Criminal Law – Bail – Transfer of Trial – Professional Misconduct by Advocates – Violation of Fundamental Rights – Petitioners, toll plaza employees, arrested in connection with a scuffle, were denied legal representation due to violent boycott by local Bar members – Supreme Court held continued custody unjustified and violative of Article 21 – Directed immediate release on bail and transfer of trial to Delhi to ensure fair trial and legal representation – Condemned hooliganism by advocates and called for disciplinary action [Paras 14–17, 19].

Bail – Unjustified Denial – Article 21 – Petitioners remained in custody for over two months despite allegations arising out of a minor scuffle during discharge of official duties – FIR did not disclose grave circumstances warranting denial of bail – Held: Continued incarceration amounts to violation of personal liberty under Article 21 [Paras 15–16].

Access to Justice – Right to Legal Representation – Boycott by Bar – Resolution passed by local Bar preventing representation of accused and acts of violence against advocate who filed bail application created atmosphere of fear – Resulted in denial of effective legal remedy – Held: Such conduct strikes at the root of fair trial and administration of justice [Paras 8–10].

Transfer of Criminal Proceedings – Ensuring Fair Trial – Article 32 – In light of hostile environment and inability to secure legal representation, proceedings transferred from Barabanki, Uttar Pradesh to Tis Hazari Courts, New Delhi – Held: Transfer necessary to uphold fairness and integrity of judicial process [Para 17].

Professional Ethics – Misconduct by Advocates – Court strongly deprecated acts of violence, arson, and intimidation by members of Bar – Observed that legal profession has been tarnished – Directed Bar Council of India to take appropriate action [Paras 14, 19].

Decision: Writ petition allowed – Petitioners directed to be released on bail forthwith – Criminal proceedings transferred to Tis Hazari Courts, New Delhi – Directions issued to ensure safety of petitioners – Bar Council of India to take appropriate action against erring advocates – Petition disposed of.

Criminal Law – Murder – Conviction under Sections 302 and 498A IPC – Dying Declaration – Eyewitness Testimony – Conviction Upheld – Appellant-husband convicted for pouring kerosene on his wife and setting her on fire, causing 80–90% burn injuries resulting in death after three days – Trial Court acquitted the appellant on the ground that the bathroom was too small for the incident, family witnesses were inconsistent, and the dying declaration was unreliable given the extent of injuries – High Court reversed the acquittal and convicted the appellant – Held: High Court justified in reversing the acquittal; appeal dismissed [Paras 1–25].

Dying Declaration – Reliability – Medical Certification – Fit State of Mind – Deceased recorded statement (Exhibit P-12) at 2:00–2:30 a.m. with medical endorsement certifying fitness to make a statement – Attending doctor (PW-11) examined the deceased and permitted police to record her statement after satisfying himself that she was conscious – Though OPD slip mentioned self-inflicted burns, PW-11 could not identify who recorded that entry – Contrary oral evidence of PW-7 and PW-16 suggesting unconsciousness held unreliable – Held: Burn injuries being superficial though extensive, the deceased was conscious most of the time and capable of making the dying declaration; absence of nurse at the time of recording does not invalidate it [Paras 13–19].

Eyewitness Testimony – Daughter as Eyewitness – PW-3, the sixteen-year-old daughter of the appellant and the deceased, deposed that she witnessed her father bring kerosene, pour it on her mother and set her on fire – Her testimony was consistent and unrebutted – No material on record to suggest why she would falsely depose against her own father – Held: Testimony of PW-3 clinchingly proves the commission of the offence by the appellant [Paras 10–11].

Circumstantial and Medical Evidence – Recovery of Kerosene Tin and Matchbox – Post-Mortem – PW-4 (post-mortem doctor) confirmed death due to septicaemia resulting from 85–90% superficial burn injuries – Recovery of kerosene tin, matchbox and burnt cloth from the scene of incident proved through Recovery Memo (Exhibit P-1) and neighbour PW-6 – Cumulative evidence of eyewitness PW-3, dying declaration, medical evidence of PW-4, PW-10 and PW-11, and physical recovery unequivocally establish the appellant's guilt – Held: Trial Court erred in acquitting on slight discrepancies; conviction by High Court confirmed [Paras 20–24].

Decision: Appeal dismissed – Conviction and sentence under Sections 302 and 498A IPC affirmed – Appellant directed to surrender forthwith to undergo the remaining part of the sentence.

Criminal Law – Section 319 CrPC – Summoning Additional Accused – Standard of Evidence – "Strong and Cogent" Standard – Complainant (PW-1) sought summoning of two additional persons, Rajendra and Mausam, as accused on the basis of alleged conspiracy – Trial Court rejected the application holding that evidence of PW-1, PW-6 and PW-7 was materially inconsistent and did not meet the standard for summoning under Section 319 CrPC – High Court affirmed the rejection – Held: The power under Section 319 CrPC is extraordinary and to be exercised sparingly, but the standard is "strong and cogent evidence" and not proof beyond reasonable doubt – Trial Court misdirected itself by applying a higher-than-necessary standard, conducting a virtual mini trial, and fragmenting the evidence rather than assessing its cumulative weight – Appeals allowed [Paras 6–12].

Evidentiary Threshold – Three Stages of Judicial Scrutiny – Section 319 CrPC – Court explained three distinct levels of evidentiary threshold applicable at different stages of criminal proceedings – Prima facie standard at the charge-framing stage requires only reasonable ground to believe involvement – "Strong and cogent" standard at the Section 319 stage requires reliable and reasonably persuasive evidence without demanding proof beyond reasonable doubt – Proof beyond reasonable doubt is the highest standard applicable only at the conviction stage – Held: At the Section 319 stage, minor inconsistencies in witness accounts do not automatically negate the overall reliability of evidence; the court assesses only whether a reasonable inference of involvement exists [Paras 6–7].

Section 319 CrPC – Scope of Pre-Trial Scrutiny – Limits on Trial Court Discretion – Trial Court erred in relying on absence of jail records and minor discrepancies in hospital admission details and FIR as grounds to reject the Section 319 application – Such issues go to credibility at trial and cannot be examined threadbare at the pre-summoning stage – Trial Court further erred by treating each inconsistency in isolation rather than assessing the cumulative weight of all testimonies – Oral evidence alone, if credible, may suffice; insistence on documentary corroboration at this stage is unwarranted – Held: Court overstepped the intended scope of pre-trial scrutiny; testimony on oath by three witnesses including the complainant is sufficient to meet the strong and cogent evidence standard on the facts of this case [Paras 9–11].

Decision: Appeals allowed – Orders of the Trial Court and High Court set aside – Rajendra and Mausam directed to be produced as additional accused and proceeded against in accordance with law – Copy of order directed to be sent to the Trial Court through the Registrar General, High Court of Allahabad.

Coal Supply – Compliance of Court Orders – Suspended Period – Choice of Reference Date – Union of India and SECL directed to supply coal at current price for the suspended period (09.11.2011 to 31.07.2013) in compliance with orders dated 09.04.2014 and 17.05.2019 – Respondent/PIL given the choice to select either 09.04.2014 or 17.05.2019 as the reference date for operating the current price and prevalent policy in the proposed Fuel Supply Agreement – Supply to be on normal coal linkage basis, not tapering – Fuel Supply Agreement to be completed within four weeks [Paras 13-15].

Compensation – Price Difference – Rejection of Monetary Claim – Respondent claimed compensation of approximately Rs. 106 Crore representing the difference between E-auction prices paid and FSA prices during the suspended period – Held: No order of the High Court or this Court can be construed as a direction to pay monetary compensation towards price difference – The direction is solely to supply coal for the suspended period at the current price in accordance with prevalent policy [Para 14].

Compliance Affidavit – Adequacy – SECL offered to supply coal via fresh MoU at current E-auction rates – Respondent contended that offer was not in conformity with Order dated 09.04.2014 and that coal was not required due to existing FSAs valid till 2027 – Court found both sides interpreting orders to suit their convenience and rejected such approach – Prayers in M.A. Nos. 2111-2112 of 2025 held to be unavailable and rejected [Paras 10-11, 15].

Decision: Miscellaneous Applications disposed of – Union of India and SECL directed to call upon Respondent/PIL to choose the reference date (09.04.2014 or 17.05.2019) for current price and prevalent policy – Fuel Supply Agreement for suspended period to be entered into within four weeks on normal linkage basis – All pending applications including I.A. No. 250465 of 2025 disposed of.

Insurance Law – Fraudulent Claim – Fire in Godown – Arson – Respondent raised a claim of Rs. 28.20 crores attributing fire in its godown on 25.03.2011 to a short circuit — Insurance coverage enhanced shortly before the incident from Rs. 15 crores to Rs. 19 crores and an additional policy for Rs. 17 crores obtained — Truth Labs forensic report established presence of kerosene, a known fire accelerant, at the seat of fire through GC-MS analysis, ruling out accidental cause — Forensic examination of electrical infrastructure found no evidence of short circuit or electrical malfunction — Held: Fire was the result of deliberate human intervention engineered for unlawful gain [Paras 4, 5, 13, 14, 18].

Fraudulent Claim – Fabricated Supplier Invoices – Surveyor's Report – Surveyor's report disclosed material discrepancies between VAT returns submitted by alleged suppliers and those filed with the Commercial Taxes Department — Alleged suppliers found to be non-existent or unrelated to claimed transactions — Invoices produced found to be fabricated — Accounts and records manipulated to inflate the claim — Respondent failed to rebut these findings with credible material — Held: Policy conditions violated — Repudiation warranted [Paras 6, 16, 17].

Fraud – Principle that Fraud Vitiates All Solemn Acts – No Partial Relief – Fraud vitiates all judicial and solemn acts — Once a claim is founded on fraud, the entire edifice of the claim collapses and no relief can be granted — There is no concept of partial or equitable relief in cases tainted by fraud — Quantification of loss cannot override the foundational requirement of a genuine and bona fide claim — Insurance contract cannot be used as an instrument of unjust enrichment — Held: NCDRC fell into error in awarding Rs. 3.33 crores merely because some loss was shown to have occurred [Paras 20, 21, 22, 23].

SIT – Directions for Criminal Investigation – Fraudulent insurance claims involving staged incidents have serious ramifications on the integrity of the insurance system and public confidence — Commissioner of Police, Ahmedabad, directed to constitute a Special Investigation Team (SIT) headed by an officer not below the rank of Deputy Commissioner of Police — SIT to conduct comprehensive investigation into the incident and persons involved — Investigation to be completed within three months — Report to be submitted before this Court in a sealed cover [Paras 25, 26, 27].

Decision: Civil Appeal No. 6100 of 2024 allowed — Impugned order of NCDRC set aside — Claim of respondent repudiated in toto — Appellant-Insurance Company absolved of all liability — Amount deposited before the Registry to be refunded with accrued interest within two weeks — SIT directed to be constituted by Commissioner of Police, Ahmedabad — Matter listed on 21.07.2026 — Civil Appeal No. 10019 of 2024 dismissed.

Motor Vehicles Act – Compensation – Group Insurance Deduction – Whether employer-provided group insurance benefits constitute "pecuniary advantage" deductible from motor accident compensation – Two sets of appeals involving separate accidents where tribunals deducted group insurance amounts from compensation – High Courts in both cases set aside the deductions – Supreme Court affirms High Court orders holding that such benefits arise from independent contractual relationships and cannot be deducted from statutory compensation – Appeals dismissed [Paras 1-18].

Motor Accident Compensation – Deduction of Collateral Benefits – Employer Group Insurance – Principle that a claimant should not gain twice from the same accident examined – Held: Employer-provided group insurance benefits are earned by the deceased through contractual relations entered into during his lifetime and do not accrue to dependants solely by reason of the accident – Such amounts lack the requisite nexus with accidental death to qualify as deductible "pecuniary advantages" under the Motor Vehicles Act – Principle of balancing loss and gain cannot be invoked to diminish statutory entitlement to just compensation [Paras 10-16].

Procedural Objection – Non-joinder of Driver – In Civil Appeal Nos. 5492-5493, appellant raised procedural objection regarding non-joinder of driver as party – Both Tribunal and High Court rightly rejected the objection – Motor Vehicles Act compensation provisions are beneficial in nature and rigours of procedure cannot be allowed to defeat their purpose as trial is summary in nature [Paras 11-12].

Decision: Appeals dismissed – High Court judgments in MFA No. 2593 of 2020 c/w MFA No. 3299 of 2020 and MFA No. 9538 of 2017 affirmed – Appellants directed to deposit awarded compensation within six weeks if not already deposited – No order as to costs.

NDPS Act – Section 50 – Personal Search – Third Option – Non-Compliance – Accused apprehended carrying bag containing 11 kg 50 grams of charas – Trial Court convicted and sentenced accused to 10 years rigorous imprisonment with fine of Rs. 1,00,000 – High Court acquitted accused holding that Investigating Officer offered accused a third option of being searched before a police officer, which is impermissible under Section 50 – Section 50 mandates only two options: search before a Magistrate or a Gazetted Officer – Offering a third option vitiated the entire trial – Held: High Court committed no error – Appeal dismissed [Paras 1-19].

NDPS Act – Section 50 – Mandatory Compliance – Strict Construction – Where both a bag and the person of the accused are searched, Section 50 is attracted – Failure to apprise accused of his right to be searched before a Gazetted Officer or Magistrate renders recovery suspect and conviction unsustainable – Concept of substantial compliance not acceptable – Compliance with Section 50(1) is mandatory and requires strict observance [Paras 16-18].

Prosecution Case – Credibility – Recovery by Chance – PW-8's testimony that only a traditional weighing scale was available at his shop directly contradicted prosecution's claim that an electronic weighing scale was used for weighing the contraband – This additional infirmity rendered the prosecution case doubtful and untrustworthy – Prosecution failed to establish recovery beyond reasonable doubt [Paras 15, 18].

Decision: Appeal dismissed – Acquittal of respondent-accused upheld.

Criminal Law – Murder – Section 302 IPC altered to Section 304 Part II IPC – Remand Ordered – Appellant convicted for murder committed on 28.10.2000 – Sessions court awarded life imprisonment – High Court on appeal, after 21 years, altered conviction to Section 304 Part II IPC with 5 years rigorous imprisonment through amicus curiae appointed in the absence of appellant's counsel – Supreme Court finds that appellant was not informed of appointment of amicus or listing of appeal for final hearing – Held: Impugned order set aside; appeal remanded to High Court for hearing de novo; all points on merits kept open [Paras 13-18].

Fair Trial – Appointment of Amicus Curiae – Duty to Inform Convict – Appellant's counsel did not appear; Division Bench appointed amicus after 20 years of pendency – Amicus urged a ground not raised in the memorandum of appeal and did not press grounds actually raised – High Court issued no notice to appellant of counsel's absence or appointment of amicus – Held: While the High Court was under no obligation to inform the appellant, it would have been a desirable precaution to do so; legal aid must be real and meaningful and not a token gesture; justice would have been better served had a notice been sent to the convict [Paras 13-15].

Convict on Bail – Duty to Pursue Appeal – Appellants Neglecting Proceedings – Appellant was on bail for 20 years without pursuing his appeal and did not keep track of proceedings – Held: Appellant while on bail has himself to blame for not keeping track of his appeal; he cannot urge before the Supreme Court grounds that were never pressed before the High Court; the tendency of convicts to misuse bail concessions must be dealt with firm hands [Para 13].

Guidelines – Procedure When Amicus Appointed for Absent Convict – Henceforth, when an appellate court appoints an amicus for an absent convict, the court should also consider issuing a notice to the convict through the jurisdictional police station to the address in the memorandum of appeal, informing the convict to contact the amicus and provide instructions – If the convict desires his own counsel, the court may hear both; if the convict remains dormant after service or refusal of notice, the High Court may proceed to decide the appeal; if notice cannot be served, pasting on the outer wall of the premises shall be sufficient compliance [Para 23].

Decision: Appeal partly allowed – Impugned order of the High Court dated 02.12.2024 set aside – Appeal revived on the file of the High Court for hearing de novo – Appellant released on bail forthwith on terms and conditions imposed by the trial court – High Court directed to decide the appeal as early as possible; preferably by the same Division Bench; not to be influenced by observations in the impugned order.

Service Law – Recruitment – ICDS Supervisor Posts – Quota Interpretation – Whether Graduate Anganwadi Workers excluded from 29% quota – Amendment provided 11% exclusive ratio for graduates carved out from open category – High Court treated quotas as mutually exclusive – Held: No exclusion of graduates from 29% quota meant for Anganwadi Workers with SSLC and 10 years’ experience – Graduates eligible to compete in both categories subject to rules – High Court interpretation erroneous [Paras 12-14, 23].

Service Law – Higher Qualification – Right to Compete – Possession of higher qualification (graduation) does not disqualify candidate from competing in category requiring lower qualification unless expressly barred – Rules did not prohibit graduates – Denying participation would unjustly penalize acquisition of higher qualification – Held: Graduates cannot be excluded in absence of explicit prohibition [Paras 14, 20].

Recruitment Rules – Ratio vs Quota – Amendment increasing Anganwadi Worker quota from 29% to 40% – 11% earmarked for graduates carved out from open category and not from 29% quota – Held: 29% quota remains intact for all eligible Anganwadi Workers irrespective of graduation – Distinction between “ratio” and “exclusive quota” clarified [Paras 12-13].

Selection Process – Merit-Based Evaluation – No Weightage to Higher Qualification – Selection based on OMR and written test without preference to graduates – Data showed majority selected were non-graduates – Held: No prejudice or unfair advantage to graduates in competing under 29% quota [Paras 15-16].

Judicial Review – Interpretation of Service Rules – Courts cannot introduce restrictions not contemplated by rule-making authority – High Court’s reading creating mutual exclusivity amounted to judicial legislation – Held: Such interference impermissible [Para 22].

Relief – Appointment from Expired Merit List – Due to status quo order of Supreme Court, appointments could not be made before expiry of list – Held: Eligible candidates to be appointed without retrospective benefits or notional seniority [Para 25].

Decision: Appeals allowed – High Court judgment set aside – Tribunal order restored – Eligible candidates from merit list directed to be appointed without retrospective benefits.