Criminal Law — Quashing of Chargesheet — Section 482 CrPC — CCTV Footage — Parity among Co-accused — Appellants, residents of the same apartment complex as the complainant, arraigned in chargesheet under Sections 143, 341, 323, 324, 354, 504, 506, 509 and 427 IPC arising from a neighbourly altercation on 11.10.2022 — High Court quashed proceedings against two co-accused (wives of appellants) but declined similar relief to appellants — On appeal, Supreme Court viewed CCTV footage forming part of chargesheet and found appellants not visible at scene during acts of assault, their gestures demonstrative of restraint and efforts to pacify — Allegations in FIR vague and without specific attribution of overt acts to appellants — Statement under Section 164 CrPC containing omnibus allegations unsupported by corroborative material and belied by electronic evidence — High Court's differential treatment of similarly placed accused without cogent reasoning held unsustainable — Held: Case falls within categories (1), (3) and (7) of Bhajan Lal — Chargesheet quashed qua appellants — Appeals allowed [Paras 3–4, 24–31, 35–36].

Section 482 CrPC — Scope and Ambit — Inherent Jurisdiction — Seven categories enumerated in State of Haryana v. Bhajan Lal wherein High Court may exercise power to quash proceedings — Jurisdiction exercisable inter alia where allegations in FIR, taken at face value, do not prima facie constitute any offence; where uncontroverted allegations and material collected fail to disclose commission of offence; or where criminal proceeding is manifestly attended with malafide and instituted with ulterior motive for wreaking vengeance — Categories are illustrative and not exhaustive — Structured four-step test in Pradeep Kumar Kesarwani reiterated: material must be of sterling and impeccable quality; sufficient to negate allegations; unrefuted or incapable of justifiable refutation; and continuation must amount to abuse of process — Where all four steps are answered in affirmative, High Court ought to quash proceedings [Paras 22–23, 32].

CCTV Footage — Evidentiary Weight at Quashing Stage — Electronic evidence forming part of chargesheet viewed by Supreme Court at appellants' request — Footage demonstrated that alleged acts of assault had already occurred prior to appellants' arrival at scene — Appellants not shown engaging in any act of aggression — Visual record indicated appellants made efforts to pacify parties — Allegation that appellant No. 2 ignited a lighter to burn the complainant's family member found not discernible in footage — Held: CCTV footage, being of unimpeachable provenance and forming part of prosecution's own record, substantially dislodges the factual foundation of allegations against appellants — High Court's failure to meaningfully analyse this crucial piece of evidence renders impugned judgment unsustainable — Unimpeachable electronic evidence collected during investigation and relied upon by both sides cannot be brushed aside even at the stage of quashing [Paras 26–28, 33].

Parity — Co-accused — Differential Treatment — High Court quashed proceedings against Nabina Bose and Pampa Joardar (wives of appellants) on the basis of the same FIR and chargesheet arising from the same incident — No cogent or discernible reasoning assigned for declining similar relief to appellants despite substantially similar allegations — Held: Differential treatment without clear rationale violates principle of parity and renders impugned decision arbitrary and legally unsustainable [Para 29].

Abuse of Process — Malafide Prosecution — Pre-existing disputes between parties arising from co-residency in same apartment complex regarding maintenance charges and earlier complaints — Specific overt acts not attributed to appellants in FIR — Prosecution record bereft of credible material connecting appellants with alleged offences — Continuation of trial would not advance the cause of justice — Held: Proceedings manifestly attended with malafide initiated with ulterior motive — Compelling appellants to face full-fledged trial would amount to misuse of criminal process and wastage of precious judicial time [Paras 30–31, 34].

Decision: Appeals allowed — Impugned judgment and order dated 08.03.2024 of the High Court at Calcutta set aside — Chargesheet No. 135 of 2022 under Sections 143, 341, 323, 324, 504, 506, 509, 427 and 354 IPC arising out of FIR No. 150 of 2022 registered at Police Station Survey Park, pending in ACGR No. 4659 of 2022 before the Additional Chief Judicial Magistrate, South 24 Parganas at Alipore, quashed insofar as it relates to appellants Nos. 1, 2 and 3 — Pending applications disposed of.

Service Law – Promotion – Relaxation of Service Rules – Notional Promotion – Validity of Government Order – Appellant, initially appointed as Fitter in 1988 and promoted as Overseer on 01.12.1995 pursuant to High Court direction, acquired a B.E. (Civil) degree in 1996 and was directed to discharge duties of Junior Engineer from 05.11.1997 – Pursuant to successive High Court orders in W.P. Nos. 18493 of 2001 and 21461 of 2003, Government issued G.O. (D) No. 19 dated 18.01.2005 promoting him as Assistant Engineer with effect from 14.04.1997 notionally, with monetary benefits from 26.10.1998 – Division Bench set aside the said G.O. and directed fresh scrutiny – Held: G.O. (D) No. 19 was validly issued in compliance with prior High Court orders and in consonance with the merger policy under G.O. Ms. No. 237 dated 26.09.1996; impugned judgment set aside and G.O. (D) No. 19 restored [Paras 3, 7.6, 19, 27].

Inter Se Seniority – Merger of Departments – Engineering Department vs. Town Planning Department – G.O. Ms. No. 237 dated 26.09.1996 framed the Tamil Nadu Municipal Corporations Service Rules, 1996 merging the Engineering and Town Planning Departments – Annexure I thereto expressly directed that Assistant Engineers transferred from the Town Planning Department be placed below Assistant Engineers of the Engineering and Water Supply Department – Appellant belonged to Engineering Department; Respondent No. 1 to Town Planning Department – Placement of appellant above Respondent No. 1 in seniority held to be in strict conformity with the said instructions – Government Order never challenged by any party – Held: Inter se seniority as determined by G.O. (D) No. 19 is valid and binding [Paras 17, 20, 27].

Judicial Review – Division Bench – Interference with Government Order – Absence of Discussion on Merits – Division Bench appears to have been swayed by unsubstantiated assertions of violation of Service Rules without meaningful engagement with the factual record – Failed to notice that both appellant and Respondent No. 1 had already been promoted as Assistant Executive Engineers on 07.11.2007, and as Executive Engineers on 27.01.2016; Respondent No. 1 having retired on 30.09.2023 – No surviving contest on seniority subsisted at the time of the impugned judgment – Held: Interference with a two-decade-old Government Order, after retirement of the writ petitioner, was wholly unwarranted and would unsettle all promotions in the Corporation [Paras 22, 24].

Committee Report – Scrutiny of Promotions – Contempt Proceedings – Pursuant to directions issued in contempt and writ proceedings, Government constituted a Three-Member Committee which examined the promotions granted to the appellant and found no irregularity, malpractice, favouritism, nepotism or corrupt influence – Contempt Petition Nos. 499, 675, 762 of 2019 accordingly closed by order dated 22.01.2020 – Division Bench failed to notice this material subsequent development – Held: Direction to re-scrutinise files was unsustainable in view of the Committee's findings already accepted by the High Court [Paras 23, 24].

Laches – Fence-Sitter – Impleading Applicant – Seniority Dispute – Impleading applicant K. Saravanakumar was not a party to any proceedings before the High Court and sought impleadment only at the final stage before the Supreme Court – Disciplinary proceedings pending against him rendered him disentitled to promotion in any event – No enforceable legal right demonstrated – Held: Fence-sitters cannot be permitted to agitate stale seniority claims after rights of third parties have crystallised; relief declined [Para 25, 25.1, 25.2].

Decision: Civil Appeals allowed – Judgment dated 23.07.2024 in W.A. No. 996 of 2015 and Order dated 04.10.2024 in Review Application No. 249 of 2024 set aside – G.O. (D) No. 19 Municipal Administration and Water Supply (MC IV) Department dated 18.01.2005 restored – Subsequent promotions of the appellant as Assistant Executive Engineer and Executive Engineer held valid – Appellant entitled to further promotion from the date of eligibility – Impleading applications disposed of – No order as to costs

Consumer Law – Medical Negligence – Death of Opposite Party – Substitution of Legal Heirs – Survivability of Right to Sue – Doctor died during pendency of revision before NCDRC after having succeeded in appeal before SCDRC – NCDRC allowed substitution of legal heirs – Legal heirs challenged the order contending that no decree existed against the doctor on the date of his death and hence proceedings stood abated – Held: Upon death of the alleged medically negligent doctor, his/her legal heirs can be impleaded and brought on record; however, the extent of liability shall be confined to claims maintainable against the estate of the deceased as per Section 306 of the Indian Succession Act, 1925, read with Order XXII Rules 2 and 4 of CPC [Paras 65–67].

Maxim 'Actio Personalis Moritur Cum Persona' – Statutory Modification in India – The common law maxim 'a personal right of action dies with the person' has been statutorily modified in India by the Fatal Accidents Act, 1855, Legal Representatives' Suits Act, 1855, and Indian Succession Act, 1925 – The maxim, in its absolute form, is no longer applicable in India – Claims for pecuniary loss to the estate of the deceased survive, while purely personal claims (defamation, personal injury not causing death) abate – Held: Exceptions under Section 306 of the 1925 Act must be strictly interpreted and confined to personal claims; estate claims survive [Paras 44–55, 64].

Section 306, Indian Succession Act, 1925 – Interpretation of First Exception – 'Personal Injuries Not Causing Death' – The first exception under Section 306 bars only causes of action that are purely personal in nature (such as defamation, assault, personal injury) and does not extend to claims representing pecuniary loss to the estate of the deceased – Held: A distinction must be drawn between personal claims (which abate on death) and proprietary/estate claims (which survive) – Exception cannot be interpreted so broadly as to swallow the enabling provision [Paras 51, 55, 56, 59–61].

Consumer Protection Act, 1986/2019 – Procedure on Death of Party – Order XXII CPC – Section 13(7) of the 1986 Act and Section 38(12) of the 2019 Act mandate recourse to Order XXII of CPC in case of death of any party – Order XXII Rule 4 requires legal representatives to be brought on record where right to sue survives against the deceased – Rule 11 extends applicability to appeals/revisions – The 'right to sue' contemplated in Order XXII is a matter of substantive law governed by Section 306 of 1925 Act – Held: Procedural provisions under CPC and Consumer Protection Acts must be harmoniously construed with substantive law under the 1925 Act [Paras 34–40, 56–58, 67].

Proprietary Rights vs. Personal Rights – Classification – Proprietary rights (having economic/monetary value, transferable, forming the estate) survive the death of a party; personal rights (status-based, non-transferable, such as claims for pain, suffering, and reputation loss) do not survive – The legal representative of the deceased represents only the estate and cannot assert personal rights of the predecessor – Held: Estate claims in consumer proceedings survive; personal claims abate [Paras 59–61].

Balbir Singh Makol Case – Overruled – The five-judge bench judgment of NCDRC in Balbir Singh Makol v. Chairman, Sir Ganga Ram Hospital and Others, 2001 (1) CPR 45 (NC), applying the common law maxim without reference to statutory modifications and misreading the ratio of Melepurath Sankunni Ezhuthassan — Overruled — NCDRC erred in (a) failing to account for statutory modifications to the maxim; (b) misreading Melepurath Sankunni; and (c) treating the first exception under Section 306 of the 1925 Act as absolute, barring even estate claims [Para 66].

Decision: Appeals disposed of – Impugned orders dated 26.05.2010 and 24.05.2018 passed by NCDRC set aside – Revision petition restored to its original number – Matter remitted to NCDRC for adjudication of the revision on merits, confined to claims maintainable against the estate of the deceased doctor, within six months [Paras 72–73].

Service Law – Recruitment – Essential Qualification – Relevant Date – Candidates who had not acquired their law degree as on the last date of submission of applications applied for posts of Assistant Prosecution Officer pursuant to Advertisement No. 19/2023-24 dated 07.03.2024 issued by RPSC – High Court, affirming the Single Judge, held that candidates who acquired qualification before the date of preliminary examination were eligible – Supreme Court disagreed – Held: The relevant date for possessing the minimum essential qualification is the date of submission of the application, not any subsequent date prior to interview or examination [Paras 3, 18].

Recruitment Rules – Deletion of Proviso – Legislative Intent – Rule 12 of the Rajasthan Prosecution Subordinate Service Rules, 1978 originally contained a proviso permitting candidates appearing in the final year of the qualifying examination to apply – Said proviso was deleted by notification dated 10.10.2002 – Held: The legislative intent underlying the deletion is clear and unambiguous — candidates who have not acquired the requisite qualification as on the relevant date are not eligible to apply — what cannot be done directly cannot be permitted to be done indirectly (aliquid prohibetur ex directo, prohibetur et per obliquum) [Paras 20, 21].

Press Note – Clarification – Validity – Press notes dated 19.11.2024 and 29.11.2024 issued by RPSC clarified that candidates not possessing the prescribed qualification as on the last date of application were ineligible and were directed to withdraw their applications – High Court held that the press notes altered eligibility conditions mid-process causing prejudice – Supreme Court held otherwise – Held: The press note dated 29.11.2024 is in complete consonance with the Rules and the advertisement and merely clarifies that eligibility must be determined with reference to the date of submission of the application [Paras 22, 25].

Interpretation of Advertisement – Beneficial Construction – Limits – High Court applied the principle that where two interpretations are possible, the one favourable to candidates ought to be adopted – Held: Such an approach cannot be invoked when the language of the advertisement admits of only one clear and unambiguous interpretation — acceptance of respondents' contention would introduce uncertainty into the selection process and impose unwarranted administrative burden on RPSC [Paras 23, 24].

Decision: Appeals allowed – Common judgment dated 12.08.2025 passed by the Division Bench of the High Court of Judicature for Rajasthan at Jodhpur in D.B. Special Appeal Writ No. 169 of 2025 and connected matters set aside – Pending applications disposed of [Paras 26–28].

Company Law – Membership – Register of Members – Oppression and Mismanagement – Sections 397, 398 and 399, Companies Act, 1956 – Respondent invested substantial funds in the appellant company, was appointed Managing Director, and the hospital was rebranded reflecting his identity – Shares were alleged to have been allotted at a Board meeting on 15.07.1999, but no share certificates were issued and his name was not entered in the register of members – Company Law Board and High Court treated him as a deemed member – Held: Respondent was entitled to be treated as a member for purposes of maintaining proceedings under Sections 397 and 398 – Appeals dismissed [Paras 1, 31–32].

Definition of 'Member' – Section 2(27) vs. Section 41 – Scope and Interplay – Section 2(27) defines 'member' in wide and inclusive terms, excluding only bearers of share-warrants under Section 114 – Section 41 prescribes recognised modes of acquiring membership (subscribers to memorandum, persons agreeing in writing, entry in register, beneficial ownership in depository records) – Held: The requirement of written agreement under Section 41(2) was introduced to prevent fraudulent inclusion and protect companies from busy bodies, not to make entry in the register the sole and exclusive mode of membership – The expression 'member' in Sections 397 and 398 must be construed with reference to the broader framework of Section 2(27) and not confined to the technical requirements of Section 41(2) [Paras 21–23].

Equitable Jurisdiction – Sections 397 and 398 – Minority Shareholders – The jurisdiction under Sections 397 and 398 is equitable in character and the expression 'member' must be construed in a manner consistent with the remedial and protective purpose of the legislative scheme – It would be contrary to settled principles of interpretation to construe 'member' in a restricted technical sense so as to frustrate substantive rights of genuine investors who have been treated as shareholders by the conduct of the company – Held: Equity and justice must prevail over procedural technicalities when a person has been consistently recognised as a stakeholder [Paras 22–23, 28].

Deemed Membership – Recognition Through Conduct – Cumulative factual circumstances including: (i) letter by appellant no. 2 describing respondent as "co-owner"; (ii) conciliation proceedings and conciliator's letter acknowledging respondent's entitlement to 30% shareholding; (iii) respondent's induction as Managing Director; (iv) hospital renamed after respondent's trading concern; (v) share application money accepted, utilised and reflected in company's financial records; (vi) appellants admitting allotment as a fact before the civil court — collectively demonstrated consistent recognition of respondent's proprietary interest – Held: Respondent was in substance a member whose interest stood recognised by the company over a considerable period [Paras 14–16, 29–30].

Company Cannot Take Advantage of Own Default – The entry of a person's name in the register of members is a statutory obligation cast upon the company – The appellant company having received substantial investment, utilised it in business, and repeatedly recognised the respondent's stakeholder status, cannot thereafter be permitted to rely upon its own failure to make the formal entry so as to deny the respondent locus standi under Sections 397 and 398 – Held: Such a hyper-technical interpretation cannot be countenanced [Para 13.2–13.3].

Decision: Appeals dismissed – Findings of Company Law Board affirmed by High Court upheld – Amount deposited before Supreme Court along with accrued interest to be released in favour of respondent Dhananjay Pande – No order as to costs [Para 32].

Criminal Law – FIR – Writ Jurisdiction – Exhaustion of Alternative Remedies – Article 226 – Complainant company, aggrieved by alleged forgery, impersonation and fraud in connection with a property measurement application, filed complaints before the Land Records Authority and thereafter directly invoked writ jurisdiction of the High Court seeking registration of FIR – High Court, without issuing notice to the accused, directed police to record the Director's statement and take action in accordance with law – FIR No. 0194/2025 registered pursuant thereto under Sections 318, 319, 335, 336, 337, 338, 340 and 61(2) of BNS 2023 – Held: Complainant had not approached the Superintendent of Police under Section 173(4) BNSS or the Magistrate under Section 175(3) BNSS before approaching the High Court; invocation of writ jurisdiction in first instance was premature and contrary to settled law – Impugned interim order set aside and FIR quashed [Paras 7, 9, 11, 12].

Constitutional Law – Article 226 – Writ Jurisdiction – Self-Imposed Restrictions – Alternate Remedy – While jurisdiction of the High Court under Article 226 is wide, it is extraordinary and discretionary and subject to self-imposed restrictions – Writ jurisdiction should not ordinarily be exercised where efficacious alternative statutory remedies exist, unless: (a) fundamental rights are at stake; (b) principles of natural justice are violated; (c) proceedings are without jurisdiction; or (d) vires of legislation is challenged – Article 226 is not a panacea for all grievances and cannot be invoked to bypass the statutory scheme in its entirety – No imminent danger to life or liberty was shown in the present case [Paras 5, 9, 10].

BNSS – Statutory Framework for FIR Registration – Sequential Mechanism – The BNSS provides a structured sequential mechanism: information regarding a cognizable offence is first placed before the officer-in-charge under Section 173(1); upon refusal, recourse lies to the Superintendent of Police under Section 173(4); and thereafter to the Magistrate under Section 175(3) – Complainant bypassed this entire statutory scheme and approached the High Court directly – Held: Such recourse was impermissible in the absence of special circumstances [Para 8, 9, 10].

High Court – Writ Petition – FIR – Premature Invocation – High Court is not bound to entertain a writ petition merely because a case of alleged inaction by a statutory authority is made out – Where statute provides complete and efficacious remedy, same must be exhausted first – Entertaining writ in such circumstances would make the High Court a forum of first instance – Writ petition held to be premature [Para 11].

Decision: Appeals allowed – Impugned interim order dated 17.12.2025 set aside – FIR No. 0194/2025 quashed – Liberty reserved to parties to avail alternative statutory remedies in accordance with law – Nothing in the judgment to be construed as an expression of opinion on merits or on whether the facts disclose commission of any criminal offence.

Default Bail – UAPA – Acquiescence – Right to Default Bail Lost – Respondents arrested in connection with FIR for offences under IPC and UAPA arising out of arson, rioting and destruction of public property including a police station – Investigating agency moved application under Section 43D(2)(ii)(b) of UAPA for extension of time before expiry of 90 days – Trial Court extended time by 28 days after hearing accused's counsel – Chargesheet filed on 7th July, 2024 within extended period – Respondents' application for default bail rejected by trial Court on 3rd June, 2024 – Respondents approached High Court only in September, 2024, long after chargesheet had been filed – High Court allowed appeal and granted default bail – Held: By the time respondents approached the High Court, the right to seek default bail had been lost by their acquiescence – Impugned order set aside [Paras 9-15].

Default Bail – Extension of Time – Investigation – Adequacy – High Court's Finding Erroneous – High Court cast aspersions on the Investigating Officer holding that investigation proceeded sluggishly and that only 8 official witnesses and 4 public witnesses were examined in three months – Held: Finding was factually incorrect as statements of 65 witnesses had been recorded in the said period – Case involved widespread arson, rioting, use of petrol bombs, large number of accused and separate FIRs arising from similar incidents in nearby areas – Observation that investigation proceeded with lethargy was absolutely unreasonable in the facts and circumstances [Paras 13].

Decision: Appeal allowed – Order of the High Court granting default bail set aside – Respondents directed to surrender before the trial Court within two weeks, failing which trial Court to take stringent measures to take them into custody – Respondents at liberty to apply for regular bail, to be considered on its own merits [Paras 15-17].

Contempt of Courts – Criminal Contempt – Safety of Judicial Officers – SIR of Electoral Rolls – Suo Motu Action – Seven judicial officers, including three women, were gheraoed by anti-social elements at the BDO office, Kaliachowk, Maldah District, West Bengal, while discharging duties relating to adjudication of objections under the Special Intensive Revision (SIR) of electoral rolls — Officers were held without food or water from 3:30 p.m. until after midnight — Their vehicles were pelted with stones and attacked with bamboo sticks and bricks upon release — Held: Such conduct amounts to criminal contempt within the meaning of Section 2(c) of the Contempt of Courts Act, 1971, and constitutes a brazen challenge to the authority of this Court — Judicial officers deputed for SIR adjudication function as an extension of this Court [Paras 2, 9, 10, 11].

Judicial Officers – Extension of Supreme Court – Protection of Authority – This Court's order dated 20.02.2026 in W.P.(C) No. 1089/2025 makes clear that judicial officers assigned to adjudicate objections in the SIR process discharge their duties for and on behalf of the Supreme Court — Any obstruction of or intimidation to such officers is, in essence, a challenge to the authority of this Court — The incident is a calculated, well-planned and deliberate act intended to demoralise judicial officers and obstruct the ongoing adjudication process [Paras 9, 10].

State Administration – Failure of Duty – Show Cause – The Chief Secretary, Home Secretary, Director General of Police, District Magistrate and Superintendent of Police, Maldah, failed to take effective action despite being informed of the gherao at 3:30 p.m. — No effective evacuation measures were taken; senior officials arrived at the Chief Justice's residence only after midnight — The Chief Secretary could not be contacted as he had not shared a mobile number with WhatsApp facility — Held: Such conduct is highly deplorable; officials directed to show cause as to why action should not be taken against them [Paras 7, 11, 12, 13(vii)].

Interim Directions – Security of Judicial Officers – ECI and State Government – Pending further hearing, the following directions issued: (i) ECI directed to requisition and deploy adequate central forces at all places where judicial officers are deputed; (ii) adequate security to be provided at residences and hotels where officers and their families are staying; (iii) threat perception of family members to be assessed and remedial measures taken; (iv) not more than 5 persons to be permitted at any premises where objections are filed or adjudicated; (v) compliance report to be submitted by the Chief Secretary, Director General of Police and Chief Electoral Officer; (vi) ECI directed to entrust investigation of the incident to an independent agency such as the CBI or NIA, with a preliminary inquiry report to be submitted directly to this Court [Para 13].

Decision: Suo motu cognisance taken — Interim directions issued for immediate compliance — Show cause issued to Chief Secretary, Director General of Police, District Magistrate, Maldah and Superintendent of Police, Maldah — All concerned officials directed to remain present virtually on 06.04.2026 — Registry directed to forward D.O. letter of the Chief Justice of the Calcutta High Court to all concerned authorities.

Criminal Law – Murder – Burning of Wife – Concurrent Conviction – Dying Declaration – Reliability – The appellant was convicted under Sections 302 and 342 IPC by the Sessions Judge, Bundi and sentenced to life imprisonment with rigorous imprisonment of one year respectively – High Court confirmed the conviction – Appellant challenged concurrent findings on the ground that the magistrate who recorded the dying declaration had noted that the deceased was not in a position to give a statement and that the certificate of mental fitness was obtained on a blank paper – Held: Scope of interference in concurrent findings of conviction is restricted to cases where the courts below have committed manifest errors in law, misdirected themselves in appreciating evidence, or completely missed crucial pieces of evidence – On examination of the Magistrate's (PW-12) deposition, nowhere did the officer state that the deceased was not of sound mind – The duty doctor (PW-15) examined the condition of the deceased before certifying her fitness to make a statement – The fact that the medical certificate was on the reverse of the same paper as the dying declaration does not affect its sanctity [Paras 7–12].

Dying Declaration – Evidentiary Value – Consistency with Medical Evidence – Eyewitnesses Turning Hostile – The deceased's dying declaration (Exhibit P-20) recorded in question-answer format by the Magistrate was found consistent with the medical evidence adduced by PW-9 and PW-10, both of whom deposed that the deceased died due to septicaemia caused by burning – Eyewitnesses PW-2 and PW-3 turned hostile and supported the prosecution case – Held: Where the dying declaration is consistent with medical evidence, the testimony of hostile eyewitnesses loses significance in undermining the prosecution's case – A medical jurist's testimony cannot be disregarded merely because he was not a practicing doctor, provided he was qualified and his testimony was consistent with the treating medical officer [Paras 12, 13].

Dying Declaration – Allegation of Tutoring – Bald Assertion – Not Accepted – The appellant contended before the trial court that the parents of the deceased had tutored her into making the dying declaration – Held: Such submission was a bald assertion which was rightly rejected by the trial court – No material was brought to establish tutoring either in examination-in-chief or in cross-examination [Para 11].

Postscript – Violence Against Women – Persistence Despite Legislative and Judicial Reforms – The Court noted that the offence was of the year 2012, by which time the Constitution and numerous legislative measures had been in operation for decades – Despite the Dowry Prohibition Act, 1961, Section 498-A IPC, the Protection of Women from Domestic Violence Act, 2005, the Sexual Harassment of Women at Workplace Act, 2013, and a series of significant judicial pronouncements expanding women's rights, NCRB data shows more than 4.48 lakh crimes against women were recorded in 2023 and dowry-related violence continues to claim over 6,000 lives annually – Held: The coexistence of legal progress and persistent violence signals a deep paradox — legal and economic advancements are visible on a macro level but patriarchy still permeates the everyday — practices such as domestic abuse persist not as aberrations but as indications of a disease-afflicted social order — the answer to why control over women's bodies and choices still persists lies only with "We, the People of India" [Paras 14–18].

Decision: Appeal dismissed — Concurrent conviction and sentence under Sections 302 and 342 IPC confirmed — Pending applications disposed of.