Anticipatory Bail – Allegations of Rape and Sexual Assault – IPC Sections 376(1), 377, 354A – Bail Granted - The appellant, alleged to be a spiritual leader, was accused of sexually exploiting a married woman and others – The FIR was lodged after delay, and the High Court had rejected anticipatory bail – Supreme Court noted earlier grant of interim protection and found the case suitable for anticipatory bail – Held: Order of High Court set aside; anticipatory bail granted with conditions including cooperation in investigation and restraint from tampering with evidence [Paras 1-3].

False Implication – Allegations of Conspiracy and Blackmail – Delay in Filing FIR - Appellant contended that the complainant and her husband fabricated the case using videos to create false evidence for ulterior motives – Further claimed the relationship was consensual – Held: Without commenting on merits, Supreme Court found grounds sufficient for anticipatory bail as the FIR was belated and under suspicious circumstances [Paras 2-3].

Serious Allegations – Accused as Spiritual Leader – Court Balances Liberty and Investigation – The complainant alleged that the appellant misused his position as a godman to exploit women – The Court recognized the seriousness but emphasized liberty and fair process – Held: Conditional anticipatory bail appropriate; liberty not to be misused, and any breach would lead to cancellation [Paras 2-3].

Decision – Appeal Allowed – Anticipatory Bail Granted – The Supreme Court set aside the Bombay High Court’s order and granted anticipatory bail on furnishing ₹25,000 cash security with two sureties – Directions issued for cooperation and non-interference with evidence – Held: Non-compliance would lead to cancellation of bail [Para 3].

Anticipatory Bail – Withdrawal of Previous Applications – Co-Accused Already Granted Bail – Relief Granted - The appellant's anticipatory bail was denied by the High Court solely on the ground that he had earlier withdrawn similar applications – The Supreme Court noted that co-accused were granted bail and had already extended interim protection to appellant – Held: Interim protection confirmed; anticipatory bail granted – Arresting authority directed to release on bail if arrested, subject to Trial Court's terms [Paras 2-4].

Subsequent FIR – Interim Protection Already Secured – No Bar to Current Bail Relief - State submitted that a fresh FIR under Bharatiya Nyaya Sanhita, 2023, was registered against appellant during pendency – The appellant clarified he had secured interim protection in that case from the Sessions Court – Held: Existing relief not affected by subsequent FIR; future applications to be decided independently on merits [Paras 5, 7].

Cooperation in Investigation – Liberty to Cancel Bail If Violated – Investigative Balance Maintained - The Court emphasized that the appellant must cooperate fully with the investigation – Held: Non-cooperation would entitle the State to seek cancellation of bail from Trial Court [Para 6].

Final Disposition – Appeal Allowed – Bail Granted – Appellate Court Clarified Scope of Order - The Court clarified that its order granting bail in this case would not influence other proceedings or applications of the appellant pending elsewhere – Held: Appeal disposed with protection to liberty and due process [Paras 7-8].

Motor Accident Claim – Functional Disability – Medical Board Certificate – Acceptance Limited - Claimant suffered hemipelvectomy and produced 90% disability certificate – Supreme Court accepted the medical evidence but held that for compensation purposes, 50% functional disability was rightly assessed by High Court based on actual earning capacity and use of prosthetic limb – Held: Functional disability determines loss of income, not the medical percentage per se [Paras 7-8].

Loss of Income – Income Tax Returns Accepted – Estimation Based on Documentary Evidence - The Court found that income tax and sales tax returns submitted prior to the accident could not be disregarded – Held: Income of ₹1,91,000 (net of tax) for 2007-08 accepted; applying multiplier of 18 and 50% disability, total loss of income calculated at ₹17,19,000 [Paras 8-9].

Future Prospects – No Addition Permitted – Functional Earning Capacity Sufficient - The claimant, fitted with a prosthetic limb, could continue his business and did not require enhancement for future prospects – Held: 40% addition for future income prospects disallowed, as loss already compensated through disability-based income loss [Para 9].

Medical Expenses – Full Reimbursement Allowed – Lack of Reasoning by Lower Courts Cured - Tribunal awarded ₹3.39 lakh and High Court increased to ₹8 lakh without reasoning – Supreme Court allowed full ₹12.54 lakh based on vouchers submitted – Held: Entire verified medical expense payable in absence of valid rebuttal by insurer [Para 10].

Future Medical Expenses – Replacement of Prosthetic Limb – Additional Compensation Awarded - Recognizing that prosthetic limbs need periodic replacement and servicing, though no authenticated receipts were filed, the Court granted ₹10 lakh towards future medical needs – Held: Compensation must include realistic provision for ongoing disability management [Paras 12].

Compensation Recalculated – Enhancements Over High Court Award - Supreme Court restored ₹1 lakh for attendant expenses and ₹4.70 lakh for initial prosthetic limb purchase omitted by High Court – Combined total compensation recalculated and awarded at ₹48,44,790 with 6% interest from date of application, after deducting amounts already paid [Paras 11, 13-14].

Anticipatory Bail – Modification During SLP Pendency – High Court's Jurisdiction Restrained – Stay Issued - The petitioners challenged the anticipatory bail granted to respondent no. 1 in 31 criminal cases related to financial fraud – Despite pendency of SLP, the High Court permitted modification of bail condition allowing travel abroad – Held: Such modification during pendency of appeal before Supreme Court is impermissible and violates judicial discipline – Orders dated 12.08.2025 and 23.08.2025 stayed [Paras 1-11].

Judicial Discipline – High Court Should Exercise Restraint During Pendency of SLP – Doctrine Clarified – Supreme Court reiterated that once an SLP is admitted and notice issued, High Courts must not pass orders that may circumvent or frustrate the proceedings before the apex court – Held: Proper administration of justice demands mutual respect between courts in a hierarchical system – Precedents from Tirupati Balaji Developers and Chhavi Mehrotra relied upon to reinforce judicial propriety [Paras 8-10].

Concealment of Material Facts – Conduct of Accused Under Scrutiny – Show Cause Issued - Respondent No. 1 failed to inform the Supreme Court of filing applications before the High Court for modification of bail terms – Affidavit filed before Supreme Court omitted this material fact – Held: Court expressed grave displeasure and issued notice to explain why anticipatory bail should not be cancelled for suppression of facts [Paras 12-13].

Passport and Travel Restriction – Interim Direction – Supreme Court Mandates Compliance - In view of pending investigation in 31 criminal cases, the Court directed respondent no. 1 to immediately surrender her passport and not to leave India without prior permission – Held: Travel restriction reinstated pending further hearing [Para 15].

Anticipatory Bail – Cryptic High Court Order – Supreme Court Intervention – The petitioner sought anticipatory bail in relation to a 2021 FIR for offences under the Prevention of Corruption Act – The High Court instead of deciding the bail application on merits, adjourned the matter directing the DGP to file an affidavit explaining non-arrest of the petitioner for four years – Held: High Court erred in not deciding the application on merits – The fact that the petitioner was not arrested for four years itself was a good ground to consider anticipatory bail – Supreme Court exercised its discretion and granted protection [Paras 2-5, 7-8].

Judicial Duty – Anticipatory Bail Application – Manner of Disposal – Held: High Court ought to have either granted or rejected anticipatory bail on merits – Asking irrelevant questions to the investigating agency reflected improper exercise of jurisdiction – Supreme Court disapproved the High Court’s approach [Paras 5-6].

Bail Principles – Delay in Arrest – Significance – Held: Non-arrest of the petitioner for four years was by itself a strong ground to grant anticipatory bail – Discretion under Section 438 CrPC must be exercised to protect liberty when there is no bona fide attempt to arrest during investigation [Para 7].

Final Decision – Appeal Allowed – Supreme Court ordered that in the event of arrest, the petitioner shall be released on bail subject to conditions imposed by the Investigating Officer – SLP disposed of [Para 8-9].

Limitation Law - Motor Accident Claim – Disbursement of Compensation – Review Rejected – Delay Not Condoned – Appellant sought review of Tribunal's disbursement order alleging unfair distribution of compensation among legal heirs – Tribunal rejected review on grounds of delay (6 months, 22 days) and absence of medical evidence – High Court affirmed dismissal – Supreme Court upheld findings – Held: Appellant signed joint application and accepted cheque without protest – Review rightly dismissed [Paras 1–7].

Limitation – Review Application – Sufficient Cause Not Proved – Tribunal and High Court found no credible explanation for delay – Appellant failed to produce medical records to support claim of illness or surgery – Delay appeared to be afterthought – Courts below correctly applied settled principles of limitation law [Paras 3.4, 5, 6.4].

Estoppel – Approbat and Reprobat – Conduct Precludes Challenge – Appellant signed joint disbursal application and received ₹1,00,000/- without demur – Later attempt to challenge disbursement order treated as reversal of conscious conduct – Held: A party who voluntarily accepts benefits under a court order cannot later dispute its validity – No question of fraud or suppression arose [Paras 5.4, 6.1–6.3].

Final Decision – Appeal Dismissed – No Interference Warranted – Supreme Court found no error in decisions of Tribunal or High Court – Appellant’s challenge to disbursement treated as legally unsustainable – Appeal dismissed with observations on conduct [Para 7].

Civil Law - Will – Testamentary Succession – Section 67 of Indian Succession Act – High Court’s Finding Set Aside – Appellant claimed rights under joint will by parents – Trial and Appellate Courts upheld validity of will – High Court invoked Section 67 to void bequest due to attestation by beneficiary’s wife – Held: High Court framed additional substantial question of law without pleadings, issues, or suggestions in evidence – Introduction of Section 67 changed nature of case from factual to legal without procedural safeguards – Judgment set aside, testamentary succession upheld [Paras 1–23].

Section 100 CPC – Additional Substantial Question of Law – High Threshold – Proviso Invoked Improperly – High Court invoked proviso to Section 100(5) to frame new legal issue under Section 67 – Supreme Court held such invocation must be exceptional, with strong reasons recorded and based on pleadings – Found no foundation in plaint for applying Section 67 – Application of Section 67 in Second Appeal was legally unsustainable [Paras 16–20].

Evidence – Absence of Cross-Examination Suggestion – Application of Browne v. Dunn Principle – Court emphasized that where a party relies on new legal issue, contradiction must be suggested in cross-examination – No suggestion made to attesting witness (DW5) about disqualification – Held: Entire line of attack on will based on assumed relationship was contrary to fair procedure – Admission in pleadings or suggestion in evidence is essential [Paras 21–22].

Execution of Will – Validity Upheld – Free Will and Sound Disposing State – Trial Court and Appellate Court found will duly executed, with attestation proved under Section 63 – Medical evidence confirmed testator’s mental capacity – Held: No suspicion or infirmity in execution – Findings of lower courts reinstated [Paras 13–14].

Final Relief – Appeal Allowed – Monetary Obligations Under Will Enhanced – Though testamentary succession upheld, Supreme Court enhanced the monetary amounts payable to legal heirs under the will from ₹1 lakh / ₹50,000 to ₹10 lakhs / ₹5 lakhs respectively – Directed Appellant to pay within 3 months with interest @6% on default – Charge to be created over schedule properties [Para 24–25].

Criminal Writ – PIL - Constitutional Validity – Section 376DA IPC – Challenge to mandatory life imprisonment “for remainder of natural life” – Question left open – Petitioner assailed the provision as arbitrary and violative of Articles 14 & 21 for excluding judicial discretion and mitigating circumstances – Court held that validity cannot be examined in vacuum in a PIL without concrete factual backdrop; issue left to be raised in appropriate case – Petition disposed of [Paras 5–7, 10–12].

Sentencing – Scope of punishment under Section 376DA IPC – Though mandatory life imprisonment stipulated, accused retains constitutional and statutory rights of remission under Articles 72 & 161 of the Constitution, Section 432 CrPC, and equivalent provisions under BNSS – Each State’s remission policy applies even to sentences under Sections 376DA & 376DB IPC [Paras 9.2–9.5].

Judicial Remedies – Conviction and sentence under Section 376DA IPC subject to appeal before High Court and Supreme Court – Additional remedies of constitutional and statutory remission safeguard against rigidity – Prescription of punishment reflects legislative policy considering egregious nature of offence [Paras 7–9].

Decision – Writ Petition disposed of; question of law on constitutional validity of Section 376DA IPC kept open to be adjudicated in an appropriate case – Impleadment application also disposed [Paras 10–12].

Quashing of Summoning Order – Delay in Complaint – Vague Allegations – Criminal Proceedings Quashed – Supreme Court quashed proceedings initiated under a private complaint after finding four-year delay in lodging FIR for alleged 2010 incident – Allegations of rape and caste abuse were held to be vague, inconsistent, and unsupported by material evidence – Summoning of accused and parents held to be gross abuse of process [Paras 4–15, 22–24].

Frivolous and Vexatious Litigation – Judicial Caution Emphasized – Summons Must Not Be Issued Lightly – Citing Mohammad Wajid v. State of U.P., 2023 SCC OnLine SC 951, Court reiterated that false, motivated criminal proceedings deserve closer scrutiny – Summoning based on fabricated or exaggerated narrative can seriously harm reputation – Courts must carefully assess allegations, context, and delay [Paras 16–17].

Consensual Relationship vs. Rape – False Promise of Marriage – Legal Test Restated – Court reiterated that failed promise of marriage does not automatically amount to rape – Referred to Deepak Gulati v. State of Haryana, 2013 Cri LJ 2990 – Held: Distinction must be made between false promise made with intent to deceive and mere failure to marry due to changed circumstances [Paras 18–19].

Section 482 CrPC – Principles for Quashing Restated – Four-Step Test – Reiterated the Rajiv Thapar v. Madan Lal Kapoor framework – Courts must consider if evidence is unimpeachable, rebuts complaint, and prosecution cannot reasonably refute it – If yes, continuation of proceedings is abuse of process [Para 20].

Final Decision – Appeal Allowed – Criminal Case Quashed – Supreme Court allowed appeal, set aside Allahabad High Court’s order, and quashed proceedings in Criminal Case No. 655/2014 pending before Additional CJM, Allahabad [Paras 24–25].