Criminal Law – PMLA – Quashing at Pre-Trial Stage – Alternate Remedy – ECIR did not name appellants and CBI dropped them in supplementary report – ED complaint rests on alleged withdrawal of attached sums (post-PAO) linked to an identified quantum ₹33,80,87,617/- claimed as proceeds of crime – Held: With statutory appeals under Section 26 PMLA pending and PMLA being a self-contained mechanism, interference to quash cognizance is unwarranted – Issues whether the attached amount is “proceeds of crime” and effect of withdrawals are for Appellate Tribunal – Appeals disposed of; liberty to pursue statutory remedies; no costs [Paras 33-41].

PMLA – Provisional Attachment & Confirmations – Statutory Scheme – Court reiterates that Section 5 (provisional attachment), Section 8 (confirmation), and Section 26 (appeal) comprise a comprehensive adjudicatory path – Constitutional/appellate jurisdiction ordinarily not exercised where efficacious remedy exists and is actively pursued [Paras 34-35].

PMLA – Proceeds of Crime – Scope and Identification – Core question is confined to whether the specified sum ₹33.80 crore (unpaid consideration for iron ore supplied by AMC) is “proceeds of crime” and whether its post-PAO withdrawals constitute an offence under Section 3 – Apprehension that entire banking operations are tainted is misplaced where payments were through regular channels and in the books; determination falls within Tribunal’s domain [Paras 37-38].

Criminal Procedure – Cognizance & Summons – Where allegations are confined to recovery of quantified amount and do not presently fasten wider criminal liability, apprehension of arbitrary prosecution is misplaced – No ground made out to quash cognizance or interdict proceedings at this stage [Para 39].

Practice & Procedure – Writ/Appeal vs. Statutory Forums – Court declines to prejudge issues pending before Appellate Tribunal; proceedings may continue uninfluenced by observations in the judgment; appeals disposed of with liberty; no order as to costs [Paras 40-42].

Decision: Appeals disposed – No interference with ED proceedings/cognizance at this stage – Appellants at liberty to pursue PMLA appeals – No costs – Pending applications disposed [Paras 40-43].

Administrative Law – Judicial Overreach – High Court’s Power in Writ Jurisdiction – Directions issued by the High Court for refixation of licence fee and initiation of vigilance enquiry in a writ petition filed by the appellants against enhancement of licence fee held to be beyond the scope of the lis – High Court erred in travelling beyond pleadings and rendering appellants worse off in their own writ petition – Such directions passed without notice to affected parties violate principles of natural justice [Paras 20–23, 25–26, 29–30].

Writ Jurisdiction – Principles of Natural Justice – Party cannot be taken by surprise by directions not forming part of the pleadings – If Court intends to consider additional issues, parties must be given prior opportunity – Reaffirmed in V.K. Majotra v. Union of India (2003) 8 SCC 40 and State of U.P. v. Mohammad Naim (1964) 2 SCR 363 [Paras 23–25].

Litigant’s Rights – No Prejudice by Invoking Court’s Jurisdiction – A litigant seeking redressal cannot be placed in a worse-off position by approaching court – Courts must avoid orders that aggravate the grievance of a party invoking jurisdiction – Ashok Kumar Nigam v. State of U.P., (2016) 12 SCC 797 and Pradeep Kumar v. Union of India, (2005) 12 SCC 219, followed [Paras 26–27].

Judicial Discipline – Restraint in Observations – Courts must avoid sweeping directions or remarks that may impinge on reputation or rights without foundation in pleadings or evidence – Judicial pronouncements must be guided by justice, fairness, and moderation [Paras 24–25, 28–29].

Decision – Appeals partly allowed – High Court’s directions ordering fixation of licence fee under T. Krishnakumar and vigilance enquiry quashed – High Court judgment otherwise upheld – Appellants to pay arrears of licence fee as undertaken [Paras 30–32].

Criminal Law – Murder Conviction – Acquittal – Appellants convicted under Sections 302, 201 and 120-B IPC for the murder of a 10-year-old boy based on circumstantial evidence – Trial Court relied on testimonies of PW-2 (claimed to overhear a conspiracy), PW-3 and PW-4 (last seen witnesses) – High Court affirmed the conviction holding the chain of circumstances complete – Supreme Court held that material omissions in FIR, absence of forensic link, lack of proper identification, and unreliable witness testimonies broke the chain of circumstances – Circumstantial evidence found insufficient to prove guilt beyond reasonable doubt – Held: Prosecution failed to establish an unbroken chain of circumstances pointing exclusively to the guilt of the accused [Paras 1–6, 26–56]

First Information Report – Omission of Accused Names – Appellants Nazim and Aftab not named in the FIR lodged by PW-1 despite being allegedly known to him – FIR named six other persons with whom PW-1 had enmity – No explanation for later implication of Appellants – Supreme Court held such omission a material contradiction, weakening the prosecution case – Reliance placed on Ram Kumar Pandey v. State of M.P. regarding relevance of omissions under Section 11 of Evidence Act – Names of appellants introduced at a later stage raised suspicion of false implication [Paras 2, 12, 29–30]

Witness Testimony – PW-2's Testimony on Conspiracy – PW-2, scribe of FIR, claimed he overheard a conspiracy at a marriage feast – Did not disclose it in FIR or to PW-1 – Suppressed information during search and recovery – Marriage feast date contradicted by defence witnesses – Supreme Court held that conspiracy claim was highly improbable, belated, and appeared to be an afterthought – Testimony lacked credibility and could not be relied upon to prove motive or conspiracy [Paras 13, 31–33]

Identification of Accused – Failure to Conduct Test Identification Parade (TIP) – PW-3 and PW-4 identified the appellants for the first time in court – PW-3 admitted he did not previously know the accused – No TIP conducted – Supreme Court held dock identification without TIP inadmissible where witnesses were unfamiliar – Reference made to P. Sasikumar v. State – Such identification deemed unreliable [Paras 14, 34–43]

Last Seen Theory – Weakness of Circumstantial Link – PW-3 allegedly saw deceased with accused at 11 a.m., PW-4 saw accused in the evening – Body recovered next morning – Time gap too wide to exclude third-party intervention – No continuity in presence or proximity to time of death – Supreme Court held last seen evidence too weak to sustain conviction without corroboration – Cited State of U.P. v. Satish, Hatti Singh v. State of Haryana, Krishan Kumar v. State of Haryana – Last seen theory applied incorrectly in absence of proximate temporal link [Paras 14–15, 44–47]

Scientific Evidence – Inconclusive DNA and Forensic Reports – Axe and rope recovered from scene but not examined initially – Sent to FSL only during High Court appeal – DNA report inconclusive; no match to accused – Axe never properly tested – Supreme Court held such neutral or exculpatory evidence could not be brushed aside – Conviction cannot rest solely on unreliable ocular testimony when scientific evidence does not support prosecution case – Cited Padman Bibhar v. State of Odisha [Paras 17, 49–53]

Motive – Absence of Proven Motive – Prosecution alleged motive of revenge for insult to sister of co-accused – No evidence led to establish this – No direct grudge against child – Supreme Court held vague or speculative motive insufficient in circumstantial evidence case – Cited Kali Ram v. State of Himachal Pradesh – Benefit of doubt must be given [Paras 18, 54]

Juvenility – Claim Based on School Records and Medical Board – Juvenile Justice Board rejected based on electoral roll – Supreme Court noted JJ Rules require preference to school records – Did not adjudicate issue in view of acquittal but noted improper rejection as indicative of lack of full reappreciation by courts below [Paras 19, 55]

Decision: Appeal allowed – Conviction and sentence under Sections 302, 201 and 120-B IPC set aside – Appellants Nazim, Aftab and Arman Ali acquitted – Bail bonds and sureties discharged – Held: Prosecution failed to prove its case beyond reasonable doubt – Circumstantial evidence incomplete and inconsistent with guilt – [Paras 56–59]

Public Procurement – Tender Eligibility – State-specific Past Performance – Condition requiring bidders to have supplied sports goods worth ₹6 crores cumulatively to Chhattisgarh State agencies in the last three years held arbitrary and discriminatory – Creates an artificial barrier and closes the market to otherwise competent bidders from outside the State – Violates Articles 14 and 19(1)(g); lacks rational nexus with the object of securing quality sports kits at best price – High Court orders and tender notices quashed – Liberty to re-tender [Paras 13-14, 17-23].

Judicial Review of Tender Conditions – Courts will not rewrite eligibility terms unless action is arbitrary, discriminatory or mala fide – Applied to strike down the impugned condition for want of rational nexus to the procurement objective and for disproportionate impact on competition [Paras 15-17, 22].

Level Playing Field – Embedded in Article 19(1)(g) – State cannot skew the market by erecting State-specific experience filters – Past performance may be insisted upon for similar contracts irrespective of location; confining eligibility within one State is irrational and disproportionate [Paras 16, 18-20].

Justification Rejected – Maoist-affected-State rationale untenable – Procurement is for sports kits (not security sensitive) – Only some districts are affected – Non-local bidders can deploy local logistics partners; exclusion of outsiders is unjustified [Para 21].

Corrigendum & Scope – With deletion of other impugned conditions during pendency, the contest narrowed to Condition No. 4 (past performance in Chhattisgarh) – High Court upheld it by analogy with Association of Registration Plates; Supreme Court distinguishes and reverses [Paras 8-9, 5, 22].

Relief – Impugned High Court orders dated 11.08.2025 and 12.08.2025 and tender notices dated 21.07.2025 set aside – Respondents at liberty to issue fresh NITs [Para 23].

Motor Accident – Insurer’s Liability – Pay and Recover – Tribunal and High Court exonerated insurer from liability due to absence of valid driving licence with the driver – Supreme Court invoked “pay and recover” principle on basis of consistent jurisprudence – Relied on Rama Bai v. Amit Minerals (2025 SCC OnLine SC 2067), Shamanna and Parminder Singh where insurance companies were directed to pay compensation and recover from vehicle owners – Held: Even where driver lacks valid licence, insurer must first compensate third-party victims and may then recover the amount from the insured-owner [Paras 7–10].

Criminal Law – Murder – Conspiracy – Acquittal – Accused convicted by Trial Court for murder based on motive, last seen theory, and recovery of incriminating material – High Court reversed conviction citing lack of reliable evidence, failure to prove motive, and inadmissibility of call detail records – Supreme Court upheld acquittal – Held: No reliable, cogent or admissible evidence was led to prove conspiracy or direct involvement of accused in the murder of deceased – Acquittal justified [Paras 3, 32-34, 38-41].

Circumstantial Evidence – Last Seen Theory – Reliability – Witnesses claimed to have seen deceased parking scooter outside accused’s house but informed police after more than a month – Conduct found unnatural – High Court rightly discarded their testimony – Supreme Court agreed with finding that prosecution failed to prove “last seen” circumstance beyond reasonable doubt [Paras 23-25].

Evidence – Recovery under Section 27 Evidence Act – Validity – Recovery of blood-stained chunni from accused’s house held inconsequential – No blood grouping done – House remained accessible till police visit – Recovery found unreliable and ineffective in linking accused to crime [Paras 26-27, 32].

Evidence – Electronic Evidence – Admissibility – Call Detail Records – Not supported by certificate under Section 65-B of Evidence Act – Based on handwritten note; scribe not examined – Held: Call detail records inadmissible and cannot be relied upon to prove conspiracy or contact between accused – High Court’s conclusion upheld [Paras 30-31].

Criminal Law – Motive – Land Dispute – Contradictory and improved statements – Alleged motive based on land dispute and threats found to be exaggerated and uncorroborated – Witness contradicted herself on material points – Held: Theory of motive unproved and not supported by substantive evidence [Paras 18-22, 34-35].

Appellate Jurisdiction – Interference with Acquittal – Scope – Reiterated: Acquittal can be reversed only if findings suffer from patent perversity, are based on misreading of evidence, or no other view is possible – Held: High Court’s view was reasonable and supported by record – No grounds for interference by Supreme Court [Paras 39-41].

Decision: Appeals dismissed – Acquittal confirmed – No infirmity found in High Court’s judgment warranting interference.

Judicial Services – Eligibility Criteria – Telangana State Judicial Service Rules, 2023 – Rule 5(5.1)(a) restricting eligibility to advocates practicing in Telangana High Court or its subordinate courts for not less than 7 years – Petitioners challenged rejection of their applications on ground of discrimination and violation of Articles 14 and 233 – High Court dismissed writ petitions holding Rule valid – Supreme Court refrained from adjudicating constitutionality of Rules but permitted qualified petitioners to be appointed as District Judges as a special case without treating it as precedent [Paras 4, 6-9, 11-12].

Recruitment – Judicial Service Examinations – Petitioners permitted by interim orders to participate in written and viva-voce examinations – They secured qualifying marks – Supreme Court directed High Court to declare results and proceed with verification of antecedents – Qualified candidates to be appointed within two months but without arrears of benefits – Seniority to be reckoned from date of actual appointment; existing appointees to rank senior [Paras 8-10].

Civil Judge (Junior Division) – Connected Petitions – Writ petitioners challenging Bar Association enrolment requirement also permitted to appear in exams pursuant to interim order – Supreme Court extended similar relief, directing declaration of results and appointment if qualified [Para 10].

Constitutional Law – Scope of Relief – Supreme Court clarified that directions were confined to peculiar facts and circumstances and would not operate as precedent – All questions of law kept open for determination in future [Para 11].

Decision: Appeals, SLPs, and Writ Petition disposed of – Qualified petitioners directed to be appointed as District Judges as special case – No precedent – Parties to bear own costs.

Criminal Law – Quashing of FIR – Section 498-A IPC – Dowry Harassment – Vague and General Allegations – FIR filed by complainant alleging dowry demands and mental cruelty by in-laws – Specific demand mentioned only once in complaint; other allegations vague and lacking particulars – Held: Allegations in FIR did not disclose essential ingredients of cruelty as required under Explanation to Section 498-A – No prima facie case made out to warrant prosecution of in-laws – FIR against appellants quashed [Paras 8-10].

Criminal Law – Offences under Sections 377 and 506 IPC – Allegations restricted to complainant’s husband – No specific allegations against in-laws – Held: Complaint solely implicated husband in charges of unnatural sex and criminal intimidation – No basis to prosecute in-laws under Sections 377 and 506 IPC – Proceedings against appellants quashed [Paras 11].

Criminal Procedure – Power under Section 482 CrPC – Abuse of Process – Applicability of Bhajan Lal Guidelines – FIR containing omnibus allegations with no specific role assigned to appellants – Continuation of proceedings against in-laws would amount to abuse of process – Supreme Court invoked inherent powers to quash proceedings following principles in State of Haryana v. Bhajan Lal [Paras 12-13].

Decision: Appeal allowed – FIR and criminal proceedings under Sections 498-A, 377, and 506 read with Section 34 IPC quashed as against appellants – Clarified that proceedings against complainant’s husband (accused No.1) to continue independently on merits.

Criminal Law – Murder vs. Culpable Homicide – Accused (landowners) attacked complainant’s father and uncles during land measurement dispute using sticks, pike and spear – PW-1 (son/nephew of deceased) was sole eyewitness; PW-2 hostile – Medical evidence showed lacerated and contused wounds only; no incised injuries – Weapons used with blunt side – Just Knowledge – No Intention - Though Armed with Sharp Weapons, Only the Blunt Side Was Used - Court held deaths caused by accused established, but absence of intent to kill proved; only knowledge of likely death attributable – Conviction under Section 302 IPC not sustainable – Altered to Section 304 Part I IPC [Paras 7–15].

Eyewitness Testimony – Related Witness – Sole reliance on testimony of PW-1 (related witness) not unsafe where corroborated by medical evidence – PW-2 turned hostile, but prosecution case stood corroborated [Paras 7–10].

Medical Evidence – Nature of Injuries – Only blunt force injuries present; no use of sharp edge despite possession of sharp weapons – Consistent with PW-1’s deposition – Supports conclusion of culpable homicide not amounting to murder [Paras 8, 10–11].

Sentence – Appellants already undergone more than 12 years of imprisonment – Court held sentence already served sufficient to meet ends of justice – Ordered release forthwith if not required in any other case [Paras 15–16].

Decision: Appeal partly allowed – Conviction under Section 302 IPC set aside – Conviction modified to Section 304 Part I IPC – Sentence confined to period already undergone – Appellants directed to be released forthwith if not required in any other case.