Facts:The appeals concern assessees who established manufacturing units in specified areas, including Himachal Pradesh, and claimed exemption at 100% under Section 80-IC for the first five assessment years. They sought continued exemption at the same rate for the subsequent five years based on substantial expansion.

Issues:

Whether assessees, after availing 100% exemption for the initial five years under Section 80-IC, are entitled to claim the same rate of exemption for the next five years due to substantial expansion.

Held:

The Court rejected the assessees' claim and ruled in favor of the Revenue. It held that once the initial assessment year commences and the assessee starts enjoying deduction under Section 80-IC, there cannot be another initial assessment year within the 10-year period, even with substantial expansion. The Court emphasized the clear provisions of sub-sections (3) and (6) of Section 80-IC, limiting the deduction to 100% for the initial five years and 25% (or 30% for companies) for the subsequent five years, with a total cap of 10 years.

The Court distinguished this case from previous judgments where assessees claimed deductions under different provisions. It clarified that in this case, the assessees had initially claimed deductions solely under Section 80-IC. Therefore, the Court held that after availing deduction for the initial five years at 100%, the assessees are entitled to deduction for the remaining five assessment years at the rate of 25% (or 30% for companies), as per the provisions of Section 80-IC.

The appeals were allowed, and the Court directed the Assessing Officer to carry out fresh assessments and pass appropriate orders accordingly. No costs were awarded in the case.

Facts:

In a writ petition filed by the appellants against the State in the High Court of Punjab & Haryana, the appellants sought ad-interim stay during the pendency of the writ petition regarding a land matter. The High Court declined to grant the ad-interim stay, citing that the required land was vacant.

Issues:

The High Court's refusal to grant ad-interim stay during the pendency of the writ petition.

Held:

The Court allowed the appeal, setting aside the impugned order, and remanded the case back to the High Court for fresh consideration. The Court found two main reasons for remand: Firstly, the impugned order lacked adequate reasons for not granting the stay. Secondly, the reason provided by the High Court did not justify the rejection considering the nature of the controversy involved in the writ petition.

The Court emphasized the need for justifiable reasons to support either the grant or rejection of the stay application. Therefore, the case was remanded to the High Court to reconsider the ad-interim prayer made by the appellants or consider disposing of the writ petition itself based on merits and in accordance with the law.

Facts:

The case involved a challenge to the validity of Rule 3(1)(c) of the Medical Colleges and Dental Colleges of Assam (Regulations of Admission into 1st year MBBS/BDS Courses) Rules, 2017, which stipulated eligibility criteria for state quota seats. The rule required candidates to have obtained education from Class VII to XII in the State of Assam.

Issues:

Whether Rule 3(1)(c) violated Article 14 of the Constitution, which guarantees equality before the law.

Held:

The Court upheld the validity of Rule 3(1)(c), stating that it was permissible to lay down essential educational requirements and residential/domicile conditions for basic courses like MBBS/BDS/Ayurvedic. This decision was in line with previous rulings where preferences for state residents had been upheld to uplift educational standards and ensure service to the state.

The Court found that the exclusion of certain categories of students, such as those whose parents were government employees of other states or private employees working outside the state, was justified. Such students were less likely to return to the state after completing their education elsewhere.

Concerns about students obtaining education outside the state for better coaching were addressed by stating that they could compete for All India Quota seats or open seats within the state if they could afford coaching in other states. The criteria laid down in Rule 3(1)(c) were deemed to be in line with the spirit of Article 14.

Decision: The petition was dismissed, affirming the validity of Rule 3(1)(c) and stating that it did not violate the constitutional principle of equality.

Facts:

The case involves the State of Karnataka appealing against the acquittal of the respondents (accused) for the offense under Section 302 IPC.

The prosecution alleged that the accused conspired to murder Mohan Kumar due to his wife's alleged illicit relationship with one of the accused.

Issues:

Whether the evidence presented by the prosecution is sufficient to establish the guilt of the accused beyond a reasonable doubt.

Whether the acquittal of the respondents by the High Court should be upheld or overturned by the Supreme Court.

Held:

The Court, after careful consideration of the evidence and legal arguments, upheld the acquittals of respondent nos. 1 and 2. The court found that the evidence presented by the prosecution was insufficient to establish guilt beyond a reasonable doubt. Specifically, the court noted:

The weaknesses in the prosecution's case, including the retraction of extra-judicial confessions and the lack of substantive evidence supporting the allegations against the accused.

The court emphasized that an extra-judicial confession is a weak piece of evidence and must be supported by other substantive evidence, which was lacking in this case.

The photographs recovered from one of the accused only indicated an illicit relationship but did not establish involvement in the murder conspiracy.

Therefore, the court concluded that there were no compelling reasons or substantial infirmities warranting interference with the order of acquittal.

Facts:

An F.I.R. was lodged against the appellant by PW-1, a Sub-Inspector, alleging possession of opium.

The appellant was searched in the presence of a Gazetted Officer, leading to the recovery of 4 kg of opium.

Certain irregularities were noted in the investigation, including the absence of deposition of seized narcotics in the malkhana, delay in sending samples for analysis, and non-examination of key witnesses.

The appellant alleged false implication due to a dispute with PW-1.

Issues:

Whether the investigation in the present case was fair and judicious, considering the reverse burden of proof under the NDPS Act.

Whether the involvement of the informant as the investigating officer affects the fairness of the investigation.

Whether the prosecution established a prima facie case beyond reasonable doubt before shifting the burden of proof onto the accused.

Held:

The Court held that the investigation in the present case was not fair and raised serious doubts about its veracity. Several irregularities, such as the failure to deposit seized narcotics in the malkhana, delay in sending samples for analysis, and non-examination of key witnesses, undermined the credibility of the prosecution's case. The involvement of the informant as the investigating officer was deemed to compromise the fairness of the investigation, especially under laws like the NDPS Act with a reverse burden of proof. The Court emphasized the importance of a fair investigation as a constitutional guarantee under Article 21 of the Constitution. It was held that the appellant should be acquitted due to the infraction of the constitutional guarantee of a fair investigation, and the prosecution was held to be vitiated. Consequently, the appellant was directed to be set at liberty forthwith unless wanted in any other case.

Facts:

A motor accident claim was filed after the death of Sanoj Kumar in a road accident.

The driver of the vehicle involved in the accident was found to be driving negligently and in a rash manner.

The Motor Accident Claims Tribunal partly allowed the claim but absolved the insurance company from liability because the driver had a fake driving license.

The vehicle owner appealed to the High Court, which upheld the Tribunal's decision.

Issues:

Whether the insurer could be absolved of liability solely based on the driver possessing a fake license.

Held:

The Court found that neither the Tribunal nor the High Court adequately analyzed whether the owner was aware of the fake license.

The Court emphasized that the mere existence of a fake license does not automatically absolve the insurer from liability. It is essential to prove that the owner was aware of the fake license and took no corrective action.

The Court referred to previous judgments, including PEPSU Road Transport Corporation v. National Insurance Company and Premkumari v. Prahlad Dev, to highlight the importance of the owner's awareness in such cases.

Accordingly, the Court set aside the High Court's judgment and remanded the case back to the High Court for fresh consideration solely on the question of liability for compensation. No other issues were to be examined in the remand proceedings.

Facts:

The appellant was convicted under Section 18 of the NDPS Act based on the recovery of opium from his possession during a police check.

The trial court acquitted the appellant, citing non-compliance with Section 50 of the NDPS Act and insufficient evidence regarding the production of contraband before the court.

The High Court reversed the trial court's decision based on oral evidence presented by prosecution witnesses indicating the production of contraband before the Magistrate.

Issues:

Compliance with legal procedures, particularly Section 50 of the NDPS Act.

Sufficiency of evidence regarding the production of contraband before the court.

Held:

The Court analyzed the evidence and found discrepancies regarding the production of contraband before the Magistrate. The Court emphasized the necessity of producing contraband substances seized from the accused before the trial court, citing precedents. It noted the absence of documented evidence supporting the oral testimony regarding the production of contraband. The Court reiterated the principle that in appeals against acquittals, interference is warranted only if substantial and compelling reasons exist.

The Supreme Court concluded that the findings of the trial court were not distorted, and there were no compelling reasons to interfere with the order of acquittal. Thus, the conviction of the appellant under Section 18 of the NDPS Act was set aside, and the appellant was acquitted of the charge.

Facts:

The case involves a contractual dispute between M/s Vijay Nirman Company Pvt. Ltd. and M/s Ksheerabad Constructions Pvt. Ltd., which was referred to an Arbitral Tribunal. The respondent obtained an Arbitral Award against the appellant. Subsequently, the respondent initiated insolvency proceedings against the appellant under Section 9 of the Code.

Issues:

Whether the Insolvency and Bankruptcy Code can be invoked for an operational debt when an Arbitral Award has been passed but not yet finally adjudicated upon.

Held:

The Court referred to its previous judgment in Mobilox Innovations Private Limited vs. Kirusa Software Private Limited and emphasized that the existence of a dispute is crucial before invoking the Insolvency Code. It was held that the mere pendency of a Section 34 petition challenging an Arbitral Award indicates a pre-existing dispute, which continues even after the Award until final adjudication. The Court stated that operational creditors cannot use the Insolvency Code prematurely or for extraneous considerations. The judgment of the Appellate Tribunal was set aside, and the appeals were allowed in favor of the appellant. The bank guarantees furnished were discharged.

Facts:

The case involved two separate special leave petitions, each challenging a decision by a High Court affirming the appellant's conviction under Section 302 IPC and his sentence of imprisonment for life.

The prosecution's case relied on the testimony of two eyewitnesses, PWs 3 and 5, which was found reliable by the respective High Courts.

Issues:

Whether the convictions under Section 302 IPC should be overturned based on the appeals presented by the appellant.

Held:

The Court dismissed both special leave petitions.

It upheld the decisions of the respective High Courts, finding no reason to interfere with the convictions and sentences imposed.

The Court also commended the direction by the Supreme Court Legal Services Committee to facilitate video conferencing between counsel and accused individuals, emphasizing the importance of effective communication for meaningful legal representation.

It directed all Legal Services Authorities/Committees in every state to extend similar facilities for video conferencing in criminal cases involving accused individuals in jail.