Criminal Law – Abetment of Suicide – Lack of Evidence – Allegations against appellant included refusal to marry the deceased leading to his suicide – FIR claimed appellant and her family abused deceased with casteist remarks and forced poison – No material evidence of relationship or abetment by appellant – Appellant had previously complained to police about deceased stalking her – Supreme Court finds no credible evidence to proceed against appellant under Section 306 IPC or Section 3(2)(v) of the SC/ST Act – Proceedings quashed [Paras 1-12].

Quashing of Proceedings – Scope of Section 482 CrPC – High Court dismissed application for quashing due to factual disputes – Supreme Court emphasizes need for positive act instigating suicide to establish abetment under Section 306 IPC – Mere harassment without direct act insufficient for conviction – Application under Section 482 CrPC appropriate for lack of prima facie evidence [Paras 6-11].

Decision – Appeal allowed – High Court's order set aside – Proceedings under Section 306 IPC and Section 3(2)(v) of SC/ST Act quashed – Application under Section 482 CrPC allowed [Paras 12].

Income Tax – Advance Tax and Interest – Assessee's liability for interest under Section 234B – Assessee, a non-resident company, contended no liability due to the payer's default in deducting tax – Supreme Court held that prior to financial year 2012-13, assessee could reduce advance tax liability by the amount deductible at source – Post-2012 amendment introduced proviso to Section 209(1)(d) barring such reduction if tax was not deducted – Amendment applicable from financial year 2012-13 onward – Appeals for periods before this amendment not liable for interest under Section 234B – Revenue's remedy against defaulting payer remains unaffected [Paras 1-25].

Interpretation of Tax Provisions – Sections 209(1)(d) and 234B – Court observed Section 209 relevant for computing advance tax – Prior to 2012 amendment, advance tax calculation allowed reduction for tax deductible even if not actually deducted – Post-2012 amendment clarified non-reduction if tax was not deducted – Section 234B construed in conjunction with Section 209 – Interest under Section 234B not applicable for periods before amendment where tax was deductible at source but not deducted [Paras 14-20].

Decision – Appeals dismissed for periods prior to 2012 amendment – Appeals for periods post-amendment upheld – High Court and ITAT judgments favoring assessee for pre-2012 periods affirmed – Costs in favor of assessee [Para 22].

Service Law – False Declaration and Suppression of Facts – Employee failed to disclose criminal conviction during application and document verification – Terminated after discovery – High Court quashed termination relying on Avtar Singh v. Union of India (2016) 8 SCC 471 and benefit of Section 12 of Probation of Offenders Act – Supreme Court emphasizes employer's right to assess suitability and trustworthiness – Employee's suppression of material facts and false declaration justify termination – High Court's reliance on subsequent benefit under Section 12 not applicable as material facts were suppressed at relevant time [Paras 1-13].

Judicial Review – Employment and Character Verification – Importance of truthful disclosure in employment applications – False declarations undermine trust and suitability for employment – Employer has discretion to terminate services for such dishonesty – Subsequent acquittal or benefit under law does not negate initial suppression and dishonesty – Supreme Court reiterates principles from precedents emphasizing non-disclosure and false declarations as grounds for termination [Paras 6-11].

Decision – Appeals allowed – High Court's orders set aside – Termination of respondent upheld – No order as to costs [Paras 13-14].

Judicial Review – Tender Process – Scope and Limitations – Judicial review of contractual matters is limited to checking arbitrariness, irrationality, unreasonableness, bias, and mala fides – Courts should not substitute their decision for that of the tendering authority – The process must be lawful, not necessarily sound – Transparency and fair play are essential, but the Government must have freedom in contractual matters to ensure commercial prudence [Paras 2-7].

Tender Specifications – Competition and Transparency – Challenge to tender conditions alleged to favor certain bidders – Petitioners claimed conditions were designed to limit competition – Supreme Court emphasizes that conditions for tenders are within the domain of the executive – Courts should refrain from interfering unless there is clear evidence of arbitrariness or mala fides – The tendering authority's expertise in commercial decisions must be respected [Paras 27-29].

Public Interest and Costs – Judicial Intervention – Tender jurisdiction must balance transparency and efficiency in public procurement – Excessive judicial interference can hinder commercial activities – Costs should follow the event to deter frivolous litigation – Supreme Court awarded costs to the successful appellant and the State for defending against the challenge, emphasizing the need for judicial restraint in commercial matters [Paras 50-60].

Decision – Appeals allowed – High Court's order set aside – Costs awarded to appellant and the State [Paras 50-60].

Civil Procedure – Rejection of Plaint – Limitation – Plaintiffs filed suit in 1987 challenging tenancy order and sale certificate from 1963 and 1954 respectively – Claimed lack of notice and fraud in proceedings – Supreme Court emphasizes limitation as a mixed question of fact and law, asserting that claims of knowledge at a particular time must be accepted at Order 7 Rule 11 stage – Courts erred in rejecting plaint without considering evidence on plaintiffs' lack of notice [Paras 10-14].

Jurisdiction – Section 85 and 85A of Maharashtra Tenancy and Agricultural Lands Act – Bar of Civil Court jurisdiction not absolute – Section 85A mandates Civil Court to refer issues to competent authority under Act before deciding suit – Plaintiffs alleged fraud and collusion in tenancy proceedings – Civil Court required to examine these claims and possible exemption under Section 88-B before rejecting plaint [Paras 20-25].

Decision – Appeal allowed – Judgments of trial court and High Court set aside – Suit restored to file – No order as to costs [Para 26].

Service Law – Judicial Appointments – Criminal Antecedents – Candidate involved in multiple criminal cases acquitted, but not honorably – High Court allowed writ petition for appointment to Civil Judge post – Supreme Court emphasized the importance of judicial officers’ integrity and public confidence – Found committee's decision to deny appointment based on antecedents justified – High Court's interference unwarranted [Paras 2-30].

Public Employment – Judicial Discretion – Employer’s Right to Assess – Employer's discretion to assess candidate’s suitability considering antecedents – Acquittal not always equivalent to clean slate – Importance of maintaining high standards for judicial appointments highlighted – Supreme Court found no fault in committee's process and decision [Paras 22-30].

Decision – Appeal allowed – High Court’s order set aside – Respondent's appointment as Civil Judge (Junior Division) not endorsed – No order as to costs [Paras 31-33].

Criminal Law – Murder vs. Culpable Homicide – Distinction – Incident where the appellant was accused of running over a police officer after a truck inspection – Appellant initially convicted under Section 302 IPC – Supreme Court reevaluated circumstances, noting absence of premeditation and direct animus – Conversion of conviction to Section 304 Part I IPC justified, considering the act was in the heat of passion without clear intention to kill [Paras 9-16].

Criminal Intent – Analysis – Accused's reaction to police officer boarding the truck seen as instinctive and disproportionate rather than intentional murder – Evidence did not support deliberate action to kill – Supreme Court highlighted need for nuanced understanding of intent in such cases [Paras 11-15].

Decision – Conviction altered from Section 302 IPC to Section 304 Part I IPC – Sentence modified to 10 years of rigorous imprisonment instead of life imprisonment – Fine maintained as directed by lower courts [Para 16].

Civil Procedure – Disclosure and Discovery – Commercial Suits – Appellant sought to place additional documents on record under Order VII Rule 14(3) CPC – Commercial Court and High Court dismissed the application – Supreme Court analyzed Order XI Rule 1 applicable to commercial suits, emphasizing the need to disclose all documents in possession at the time of filing – Additional documents discovered later can be filed within 30 days with the court's leave – Rigour of establishing reasonable cause for non-disclosure at the time of filing applies only to documents in possession [Paras 7-8].

Document Production – Commercial Courts Act – Applicability – Application under Order VII Rule 14(3) CPC misapplied as Order XI Rule 1 governs commercial suits – Plaintiff allowed to file additional documents discovered after the plaint within 30 days – Documents in possession at filing require reasonable cause for later submission – Supreme Court granted leave to file invoices found later but rejected inclusion of other voluminous documents not filed initially due to plaintiff's negligence [Paras 8.1-8.5].

Decision – Appeal partly allowed – High Court's order set aside to permit filing of additional invoices – Application to file other documents dismissed due to lack of reasonable cause for non-disclosure at initial filing – No costs [Paras 9-10].

Arbitration Law – Interim Measures – Appeal against High Court’s order directing Commercial Court to adjudicate applications under Section 9 of the Arbitration Act post-constitution of an Arbitral Tribunal – Court’s power to entertain applications under Section 9(1) once the Tribunal is constituted – Supreme Court held Section 9(3) restricts court's role unless the remedy under Section 17 is inefficacious – Emphasized the process of consideration under Section 9(3) ends once the application is entertained and under active consideration by the court [Paras 1-12, 93-101]​​.

Definition of "Entertain" – Court interpreted "entertain" to mean considering an application on merits – High Court's direction to Commercial Court to proceed with adjudication upheld – Court emphasized that legislative intent behind Section 9(3) is to minimize judicial intervention once an Arbitral Tribunal is constituted [Paras 94-108]​​.

Decision – Appeal partly allowed – Clarification provided that efficacy of relief under Section 17 need not be considered by the Commercial Court as the application under Section 9 was already entertained and considered – Commercial Court directed to complete adjudication without reevaluating the remedy under Section 17 [Paras 102-108]​​.