Criminal Law - Murder – Conviction Based Solely on Circumstantial Evidence – Standards of Proof – Supreme Court Orders Acquittal – Appeal against concurrent conviction under Section 302 IPC for alleged drowning of minor children by their mother – The Court found that the prosecution’s case rested solely on the testimony of a single witness (PW-2), whose evidence was found to be unreliable and substantially improved from earlier statements – No other credible evidence connected the appellant to the crime and the Rickshaw Puller, allegedly a key witness, was not examined – Held: The chain of circumstances was incomplete, and the conviction was based on conjectures and surmises, not legal proof beyond reasonable doubt – Conviction and sentence set aside, appellant acquitted and ordered to be released forthwith [Paras 1-15].

Circumstantial Evidence – Five Golden Principles – The Court reiterated that, for conviction based on circumstantial evidence, all links in the chain must be fully established and consistent only with the hypothesis of guilt; suspicion, however strong, cannot replace legal proof – Applied the law laid down in Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116 [Paras 6-7].

Reliability of Single Witness – Evidence Must Be Wholly Reliable – Reaffirmed that conviction can be based on the testimony of a single witness only if it is wholly reliable; where witness is neither wholly reliable nor wholly unreliable, corroboration is necessary – Cited Vadivelu Thevar v. State of Madras, AIR 1957 SC 614 [Paras 11-12].

Acquittal – Conviction Set Aside for Lack of Reliable Evidence – Where main prosecution witness was unreliable and other evidence was lacking, conviction could not be sustained – Appellant acquitted of all charges and to be released forthwith unless required in another case [Paras 13-15].

Decision – Appeal Allowed – Judgments of the High Court and Trial Court Quashed and Set Aside – Appellant Acquitted – Pending applications, if any, also disposed of [Paras 15-16].

Civil Writ – PIL - Right to Education – Inclusion of Orphans as Disadvantaged Group under RTE Act – Mandate to States for Compliance – Petitioner-in-person highlighted the exclusion of orphans from the 25% quota for disadvantaged groups under Section 12(1)(c) of the RTE Act – Court recognized orphans as disadvantaged due to lack of parental care and directed States/UTs to identify orphan children admitted under RTE provisions and those excluded – Ordered admission of eligible orphans in neighbourhood schools under the 25% quota and directed filing of compliance affidavits – Held: State, as parens patriae, must ensure orphans are not deprived of their fundamental right to free and compulsory education [Paras 5–10].

Child Welfare – Policy Directives for Orphan Welfare – PIL Seeks Extensive Reliefs – Petitioner sought multiple directions for orphan welfare, including reservation in education and jobs, access to government schemes, removal of legislative inconsistencies, enhanced funding, and systemic reforms – Court took note of extensive prayers and emphasized need for a coordinated national response – Directed States that have not issued notifications for inclusion of orphans under RTE 25% quota to do so or explain reasons via affidavit – Acknowledged progressive steps taken by Delhi, Gujarat, Odisha, Sikkim, and others [Paras 4, 11–14].

Public Interest Litigation – Orphan Rights – Recognition and Protection under Constitutional and Statutory Framework – Petition invoked Article 32 seeking enforcement of fundamental rights of orphan children – Court recognized orphan children as a distinct class needing focused protection – Affirmed State’s obligation to ensure equality and protection from discrimination, and called for uniformity in policy implementation across States – Directed survey and data collection to be completed within four weeks [Paras 2–3, 6–9].

Decision – Directions Issued to Union and State Governments – Compliance Mandated within Four Weeks – Court issued specific directions to conduct surveys of orphan admissions under the RTE Act and reasons for non-admissions – States required to issue necessary notifications or submit explanations – Matter to be listed for further compliance on 09/09/2025 [Paras 10, 12–15].

Criminal Law - Suspension of Sentence – Parameters under Section 389 CrPC – Grant of Bail after Conviction under POCSO Act – Order Set Aside – The appeal by the father of the prosecutrix challenged the High Court's order suspending the sentence of Respondent No.2, convicted under Section 3/4(2) POCSO Act and Section 376(3) IPC – The Supreme Court held that the High Court failed to consider relevant factors required for suspension of sentence, including the nature of offence, gravity, and antecedents of the accused, and instead relied on inadequate reasons like lack of medical signs and non-availability of FSL/DNA reports, which do not outweigh the ocular evidence and legal presumptions under POCSO – Held: The order of the High Court suspending sentence and granting bail is unsustainable and is set aside [Paras 5, 10, 12, 15, 16].

POCSO Conviction – Evidentiary Value of Victim's Testimony – Corroborative Forensic Evidence Not Mandatory – The Trial Court's reliance on the testimony of the minor prosecutrix, supported by documentary evidence regarding age, and presumption under Sections 29 and 30 of the POCSO Act was upheld – Non-availability of FSL/DNA report does not vitiate conviction where ocular and documentary evidence suffice – High Court's approach ignoring this principle was found to be erroneous [Paras 6-9, 16].

Distinction between Setting Aside Bail and Cancellation of Bail – Justifiability of Bail Order – The Court clarified the distinction between setting aside bail due to improper exercise of judicial discretion, and cancellation of bail for supervening misconduct – In the present case, the order was set aside for lack of soundness in the bail grant and not for breach of conditions [Paras 13, 14].

Decision – Appeal Allowed – High Court's Order Suspending Sentence Set Aside – Respondent No.2 Directed to Surrender – Supreme Court allowed the appeal, set aside the High Court's order suspending sentence, and directed the respondent to surrender before the Special Judge (POCSO) Karauli, Rajasthan, by 30th August 2025, failing which the State shall take the respondent into custody [Para 19].

Motor Accident Claim – Enhancement of Compensation – Contributory Negligence, Future Prospects, and Functional Disability – Supreme Court Enhances Award – Appeal by injured claimant seeking enhancement of compensation for permanent disability sustained in a motor vehicle accident – The Court affirmed the finding of 20% contributory negligence, but found error in the omission of future prospects and in adopting a lower percentage of disability – Held: Appellant entitled to 40% addition for future prospects (self-employed), and functional disability fixed at 41.77% based on unchallenged medical evidence – Total compensation recalculated and enhanced to ₹16,60,891/- with interest at 6% per annum from the date of claim petition till payment, after deduction for contributory negligence; insurer directed to deposit the enhanced amount within six weeks [Paras 4-11].

Future Prospects for Self-Employed – Law Settled – Supreme Court reiterates that self-employed claimants are entitled to future prospects as laid down in Santosh Devi and Pranay Sethi – 40% added to income for calculation of loss of future earning capacity [Para 7].

Assessment of Functional Disability – Medical Evidence Paramount – The unchallenged evidence of the neuropsychologist (PW3) assessing neuro-behavioural and cognitive disability at 41.77% accepted as functional disability, rejecting arbitrary reduction by Tribunal and High Court – Compensation for loss of future earning capacity recalculated accordingly [Para 8].

Computation and Apportionment – Calculation of compensation detailed under all heads, including medical expenses, pain and suffering, attendant and conveyance, loss of income during treatment, and loss of amenities – Contributory negligence deduction applied – Directions for prompt deposit and disbursal to claimant [Paras 9-11].

Decision – Appeal Allowed in Part – Compensation enhanced to ₹16,60,891/- with interest; directions issued for compliance – All pending applications disposed of [Paras 11-13].

Motor Accident Compensation – Determination of Income – Inclusion of Allowances – The Tribunal and High Court erred by excluding allowances from computation of deceased’s monthly income, considering only basic pay – Supreme Court held that salary slip (Ex. P6) evidences income of Rs. 6,500/- per month including allowances, and there was no contrary evidence that allowances were not regularly received or for family benefit – Held: Allowances should be included for computation of income, and Rs. 6,500/- per month adopted as monthly income [Paras 15-18].

Future Prospects and Multiplier – Application of Sarla Verma and Pranay Sethi – The Court applied 1/3rd deduction for personal expenses, added 50% towards future prospects (as deceased was 35 years old), and applied a multiplier of 16 as per the settled law – Loss of dependency thus calculated at Rs. 12,48,000/- (6,500 x 12 x 16) [Paras 19].

Conventional Heads – Award under Pranay Sethi and Magma – The Court awarded Rs. 18,150/- each for loss of estate and funeral expenses, Rs. 48,400/- to wife as spousal consortium, and Rs. 48,400/- each to the two minor children as parental consortium, strictly in line with Supreme Court precedents [Para 20].

Interest and Apportionment – Delay in Appeal – Respondents jointly and severally liable to pay total compensation of Rs. 14,29,500/- with 7% interest per annum from the date of filing till deposit, excluding delay period – Compensation apportioned 50:25:25 among the claimants with appropriate safeguards for minors – Directions given for release and deposit of awarded amounts [Para 22].

Decision – Appeal Allowed in Part – Supreme Court enhanced compensation to Rs. 14,29,500/- with applicable interest and apportioned as directed – Pending applications, if any, disposed of [Para 21-22].

Criminal Matrimonial Law  – Quashing of FIR under Section 498-A IPC – Matrimonial Dispute – Irretrievable Breakdown of Marriage – Marriage Dissolved under Article 142 – Parties married on 25.07.2015 – After brief conjugal life, appellant-husband alleged harassment and left the matrimonial home at Mumbai for Faridabad to care for aged parents and autistic child from previous marriage – Respondent-wife filed FIR alleging cruelty and abandonment under Section 498-A IPC one year after separation – Both parties engaged in protracted litigation – Settlement agreement reached during divorce mediation but respondent-wife subsequently resiled demanding enhanced alimony – Allegations found vague, commonplace, and without substantial specifics – FIR and related criminal proceedings quashed invoking power under Article 142, dissolving marriage due to irretrievable breakdown, ensuring closure of all matrimonial litigation – Held: No prima facie case under Section 498-A established, quashing justified, marriage irretrievably broken down; dissolved under Article 142 subject to settlement terms and conditions [Paras 1-23].

Section 498-A IPC – Allegations Vague and Commonplace – Quashing Justified – Allegations by respondent-wife against appellant under Section 498-A IPC held to be vague, general, commonplace marital disputes without specific credible instances – FIR filed belatedly, one year after separation – Held: Allegations did not constitute prima facie offence; FIR quashed to prevent misuse of judicial process [Paras 8-14].

Divorce on Mutual Consent – Respondent-Wife Resiled from Agreement – Effect on Criminal Proceedings – Wife initially agreed to mutual divorce and property settlement, resiled later demanding enhanced permanent alimony – Appellant sought quashing of FIR based on withdrawal from consent terms – Held: Wife's statutory right to withdraw consent for second motion divorce affirmed; however, this alone not sufficient for refusal to quash FIR when no substantive offence under Section 498-A made out [Paras 4,12-13].

Permanent Alimony – Irretrievable Breakdown of Marriage – Just and Equitable Compensation – Respondent demanded Rs. 12 crore alimony in addition to encumbrance-free apartment – Respondent highly educated, capable, previously employed; appellant currently unemployed with substantial responsibility of autistic child from first marriage – Appellant agreed to gift valuable Mumbai apartment with parking areas and settle all pending dues as final settlement – Held: Gift of apartment sufficient compensation, further claim of alimony unjustified considering financial status of parties [Paras 16-20].

Article 142 – Dissolution of Marriage – Irretrievable Breakdown – Closure of Multiple Proceedings – Prolonged litigation, acrimonious relationship, and failed reconciliation attempts established irretrievable breakdown of marriage – Supreme Court invoking powers under Article 142 dissolved marriage to achieve complete justice and terminate all pending and future litigations between the parties – Held: Marriage dissolved, criminal and civil litigations closed, no further proceedings permitted [Paras 16-23].

Decision – Criminal Appeal Allowed – FIR and Criminal Proceedings Quashed – Marriage Dissolved under Article 142 – Criminal proceedings against appellant under Section 498-A IPC quashed – Marriage dissolved due to irretrievable breakdown under Article 142 of Constitution subject to compliance with terms agreed upon in settlement, including gifting of apartment and payment of maintenance charges by appellant – All pending matrimonial litigation between parties terminated – Held: Appeal allowed, proceedings closed, marriage dissolved under Article 142 [Paras 21-23].

Civil Law - Maintainability of Suit under Section 92 CPC – Nature of Suit Must be Representative – Leave Upheld – The appellant-society challenged the Delhi High Court’s order granting leave under Section 92 CPC to respondents for instituting a representative suit – The plaint included allegations of gross financial impropriety, misconduct by trustees, and misadministration, as well as private grievances such as wrongful removal of respondent no. 1 from the post of President – Held: Suit was not solely based on private grievances – The presence of reliefs under clauses (a), (d), and (g) of Section 92(1) justified grant of leave – Leave granted by the High Court was proper and appeal dismissed [Paras 1, 133–138].

Registered Society – When Can Be Subject to Section 92 CPC – Trust or Constructive Trust Must Exist – Court considered whether a society registered under the Societies Registration Act, 1860 could fall within Section 92 CPC – Held: Though a society is not a juristic person and cannot hold property in its own name, the governing body may hold property under a fiduciary obligation – If misappropriation or misuse of property by governing members is established, a constructive trust arises – Suit under Section 92 is maintainable in such circumstances [Paras 120–125, 137(iv–xv)].

Constructive Trust – Misuse of Fiduciary Powers – Court Must Examine Allegations – Plaintiffs alleged siphoning of funds and abuse of fiduciary position by board members – Held: If established, such conduct would give rise to constructive trust – Constructive trustees can be proceeded against under Section 92 CPC – The trial court must determine whether the constructive trust exists and delineate the properties subjected to it [Paras 134–135, 138].

Private Grievances in Section 92 Suit – Not Bar to Maintainability if Suit Predominantly Public – Suit included personal claims of wrongful removal and reinstatement – Held: Inclusion of personal grievances does not invalidate the entire suit – Only those reliefs that fall within Section 92 CPC can be considered – Others must be agitated in separate proceedings – Courts must focus on predominant purpose and object of the suit [Paras 133–136, 137(xviii–xx)].

Reliefs Under Clauses (a), (d), and (g) – Other Reliefs to be Treated as Further Reliefs – Prayers in the plaint included reliefs for removal of trustees, account-taking, and settling of scheme – These fall within clauses (a), (d), and (g) of Section 92(1) – Held: Remaining private reliefs may be treated as further reliefs and do not affect maintainability – If the suit had contained only personal claims, it would have failed [Paras 135–136].

Purpose and Character of Suit – Representative Nature Essential – Capacity of Plaintiffs Crucial – Court reiterated that the true nature of a Section 92 suit depends on the purpose and the capacity in which it is instituted – Held: The court must go beyond the language of the reliefs and examine the intent and dominant object – Suit filed by persons with a substantial interest in the trust and in a representative capacity is maintainable [Paras 129–132, 136, 137(xvii–xix)].

Decision – Appeal Dismissed – Suit directed to proceed before the High Court – High Court to examine whether constructive trust is established and whether reliefs under clauses (a), (d), and (g) may be granted – Other reliefs must be dealt with as per law [Paras 138–140].

Civil Law - Specific Performance – Forged Settlement Agreement – Decree Set Aside – Alleged Fraudulent Compromise – The petitioner obtained a favorable decree from the Supreme Court in terms of an alleged settlement agreement dated 24.10.2024, resulting in the setting aside of concurrent findings by three lower courts dismissing a suit for specific performance – Respondent filed a Miscellaneous Application alleging he never entered into the said settlement or engaged any counsel in the Supreme Court – Held: Prima facie case of fraud established, Supreme Court recalled its earlier order dated 13.12.2024 and restored the appeal – Bar Council of India directed to conduct inquiry into the involvement of advocates and authenticity of representation [Paras 3-4, 6-7].

Fraud on Court – Unauthorized Representation – Caveat Abuse – Order Recalled – Respondent alleged unauthorized filing of caveat and fraudulent appearance of counsels – Court noted discrepancies in appearance records and denials by advocates – Ordered detailed inquiry into the conduct and role of the advocates, and reserved further directions, including criminal proceedings – Restored SLP to file for fresh hearing [Paras 4-6].

Professional Misconduct – Bar Council of India Inquiry – Supreme Court expressed serious concern over possible misconduct and unethical practices in representing parties without authority – Directed Bar Council to complete inquiry and submit report by October 2025 – Case listed for further proceedings in November 2025 [Para 7].

Final Decision – Order dated 13.12.2024 recalled – Civil Appeal No. 14414/2024 restored to file – Bar Council of India directed to submit report – Case to be listed for further hearing in November 2025 [Para 8].

Criminal Law - Section 21(c), 29, and 52A of the NDPS Act – Clubbing of Contraband Quantity – No Presumption of Conspiracy – Conviction Set Aside – The appellant and co-accused were apprehended together and found with 125g and 130g of heroin respectively – Held: Mere physical proximity does not justify presumption of common intent or conspiracy – No evidence led to establish prior knowledge or conspiracy between accused – Therefore, quantity cannot be clubbed to reach commercial threshold under Section 21(c) [Paras 22–25].

Procedural Lapses – Section 52A NDPS Act – Violation Undermines Prosecution – Non-Compliance Fatal – Samples were not drawn in duplicate nor in presence of Magistrate – Inventory not certified – Absence of appellant’s signature on sealed packets – Failure to produce test memo and weighment chart – Held: Cumulative procedural lapses render seizure and sampling unreliable – Violation of Section 52A and Standing Order 1/1989 vitiates trial [Paras 26–30].

Evidentiary Value – Forensic Report Not Admissible – Flawed Sampling Process – Since FSL report was based on improperly collected samples and no procedural safeguards were followed, the report was deemed inadmissible – Held: Without legally admissible evidence, conviction cannot be sustained [Paras 31–32].

Delay in Appeal – Appeal Rejected by High Court – Supreme Court Intervenes – The High Court rejected the appeal solely on the ground of 1183-day delay – Held: Incarcerated appellant with financial constraints ought not be penalized – Delay should have been condoned – Supreme Court decided to hear appeal on merits instead of remand [Paras 13–20].

Decision – Conviction and Sentence Quashed – Acquittal Ordered – Due to failure in proving conspiracy, clubbing of quantity, and multiple procedural lapses, conviction under Sections 21(c) and 29 of NDPS Act held unsustainable – Appellant acquitted and ordered to be released forthwith [Paras 33–34].