Criminal Law - Rape - Indian Penal Code 1860 - Section 376 - Protection of Children from Sexual Offences Act 2012 - Section 3 and 4 - Juvenile Justice Act 2015 - Section 94 - Prosecution failed to prove victim's minority through prescribed statutory documents - Medical evidence proved factum of penetrative sexual assault - Trial Court and High Court had concurrently recorded findings of sexual assault - Appellate Court has powers under Section 386 CrPC to alter findings and maintain sentence - Accused was given fair opportunity to defend against underlying actus reus - Conviction modified to Section 376 IPC with 10 years imprisonment - Held - Absence of charge under IPC does not vitiate trial where cognate POCSO charge was defended and no failure of justice occurred - [Paras 36-59].

Criminal Law - Charge - Code of Criminal Procedure 1973 - Sections 222, 386 and 464 - Absence of formal charge - Accused was charged under Section 3 of POCSO Act for penetrative sexual assault - Ingredients of Section 375 IPC are same as Section 3 POCSO Act - No prejudice caused to accused as he defended the alleged act - Appellate court may convict for cognate minor offence even if not specifically charged - Held - Conviction under Section 376 IPC is sustainable despite omission in framing charge - [Paras 41-54].

Evidence Law - Age Determination - Juvenile Justice Act 2015 - Section 94 - POCSO Act 2012 - Proof of minority - Prosecution relied on Baptismal Certificate not listed under Section 94 JJ Act - Medical age determination test was not conducted - Held - Prosecution failed to prove victim was minor in manner required by law - [Paras 36-39].

Decision: Appeal partly allowed – Conviction under Section 4(2) of the POCSO Act set aside – Appellant convicted under Section 376 of the IPC and sentenced to 10 years rigorous imprisonment with a fine of Rs. 10,000 – Conviction under Section 506 IPC confirmed.

Criminal Law - Extradition and Sentencing - Terrorist and Disruptive Activities (Prevention) Act 1987 - Constitution of India - Article 72 and Article 136 - Sovereign assurance regarding 25-year imprisonment limit - Appellant sought release claiming 26 years 9 months 22 days incarceration by combining undertrial and post-conviction periods and adding jail-earned remissions - Court held that concurrent sentences cannot be counted twice to create an artificial or accelerated computation of the 25-year limit prescribed by sovereign assurance - Sovereign assurance does not convert a life sentence into a fixed-term sentence of 25 years - Held - High Court rightly dismissed the writ petition as the 25-year term is an outer limit to be computed as per earlier Supreme Court directions and does not permit overlapping period benefits or notional addition of remissions to life sentences - [Paras 1-32].

Criminal Law - Remission - Code of Criminal Procedure 1973 - Sections 432 and 433 - Jail-earned remission - Appellant sought to add jail-earned remissions to the 25-year period - Court held that since the appellant stands convicted of life imprisonment and the sovereign assurance does not alter the nature of the sentence to a fixed-term sentence - the benefit of jail-earned remission cannot be notionally added to advance the release date - Held - claim for jail-earned remission is not maintainable as the sentence remains one of life imprisonment - [Paras 20-29].

Criminal Law - Precedent - Law of Precedent - Applicability - Appellant relied on Yovehel v. State of Maharashtra and Union of India v. V. Sriharan @ Murugan and Swamy Shraddananda v. State of Karnataka - Court held these cases materially different as they did not involve sovereign extradition assurances - Held - precedents cannot be applied divorced from the factual and statutory setting in which they were rendered - [Paras 30-31].

Decision: Appeal dismissed in limine – The judgment of the High Court is upheld.

Civil Law - Electricity - Electricity Act 2003 - Sections 42 and 56 - Recovery of arrears - Appellant-licensee sought recovery of MCGC for additional load not actually released to respondent-consumer - Ombudsman set aside demand noting absence of consumer consent and limitation bar under Section 56(2) - High Court dismissed writ petition confirming findings on lack of consent and limitation - Supreme Court held that liability to pay arises on consumption and first bill issuance - demand barred by statutory limitation - Appeal dismissed - [Paras 1-11].

Civil Law - Limitation - Electricity Act 2003 - Section 56(2) - Supplementary demand - Period of limitation - Two-year limitation period under Section 56(2) restricts right to disconnect supply for non-payment of electricity dues - Section does not preclude recovery of dues through other modes but limits disconnection rights - Demand raised years later for period 1998 is barred by limitation - Held - licensee cannot recover time-barred arrears through disconnection - [Paras 6-11].

Decision: Appeal dismissed – Impugned judgment of the High Court upheld – The demand for MCGC for the period February 1998 to September 1998 held barred by limitation.

Writ Law - Public Health - Constitution of India - Article 21 and Article 47 - Petitioner sought implementation of Front-of-Package Labelling (FoPL) on high fat sugar and salt (HFSS) foods - Supreme Court previously directed Union and FSSAI to implement clear labelling - FSSAI proposed a phased, red hexagonal label for products high in two or more nutrients - Petitioner challenged the two-or-more threshold as scientifically unsupported and requested mandatory compliance - Court expressed concerns regarding the ambiguity in phases, lack of timelines, potential for increased use of additives, and the adequacy of the proposed label size - Held - FSSAI directed to provide specific responses to queries regarding threshold basis, timeline for phases, scientific justification for nutrient thresholds, and regulation of additives within 10 days - [Paras 1-55].

Civil Law - Food Safety - Food Safety and Standards (Labelling and Display) Regulations 2020 - Regulatory compliance - FSSAI proposed red hexagonal warning labels for HFSS products - Court noted discrepancy between 2024 Guidelines and 2022 Draft Regulations regarding definition of HFSS foods - Court highlighted need for clarity on whether labels should reflect Total Sugar and Saturated Fat as per past stakeholder consensus - Held - FSSAI required to clarify criteria and address concerns on label legibility and pictorial representation - [Paras 9-45].

Writ Law - Nutritional Literacy - Constitution of India - Article 21 - School curriculum - Recognizing the vulnerability of children to unhealthy dietary habits and the increase in overweight school-age children as per UNICEF data - Court enquired into plans for incorporating nutritional literacy and interpretation of food labels into school curriculum - Held - Union of India directed to respond on initiatives for nutritional literacy at the school level - [Paras 51-53].

Decision: FSSAI directed to file a detailed response via affidavit within 10 days on 13 specific queries including timelines, thresholds, labelling standards, and mitigation of artificial additive usage – Matter posted for further hearing on 28/09/2026.

Civil Law - Partnership - Indian Partnership Act 1932 - Sections 43, 46, 48 - Partnership at will - Dissolution - Valuation of assets - Respondent-plaintiff sought accounts and share after dissolving partnership at will in 1983 - Trial Court restricted share to value as on 1983 - High Court set aside restriction and directed Commissioner to sell immovable asset by public auction to determine real value and distribute proceeds - Supreme Court affirmed - Held - Upon dissolution of partnership at will every partner is entitled to share in residue of assets based on real market value at time of liquidation and not notional value at date of dissolution - New partnership formed by remaining partners cannot retain assets without purchasing them from erstwhile firm - Liquidating assets via public auction is the correct legal recourse when parties cannot agree on value - Appeal dismissed - [Paras 1-62].

Civil Law - Partnership - Indian Partnership Act 1932 - Section 48 - Settlement of accounts - Right of partner - Outgoing partner's entitlement - Partner is entitled to share in profits till dissolution and share in value of assets after liquidation - Held - Reconstituted firm has no right to utilize assets of dissolved firm without paying outgoing partner his rightful share based on market value - [Paras 57-60].

Decision: Civil appeal dismissed – Interim stay orders vacated – Parties and Commissioner directed to comply with High Court directions for sale of assets – No order as to costs.

Civil Law - Securities Law - SEBI Act 1992 - Section 15HA and 15HB - Appellant-SEBI imposed penalties on Respondent-Company for alleged misleading share buyback announcement without intent to fulfill - SAT set aside penalty citing fulfillment of escrow release conditions under Buyback Regulations - Supreme Court held that inquiry into escrow release under Regulation 15B(8) of Buyback Regulations is distinct from inquiry into fraud under PFUTP Regulations - Mere release of escrow does not grant immunity from fraud allegations - Matter remanded to SAT to adjudicate on fraud allegations by scrutinizing historical trading data discrepancies and internal contradictions in SEBI investigation reports - Held - Appeals partly allowed and matter remanded - [Paras 1-59].

Civil Law - Securities Law - SEBI (Buyback of Securities) Regulations 1998 - Regulation 15B(8) - Escrow account forfeiture - Whether satisfaction of escrow release conditions bars fraud inquiry - Held - Scope of Regulation 15B(8) is limited to escrow forfeiture and does not constitute a finding on fraudulent intent under PFUTP Regulations - [Paras 30-35].

Evidence Law - Standard of Proof - PFUTP Regulations 2003 - Fraud - Proof of fraudulent conduct - Held - Fraud must be established on the touchstone of balance of probabilities through objective perusal of evidence - In absence of direct evidence of inducement to third parties or other corroborative circumstances it is necessary that the device or tactic deemed manipulative must admit of no explanation other than that of fraud - [Paras 47-50].

Decision: Appeals partly allowed – Matter remanded to SAT for fresh adjudication on the question of fraud alone within six months – SAT directed to resolve discrepancies in historical trading data and examine corroborating circumstances.

Service Law - Compulsory Retirement - Fundamental Rule 56(j) - Appellant an Indian Trade Service officer compulsorily retired on 10 May 2018 - Challenged order before CAT and Delhi High Court - Both forums dismissed the challenge citing limited scope of judicial review - Supreme Court observed that the appellant was granted regular promotion to Joint Secretary barely two months prior to the retirement order after merit-based assessment - The Court held that a promotion granted shortly before compulsory retirement without any intervening act of misconduct makes the retirement order ex facie arbitrary and perverse - The Court noted malice in law as the decision ignored consistently outstanding service records for over two decades and relied on a sinister confidential note without credibility - Held - Impugned judgment and CAT order set aside - Appellant entitled to all service benefits as if he had not been compulsorily retired - [Paras 49-67].

Service Law - Compulsory Retirement - Fundamental Rule 56(j) - Doctrine of Washed-off theory - Review Committee ignored the appellant's merit-based promotion and relied on selective old adverse materials - Court emphasized that while old records can be considered, the immediate past performance must be given due weightage - Promotion based on merit shortly before retirement is irreconcilable with the conclusion that the officer has become dead wood - Held - Compulsory retirement order is mutually destructive to the recent promotion order - [Paras 38-50].

Service Law - Judicial Review - Fundamental Rule 56(j) - Scope of interference - While judicial review of compulsory retirement is limited, the Court is duty-bound to interfere if the order suffers from manifest arbitrariness perversity or mala fides - Administrative discretion is not a charter for arbitrariness and must be informed by fairness - Held - The action was a colourable exercise of power and a shortcut to avoid regular proceedings - [Paras 51-62].

Decision: Appeal allowed - Impugned judgment of the High Court and order of the CAT set aside - Appellant to be entitled to all service benefits and notional promotion if any juniors were promoted - Respondent directed to pay Rs 6 lakh as costs and Rs 9 lakh as compensation for loss of reputation - Liberty granted to the respondent to recover the amount from officers responsible for the arbitrary action - [Paras 65-71].

Civil Law - Labour Law - Payment of Gratuity Act 1972 - Section 4 - Jurisdiction of Controlling Authority - Appellant challenged liability for payment of gratuity to workers engaged through a contractor - Controlling Authority held appellant liable despite lack of employer-employee relationship - High Court confirmed liability - Supreme Court noted appellant engaged workers through a job contract at arms length - Court held that Controlling Authority is only empowered to compute amount payable to an employee and cannot adjudicate upon the existence of employer-employee relationship to fasten liability on principal employer - High Court order set aside and Appellate Authority order revived - [Paras 1-14].

Civil Law - Contract Labour - Contract Labour (Regulation and Abolition) Act 1970 - Section 21(4) - Responsibility for payment of wages - Distinction between wages and gratuity - Appellant contended that the Act only covers wages and not gratuity which is a separate component under the Payment of Wages Act - Supreme Court found contentions sustainable and confirmed no liability on principal employer - [Paras 6-7, 13].

Civil Law - Employer-Employee Relationship - Contractual terms - Clause 12.4.1 of the agreement between appellant and contractor explicitly barred creation of employer-employee relationship - Court reiterated that persons working under an establishment through a contractor cannot claim direct employment with the principal employer - [Paras 7, 9].

Decision: Appeals allowed - The order of the High Court is set aside and the order passed by the Appellate Authority stands revived - No recovery to be made from respondents for amounts already paid under previous court orders - [Paras 14-15].