Criminal Writ - Challenging Continued Imprisonment Of Foreign Nationals - Illegal Detention – Post-Sentence Confinement – Unlawful Continuation of Custody – Court held that once a foreign national completes their sentence, they cannot be kept in prison merely due to pending deportation – Detention beyond sentence period is impermissible in absence of designated correctional homes – State of West Bengal directed to address infrastructure gap [Paras 11–14].

Detention Conditions – Absence of Dedicated Centres – Urgent Rectification Ordered – Court noted that West Bengal lacks correctional homes/detention centres for illegal immigrants – Despite sentence completion, immigrants remain confined in prisons – State directed to expedite construction of such centres and update progress [Paras 13–15].

Release Guidelines – Bail for Prolonged Post-Sentence Detention – Structured Conditional Release – Court ordered bail for immigrants detained for more than 3 years post-sentence, subject to bond, verifiable address, biometric data, weekly reporting and police supervision – Directions modeled on previous Supreme Court guidelines in similar cases [Paras 17–20].

Judicial Propriety – Matter Transferred to Larger Bench – Case Tagged – Court held the core issue is under consideration in pending petitions before a larger bench (W.P. (C) No. 859/2013) – This matter to be tagged for final resolution with connected cases – Interim relief provided without adjudicating constitutional validity of impugned clauses [Paras 6–10, 23].

Decision: Interim Bail Granted – All illegal immigrants detained in West Bengal prisons for over 3 years post-sentence to be released on bail with strict conditions – State directed to complete identification within 4 weeks – Case tagged with W.P. (C) No. 859/2013 for comprehensive adjudication [Paras 17–23].

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 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].

Education Law - Medical Education – Power of Committee to Create Corpus Fund – Not Traceable to Law – GO Dated 06.06.2018 Struck Down - The Court held that neither the Admission and Fee Regulatory Committee nor the State Government had legislative authority to mandate diversion of fees from NRI students towards a corpus fund for BPL/EWS scholarships – Such a measure, however noble, requires statutory sanction and cannot be imposed through executive fiat [Paras 16–20, 25–27].

Constitutional Law – Welfare Objective Cannot Override Statutory Limits – Absence of Legislative Backing Fatal - The Court acknowledged the intent behind the GO was laudable but emphasized that policy must operate within constitutional and statutory limits – Welfare schemes must be supported by legislation, not executive orders [Paras 26–27].

Education Law – Autonomy of Private Institutions – Article 19(1)(g) and Article 30 Rights Invoked - Self-financing medical colleges argued that diversion of fee amounts infringes their right to reasonable fee fixation and institutional autonomy – Court upheld the institutions’ right to utilize approved fees subject to reasonable regulation, but not for state-enforced welfare without statutory basis [Paras 6, 30].

Refund of Corpus Fund – NRI Students Not Entitled to Direct Refund – Court Orders Amounts Be Retained for In-House Subsidy - Though the collection was held illegal, the Court declined to refund corpus amounts to NRI students – Instead, it directed that funds be retained by respective institutions and used exclusively for subsidizing education of BPL students admitted therein [Paras 28–32].

Decision – GO Struck Down – No Further Collection Permitted – Funds Already Collected to Benefit EWS Students Only - Held: GO dated 06.06.2018 declared illegal and unsustainable – State directed not to collect any further corpus funds from NRI students – Amounts already collected to be retained in institutional accounts, to be used exclusively for BPL/EWS students within that institution [Paras 33–34].

Society and Trust Law – Religious Property Ownership Dispute – ISKCON Bangalore vs. ISKCON Mumbai – Long-standing dispute over title and management of ISKCON Bangalore resolved – Supreme Court held that ISKCON Bangalore, a registered Karnataka society, is the absolute titleholder of Schedule ‘A’ land allotted by Bangalore Development Authority (BDA) – Held: No legal basis to the claim of ISKCON Mumbai over said property via an unincorporated branch – High Court’s findings contrary to documentary evidence and thus set aside [Paras 33–51, 55–57].

Documentary Evidence – Land Allotment and Registered Sale Deed – Application for BDA allotment (Exh. P-51) made in name of ISKCON Bangalore, signed by its President – Sale deed dated 3rd August 1988 executed in favour of ISKCON Bangalore – All communications, payments, and ULC exemption corresponded to ISKCON Bangalore – No competing application from ISKCON Mumbai or proof of benami transaction produced – Held: Valid title passed to ISKCON Bangalore [Paras 44–51].

Statutory Interpretation – Section 38B BDA Act – Only societies registered under Karnataka Societies Registration Act or trusts under MPT Act eligible for BDA allotment – ISKCON Bangalore, being a registered society, legally eligible – No evidence of ISKCON Mumbai applying under trust provisions – High Court erred in overlooking statutory eligibility and clear application trail [Paras 52–54].

Branch Status and Legal Entity – No Independent Existence of “ISKCON Mumbai, Bangalore Branch” – ISKCON Mumbai failed to produce incorporation documents or authority letters – Application, sale deed, and ULC exemption made only by ISKCON Bangalore – Held: Mere reference to branch functioning does not confer legal title or ownership – Branch lacked legal personality to hold property [Paras 50–51].

Adverse Inference – Key Witness Withheld – ISKCON Mumbai did not produce Stoka Krishna Dasa, alleged source of manipulation claims – Court held that non-examination of material witness warranted adverse inference – Held: Allegations of fraud and manipulation unsubstantiated in absence of direct testimony [Para 47].

Procedural History – Trial Court Decree in Favour of ISKCON Bangalore Restored – High Court Judgment in RFA No. 421 of 2009 reversed – All related appeals rendered infructuous – Oversight Committee managing temple to be dissolved after one month [Paras 56–58, 73(d)].

Internal Governance Dispute – Governing Body of ISKCON Bangalore – Suit No. 1758 of 2003 by members claiming to be rightful management dismissed – Concurrent findings by Trial Court and High Court accepted – Annual General Meeting of 1 July 1984 validly elected new governing body – Plaintiffs’ evidence found weak, contradictory and largely withdrawn – Held: No interference warranted in findings of fact [Paras 59–70].

Decision: Civil Appeal Nos. 3821–3822 of 2023 dismissed – Civil Appeal No. 9313 of 2014 allowed – High Court findings in RFA No. 421 of 2009 set aside – Decree in Suit No. 7934 of 2001 in favour of ISKCON Bangalore restored – Oversight Committee dissolved after one month – All connected appeals disposed of as infructuous – No order as to costs [Paras 73–74].

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].

Employment Law - Public Employment – Format of Caste Certificate – Format compliance mandatory – Rejection of candidature upheld – Petitioners submitted OBC-NCL certificates in Central Government format rather than in the format required by the State of Uttar Pradesh – Clause 5.4(4) of recruitment advertisement clearly specified the required format and the consequence of non-compliance – Held: Non-submission in the prescribed State format rendered petitioners ineligible for OBC reservation – Authority acted within jurisdiction by excluding petitioners from consideration under OBC category [Paras 14–17].

Recruitment Rules – Non-discretionary application – Procedural fairness does not override explicit requirements – Plea that the Board should have granted a chance to correct the certificate format rejected – Held: Opportunity already existed at the time of application – Procedural fairness does not mean condoning clear procedural defaults – Equal treatment requires adherence to rules by all [Paras 19–21].

Judicial Review – Limited role of Courts – No interference when recruitment norms are unambiguous – Held: Recruitment authority is entitled to frame and implement rules unless proven to be arbitrary or violative of constitutional rights – Courts will not dilute terms of advertisement by equitable considerations unless warranted by exceptional circumstances [Paras 19–20].

Article 141 – Precedent – Summary dismissal of SLPs does not constitute binding law – Reference to previous reliefs granted to similarly situated candidates not helpful – Held: Dismissal of Special Leave Petitions in limine without reasons does not have precedential value – Does not create binding precedent under Article 141 of the Constitution [Para 23].

Decision of the Court – Appeals decided accordingly – Civil Appeal No. 5233 of 2025 (Mohit Kumar) dismissed – Civil Appeal No. 5234 of 2025 (State of U.P.) allowed – Held: Requirement of caste certificate in prescribed State format is justified and non-arbitrary – Rejection of candidature sustained [Paras 24–25].

Suo Motu - POCSO Cases – Setting Up of Exclusive Courts – Implementation of Judicial Directives – Compliance Directed - The Court directed that each district with more than 100 POCSO cases must establish exclusive courts under a Central scheme with appropriate staffing and child-friendly infrastructure – Majority of States complied but high-pendency States (UP, WB, Bihar, TN, Orissa, Maharashtra) were found lacking – Held: Union and State governments must prioritise timely establishment of such courts [Paras 1, 3, 5-6].

Forensic Delay – Effective Functioning of FSLs – Expedited Processing Ordered – Court acknowledged forensic delays as key bottleneck in trial completion – Directed State Forensic Labs to ensure swift analysis and reporting in POCSO cases – Mandated Chief Secretaries to ensure compliance [Para 1].

Child Sensitisation and Support – Appointment of Trained Support Persons and Prosecutors – Awareness Measures – Directions were issued to appoint child-sensitive support persons and prosecutors, and to run public awareness campaigns in cinemas and media with helpline information prominently displayed – Responsibility assigned to Ministry of Women and Child Development [Paras 1, 4].

Timely Trial – Adherence to Statutory Deadlines – States Reminded of Duty – Despite POCSO Act’s time-bound process for investigation and trial, delay persists due to inadequate infrastructure – States instructed to strictly follow the law and ensure completion of investigations and trials within statutory periods [Paras 2, 6].

Closure of Proceedings – Compliance Noted – Matter Concluded – Noting significant implementation of earlier directions and pending areas requiring attention, the Court closed the suo motu proceedings with appreciation for the amicus curiae and counsel – Held: Further monitoring not required at this stage [Paras 7-8].

Criminal Law - Probation of Offenders Act – Inapplicability under PoFA Act – Section 20AA prohibits probation – Probation benefit denied - Section 20AA clearly excludes the application of the Probation of Offenders Act and Section 360 of the CrPC to those convicted under the PoFA Act unless the offender is under 18 years of age – The Court held that the provision is explicit, unambiguous, and constitutionally valid – Hence, probation not applicable [Paras 40-42].

Mollification of Sentence – FSS Act Repeal and Savings Clause – Reduced punishment not permitted – Benefit denied - Despite lesser punishment under the FSS Act, the repeal and savings clause under Section 97 preserves penalties under the repealed PoFA Act – The Court held that the presence of such a clause prevents application of lighter sentence from new law – Hence, no reduction in sentence permissible under FSS Act [Paras 43-44].

Adulteration Evidence – Discrepancy in Reports – Sentence converted to fine – Lead appeal partly allowed - In the case of Nagarajan and Selvaraj, the two lab reports on curd adulteration had significant differences—one showing deficiency in fat content, the other meeting the required standard – Applying precedent in C. Mohammed, the Court converted the 6-month imprisonment to a fine of Rs. 30,000 each [Paras 45-46].

Judicial Comity – Reliance on Coordinate Bench despite disagreement – Connected appeal partly allowed - Although the Bench disagreed with the reasoning in A.K. Sarkar & Co., it followed the decision to prevent further litigation, converting Naresh Chandra’s sentence to a fine of Rs. 20,000 in the interest of equity and justice [Paras 47-48].

Decision – Convictions upheld, Sentences modified – Probation relief and sentence reduction under FSS Act denied – However, due to specific factual circumstances and prior rulings, sentences were converted to fines – Appeals partly allowed [Paras 48-51].