Criminal Law - Sections 7, 13(1)(d) read with 13(2), and Section 20 of the Prevention of Corruption Act, 1988 - Corruption Charges – Demand and Acceptance of Bribe – Proof Required – Acquittal Upheld – Respondent was accused of demanding and receiving ₹1,500 as bribe for submitting a spot inspection report – Trial Court convicted him based on recovery of tainted money – High Court acquitted him citing lack of credible evidence of demand – Supreme Court upheld acquittal, holding demand was not proven beyond reasonable doubt, and testimony of complainant lacked reliability [Paras 1, 6–7, 23–26].

Presumption under Section 20 of Prevention of Corruption Act – Applicability Conditional on Proof of Demand – Rebuttable Presumption Not Triggered – The Court clarified that presumption under Section 20 arises only upon proof of demand – In absence of credible evidence on demand, recovery alone does not sustain conviction – Cited decisions in Paritala Sudhakar and Om Parkash for proposition that presumption cannot substitute proof of demand [Paras 10, 24–25].

Credibility of Complainant – Contradictions and Admissions – Testimony Deemed Unreliable – Complainant denied prior spot inspection, then admitted the same upon confrontation with signed report – Such conduct considered sufficient to reject his testimony as unreliable – Benefit of doubt extended to accused [Paras 24–26].

Final Relief – Acquittal Not Interfered – Appeal Dismissed – Though High Court gave limited reasons for overturning conviction, Supreme Court independently examined the material and found no perversity in acquittal – Held: Chain of demand, acceptance, and recovery was incomplete – Appeal dismissed [Paras 27–29].

Criminal Law – Dishonour of Cheques – Quashing of Proceedings – Appellant filed complaint under Section 138 of the Negotiable Instruments Act, 1881 against a Partnership Firm and its partners, including Respondent, for dishonour of cheques aggregating ₹6 crores – High Court quashed proceedings against Respondent under Section 482 CrPC on ground that he had retired from partnership before issuance of cheques – Held: Retirement not duly notified under Sections 32, 62, 63, and 72 of Partnership Act – No public notice published – Respondent continued to be liable as partner – Order of High Court set aside – Trial to proceed [Paras 1–6, 9–14].

Negotiable Instruments Act – Section 141 – Vicarious Liability – Cheques signed by another partner (Accused No.2), but complaint contained specific averments of involvement of Respondent in day-to-day affairs and assurance of repayment – Held: Sufficient prima facie material to attract Section 141 NI Act – Signing of cheques by one partner does not absolve others where firm liability is pleaded and substantiated [Paras 11–12].

Criminal Procedure – Section 482 CrPC – Scope and Limits – High Court quashed criminal proceedings without trial based on disputed factual claims of retirement – Held: Disputed questions of fact and law cannot be adjudicated under Section 482 CrPC – Requires trial and evidence – High Court exceeded jurisdiction [Paras 13–14].

Decision: Appeal allowed – High Court's quashing order dated 23.09.2023 set aside – Criminal complaint proceedings restored for trial – No observation to affect merits of trial [Paras 14–15].

Insurance Law – Section 23 of the Consumer Protection Act - Flood Damage – Repudiation Based on Seepage – Held Invalid – Appellant’s premises suffered damage due to heavy rainfall between 25–31 August 2016—First surveyor attributed damage to flooding from rainwater—Insurer rejected claim citing “seepage,” based on a second survey—Held: Second survey arbitrary and unsupported—First survey and expert reports confirmed flood damage—Repudiation unjustified [Paras 3–9, 27–30].

Survey Report – Preference for First Survey Conducted Promptly – First survey conducted on 03.09.2016 concluded rainwater entered through flooring—No flaws cited—Second survey conducted after delay without justification contradicted earlier findings—Held: First report valid and reliable—Second report set aside [Paras 27–30].

Expert Evidence – Structural Engineer Reports Confirmed Flooding – Reports from M/s International Consultants & Technocrats and M/s Chordia Engineering Consultancy confirmed flooding due to rainfall—Unique Consulting Engineers’ report referred to unrelated seepage in structural elements—Held: No basis to infer seepage caused basement damage—NCDRC erred in relying on irrelevant structural data [Paras 14–17, 27–28].

Consumer Protection – Wrongful Repudiation – Arbitrary Conduct by Insurer – Insurer failed to address first survey or trace water source—Multiple surveys used to evade liability—Court found insurer’s approach mala fide and unfair—Set aside repudiation and remanded for quantum determination [Paras 19, 30–31].

Decision – Appeal allowed – Repudiation of claim set aside – Matter remanded to NCDRC for computation of compensation as per policy – Second survey report dated 18.10.2016 quashed – No costs [Paras 31–32].

Criminal Procedure – Transfer and Clubbing of FIRs – Multiple FIRs lodged against petitioner across 10 States for offences under IPC and local deposit protection laws – Petitioner initially sought transfer of all FIRs to Panchkula, Haryana – Court noted similar relief was denied in 2020 – Alternative prayer for consolidation within respective States allowed due to non-objection by respondent States – Held: Clubbing of FIRs within each State directed, with the earliest FIR to act as the principal FIR and subsequent FIRs to be treated as statements under Section 161 CrPC – Supplementary charge-sheets may be filed accordingly [Paras 1-3, 9-13, 19-22]

Criminal Law – Offences under IPC and Special Laws – FIRs allege offences under Sections 406, 420, 465, 467, 468, 471 IPC read with Sections 120B, 34, 263, 114 IPC and various State Acts such as the Gujarat Police Act, Haryana Depositors Act, and others – Petitioner accused of collecting deposits fraudulently via land allotment schemes – SEBI declined registration as Collective Investment Scheme citing pre-launch requirement – CBI preliminary inquiry reported KIDL lacked capacity to repay investors – Held: Trials must be held under Special Acts if any clubbed FIR invokes such legislation, even if principal FIR was under general law [Paras 4-8, 10]

Criminal Procedure – Bail Implications on Clubbed FIRs – Petitioner in custody since 11.10.2018 – Court directed that bail granted in the principal FIR would extend to clubbed FIRs unless they relate to special enactments or distinct IPC offences – In such cases, fresh bail applications must be moved and considered on merits – Direction issued under Article 32 read with Article 142 of the Constitution [Paras 20-21]

Legal Precedents and Jurisdiction – Reliance on Radhey Shyam v. State of Haryana and Abhishek Singh Chauhan v. Union of India – Court reaffirmed that multiplicity of proceedings not in public interest – Clubbing required to avoid conflict and ensure coherent prosecution – Clarified that if special laws are involved in subsequent FIRs, Special Courts shall retain jurisdiction [Para 10]

Decision: Writ Petition allowed – FIRs in Gujarat, Haryana, Himachal Pradesh, Madhya Pradesh, Punjab, Rajasthan, Uttar Pradesh, and Uttarakhand to be merged within each State respectively – Chhattisgarh and Delhi FIRs to proceed independently as only one FIR is pending in each – Proceedings to continue in line with directions under Article 142 of the Constitution [Paras 19, 22]

Criminal Procedure – Inherent Powers under Section 482 CrPC – High Court Cannot Recall Quashing Order – Held Without Jurisdiction - The Supreme Court held that once a final judgment quashing an FIR is passed, it cannot be recalled under Section 482 CrPC due to the bar under Section 362 CrPC – High Court exceeded jurisdiction by reviving a quashed FIR on grounds of compromise violation – Review or recall of final orders not permissible except for clerical or arithmetical errors [Paras 9–12, 14].

Criminal Law – Compromise Between Parties – Breach of Terms No Ground for Criminal Revival – Alternate Legal Remedies Available - Breach of compromise terms does not justify revival of quashed criminal proceedings – Held: Remedy for enforcement lies in civil proceedings or appropriate forums, not through recall of a concluded criminal order [Para 12].

Judicial Discipline – Section 362 CrPC – Recall Power Limited to Clerical Corrections – Law Reiterated - Court reiterated that once a final judgment is signed, courts become functus officio – Inherent power cannot override express prohibition in Section 362 CrPC – Exceptions allowed only in cases involving jurisdictional error, natural justice violations, or fraud [Paras 9.3.2–9.3.4, 10.1, 14].

Decision – Appeals Allowed – High Court’s Orders Recalled – Quashing Restored - Held: High Court acted without legal authority in reviving FIR – Supreme Court set aside all impugned orders and restored original quashing – Registry directed to circulate judgment to High Courts to prevent such procedural errors in future [Paras 13–16].

Civil Law - Execution of Decree – Successive Execution Petitions – Satisfaction Recorded in Prior EP Not a Bar – Fresh EP Maintainable on Subsequent Interference - Held: Recording of satisfaction in an earlier EP due to absence of decree-holder and written statement by judgment-debtor cannot bar future EP if fresh breach is alleged – Res judicata not attracted where new cause arises [Paras 2–4, 6].

Limitation – No Bar to Execution of Decree Granting Perpetual Injunction – Article 136 of Limitation Act – Perpetual Right of Decree-Holder - Supreme Court held that there is no limitation for execution of a decree granting permanent injunction – Right to seek enforcement survives perpetually against judgment-debtor, their assignees or successors whenever breach occurs [Para 7].

Civil Procedure – Objection under Section 47 CPC – Consideration Deferred to Executing Court – Only Prima Facie Observations Made - Apex Court clarified that its observations regarding objections under Section 47 CPC are prima facie – Objections can be re-agitated before Executing Court which shall decide afresh including claims about cancellation proceedings [Para 8].

Decision – High Court and Lower Courts’ Orders Set Aside – Execution Petition Restored - Supreme Court set aside all impugned orders and restored EP No. 2 of 2012 – Matter remanded to Executing Court for fresh consideration on merits, except on validity of decree which stands untouched [Paras 8–9].

Matrimonial Law – Transfer of Matrimonial Case – Divorce by Mutual Consent – Petition under Section 25 CPC – Allowed in part - The Supreme Court exercised its power under Article 142 to dissolve the marriage between the parties despite pending transfer petition – Mutual consent for divorce recorded, and transfer petition was accordingly disposed of [Paras 1-3, 10-11, 20-21].

Article 142 – Divorce by Mutual Consent – Settlement of Ancillary Issues – Liberty Reserved - Though mutual consent for divorce was granted, the petitioner insisted on return of stridhan or alternative monetary compensation – Liberty was reserved to the petitioner to pursue appropriate civil proceedings if Rs. 7,00,000 or stridhan articles are not returned by the respondent within 3 months – Respondent denied retaining stridhan – Court issued enabling direction for resolution while preserving petitioner’s remedies [Paras 6-13, 15-16].

Criminal Proceedings – Section 498A IPC – Quashing on Equitable Grounds – Criminal Complaint Quashed - Given the mutual consent divorce and settlement, the Court quashed the criminal complaint and proceedings under Section 498A IPC filed by the petitioner, holding there was no further purpose in prosecution [Paras 9, 18].

Jurisdiction – Article 142 – Equitable Relief and Complete Justice – Civil and Matrimonial Proceedings Disposed - The Court invoked its extraordinary jurisdiction to ensure complete justice between the parties by dissolving marriage, quashing criminal proceedings, disposing of both matrimonial suits and clarifying liberty to seek civil remedies [Paras 11, 14, 19, 22].

Decision: Transfer petition disposed – Marriage dissolved under Article 142 – Criminal complaint under Section 498A IPC quashed – Liberty granted to petitioner to pursue civil remedies for recovery of stridhan or equivalent compensation [Paras 13-16, 22].

Criminal Law - Bail – Section 302, 323, 427, 34, 120B of the Indian Penal Code (IPC) - Grant of Bail in Heinous Crime – Parameters of Judicial Discretion – Bail Cancelled – The Supreme Court set aside the High Court’s order granting bail to the accused in a case involving murder charges under Section 302 IPC – The Court found that the High Court had failed to adequately consider the heinous nature of the offence and the criminal antecedents of the accused, especially when the trial court had rightly refused bail for valid reasons – Held: The cryptic reasoning by the High Court warranted interference, and the Sessions Court’s denial of bail was restored [Paras 13–15, 19–20].

Investigation Stay and Bail – Incompatibility – Prejudice to Trial Process – The accused were granted bail by the High Court even while the trial proceedings remained stayed due to pending proceedings under Section 482 CrPC – The Court found that such simultaneous stay of trial and grant of bail created imbalance and potential prejudice – Held: Continuation of bail in these circumstances was unwarranted and legally untenable [Para 15].

No Reformatio in Peius – Safeguard in Appeal Proceedings – Relevance in Bail Orders – Though not directly reversing an appeal against acquittal or conviction, the Court emphasized that altering status of an accused beneficially without compelling grounds while higher judicial scrutiny is pending undermines fair process – Held: Criminal antecedents and gravity of offence should not have been diluted without detailed justification [Paras 14–15, 19–20].

Appellate Interference – High Court’s Bail Order – Cryptic Reasoning – Supreme Court held that the High Court’s order granting bail lacked reasoned analysis and failed to deal with the gravity of the allegations – The Court reiterated that bail in serious offences must be granted only with due diligence – Held: High Court order set aside and Sessions Court’s order denying bail restored [Paras 19–20].

Final Disposition – Supreme Court Directions – Accused Ordered to Surrender – Supreme Court directed the accused to surrender before the jurisdictional Magistrate or concerned Police Station by 16.06.2025 – Ordered deposit of passports at Police Station Nangal by 19.05.2025 – Held: Appeals allowed and High Court’s order granting bail set aside [Paras 21–23].

Civil Writ - Judicial Administration – Creation and Role of Court Managers – Thirteenth Finance Commission Recommendation – Approved - The Court Managers were introduced to improve court efficiency by supporting administrative functions, allowing judges to focus on adjudication – The Finance Commission allocated Rs. 300 crore for the scheme – Guidelines were issued by the Ministry of Finance prescribing the roles, qualifications, and functions of Court Managers – Implementation varied widely across States and High Courts, leading to disparity and ad hoc employment practices [Paras 5–12, 28–30].

Service Conditions – Contractual Appointments and Disparity in Pay – Non-Uniform Practices – Criticized - Most Court Managers were appointed on a contractual basis with no consistent service rules or benefits – The Supreme Court had earlier directed regularization (2018 judgment) – The SNJPC reiterated this need and recommended uniformity, higher pay, and structured recruitment and promotion avenues – Found that several High Courts and State Governments failed to act on the earlier directions [Paras 12–17, 31–36].

Model Framework – Assam Rules of 2018 – Adopted as Model – Recognized - The Court endorsed the Gauhati High Court’s 2018 Rules as a comprehensive model for adoption across jurisdictions – The Rules include regular appointments, clear duties, promotional avenues, and benefit structures – Other High Courts directed to take these Rules as a base with necessary modifications [Paras 39–42].

Directions Issued – Uniformity, Regularization, and Suitability Test – Mandated - All High Courts directed to frame or amend rules for Court Managers within 3 months based on Assam Rules – State Governments to approve within 3 additional months – Suitability tests to be conducted for existing Court Managers; those qualifying to be regularized with retrospective seniority but without arrears – Registrar Generals and Chief Secretaries made personally responsible for compliance [Paras 43–44].

Decision – Writ Petitions and IAs Disposed – Directions Binding - The Supreme Court disposed of the writ petitions and applications with binding directions to ensure regularization and standardization of the Court Manager system nationwide [Para 44].