Matrimonial Law – Divorce – Irretrievable Breakdown – Article 142 Invoked – Trial Court and High Court rejected husband’s petition under Section 13 on grounds of cruelty and desertion – Parties living separately for nearly two decades – Despite opportunity, mediation failed – Supreme Court held: Marital relationship broken beyond repair – Continued cohabitation futile – Marriage dissolved under Article 142 – [Paras 4–8, 10].

Constitutional Law – Article 142 – Complete Justice – Dissolution Despite Denial by One Party – Respondent-wife opposed divorce and denied cruelty – But long separation and lack of reconciliation attempts justified exceptional exercise of power under Article 142 – Held: Ends of justice warrant granting divorce to avoid further hardship – [Paras 7–8].

Family Law – Permanent Alimony – Lump Sum Settlement – Parties are government teachers – Appellant offered ₹15 lakhs; Court enhanced to ₹20 lakhs – Held: Fair and reasonable amount considering long separation and financial parity – Amount to be paid within two months – [Paras 9–11].

Civil and Criminal Proceedings – Closure on Divorce – Upon proof of payment of alimony, all pending proceedings between parties arising out of matrimonial dispute shall stand closed – [Para 12].

Decision: Appeal allowed – Orders of Trial Court (14.08.2012) and High Court (28.02.2014) set aside – Decree of divorce granted under Article 142 – ₹20 lakhs directed as full and final alimony – All pending proceedings to stand closed on compliance – [Paras 13–14].

Administrative Law – Power of Chief Justice – High Court Additional Sitting – Section 51(3) of States Reorganisation Act – Validity of Notification – Notification appointing Kolhapur as an additional place of sitting of the Bombay High Court challenged under Article 32 – Petitioner contended that such appointment amounts to establishing a permanent bench, requiring Presidential order under Section 51(2) – Held: Section 51(3) is an independent and continuing source of power – No requirement of central government approval – Power lies with Chief Justice with Governor’s approval – Establishment of additional place of sitting does not result in territorial bifurcation or require permanence – No colourable exercise of power – Reaffirmed precedent in State of Maharashtra v. Narayan Shamrao Puranik – [Paras 19–30, 55]

Judicial Administration – Role of Chief Justice – Consultation – Full Court not mandatory – Chief Justice is master of roster and head of administration – Statute does not require consultation with Full Court under Section 51(3) – While internal deliberation is desirable, absence thereof does not vitiate exercise of power – [Paras 31–37]

Judicial Review – Administrative Decisions – Scope – Courts will not interfere unless mala fides, extraneous considerations, or manifest illegality shown – No fundamental right of the petitioner violated – Objections pertain to policy disagreement, not legal infirmity – [Paras 18, 42–44, 54]

Equality before Law – Article 14 – Rational Basis – Selection of Kolhapur not arbitrary – Geographic proximity, volume of litigation, and logistical feasibility justify the decision – Simultaneous consideration of all regional demands not constitutionally required – Article 14 not violated – [Paras 45–48]

Access to Justice – Article 21 – Establishment of High Court sittings at convenient locations enhances access – Resource allocation is a policy matter – Decision furthers constitutional mandate – [Paras 49–52]

Decision: Writ petition dismissed – Notification dated 01.08.2025 upheld – Held to be within statutory power under Section 51(3) – No costs. [Paras 53–57]

Medical Education – BDS Admissions – NEET – Lowering of Qualifying Percentile – Power of Relaxation – Regulation II(5), Revised BDS Course Regulations, 2007 – Proviso vests exclusive power in Central Government in consultation with DCI – State Government has no authority to lower NEET percentile – Letter of Central Government directing “necessary action as deemed fit” does not amount to delegation – Relaxation granted by State of Rajasthan of 10% and additional 5% held illegal – Admissions pursuant thereto declared unlawful [Paras 42–46].

Interpretation of Statute – Delegation of Power – Absence of Enabling Provision – Delegation cannot be inferred by implication – Words “necessary action as deemed fit” cannot override express statutory mandate – High Court erred in treating Central Government communication as delegation of power [Paras 44–45].

NEET – Sanctity of Merit – Uniform Entrance Examination – Admission to MBBS/BDS must strictly conform to NEET Regulations – Dilution of eligibility impermissible except as expressly permitted – Reaffirmation of Sankalp Charitable Trust and Christian Medical College Vellore principles [Paras 40–41].

Private Dental Colleges – Unauthorized Admissions – Greed to Fill Vacant Seats – Admissions beyond even State-granted relaxation – Students with zero and negative percentile admitted – Reliance on 10+2 marks impermissible – Such admissions a mockery of statutory framework and destructive of educational standards [Paras 48, 60].

Promissory Estoppel – No Estoppel Against Statute – Colleges cannot claim protection based on State’s illegal relaxation – Admissions in violation of statutory regulations cannot be legitimized by equity or conduct – Reliance placed on Maharishi Dayanand University v. Surjeet Kaur [Para 49].

Students – Knowledge of Irregularity – No Conclusive Proof of Informed Consent – Students acted on assurances of colleges and interim court orders – Sole victims of administrative and institutional failure [Paras 50–53].

Article 142 – Complete Justice – Equitable Regularisation – Students who have completed BDS course and received degrees protected – Degrees regularised subject to filing undertaking to render pro bono services up to cumulative two years during public emergencies – Relief confined to peculiar facts and not to be treated as precedent [Paras 57, 59].

Medical Education – Outer Time Limit – BDS Course – Nine-Year Completion Rule – Students who failed to complete course within prescribed period not entitled to relief – Discharge upheld [Para 58].

Costs and Accountability – Deterrent Punishment – Private Colleges directed to deposit Rs. 10 Crores each – State of Rajasthan directed to deposit Rs. 10 Lakhs – Funds to be utilised for social welfare institutions under judicial oversight [Paras 62–63].

Decision:

Appeals partly allowed – High Court judgment modified –

(i) Admissions of students who have completed BDS course and obtained degrees regularised under Article 142, subject to pro bono service undertaking

(ii) Students who failed to complete BDS course within statutory time discharged

(iii) State-level reduction of NEET percentile declared illegal

(iv) Heavy costs imposed on erring colleges and State – Directions issued for utilisation of funds for social welfare – Appeals disposed of – No precedent value.

Forest Conservation – Lease of Forest Land for Agriculture – Illegality – State granted lease of 134 acres 6 guntas of forest land to cooperative society for agricultural purpose – Cultivation involved clearing trees and deforestation – Lease not liable to be extended and could not be continued through representation mechanism – High Court erred in granting liberty to seek continuation/extension through Central Government consideration – Held: permission for non-forest use (agriculture) is barred under Section 2 of Forest (Conservation) Act, 1980 without prior Central approval and continuation would perpetuate illegality [Paras 4, 5, 13-16].

Forest Land – Eviction Proceedings – Possession Taken – After lease termination and dismissal of earlier writ petitions/suits/appeals, Forest Department initiated eviction under Karnataka Forest Act/Manual – Eviction order passed – Department took possession on 23/01/2007 and placed caution boards – Held: once possession reverted to Forest Department, direction allowing respondent to seek continuation of lease is unsustainable [Paras 8-10, 16].

Environment & Forests – Non-dereservation Directions – Binding effect – Reliance on Supreme Court’s continuing mandamus/orders restraining de-reservation and requiring cessation of non-forest activities without Central approval – Held: cultivation on forest land is a non-forest purpose; no permission could be granted to allow such use contrary to Section 2 FCA and Court directions [Paras 11-14].

Relief – Restoration/Reafforestation – Mandatory direction – Appeal allowed – High Court orders set aside insofar as they enabled representation for continuation of lease – Forest Department directed to restore forest on 134 acres by planting indigenous species in consultation with experts – Compliance within 12 months – Matter listed for compliance report on 17/12/2026 [Paras 16-20].

Decision: Appeal allowed – Impugned High Court directions permitting representation for continuation of lease set aside – Forest Department directed to restore forest land by plantation of indigenous trees – Compliance within 12 months – Listed on 17/12/2026 for compliance report.

Service Law / Recruitment – Eligibility Condition – Driver Posts – Continuous valid driving licence for two years – Renewal after expiry – Break cannot be treated as “continuous” merely because renewal is granted – After Motor Vehicles (Amendment) Act, 2019, licence does not continue even for a single day beyond expiry and renewal takes effect from date of renewal – “Continuously” means uninterrupted legal capacity to drive – High Court orders treating expired-and-later-renewed licences as continuous set aside – Writ petitions dismissed [Paras 22-35].

Recruitment Notification – Technical qualification – “Must have possessed… LMV (Transport) / HMV licence… continuously for full two years and above as on date of notification” – Meaning – Must be read literally to require unbroken validity with no intervening period of expiry/disqualification – Weight must be given to use of word “continuously” and not treated as redundant [Paras 25, 32-33].

Motor Vehicles Act, 1988 – Sections 14 & 15 (post-2019) – Proviso to Section 14 granting 30-day continuation after expiry omitted – Statute now does not allow licence to continue after expiry even for a single day – Section 15 only provides a window for renewal but does not erase the legal disability during interregnum – Harmonious construction applied [Paras 27-31].

Interpretation – “Continuously” – Defined as “uninterruptedly; in unbroken sequence; without intermission… without intervening time” (Black’s Law Dictionary) – Applied to conclude that backdated/retrospective effect of renewal cannot be used to claim continuous validity for the gap period [Para 33].

Selection Process – Driving test at later stage – Does not dilute threshold eligibility – Candidate cannot gain eligibility merely because later driving proficiency is tested – Otherwise similarly placed candidates who did not apply considering themselves ineligible would be prejudiced (equality concern) [Para 34].

Decision: Appeals allowed – Impugned High Court Division Bench judgment dated 03/10/2023 and Single Judge interim orders dated 13/03/2023 & 28/03/2023 set aside – Underlying writ petitions dismissed – Recruitment process directed to be completed expeditiously, within three months – No order as to costs – Connected Diary No.12553/2024 appeals also allowed on same terms [Paras 35-37].

Criminal Law – Murder – Conviction – Affirmation – Deceased widow set ablaze for resisting sexual advances – Medical evidence proved homicidal death due to 60% burns – Hostile witnesses not fatal – Presence of accused and flight from scene proved through corroborative testimony – Dying declarations recorded by police officer and Magistrate found reliable and voluntary – Conviction under Section 302 IPC upheld [Paras 4–7].

Evidence Act – Dying Declaration – Multiple Declarations – Reliability – Dying declarations recorded by police officer and Magistrate corroborated by medical evidence – Doctor certified fitness of declarant – Minor inconsistencies and hostile witnesses do not dilute probative value – Sole dying declaration sufficient to sustain conviction [Paras 6–7].

Sentencing – Life Imprisonment – Meaning – Life imprisonment ordinarily means imprisonment for entire natural life subject to remission and commutation – Sessions Court has no power to direct that life sentence shall mean imprisonment till end of natural life without remission – Such power vests only in Constitutional Courts [Paras 9, 13–15].

Sentencing Policy – Special Category Sentence – Swamy Shraddananda (2) Principle – Life Imprisonment Without Remission – Power restricted to Supreme Court and High Courts – Sessions Courts incompetent to impose sentence beyond statutory framework – Reaffirmation of Constitution Bench ruling in V. Sriharan (Murugan) [Paras 11–15].

Criminal Procedure – Section 428 CrPC – Set-off – Mandatory Statutory Right – Period of detention during investigation, inquiry and trial must be set-off against sentence – Sessions Court cannot deny statutory set-off – Direction denying set-off illegal and liable to be deleted [Paras 16–17].

Remission and Commutation – Executive Power – Articles 72 & 161 – Cannot be curtailed by trial court – Accused entitled to be considered for remission as per law and government policy [Paras 9, 14–15, 18].

Sentencing Discretion – Proportionality – Heinousness of offence acknowledged – Case not warranting special category sentence of fixed minimum term without remission – Distinction from cases such as Ravinder Singh applied [Para 17].

Decision: Appeal partly allowed –

(i) Conviction under Section 302 IPC affirmed

(ii) Sentence modified to imprisonment for life simpliciter

(iii) Direction that sentence shall run till end of natural life set aside

(iv) Statutory set-off under Section 428 CrPC restored

(v) Accused entitled to consideration of remission/commutation as per law – Other sentences to run concurrently – Pending applications disposed of.

Service Law – Appointment from Rank List – Validity of Rank List vs. Communal Rotation – Vacancy Arising Due to Resignation – Appellant, a Scheduled Caste candidate, was second in rank list for Associate Professor post reserved for SC – First-ranked candidate (Dr. Anitha) resigned after serving over a year – Appellant claimed right of appointment during currency of two-year rank list under Section 31(10) – University rejected on ground of communal rotation under Section 31(11) – Held: Section 31(10) and Section 31(11) must operate harmoniously – Rank list provides validity period, but appointment must adhere to rotation rules during that time – Post reserved for SC deemed satisfied in form and substance by Dr. Anitha’s appointment – Fresh vacancy on resignation rightly assigned to Latin Catholic/Anglo Indian turn under roster [Paras 5.4–5.5.4, 6.4, 9–10].

Wait List – No Indefeasible Right – Appellant has no vested right to appointment from wait list unless vacancy corresponds with her category under roster – Vacancy post-resignation not earmarked for SC in roster cycle – Rejection justified [Paras 4.2, 5.5.2, 5.5.3, 7.4, 8].

Statutory Interpretation – Harmonious Construction – Sections 31(10) and 31(11) must be construed to avoid rendering either provision redundant – Communal rotation applies even during rank list’s validity – Wait list cannot override statutory reservation rotation [Paras 5.4.5–5.5.4].

Reservation – Fulfilment of Reserved Post – SC reservation deemed fulfilled upon appointment and probation of Dr. Anitha – Vacancy arising from resignation does not entitle same category appointment again if roster indicates otherwise – Held: Reservation not just in form, but must be in substance – Post cannot be recycled for same category [Paras 6.3–6.4].

Lien – Resignation Terminates Lien – Initial rejection of appellant’s claim based on lien of earlier appointee (Dr. Anitha) found untenable – Lien ends on resignation and substantive appointment elsewhere – Cannot be ground to deny appointment [Paras 5.1–5.1.2].

Decision: Appeals dismissed – High Court’s judgment and order affirmed – No costs.

Criminal Law – Murder – Conviction set aside – Prosecution case resting mainly on testimony of related eyewitness (mother of deceased) suffering from material contradictions – Non-examination of material witness (granddaughter who allegedly informed informant) – Independent witnesses turned hostile – Medical evidence not conclusively corroborating ocular version – Held: Prosecution failed to prove guilt beyond reasonable doubt – Accused entitled to acquittal [Paras 7–18].

Evidence – Related / Interested Witness – Mother of deceased claimed to be eyewitness – Law reiterated that testimony of related witness cannot be discarded solely on that ground but requires strict scrutiny – On facts, deposition contained serious inconsistencies regarding manner of assault, timing and presence at scene – Reliance on such testimony held unsafe [Paras 8–9, 13–15].

Evidence – Non-Examination of Material Witness – Granddaughter of informant allegedly first informant of incident not examined – Prosecution failed to explain omission – Adverse inference drawn against prosecution version [Paras 9, 14].

Witnesses – Hostile Independent Witnesses – PW-1, PW-2, PW-3 and PW-9 did not support prosecution case – Seizure and recovery of weapons through memorandum statements not proved – Recovery evidence held unreliable [Paras 10–11, 15].

Medical Evidence – Inconsistency with Ocular Testimony – Post-mortem revealed three incised wounds – Prosecution alleged use of sticks and one stone – Doctor failed to specify which injury was caused by which weapon – Improbability of incised wounds being caused by single stone – Medical evidence not supporting prosecution story [Paras 12, 16].

Common Object – Unlawful Assembly – Section 149 IPC – Mere presence of accused at spot without clear proof of participation or overt act insufficient – Failure to establish common object beyond reasonable doubt [Paras 14–16].

Standard of Proof – Criminal Trial – Benefit of Doubt – Where prosecution evidence suffers from contradictions, hostile witnesses and weak medical corroboration – Conviction cannot be sustained – Benefit of doubt must go to accused [Paras 15–17].

Decision: Appeals allowed – Judgment of Chhattisgarh High Court dated 17.02.2021 affirming conviction and sentence set aside – All appellants acquitted – Bail bonds discharged – Pending applications disposed of [Paras 18–20].

Criminal Law – Murder - Circumstantial Evidence – Last Seen Theory – Acquittal – Conviction based solely on “last seen together” without corroborative evidence is unsustainable – Appellant alleged to have taken deceased on motorcycle and later found to be dead – Trial Court and High Court convicted based on testimonies of PW-18 and PW-20 – Supreme Court held: Mere fact of last seen together, in absence of complete chain of evidence or motive, insufficient for conviction – Benefit of doubt must be extended – [Paras 1–6, 15–24, 34].

Evidence Law – Section 106 Evidence Act – Failure to explain last seen not conclusive – Court reiterated that Section 106 does not shift burden of proof from prosecution – Adverse inference under Section 106 applicable only when prosecution has established complete chain of incriminating facts – [Paras 29–33].

Motive – Lack of Proof – Prosecution claimed motive of looting a tractor to raise money to retrieve jeep – No evidence proving theft or sale of tractor by appellant – Recovery of tractor one month later from another location – Held: Motive not established – [Paras 15(i)].

Criminal Jurisprudence – Benefit of Doubt – Standard of Proof – Appellant convicted while co-accused acquitted on same evidence – Discrimination and incomplete chain of circumstances – Held: Possibility of appellant’s guilt insufficient; chain of evidence not complete – Acquittal directed – [Paras 7, 34].

Precedents – Application of Sharad Birdhichand Sarda principles – Supreme Court reaffirmed five golden rules for conviction on circumstantial evidence – Prosecution failed to meet cumulative threshold – [Paras 13–14].

Decision: Conviction under Sections 302 and 201 IPC set aside – Appellant acquitted – Bail bonds discharged – Appeal allowed – [Paras 34–36].