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.

Criminal Law – POCSO – SC/ST Act – Conviction – Quashing – Article 142 – Subsequent Marriage – FIR No. 129 of 2022 registered against the appellant for offences under Sections 363, 366-A and 376 IPC, Sections 3(2)(v), 3(2)(va) and 3(1)(w) of the SC/ST (Prevention of Atrocities) Act, and Sections 3 and 4 of POCSO Act – Appellant convicted by Sessions Court in S.C. ATR No. 78 of 2022 vide judgment dated 11.12.2023 – High Court dismissed application for suspension of sentence on 13.10.2025 – During pendency of appeal, the appellant and the victim/respondent No. 2 married each other and filed a joint application for quashing the FIR, proceedings and conviction – Held: Although the victim was a minor at the relevant time, she and the appellant are now husband and wife leading a happily married life – Continuation of incarceration would be harassment not only to the appellant but also to respondent No. 2 who is no longer interested in prosecuting her husband – Fit case for exercise of power under Article 142 of the Constitution of India to do complete justice – FIR, sessions trial and judgment of conviction and sentence quashed – Appellant discharged of all offences [Paras 5-9].

Decision: Leave granted – Appeal allowed – FIR No. 129 of 2022 and the sessions trial leading to judgment of conviction and sentence dated 11.12.2023 quashed – Appellant discharged of all offences – Criminal Appeal No. 15783 of 2023 pending before the Madhya Pradesh High Court rendered infructuous and disposed of.

Public Health - COVID-19 Vaccination - Adverse Events Following Immunisation (AEFI) - No-Fault Compensation - Article 21 - Petitioners, parents and family members of individuals who died or suffered serious injuries following COVID-19 vaccination, sought constitution of an independent expert medical board, formulation of AEFI protocols, and compensation - Respondent Union of India contended that vaccines underwent rigorous regulatory approval, existing AEFI surveillance mechanism is adequate and transparent, and aggrieved persons may seek remedies before consumer courts or civil courts - Held: Court is not adjudicating upon vaccine efficacy or sitting in scientific review over the regulatory approval process - Constitutional inquiry is confined to whether absence of any structured framework to address serious adverse events following a State-led mass immunisation programme raises constitutional concerns warranting an institutional response - Directed Union of India to expeditiously formulate a no-fault compensation framework for serious adverse events following COVID-19 vaccination [Paras 2-3, 12, 17, 37-38].

Right to Health - Article 21 - Positive Obligation of State - Right to health and bodily integrity is a recognised facet of the right to life under Article 21 - State bears a positive obligation to safeguard health of its citizens and ensure conditions necessary for meaningful enjoyment of life - Where grave harm is alleged to have occurred in the course of a State-led public health intervention, affected families cannot be left without any accessible mechanism of redress - Absence of such an institutional framework raises constitutional concerns - Directive Principles under Articles 41 and 47 further illuminate the State's welfare obligations in matters of public health [Paras 14-17, 20, 24-25, 27].

No-Fault Compensation - Vaccine Injury - Inadequacy of Fault-Based Remedies - Principle of no-fault liability is not alien to Indian law, as reflected in Section 164 of the Motor Vehicles Act, 1988 - Several countries including Australia, United Kingdom, Japan and the WHO-COVAX initiative have recognised dedicated no-fault compensation mechanisms for vaccine-related injuries - Insisting upon proof of negligence and fault in each individual case imposes an onerous burden upon affected families - Multiplicity of individual proceedings risks inconsistent outcomes and unequal access to relief - Relationship between individual and State in the context of a mass immunisation programme cannot be viewed through the prism of fault-based liability - State's responsibility must extend beyond surveillance to providing fair compensation to those who suffered vaccine-related injury [Paras 26-31, 34].

AEFI Surveillance - Independent Expert Body - Existing Mechanism - Court satisfied that existing framework of National and State AEFI Committees is adequate for investigation of deaths and injuries following vaccination - No material placed on record to indicate that such mechanisms are non-functional - Held: It would not be appropriate for the Court, in exercise of writ jurisdiction, to constitute a parallel body to undertake individual medical determinations - No separate court-appointed expert body considered necessary - Union of India directed to continue ensuring efficient AEFI monitoring and periodic public disclosure of relevant data, consistent with directions in Jacob Puliyel [Paras 35-36, 38].

Separation of Powers - Judicial Review - Policy Formulation - Executive vested with competence and authority to draft policies - Constitutional separation of powers cannot eclipse the judicial duty to safeguard fundamental rights when executive policies, or absence thereof, result in violation of rights - Court's direction to formulate a no-fault compensation framework shall not be construed as an admission of liability or fault on the part of the Union of India or any authority [Paras 33, 38].

Decision: Writ petition and all connected matters disposed of - Union of India directed through Ministry of Health and Family Welfare to frame a no-fault compensation policy for serious adverse events following COVID-19 vaccination - Existing AEFI surveillance mechanisms to continue with periodic public disclosure of data - No separate court-appointed expert body constituted - Liberty reserved to all persons to pursue such other remedies as may be available in law [Para 38].

Criminal Law - Murder - Circumstantial Evidence - Acquittal - Appellant convicted along with co-accused Ladu Lal for the murder of Aruna (wife of Ladu Lal) under Sections 302/34 and 201 IPC and sentenced to life imprisonment - Trial Court conviction affirmed by High Court - On appeal by special leave (filed through legal aid after delay of 2749 days, condoned), Supreme Court finds that all three incriminating circumstances relied upon by prosecution — call detail records, recovery of blood-stained shirt, and recovery of currency notes — fail to withstand scrutiny - Prosecution held to have failed to establish an unbroken chain of circumstances pointing unequivocally to guilt - Held: Conviction unsustainable — appeal allowed — appellant acquitted [Paras 3-55].

Recovery of Currency Notes - Discrepancy in Amount - Doubtful Recovery - Prosecution relied on recovery of Rs. 46,000/- allegedly paid by co-accused Ladu Lal to appellant for committing murder - Investigating Officer (PW.22) admitted in cross-examination that actual notes counted in Court amounted to Rs. 46,145/-, with no mention of the extra Rs. 145/- on the sealed packet - Recovery itself held doubtful - Further, mere recovery of currency notes, without cogent evidence establishing a nexus between the amount and the crime, cannot constitute an incriminating circumstance [Paras 29-33].

Recovery of Blood-Stained Shirt - Chain of Custody - FSL Report - Reliability - Blood-stained shirt recovered at instance of appellant from an iron box tested positive for blood group O, matching deceased - Recovery held inherently improbable as appellant, being a free man between the date of incident and his arrest, would have destroyed or washed the shirt rather than meticulously concealing it - Chain of custody breached: malkhana register (Ex. D-3) showed articles forwarded to FSL on 12th March, 2010, whereas PW.19 and PW.16 deposed they were forwarded only on 18th March, 2010 - Prosecution failed to disclose reasons for return of samples from FSL - FSL Report (Ex. P-49) rendered redundant - Held: Even if blood group on recovered shirt matches deceased, such finding in isolation is insufficient to link accused with the crime, in absence of corroborative evidence [Paras 34-47].

Electronic Evidence - Call Detail Records - Certificate under Section 65-B - Mandatory Requirement - Prosecution relied on call detail records showing continuous contact between appellant and co-accused proximate to time of incident - Prosecution failed to produce certificate under Section 65-B(4) of the Evidence Act [Section 63(4) BSA] - State's contention that nodal officers (PW.23 and PW.24) proved the records by oral evidence, rejected - Held: Certificate under Section 65-B is a condition precedent to admissibility of electronic evidence and cannot be dispensed with by substituting oral evidence - Call detail records held inadmissible [Paras 48-52].

Decision: Appeal allowed - Conviction and sentences of the appellant-Pooranmal under Sections 302/34 and 201 IPC as recorded by the Trial Court and affirmed by the High Court set aside - Appellant acquitted of all charges - Appellant, being in custody, directed to be released forthwith if not wanted in any other case - Pending applications, if any, disposed of [Paras 55-57].

Constitutional Law - Manifest Arbitrariness - Article 14 - Legislative Action - Impugned Act enacted by Bihar Legislature in 2015 providing for complete takeover of Smt. Radhika Sinha Institute and Sachchidanand Sinha Library, established in 1924 by Shri Sachchidanand Sinha as a private trust - Section 3 of Act vested all rights, title and interest of the Institute and Library in the State Government - Section 4(2) dissolved the Deed of Trust, Agreement, Lease of Land and all committees thereunder - High Court upheld validity of Act - On appeal, Held: Manifest arbitrariness is a well-settled ground available to Courts to strike down legislation under Article 14 - A law which proceeds on unreasoned assumptions, adopts excessive means, or operates without adequate determining principles attracts constitutional censure - Complete vesting of property, dissolution of century-old trust arrangements, absence of any finding of necessity or mismanagement, provision for illusory compensation, and lack of guiding principles or safeguards, cumulatively render the Act manifestly arbitrary - Impugned Act struck down as unconstitutional [Paras 23, 36-48, 50].

Manifest Arbitrariness - Doctrine - Evolution - No Prior Inquiry or Mismanagement - Proportionality - Examination of original records summoned by this Court revealed not a single communication from the State Government to the Trust bringing to their notice any allegation of mismanagement, financial irregularity or neglect - No inquiry preceded the enactment - State Librarian, functioning as ex-officio Chief Librarian under day-to-day supervisory responsibility, was never subjected to any inquiry regarding mismanagement - State cannot rely on mismanagement as justification for total legislative takeover when its own appointee bore supervisory responsibility and no action was ever taken against him - Further, State's post-takeover investment of Rs. 72 crores demonstrates that the objective of development could have been achieved through grant-in-aid, conditional funding, statutory audit and supervisory oversight, without resorting to outright acquisition - Legislature chose the most extreme measure when less invasive alternatives were plainly available - This itself constitutes manifest arbitrariness [Paras 39-42, 47-48].

Article 300A - Deprivation of Property - Illusory Compensation - Confiscatory Nature - Section 7 of impugned Act authorised State Government to pay compensation up to a maximum of one rupee, without prescribing any principles, criteria or procedural safeguards - While Article 300A permits deprivation of property by authority of law, such law must be just, fair and reasonable and not arbitrary or confiscatory in effect - Statutory provision reducing compensation to a token amount lacks basic attributes of fairness - Held: Confiscatory nature of vesting under the Act further reinforces conclusion of manifest arbitrariness [Paras 44-45, 51].

Private Trust - Public Trust - High Court's Finding - Issue Not Pleaded - High Court suo motu found the Trust to be a public trust, contrary to the common position taken by both parties before it - Held: Fact that an institution is intended to serve a public purpose or is open to public use does not, by itself, conclusively determine that the trust is a public trust in law - Legal character of a trust depends on manner of dedication, structure, nature of control and management, and rights reserved by Settlor - Neither party pleaded or argued that Trust was a public trust - High Court could not have decided the case on an entirely different basis without affording an opportunity to address that issue - In any event, whether Trust is public or private is not determinative of validity of the impugned Act, as any legislative measure resulting in compulsory acquisition must independently satisfy Article 14 [Paras 18-22].

Legislative History - Re-enactment of Failed Ordinance - Relevant Consideration - Earlier attempt by State to take over the Institute and Library through ordinances in 1983 was set aside by this Court in 1996 upon their lapse - Impugned Act of 2015 sought to achieve substantially the same outcome without any intervening change in circumstances or fresh material justifying acquisition - Held: When a legislature re-enacts substantially the same measure that has previously failed without placing any cogent new material on record, legislative history becomes a relevant consideration reinforcing findings of manifest arbitrariness [Para 46].

Decision: Appeal allowed - Judgment and order dated 29.02.2024 of the Patna High Court set aside - Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 declared unconstitutional and struck down - Trust governing the Institute and Library, together with its rights of management and administration, restored to its pre-existing legal position - State Government not precluded from providing financial assistance, administrative support or regulatory oversight in accordance with law - Pending applications disposed of [Paras 52-55].

Service Law – Regularisation of Employees – Academic Arrangement Appointments – Appellants appointed between 2011–2013 as paramedical staff under 2009 Rules on “academic arrangement basis” – State later initiated regular recruitment process for posts already occupied by appellants – Appellants sought regularisation under the Jammu and Kashmir Civil Services (Special Provisions) Act, 2010 – High Court rejected claim holding that such appointments were excluded under Section 3(b) of the Act – Held: Such exclusion creates arbitrary classification and violates equality principles – Appeals allowed [Paras 3–5, 12].

Constitutional Law – Article 14 – Reasonable Classification – Section 3(b) of the 2010 Act excluded employees appointed on academic arrangement basis from the benefit of regularisation – Court held that such exclusion lacks intelligible differentia and bears no rational nexus with the object of the Act, which is to regularise long-standing irregular appointments – Provision results in invidious discrimination and is unconstitutional [Para 12].

Service Jurisprudence – Nomenclature of Appointment – Constitutional Entitlement – Court held that nomenclature such as “academic arrangement”, “ad hoc”, “contractual” or “consolidated” cannot determine entitlement to regularisation when employees are similarly situated in terms of duties, tenure and conditions of service – Equal treatment cannot be denied solely on the basis of terminology used for appointment [Para 12(I)].

Regularisation – Determinative Factors – Section 5 of the 2010 Act – Eligibility for regularisation depends on fulfilment of statutory conditions prescribed under Section 5(i)–(v) – Once those conditions are satisfied, the nature of initial engagement becomes legally irrelevant for determining entitlement to regularisation [Para 12(III)].

Interpretation of Beneficial Statute – Purposive Interpretation – Second proviso to Section 5 of the 2010 Act held to be a beneficial provision intended to protect employees who subsequently complete the qualifying service period – Any interpretation defeating legislative intent would be constitutionally impermissible [Para 12(IV)].

State as Model Employer – Equality in Public Employment – Court emphasised that the State cannot adopt artificial classifications to deny statutory benefits – Repackaging similar contractual engagements under different nomenclature to deny regularisation violates Articles 14 and 16 of the Constitution [Para 12(V)].

Decision: Appeals allowed – Judgments of the High Court dated 22.02.2023 and 27.12.2024 set aside – Section 3(b) of the Jammu and Kashmir Civil Services (Special Provisions) Act, 2010 declared unconstitutional to the extent it excludes employees appointed on academic arrangement basis – State directed to consider appellants’ cases for regularisation under Section 5 of the Act within four weeks – Benefit extended to all similarly situated employees.

Criminal Law – Dowry Harassment – Quashing of Proceedings – Omnibus Allegations – Section 498A IPC – FIR registered against husband, father-in-law, mother-in-law, and sister-in-law of complainant under Sections 341, 323, 498A, 34 IPC and Sections 3 and 4 of the Dowry Prohibition Act – High Court quashed proceedings against sister-in-law holding allegations against her to be general and omnibus – Declined same relief to appellants (father-in-law and mother-in-law) – Held: Allegations against appellants and sister-in-law were, in all material particulars, identical – FIR assigned no specific overt act, date, place or individual role to the appellants – Lone additional allegation that they "would quarrel" does not constitute a criminal offence and cannot sustain cognizance – Same standard applied to quash proceedings against sister-in-law must apply equally to appellants – No principled basis for distinguishing between them – Criminal proceedings against appellants quashed [Paras 7, 10–11].

Counter-blast to Divorce Petition – Delay in Filing FIR – Marriage solemnised in July 2019 – Husband filed divorce petition in March 2021 – Criminal complaint lodged by complainant only in March 2022, nearly a year after the divorce petition – Delay alone held not sufficient to quash – However, when read conjunctively with the complete absence of any specific allegations attributable to the appellants, the delay lends credence to the contention that the criminal complaint was instituted as a counter-blast to the divorce proceedings – Material improvement in the complainant's version between the FIR and the subsequent complaint before the CJM (addition of Maruti car as dowry, absent in the FIR) further casts doubt on the credibility of the complaint – Continuation of criminal proceedings against appellants cannot be sustained [Para 8].

Parity Among Co-Accused – Consistent Application of Standard – High Court fell into error in applying different standards to persons standing on an identical footing as regards the nature of the allegations – Reasoning that led to quashing of proceedings against sister-in-law ought equally to have led to quashing of proceedings against appellants – Observations confined to maintainability of proceedings against appellants and not an expression of opinion on the merits of the case as a whole – Criminal proceedings against the husband to continue in accordance with law [Paras 9–10].

Decision: Appeal allowed – Impugned order of the Patna High Court dated 8th August 2023 set aside to the extent it declined to quash proceedings against the appellants – All proceedings arising out of L.N.M.U. P.S. Case No. 81 of 2022 quashed insofar as the present appellants are concerned – Criminal proceedings against the husband to continue.

Civil Law – Declaration of Title – Ancestral Land – Ex Parte Decree Not Binding on Non-Party – Appellant-plaintiffs claimed ownership of land bearing Survey No. 2029, Murar, Gwalior as ancestral property held for over fifty years – Trial Court decreed the suit holding title and possession in favour of appellant-plaintiffs and finding that respondent-defendants failed to establish any title – High Court reversed the decree holding that the earlier ex parte decree obtained by the predecessors-in-interest of the plaintiffs against the State of Madhya Pradesh was not binding on the Union of India, which had not been impleaded as a party – Consequently, entries in revenue records made on the strength of such decree were of no legal sanctity – Once this foundational finding was set aside, the entire claim of ownership fell and the burden shifted to the plaintiffs to independently establish title, which they failed to discharge – Appeals dismissed [Paras 9–11.14].

Additional Evidence – Order XLI Rule 27 CPC – Conditions Precedent – Not a Matter of Right – Application by appellant-plaintiffs to produce certified copies of General Land Register at appellate stage under Order XLI Rule 27 CPC not adjudicated by the High Court in its judgment dated 12th August 2009 – Application dismissed by High Court subsequently in review – Held: Order XLI Rule 27 CPC is couched in negative terms; parties to an appeal are not entitled as of right to adduce additional evidence – Permission may be granted only in three contingencies: (i) where evidence was wrongly refused by the trial court; (ii) where despite due diligence the evidence was not within the party's knowledge or could not be produced at trial; (iii) where the appellate court itself requires the evidence to pronounce judgment – Admission of additional evidence is a matter of judicial discretion to be exercised sparingly – Where the appellate court can pronounce a satisfactory judgment on the record already available, the provision has no application – Sub-rule (2) mandates recording of reasons where additional evidence is admitted, and omission to do so is a serious defect, though the provision is directory and not mandatory [Paras 11.2–11.7].

Additional Evidence – Cannot Cure Inherent Defects in Pleadings – Appellant-plaintiffs were fully aware from the outset that the Union of India had not been impleaded in the earlier suit – Their claim was founded on an ex parte decree which was non-est against the respondents – Introduction of entries in the General Land Register at the appellate stage to show the land as private land was impermissible in the absence of foundational pleadings – No plea of adverse possession was raised against the respondent-defendants – A suit for declaration of title requires adduction of best and complete evidence at trial where such evidence could be produced as of right – Attempt to fill gaps in the case at the appellate stage wholly impermissible – Even if the GLR entries had been admitted, the same would have had no impact on the findings of the High Court [Paras 11.10–11.15].

Title of Union of India – Vesting by Gazette Notification – Respondent-defendants traced their title to the decision of the Union of India dated 17th July 1953, under which the suit land vested in the Union with title, ownership and possession – This was fortified by the Gazette Notification dated 4th November 1954 issued by the erstwhile State of Madhya Bharat – Appellant-plaintiffs were characterised as rank trespassers and encroachers – Proximity between the ex parte decree and the subsequent expeditious mutation of revenue entries in favour of the appellant-plaintiffs, combined with the fact that appellant-plaintiff No. 1 was employed in the Commissioner's office, cast a shadow over the bona fides of the proceedings – Unscrupulous conduct disapproved [Paras 11.13–11.16].

Decision: Appeals dismissed – Judgments of the High Court of Madhya Pradesh at Gwalior dated 12th August 2009 in First Appeal No. 80 of 1996 and 15th March 2011 in Review Petition No. 300 of 2009 affirmed – No infirmity found in the impugned judgments.

Civil Procedure – Injunction Suit – Advocate Commissioner – Objections to Commissioner’s Report – Trial Court dismissed objections relying upon purported Supreme Court decisions later alleged to be non-existent – High Court recorded caution that citations were AI-generated/fake but still decided revision on merits and affirmed Trial Court – Supreme Court issues notice and stays Trial Court from proceeding on basis of Advocate Commissioner’s report pending SLP [Paras 2–6].

Administration of Justice – Integrity of Adjudicatory Process – AI-Generated Fake Judgments – Supreme Court takes cognizance of Trial Court deploying AI-generated non-existing/fake/synthetic alleged judgments – Held: Decision based on such non-existent and fake judgments is not mere “error” in decision-making but constitutes “misconduct” and legal consequences shall follow – Court to examine consequences and accountability [Para 7].

Institutional Accountability – Notice to Attorney General, Solicitor General and Bar Council of India – Court issues notice to AG, SG and BCI to assist in examining ramifications of AI-generated fake citations in judicial orders and to evolve safeguards/accountability framework [Para 8].

Amicus Curiae – Appointment – Mr. Shyam Divan, Senior Advocate appointed to assist Court – Liberty to nominate an Advocate-on-Record for assistance [Para 9].

Interim Directions: Notice issued returnable 10/03/2026 – Trial Court directed not to proceed on basis of Advocate Commissioner’s report pending disposal of SLP [Paras 5–6].

Decision: Notice issued – Interim restraint imposed – Wider institutional issue flagged – Amicus appointed.