Abetment of Suicide – Presumption under Section 113-A Evidence Act – The case involved the suicide of the wife within eight months of marriage due to alleged cruelty by the husband and mother-in-law. Section 113-A of the Evidence Act provides for a presumption of abetment if a married woman commits suicide within seven years of marriage and is subjected to cruelty by her husband or his relatives. The three conditions for this presumption are: (i) the woman committed suicide, (ii) the suicide occurred within seven years of marriage, and (iii) she was subjected to cruelty. The court found that all three conditions were met in this case, justifying the presumption of abetment of suicide​​.

Cruelty – Definition and Evidence – The definition of "cruelty" under Section 498-A IPC includes any willful conduct likely to drive a woman to commit suicide or cause grave injury, as well as harassment for dowry demands. The evidence showed that the husband demanded Rs. 25,000 from the deceased’s father for purchasing buffaloes and subjected her to physical and mental cruelty when the demand was not met. The mother-in-law also harassed the deceased, leading her to commit suicide by consuming poison. The court confirmed the cruelty and harassment, fulfilling the requirements under Section 498-A IPC​​.

Interested Witnesses – Reliability – The court addressed the argument that only relatives of the deceased were examined as witnesses, noting that offences of domestic cruelty often occur within the home, limiting the availability of independent witnesses. The testimonies of relatives, if consistent and reliable, are valid and cannot be rejected merely because they are interested witnesses. The court found the relatives' evidence in this case credible and supported by the facts​​.

Decision – Appeals dismissed – The Supreme Court upheld the conviction and sentences of the appellants under Sections 306 and 498-A IPC, confirming the Trial Court and High Court's findings that the deceased was subjected to cruelty and the presumption under Section 113-A of the Evidence Act applied. The sentences of one-year rigorous imprisonment and two years rigorous imprisonment, along with fines, were maintained​​.

Terms and Conditions of Employment – Dominance of Employer – The submissions made by the University's counsel that the teachers accepted the terms and conditions in their appointment letters were rejected. It was noted that employees in public employment cannot choose the terms of employment, as the employer is in a dominant position. Employees are often left with no option but to accept the dictated terms. The court acknowledged that questioning employment terms can risk the employee's job. Therefore, employees can challenge such conditions if they do not conform to statutory requirements and are not estopped from doing so when aggrieved [Paras 42-44].

Substantive Appointment – Regular Selection Process – The appellants were appointed through a regular selection process under the Uttar Pradesh State Universities Act, 1973, which signifies substantive appointments. These appointments were made following the statutory procedure, implying they were not ad hoc or temporary. The appellants are entitled to claim substantive capacity against permanent sanctioned posts and to be recognized as members of the teaching faculty of the Central University under the Central Universities Act, 2009 [Paras 48-51].

Central University Transition – Protection of Employee Rights – Upon conversion of the University to a Central University, the rights and interests of existing employees are protected under Section 4(d) of the Central Universities Act, 2009. The University must ensure compliance with the statutory requirements and recognize the substantive nature of appointments made under the previous State University regime [Paras 38-39].

Decision – Appeals allowed – The Supreme Court quashed the High Court's judgment and recognized the appellants as substantively appointed teachers of the Central University. The appellants are entitled to pay scales and notional benefits equivalent to regularly appointed teachers under the Central Universities Act, 2009 [Paras 52-54].

Lease Agreements – Government Property – The leased land, belonging to the government and located in a reserve forest, was subject to strict conditions. The lessee, M/s. Joseph & Company, breached the lease agreement by subletting and selling portions of the leased land without prior permission from the government, justifying lease termination. The Supreme Court held that the lessee’s actions constituted a clear breach of Clause 14 of the lease deed, and the State's right to terminate the lease was upheld [Paras 1-29].

Waiver of Forfeiture – The court addressed whether the acceptance of rent by the lessor constituted a waiver of forfeiture under Section 112 of the Transfer of Property Act. The court determined that mere acceptance of rent does not automatically signify waiver, especially when the lessor is a government entity and the breach involves unauthorized transfer of leasehold rights. Waiver requires clear intention and knowledge, which was not established in this case [Paras 17-20].

Equity Principles – The court emphasized that equitable principles, such as the maxim "he who seeks equity must do equity," do not support the lessee’s breach of contractual terms, particularly when public property and interests are involved. Strict adherence to lease terms is necessary to prevent misuse and unauthorized exploitation of government property [Paras 30-31].

Decision – Appeals allowed in part – The Supreme Court set aside the High Court's decision and restored the Single Judge’s order upholding the termination of the lease. The court maintained the interim status quo regarding the leased property pending final resolution of related writ petitions [Para 32].

Retrenchment Compensation – Violation of Section 25F – The appellant, a daily wager, worked for 240 days and his service was terminated without complying with Section 25F of the Industrial Disputes Act, which mandates retrenchment compensation. The Labour Court found non-compliance and ordered reinstatement with 25% back wages. However, the High Court modified this to a lump sum compensation of Rs. 25,000. The Supreme Court, noting the appellant's status as a daily wager and the lack of evidence of unfair trade practices, ruled that reinstatement is not automatic and compensation is a suitable remedy in such cases​​.

Reinstatement vs. Compensation – The Supreme Court referred to precedents, including BSNL v. Bhurumal and State of Karnataka v. Umadevi, highlighting that reinstatement with back wages is not automatic for daily wagers whose termination is due to procedural defects under Section 25F. Instead, monetary compensation is often more appropriate, unless there is evidence of unfair labor practices or violation of principles like "last come, first go." The court decided that suitable compensation, rather than reinstatement, would best serve justice​​.

Decision – Appeal partly allowed – The Supreme Court modified the High Court's order, directing that in addition to the Rs. 25,000 already paid, the appellant should be awarded an additional compensation of Rs. 3.25 lakhs. This amount is to be paid within eight weeks and constitutes full and final settlement of all claims by the appellant​​.

Motion of No-Confidence – Democratic Principles – Section 28 of the Uttar Pradesh Kshettra Panchayat and Zila Panchayats Act, 1961, ensures that an elected representative can only stay in power as long as they enjoy the support of the majority of the elected members. Once such a person loses the majority's confidence, they become unwanted. The Supreme Court upheld the High Court's decision, emphasizing that in a democratic setup, the will of the majority must prevail​​.

Procedure for Removal of Party Leader – The appellant contended that her removal was not in accordance with the rules submitted to the District Collector, which provided for a five-year term. However, the court found that the appellant’s initial appointment and the subsequent removal procedure were both presided over by the District President of the INC Party. The same process used for the appellant’s appointment was followed for her removal, making the removal valid​​.

Anti-Defection and Horse-Trading – The court rejected the appellant's argument regarding horse-trading, noting that the appellant herself acted contrary to the party’s wishes by contesting the Chairman's election with the support of a rival group. The court highlighted that the provisions of the Act and Rules aim to prevent horse-trading and maintain political purity, but they cannot be interpreted to allow a minority to impose their leadership on the majority​​.

Decision – Appeal dismissed – The Supreme Court found no reason to interfere with the High Court's decision. The appeal was dismissed, and the court upheld the decision of the District Collector approving the new Party Leader's selection. The court emphasized the democratic principle that the majority's will must prevail in political party leadership​​.

Provisional/Confidential Results – Validity – The Supreme Court held that provisional/confidential results declared by universities are valid for determining eligibility for employment, provided their authenticity is confirmed by the universities. In this case, the provisional results of B.Ed. examinations provided to the candidates before the cut-off date were valid, and the High Court's view was justified. The candidates were rightly considered qualified as on the cut-off date​​.

Eligibility Criteria – High Court's Directions – The Supreme Court found that the High Court's directions to amend the eligibility criteria to consider the date of eligibility at the time of screening or interview were unnecessary. The High Court's advice to the Haryana Staff Selection Commission and the State of Haryana was quashed as it was not an issue in the case and was beyond the scope of the dispute​​.

Appointment of Candidates – Compliance with Interim Orders – The court directed that the 90 posts kept vacant by the Haryana Staff Selection Commission, as per the interim order dated 27.11.2018, be offered to the 74 private respondents and 16 intervenors within four weeks. The appointments should be based on due verification and without delay. The seniority of these candidates will be determined based on inter se merit among them, and they will not be entitled to salary for the period they did not work, but their appointment will be deemed notional from the date of appointment of other selected candidates​​.

Decision – Appeals dismissed – The Supreme Court upheld the High Court's decision regarding the validity of provisional/confidential results but quashed the directions for future amendments to the eligibility criteria. The Haryana Staff Selection Commission was instructed to proceed with the appointments as per the interim orders​​.

Reservation for Office of Mayor – The dominant intent of the Maharashtra Municipal Corporations (Reservation of Offices of Mayors) Rules, 2006, is to ensure effective implementation of the reservation policy while avoiding repetition of reservations in particular corporations. This ensures that all eligible categories receive reservation at some point by rotation. The interpretation by the High Court, which led to repeated reservation for Backward Class in the Dhule Municipal Corporation, was found inconsistent with this intent. The rules mandate that no corporation should have repeated reservations for a particular category until the rotation cycle is complete for all categories​​.

Rotation Policy – Legislative Intent – The legislative intent under Article 243T of the Constitution and Section 19(1A) of the Maharashtra Municipal Corporations Act is to provide reservation for Scheduled Castes (SC), Scheduled Tribes (ST), Backward Classes (BC), and women in a manner that ensures equitable distribution. The High Court’s interpretation failed to account for the difference in the number of reserved seats for SCs and BCs, which could lead to some categories being reserved more frequently than others. A harmonious construction of the rules indicates that the reservation process should be balanced and equitable across all categories​​.

Decision – Appeals allowed – The Supreme Court set aside the High Court's judgment, which had directed the State of Maharashtra to reconsider the reservation process for the office of Mayor in Dhule Municipal Corporation. The court held that the proper interpretation of the rules would avoid repetitive reservation for a particular category until the cycle of reservation for all categories is complete​​.

Pay Disparity – Secretariat vs. Non-Secretariat – Appeals concerning pay disparity between Private Secretaries in Railway field offices and those in Secretariat – 6th CPC recommended some pay parity but maintained distinctions beyond Assistant grade – Tribunal's conflicting judgments on parity – Supreme Court upheld distinct recommendations for non-Secretariat organizations – Parity principle applies up to Assistant grade; higher grades require different considerations [Paras 1-23].

Principle of Equal Pay for Equal Work – Emphasis on different functional roles – 6th CPC considered demands but kept distinctions – Previous cases reiterated that equal pay principle not merely based on designation but functional roles and historical parity – Parity in pay-scales must consider functional distinctions between Secretariat and field offices [Paras 14-20].

Judicial Review of Pay Commission Recommendations – Supreme Court cautions against judicial interference in Pay Commission’s domain – Recommendations considered comprehensive and contextually appropriate – Historical parity not consistent in past Pay Commissions – Tribunal's decisions overturned, reaffirming the specialized body’s recommendations [Paras 15, 19, 21-23].

Decision – Appeals allowed – High Court's judgment set aside – Emphasis on adhering to specific recommendations by 6th CPC for non-Secretariat organizations – Recognizes functional distinctions and career progression differences as rationale for pay-scale variations [Para 21-23].

Building Regulations – Violation – Construction of Towers 16 and 17 (Apex and Ceyane) by Supertech Limited was found to be in violation of the NBR 2006, NBR 2010, NBC 2005, and the UP Apartments Act, 2010 – The towers were constructed with insufficient distance between them and other buildings, violating mandatory open space requirements – High Court's direction for demolition and sanction of prosecution upheld [Paras 49-57].

Collusion and Fabrication – Sanctioned plans for Towers 16 and 17 obtained through collusion between Supertech and NOIDA officials – Appellant produced fabricated sanctioned plans – Collusion led to serious breaches of building regulations – High Court’s decision for prosecution under Section 49 of the UP Urban Development Act and Section 12 of the UP Industrial Area Development Act against the officials involved upheld [Paras 42-43, 48].

Resident Welfare Association – Locus Standi – The Resident Welfare Association (RWA) had the locus standi to challenge the illegal construction as it affects the rights of the apartment owners – The RWA represents the interests of the residents and was entitled to initiate writ proceedings [Paras 44-46].

Judicial Orders – Necessity for Written Orders – Supreme Court emphasized that oral directions restraining actions such as arrest must be accompanied by written orders – Oral directions are not part of the judicial record and can lead to serious misgivings and abuses – Written orders ensure accountability and transparency [Paras 22-25, 48].

Decision – Appeals dismissed – High Court's judgment for demolition of Towers 16 and 17 upheld – Directions issued for safe demolition supervised by experts and reimbursement to flat purchasers with interest – Costs awarded to RWA [Para 48].