Road Safety – Public Interest Litigation (PIL) – National Highways – Implementation of Control of National Highways Act, 2002 – Directions issued to remove unauthorised occupation from National Highways and establish enforcement mechanisms – Court found the absence of dedicated inspection teams and grievance redressal portals violated statutory mandates – Held: Centre and Highway Administrations must constitute inspection squads, grievance portals, and public reporting mechanisms to ensure road safety [Paras 1-3, 5, 10, 13-14].

Highway Administration – Failure in Statutory Duties – Rule 3 of Highway Administration Rules, 2004 (as amended in 2019) – Highway Administrations failed to enforce mandatory duties such as SOP formulation, enforcement monitoring, and grievance resolution – No concrete data or compliance with SOPs submitted – Held: Detailed affidavits with implementation timelines to be filed; strict enforcement of Rule 3 required [Paras 8-9, 13].

Encroachments – Section 24 and 26 of 2002 Act – Lack of Survey and Eviction Mechanisms – Court found that despite legal powers to detect and remove encroachments, Highway Administrations lacked proactive enforcement – No regular surveys, no public complaint channels, and negligible action taken despite notices – Held: Mandatory regular inspections, citizen complaint portal, and toll-free reporting system to be established [Paras 2-7, 11-12, 14].

Public Accountability – Digital Tools and Surveillance – Rajmargyatra App – Incomplete Implementation – App intended for highway users’ complaints lacked redressal transparency and citizen feedback – Court directed upgrade of app with tracking features, status updates, and appeal mechanisms – Also ordered creation of portal with full complaint and response visibility [Paras 12-13].

Judicial Monitoring – Continuing Mandamus – Enforcement Timeline – Recognizing persistent failure of executive bodies, Court retained writ petition on file to ensure periodic judicial review and enforcement of compliance – Directed Union of India and MoRTH to file action-taken affidavits within three months – Surveillance teams with police coordination to be constituted for highway patrolling [Paras 14, 16].

Decision – Interim directions issued – Highway Administration and Union of India to implement SOPs, launch public portal, upgrade mobile app, establish patrolling teams, and file compliance reports within three months – Case to remain pending as continuing mandamus – Next compliance hearing on 15 September 2025 [Paras 16(i)-(viii)].

Criminal Law - Criminal Complaint – Bar of Limitation – Section 468 CrPC – Cognizance Set Aside – Magistrate took cognizance only under Section 323 IPC (maximum punishment: one year) after three years of the alleged incident – Held: Section 468 CrPC applies; the complaint is barred by limitation – The Magistrate's and High Court’s orders set aside; complaint quashed [Paras 3–11].

Interpretation – Section 468(3) CrPC – Scope Limited to Joint Trial – Not Applicable When Cognizance Taken for Single Offence – Though the complaint alleged multiple offences including one under Section 452 IPC (punishable with up to seven years), cognizance was taken only under Section 323 IPC – Thus, the benefit of extended limitation under Section 468(3) CrPC not available – High Court misread the provision [Paras 6–9].

Legal Principle – Act of Court Cannot Prejudice – Limitation Relates to Date of Offence – Where delay in cognizance is due to court’s process and not complainant’s fault, bar may not apply – However, no justification or extension under Section 473 CrPC invoked in this case – Hence, bar under Section 468 CrPC attracted [Para 8].

Final Relief – Complaint Quashed – Cognizance Beyond Limitation Invalid – Appeal Allowed – The Supreme Court quashed Complaint Case No.13176 of 2018 – Cognizance taken on 27 September 2019 was beyond limitation for an offence under Section 323 IPC, alleged to have occurred on 5 September 2015 [Paras 10–11].

Criminal Law - Sections 420, 406, 467, 468, 473, 474, and 120B of the Indian Penal Code, 1860 - Quashing of FIR – Forged Lease Deed Used – FIR Restored – Allegation that accused used a forged lease deed to sell land and obtained ₹10 lakh as advance – Held: High Court erred in quashing FIR by relying on defence plea that accused were unaware of forgery or were willing to return money – Such issues are matters for trial – FIR restored for continuation of investigation and trial [Paras 2–10].

Plea of Defence – Not a Ground for Quashing – Accused Claimed to Be Victims Themselves – Rejected – Supreme Court reiterated that defence pleas cannot be considered at FIR stage – Even willingness to refund money does not negate commission of cognizable offence – Quashing order set aside [Paras 8–10].

Multiple FIRs – Distinct Transactions – Not Barred – Separate Victims, Separate Offences – Held: Presence of other FIRs relating to similar modus operandi does not make the current FIR a second FIR for the same offence – Each transaction with separate victim constitutes a distinct offence [Para 10].

Final Relief – FIR Quashing Set Aside – Criminal Proceedings to Continue – Supreme Court held that allegations made out a prima facie case – Investigation having culminated in a charge sheet, FIR and proceedings restored for trial – Appeal allowed [Paras 10–11].

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].

Civil Writ – Service Law - Performance Appraisal – Role of IAS Officers in IFS PAR – Government Order Quashed – Government of Madhya Pradesh issued a G.O. on 29th June 2024 allowing IAS officers to participate in the appraisal of IFS officers – Held: Such appraisal structure is contrary to Supreme Court’s binding rulings in Santosh Bharti and P.C. Wadhwa cases – Only officers from the IFS cadre can serve as reporting/reviewing authorities up to the level of Additional PCCF, with exceptions for PCCF level – Government Order quashed for violating binding judicial orders [Paras 1-3, 34-39].

Constitutional Governance – Contemptuous Nature of Administrative Orders – Judicial Orders Must Be Followed – The impugned G.O. was issued despite existing Supreme Court directions and without seeking clarification or modification – Held: The G.O. is contemptuous and demonstrates administrative disregard for the rule of law – Court refrains from initiating contempt proceedings but warns against future violations [Paras 36-39].

Service Jurisprudence – Reporting Authority Hierarchy – IFS Confidential Reports – Reporting and reviewing officers must be immediate superiors within the same department – Past judicial interpretations and DoPT/MoEF circulars reiterated this – Evaluation by non-IFS officers is impermissible unless officer works outside the department – Observed: Superior officers must be in higher rank and grade than the one being appraised [Paras 11-20, 24-26, 30-33].

Judgment – Government Order Struck Down – Relief Granted – The impugned G.O. dated 29th June 2024 is quashed and set aside – State directed to reframe rules within one month in compliance with the directions issued by the Court in Santosh Bharti and clarified by MoEF and DoPT [Paras 41-42].

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 Writ – PIL – Allegation of Fraudulent Cost Escalation – Prima Facie Rejected – Petitioner, a former MLA and PAC Chairman, alleged wrongful revision of estimates in PRRLIS causing Rs. 2,426.07 crores loss to public exchequer – Supreme Court upheld the High Court’s dismissal of the writ petition – Held: Allegations required factual adjudication not suitable for exercise of writ jurisdiction under Article 226 – Summary dismissal by High Court justified [Paras 1, 4, 10, 18].

CBI Investigation – Scope of Judicial Discretion – Writ Court’s Non-Interference Upheld – Petitioner sought CBI investigation into the alleged irregularities – Supreme Court held that the High Court was justified in refusing to refer the matter to CBI – Mere allegations unsupported by prima facie evidence or substantiated material do not mandate such referral – Discretion exercised by the High Court cannot be faulted in SLP proceedings [Paras 9, 19].

Res Judicata – Constructive Res Judicata – Repetitive Petitions by Same Petitioner – Earlier PILs by the same petitioner on related issues (Nos. 28/2016, 179/2016, 338/2017) were already disposed of – Present SLP found to be barred by principle of constructive res judicata – Also noted suppression of material facts by the petitioner – Held: Maintainability of repeated PILs on same subject matter is seriously questionable [Paras 13, 21].

Vigilance Report – CVC Finding Complaint Unsubstantiated – Evidentiary Value – Central Vigilance Commission had closed the complaint regarding PRRLIS packages 5 and 8 as unsubstantiated by order dated 12.09.2017 – Supreme Court noted this finding while rejecting prayer for further inquiry – Held: Findings of competent statutory body carry persuasive value in assessing prima facie case in PILs [Paras 14, 21].

Final Decision – No Interference Warranted – Supreme Court found no illegality in High Court’s decision – Held: No justification to reopen the matter or interfere with impugned judgment – Special Leave Petition dismissed [Paras 20, 22].

Criminal Law – Circumstantial Evidence – Murder Trial – Last Seen Together – Conviction based solely on the theory of ‘last seen together’ without corroborative evidence – Appellant convicted under Sections 302 and 201 IPC by Trial Court, affirmed by High Court – Supreme Court found chain of evidence incomplete – Held: Last seen theory alone, absent recovery of weapon or conclusive motive, insufficient to sustain conviction – Acquittal granted [Paras 7-9, 15, 18-25].

Evidence Act – Last Seen Theory – Weak Circumstantial Evidence – Witnesses PW-1, PW-2, and PW-13 saw deceased last in the company of appellant – However, no recovery made at appellant’s instance and no admission of guilt – Stone allegedly used in the offence recovered near the body, not via any disclosure under Section 27 Evidence Act – Blood stains found but blood group not matched – Held: Suspicion not sufficient to convict in criminal jurisprudence [Paras 13-18, 22-24].

Motive and Recovery – Absence of Clear Intent or Physical Evidence – Prosecution failed to establish any convincing motive linking the appellant to the murder – Allegations about suspicion over wife’s fidelity speculative and unsupported – No recovery of weapon from accused or based on his confession – No conclusive forensic linkage between the accused and the crime – Held: Conviction cannot rest on conjecture or hypothetical intent [Paras 16-18, 22-23].

Criminal Jurisprudence – Burden of Proof – Chain of Circumstances – Prosecution must establish a complete and unbroken chain of evidence – Contradictions in witness accounts regarding recovery site – Appellant did not abscond, joined search for deceased, and showed no guilty conduct – Held: Circumstantial evidence failed to exclude every hypothesis except guilt – Benefit of doubt extended [Paras 10-12, 15-16, 23].

Precedents – Standard for Circumstantial Conviction – Legal principles from Sharad Birdhichand Sarda, Kanhaiya Lal, and Sujit Biswas reiterated – ‘Last seen together’ rule cannot be the sole basis of conviction without supporting evidence – Absence of motive, lack of recovery, and inconclusive forensic analysis undermine prosecution case – Held: Strong suspicion cannot replace legal proof [Paras 12, 20-21, 24].

Decision – Appeal allowed – Conviction and sentence under Sections 302 and 201 IPC set aside – Appellant acquitted – Directed to be released if not required in any other case [Para 25].

Service Law – Environmental Law – Performance Appraisal Reports – Directions for Appraisal of IFS Officers – Impugned G.O. dated 29th June 2024 issued by the Government of Madhya Pradesh prescribed IAS officers as reporting/reviewing authorities for Indian Forest Service officers – Challenged for violating Supreme Court’s previous orders and established rules – Held: Up to the rank of APCCF, the reporting/reviewing/accepting authorities must be from within the Forest Department – G.O. found to be in contemptuous violation of previous directions by this Court [Paras 1-3, 34-39].

All-India Services Act, 1951 – Confidential Rolls Rules – Reporting Authority – Rule 2(e), (f), and (a) of the All India Services (Confidential Rolls) Rules, 1970 and All India Services (Performance Appraisal Report) Rules, 2007 – Definitions of ‘reporting authority’, ‘reviewing authority’, and ‘accepting authority’ require supervising officer to be higher in rank and preferably from the same department – Impugned G.O. violated statutory scheme and service hierarchy – Court emphasized the need for evaluation by immediate superior within the same service to maintain objectivity and fairness [Paras 9-13, 21, 24, 32-33].

Legal Precedents – P.C. Wadhwa Case – Santosh Bharti Case – Binod Kumar Case – Supreme Court reiterated earlier rulings that confidential reports must be written by superior officers within the same department – Recognized principle of hierarchy and familiarity with work as essential for fair evaluation – Orders of 22 September 2000 and 19 April 2004 in Godavarman case held binding – Government order contrary to these directions held illegal [Paras 22-26, 30-31, 33].

Administrative Practice – Central Empowered Committee Report – Ministry and DoPT Clarifications – Ministry of Environment & Forests and DoPT had issued clarifications directing that officers up to the rank of APCCF must be appraised by superiors within the Forest Department – Comments from IAS officers may be recorded on separate sheets but cannot replace Forest Department’s appraisal – These guidelines were binding on all states – The Court observed that all other states except Madhya Pradesh complied with these directives, reaffirming that departmental superiors must assess IFS officers’ performance [Paras 17-20, 27-29, 35-38].

Interpretation of Supervisory Hierarchy – Superior Rank and Departmental Familiarity – Supreme Court noted that authority under Rules must not only supervise performance but also be in higher rank and from the same department to ensure meaningful evaluation – Discretion under rules cannot override the structural principle of intra-departmental accountability – Court stressed the objective application of hierarchy in performance appraisal systems to prevent demoralization and ensure merit-based advancement [Paras 14-16, 23, 31].

Remedial Action and Institutional Guidance – Scope of Modifications – Attempt by Madhya Pradesh to alter the established scheme through G.O. without seeking clarification/modification from Court deemed improper – Directions issued in previous orders still hold the field – Role of CEC, DoPT, and MoEF reaffirmed as central to policy implementation – Court appreciated fair stand of Solicitor General and amicus curiae support [Paras 28-30, 36-38, 42].

Decision – Applications allowed – G.O. dated 29 June 2024 quashed – State of Madhya Pradesh directed to reframe rules within one month strictly following Court’s previous orders and statutory scheme – Appreciation recorded for Amicus Curiae and Solicitor General for fair assistance [Paras 40-42].