Criminal Law  – Supplementary Evidence – Production of CDs at Trial – Permissible Omission – Upheld – CDs seized before filing of original chargesheet but not produced due to inadvertence – Supplementary chargesheet filed with forensic report but without CDs – Supreme Court held omission not fatal – CDs could be produced later with court’s permission without prejudice to accused, following precedent in R.S. Pai – Held: Such production is not barred under CrPC Section 173(5), as the provision is directory, not mandatory [Paras 10-15].

Further Investigation – Section 173(8) CrPC – Scope – Supplementary Chargesheet Valid – Even without “new” evidence – Held: Supplementary chargesheet referring to CDs and CFSL report valid, as CDs were already sent for analysis and referenced therein – Court clarified “further investigation” includes procedural completion of existing evidence, not necessarily discovery of new facts [Paras 11-13].

Evidence – Electronic Evidence – Section 65B Certificate – Admissibility and Authenticity – Kept Open – Court refused to adjudicate admissibility and genuineness of CDs or certificates under Section 65B at preliminary stage – Left open for trial court determination – Appellant permitted to cross-examine witnesses with regard to CDs [Paras 17-18].

Decision – Appeal Dismissed – High Court and Special Court Orders Affirmed – Supreme Court upheld production of CDs and denied relief to appellant – Held: No reason to reconsider precedent in R.S. Pai; no prejudice caused – However, left open issues of authenticity and admissibility for trial [Paras 15, 19].

Criminal Law – Murder Conviction – Acquittal – Appellants convicted under Sections 302 and 307 read with Section 149 IPC and Section 3(1) of Tamil Nadu Prevention of Damage to Public Property Act – Trial Court and High Court upheld conviction based on testimonies of PW-1, PW-2 and PW-9 and corroborative material including fingerprint and recovery evidence – Supreme Court finds serious infirmities in prosecution’s case – Held: Conviction unsustainable as guilt not proved beyond reasonable doubt [Paras 1, 6, 41, 42]

Witness Testimony – PW-1 (Informant and Eye-Witness) – Evidence found unreliable due to political rivalry, exaggeration, inconsistencies, and lack of clarity regarding visibility and identification – Admitted naming 36 persons initially, later retracted against 15 with no objection to their removal – Court held his testimony exaggerated and not confidence-inspiring [Paras 16–21, 29]

Witness Testimony – PW-2 (Chance Witness) – Came forward after 43 days citing fear, but prosecution failed to explain delay or examine companion Abdul Rahman – Court held testimony unbelievable and adverse inference drawn against prosecution for non-examination of material witness [Paras 22–24, 30]

Child Witness – PW-9 (Injured Minor) – Aged 10 years, no preliminary voir dire by Trial Court, no test identification parade conducted – Admitted mother told her details of incident – Court held her evidence inadmissible due to non-compliance with legal standards for examining child witnesses [Paras 25–28, 31]

Circumstantial Evidence – Fingerprint Evidence – Fingerprints of Accused Nos. 2 and 3 alleged on Scorpio car – No Mahazar prepared, photographs not exhibited, procedural irregularities found – Court held fingerprint evidence unreliable [Para 32]

Circumstantial Evidence – Recovery of Weapons – Recovered from common or open locations at different times with questionable reliability – Held: Recovery evidence alone insufficient for conviction in absence of credible primary evidence [Para 33]

Appellate Jurisdiction – Article 136 – Scope of Interference – Reiterated that Supreme Court generally does not interfere with concurrent findings unless manifest illegality or misreading of evidence causing miscarriage of justice – In this case, striking features of evidence overlooked and misread by both lower courts warranted interference [Paras 36–40]

Decision: Appeals allowed – Conviction and sentence set aside – Appellants acquitted of all charges – To be released from custody forthwith if not required in any other case [Paras 41, 42]

Service Law - Judicial Service – Probation Termination – Stigmatic Discharge Not Sustainable – The appellant, a probationer in Rajasthan Judicial Service, was discharged based on an inquiry alleging misconduct including non-disclosure of past employment and simultaneous academic degrees – The Court held that the allegations predated judicial service and were not grave enough to justify termination – Held: Discharge order stigmatic and violative of natural justice, termination set aside [Paras 17–18, 27, 31–32].

Natural Justice – Procedural Deficiency in Inquiry – Inquiry Conducted Without Full Participation – The appellant was not provided an effective hearing during the vigilance inquiry and the report was not supplied to her – Held: Violation of principles of natural justice and fair play warrants quashing of action based on such inquiry [Paras 7–8, 27].

Public Employment – Discharge on Probation – Applicability of Article 311 – The discharge was based on an inquiry concluding misconduct without formal proceedings – Held: Though on probation, the appellant was entitled to protection from stigmatic discharge under Article 311, requiring proper inquiry and opportunity of defence [Paras 24–26].

Women in Judiciary – Need for Diversity – Importance of Retaining Women Judges – The Court emphasized the systemic value of diversity and fair treatment in the judiciary – Held: Appellant, having succeeded despite systemic barriers, should not be excluded for minor procedural lapses [Paras 28–31].

Decision – Appeal Allowed – Discharge Order Quashed – Appellant Reinstated – The Supreme Court quashed the show cause notice and discharge order – Directed reinstatement with notional seniority and benefits except back wages – Probation deemed successfully completed [Paras 32–33].

Taxation Law - Customs – Duty Drawback – Circular No. 35/2010-Cus. – Clarificatory Nature – Retrospective Application – Dispute over denial of 1% AIR duty drawback to exporters of Soyabean Meal who availed Central Excise rebate – Supreme Court held that CBEC Circular No. 35/2010-Cus. was clarificatory in nature and must apply retrospectively – Circular did not introduce new benefit but clarified consistent practice under earlier notifications from 2006 to 2010 – Held: Circular operates retrospectively; appellant entitled to duty drawback for period before 20.09.2010 [Paras 1–5, 12–16, 20].

Fiscal Interpretation – Beneficial Circular – Presumption of Retrospectivity – Court applied the principle that beneficial or clarificatory circulars are to be construed as retrospective unless expressly stated otherwise – Notifications and circulars were consistent in treating the 1% rate as covering customs component regardless of CENVAT availed – Held: Doctrine of fairness and purposive construction warranted retrospective operation of Circular No. 35/2010 [Paras 9–18].

Statutory Construction – No Substantive Change – Circular Confirmed Existing Position – Language across all relevant notifications (2006 to 2010) consistent – Circular did not create new rights or burdens but clarified already available benefit – Held: Department’s denial of drawback prior to 20.09.2010 based on prospective interpretation was erroneous [Paras 13–15].

Judicial Review – Error by High Court – Improper Dismissal of Review Petition – High Court dismissed writ petition and review relying solely on effective date mentioned in Circular – Failed to assess its clarificatory nature and misapplied legal standards – Held: High Court's decision set aside for not appreciating fiscal legislative principles correctly [Paras 19–20].

Decision – Appeal allowed – Impugned orders of the Madhya Pradesh High Court dated 17.11.2014 and 01.04.2016 set aside – CBEC Circular No. 35/2010-Cus. dated 17.09.2010 held to be clarificatory and retrospective – Appellant entitled to 1% AIR duty drawback for exports of Soyabean Meal since 2008 [Para 20].

Criminal Law – Discharge – Limits under Section 239 CrPC – Special Court and High Court Orders Set Aside – Special Court and High Court discharged accused in ₹21 crore MSP fraud based on CCI's internal letter stating no loss – Supreme Court held this reliance was impermissible under Section 239 CrPC – Held: At charge stage, court can only consider prosecution material under Section 173 CrPC, not defence documents—Discharge orders illegal [Paras 13–28].

Corruption and Criminal Conspiracy – Cotton Procurement Scam – Prima Facie Case Made Out – Accused allegedly purchased cotton below MSP, hoarded it, and resold it via benami farmers to CCI at MSP using forged documents—Involvement of CCI officer (A-1) and son (A-3) established—Forgery confirmed by forensic analysis—Held: Material in charge sheet sufficient to proceed to trial—Discharge not warranted [Paras 6–8, 17–20, 27].

Judicial Process – Mini Trial at Discharge Stage Impermissible – Special Court’s evaluation of CCI's exoneration letter akin to a trial verdict rather than a charge analysis—Held: Courts below erroneously assessed defence case and presumed acquittal—Judicial discretion under Section 239 must not extend to considering accused’s evidence [Paras 20–26].

Criminal Procedure – Precedents – Accused Cannot Rely on External Evidence at Charge Stage – Court relied on State of Orissa v. Debendra Nath Padhi and State of Rajasthan v. Swarn Singh—Reiterated: Only prosecution's material under Section 173 CrPC can be examined at discharge—Accused cannot invoke right to file or rely on documents at framing of charge [Paras 24–26].

Decision – Criminal appeals allowed – Orders of discharge passed by Special Court and affirmed by High Court quashed – Discharge applications dismissed – Trial Court directed to reconsider charges strictly as per Section 239 CrPC, uninfluenced by defence material or observations in this judgment [Paras 27–28].

Crimnal Law - Section 138 & 141 NI Act - Negotiable Instruments – Quashing Set Aside - Vicarious Liability of Director – Complaint Must Disclose Responsibility for Company’s Affairs – High Court quashed criminal proceedings under Section 138 NI Act against a director on the ground of insufficient averments—Supreme Court reversed, holding that complaint sufficiently alleged that respondent was “responsible for day-to-day affairs, management and working” of the company—Held: Averment satisfies the requirement under Section 141(1) NI Act—Complaint need not reproduce statutory language verbatim if substance is clear [Paras 2–6, 17–21, 27–30].

Director Liability – No Need to Parrot Section 141 – Substantive Allegations Sufficient – Supreme Court reiterated that complainants are not required to reproduce Section 141 verbatim—Complaint as a whole must show the director was in charge of and responsible for company’s business—Detailed Board resolutions and loan documents attached supported director’s active role—Held: Complaint sustainable against respondent no. 2 [Paras 18–21, 29–31, 34–39].

Precedents – S.M.S. Pharmaceuticals, Sabitha Ramamurthy, K.K. Ahuja, S.P. Mani – Applied – Court analyzed evolution of NI Act jurisprudence—Held: Complaint met the standards set in S.M.S. Pharmaceuticals (2005), Sabitha Ramamurthy (2006), K.K. Ahuja (2009), and S.P. Mani (2023)—Averments adequate to infer vicarious liability; no hyper-technical interpretation required [Paras 22–38].

Criminal Procedure – Quashing of Complaint – High Court Order Set Aside – High Court erroneously quashed proceedings under Section 482 CrPC—Held: Trial should proceed where complaint discloses sufficient prima facie material—A complaint cannot be dismissed solely for not using statutory language in precise terms [Paras 15–16, 39–40].

Decision – Appeal allowed – High Court order dated 10.01.2024 in Criminal W.P. No. 275 of 2022 quashed – Complaint restored against respondent no. 2 – Trial to proceed before Magistrate in accordance with law [Para 40].

Environmental Law – Classification of Zudpi Jungle as Forest – Historical Usage vs. Legal Interpretation – Forest Status Upheld – Despite historical non-forestry use and poor vegetative quality, Zudpi Jungle lands recorded as forest in revenue records must be treated as ‘forest’ for the purpose of Section 2 of the Forest (Conservation) Act, 1980 in view of the 12.12.1996 Godavarman order – Held: All such lands, unless de-notified in compliance with legal procedure, continue to attract forest conservation laws [Paras 29, 48, 55, 90].

Environmental Protection – CEC’s 2025 Report – Recommendations Accepted – Extensive data collection and district-wise analysis by CEC validated – Court accepted CEC’s findings and ordered conditional declassification of certain Zudpi lands, while maintaining protection over ecologically sensitive areas – Held: Recommendations in Paras 46(i)–(xii) of 2025 CEC Report accepted in full [Paras 47, 91, 93, 95].

Encroachments and Illegal Use – Regularisation of Post-1980 Allotments Denied – State directed to remove all commercial allotments and encroachments made after 25.10.1980 – Task Forces to be constituted in each district with mandate to act within two years – Held: Post-1980 encroachments and illegal commercial uses of Zudpi Jungle land to be treated as violations requiring eviction [Paras 91(viii)–(ix), 93(viii)–(ix)].

Revenue Records – Correction Allowed for Pre-1996 Allotments – Subject to Conditions – Court permitted reclassification of Zudpi Jungle lands used for non-forest purposes prior to 12.12.1996 via consolidated proposals under Section 2(i) of FC Act – No NPV or compensatory afforestation required – Held: Revenue entries may be updated for such lands, but future use must remain unchanged and hereditary only [Paras 43(A), 47(ii), 91(ii)].

Administrative Procedure – Simplified Framework for Proposal Processing – MoEF&CC and State to develop streamlined application format for diversion proposals in consultation with CEC – Held: Simplified process to be created within three months; CEC empowered to resolve any disputes [Paras 47(iii), 91(iii)].

Sustainable Development – Balancing Ecology and Local Needs – Zudpi Jungle lands provide crucial local community support – However, environmental conservation cannot be compromised – Held: Framework permits limited, justified deletions without precedent effect, balancing Article 48A and Article 21 [Paras 48, 55, 93].

Protected Forests – Unallotted Fragmented Parcels – Mandatory Protection – All unallotted Zudpi Jungle land under 3 hectares not adjoining any forest to be declared ‘Protected Forests’ under Section 29 of Indian Forest Act, 1927 – Held: Fragmented parcels protected from alienation; diversion only possible with Central Government approval under FC Act [Paras 91(v), 93(v)].

Forest Rights – Determination Using Satellite Data – Historical imagery permitted as supporting evidence in Forest Rights Act determinations – Held: Satellite data to assist in identifying traditional use and tenure [Para 91(vii)].

Compensatory Afforestation – Flexibility in Vidarbha Region – Court allowed double-area Zudpi Jungle lands to be used in lieu of non-forest land for compensatory afforestation in five districts – Held: Chief Secretary certificate of non-availability not required; afforestation must comply with MoEF guidelines [Para 91(xi)].

Judgment – Final Order – Applications Disposed – CEC directed to monitor progress of implementation, including forest transfers, eviction drives, and proposal approvals – Held: Applications disposed of in terms of accepted recommendations with liberty to CEC to submit reports and intervene in case of non-compliance [Paras 93–96].

Consumer Law - Challenge To Constitutionality And Validity Of Specific Provisions Of The Consumer Protection Rules, 2020 - Consumerism and Constitutional Philosophy – Broad Interpretation of Consumer Rights – Socio-Economic Relevance Affirmed – The Court held that the concept of consumerism is constitutionally embedded within principles of equality, dignity, justice and participatory democracy – Consumer forums are instruments of social justice promoting public accountability and participative governance – Consumer rights cannot be narrowly construed but must be seen in the context of constitutional values under Articles 38 and 51-A(h) [Paras 2–20].

Selection Committee Composition – Rule 6(1) of 2020 Rules Struck Down – Executive Dominance Held Unconstitutional – The Court held that Rule 6(1), which allowed excessive control of executive in appointment process, violated doctrine of separation of powers – Held: Only one nominee from executive branch can be permitted – Impugned rule declared ultra vires and struck down [Paras 55–58, 83].

Tenure of Appointees – Rule 10(2) Held Invalid – Minimum Five-Year Tenure Mandated – The 4-year term under Rule 10(2) was found contrary to precedent and judicially established principles – A minimum five-year tenure is essential to ensure institutional independence and stability of consumer fora – Rule 10(2) struck down [Paras 84, 99].

Written Examination Requirement – Directions in Limaye–I Clarified – No Written Exam for Judicial Members or Presidents – Held: Requirement of written test introduced in Limaye–I applies only to non-judicial members – Judicial Members and Presidents are exempted – Review Petitions allowed to clarify this misinterpretation – Appointments made without written tests for judicial roles upheld [Paras 78–81, 100].

Appointments Made Under 2023 Advertisements – Appointments of 112 Candidates Valid – Non-Impleadment of Appointees Rendered HC Decision Invalid – Held: High Court’s failure to implead selected candidates violates natural justice – Also, written examination was substantially complied with – Hence, appointments made via notification dated 05.10.2023 upheld [Paras 86–89].

Reappointments – Not a Vested Right – Must Be Made Under New Rules – The Court held that repealed 2019 Rules cannot govern reappointments – Held: Any reappointment must comply with fresh set of rules to be framed – Rule 8(18) of 2019 Rules cannot be revived or relied upon – No automatic reappointment possible [Paras 90–98].

Appointments in Telangana – Prospective Application of Limaye–I – No Retrospective Invalidation – The Court set aside High Court's decision cancelling Telangana appointments made prior to Limaye–I – Held: Directions in Limaye–I do not operate retrospectively – Appointees to be reinstated [Para 101].

Final Relief and Constitutional Directions – Mandate to Frame New Rules – SC exercised powers under Article 142 to direct Union of India to frame fresh Rules governing appointment, tenure and conditions of service – Emphasis on permanent consumer fora with clear recruitment framework – Court underscored need for transparency and institutional efficiency [Paras 102–104].

Decision – Civil Appeals Partly Allowed, Review Petitions Allowed in Part – Appointments upheld in certain states and quashed in others depending on compliance with legal and constitutional standards – Rules 6(1) and 10(2) declared unconstitutional – Directions issued for new regulatory framework and future appointments [Paras 99–104].

Criminal Law - PMLA Offence – Bail – Predicate Offence Bail Granted – Relaxation of Section 45 PMLA – Bail Allowed – The appellant, a headmaster, was accused of conspiring to leak the question paper of a competitive government examination and was arrested along with 36 candidates found with the leaked paper – The Enforcement Directorate registered a separate ECIR under PMLA based on proceeds of crime arising from the predicate offences – The appellant was granted bail in the predicate FIR on 28.01.2025 – The Court noted that the ED investigation was ongoing and the case against the appellant, at present, rested on conspiracy – Held: In light of the nature of allegations and the fact that bail was granted in the predicate offence, rigours of Section 45 PMLA can be relaxed and the appellant released on bail with liberty to the ED to seek modification if further incriminating evidence emerges [Paras 6–10].

Decision – Appeal Allowed – Bail Granted – Supreme Court set aside the High Court's order denying bail and directed that the appellant be released on bail to the satisfaction of the Special Judge (PMLA) – Liberty granted to ED to move for recall/modification of order upon discovery of fresh material [Paras 9–11].