, not flat 30% – Multiplier 17 – High Court’s reduction set aside – Compensation enhanced to ₹74,43,631 with 6% interest [Paras 3, 6, 11–16].

Motor Vehicles – Compensation under Ss. 140 & 166 MV Act – Computation – Allowances includible – Future prospects @ 50% (age below 40) – Income tax deduction to follow slab rates applicable for the relevant financial year and not a flat 30% – Multiplier 17 applicable – Tribunal rightly included salary allowances and computed compensation at ₹74,43,631 – High Court’s reduction set aside – Held: Compensation to be enhanced and interest @ 6% p.a. payable from date of claim petition till payment [Paras 3, 6, 11–16].

Motor Accident Claims – Inclusion of Allowances – “Income” for the purpose of loss of dependency includes allowances and perquisites reflected in the last pay slip – Exclusion by High Court erroneous – Tribunal’s determination of ₹53,367 per month upheld [Para 12].

Income Tax Deduction – Deduction permissible but must be based on slab rates as per the relevant year – Flat deduction of 30% unjustified – Annual income ₹6,40,400; tax liability ₹62,080; net income ₹5,78,324 accepted for computation [Para 13].

Future Prospects – For a permanent salaried employee aged 27 years, addition of 50% towards future prospects correct – High Court’s reduction to 40% unsustainable [Para 14].

Multiplier – Multiplier of 17 correctly applied as per Sarla Verma guidelines, deceased aged 27 years [Para 11].

Computation of Compensation – After applying deductions and future prospects, loss of dependency ₹73,73,631 – Conventional heads (estate ₹15,000; filial consortium ₹40,000; funeral ₹15,000) – Total ₹74,43,631 – Interest @ 6% from date of claim petition till realization [Para 15].

Decision: Appeal allowed – High Court’s judgment set aside – Compensation enhanced to ₹74,43,631 with 6% interest p.a. from the date of the claim petition till actual payment [Para 16].