Regular Bail – Sexual Offences – Allegations Under IPC Sections 376, 377, 384, etc. – Bail Granted - The appellant was accused of serious offences including rape, blackmail, and assault by a woman nearly twice his age – The FIR was followed by a charge sheet including multiple IPC provisions – The High Court had rejected regular bail – Supreme Court noted interim bail had been granted earlier, and the complainant did not appear despite notice – Held: Considering the nature of relationship, age gap, alleged business dealings, and prolonged custody since 07.08.2024, regular bail is justified – Impugned order set aside – Bail granted on conditions to be imposed by Sessions Court [Paras 1-3, 7].

Frivolous Allegations – Consensual Relationship Plea – Age Disparity – Accused’s Argument Accepted - The appellant contended that the complainant was 42 years old while he was only 21, and that the relationship was consensual and commercial – Supreme Court did not delve into the truth of the claims but acknowledged the argument as relevant for bail consideration – Held: Charges not yet framed; allegations appear doubtful prima facie – No justification to keep appellant in further custody [Paras 2-3].

Failure to Prosecute – Non-Appearance of Complainant – Interim Bail Made Absolute – Despite prior notice and adjournment, the complainant did not appear – Court recorded counsel’s submission that he had no vakalatnama or instructions – Held: Absence of complainant and prolonged interim bail weighed in favour of granting regular bail [Para 2].

Decision  – Impugned Order Set Aside – Appeal Allowed – Supreme Court allowed the appeal, set aside the Delhi High Court’s rejection of bail, and directed that the appellant be released on regular bail upon appearance before Sessions Court on 19.09.2025 – Held: Sessions Court to impose appropriate conditions for bail – Pending applications also disposed of [Paras 6-8].

Anticipatory Bail – Modification of Conditions – Judicial Propriety – Respondent No. 1 accused in 31 criminal cases involving serious financial offences under IPC and BUDS Act – High Court granted anticipatory bail subject to condition not to leave India without prior permission – During pendency of SLP challenging said bail order, respondent filed application before High Court seeking permission to travel abroad – High Court allowed modification and released passport without disclosing to Supreme Court that such relief had been sought – Held: Conduct of respondent undermines judicial discipline and violates comity between courts – All orders passed by High Court modifying bail conditions during pendency of SLP stayed [Paras 1–11].

Judicial Discipline – Hierarchical Judicial System – Supreme Court emphasized that though High Courts are not subordinate, once a matter is under challenge and seized by the Supreme Court, High Courts must exercise restraint from modifying or passing orders that may prejudice pending proceedings – Reference made to Tirupati Balaji Developers v. State of Bihar and Chhavi Mehrotra v. DGHS highlighting the need for deference and avoidance of parallel jurisdictional exercise [Paras 8–10].

Suppression and Misconduct – Respondent’s Failure to Inform Supreme Court – Though respondent filed application before High Court on 06.07.2025, no disclosure made to Supreme Court when case was listed on 14.07.2025, 25.07.2025, and 25.08.2025 – Counter affidavit dated 14.07.2025 silent on application for modification – Held: Court expresses grave displeasure and issues notice to respondent as to why pre-arrest bail should not be cancelled due to concealment [Paras 12–13].

Interim Directions – Respondent No. 1 restrained from leaving India without permission of Supreme Court – Directed to surrender her passport immediately – Response to show-cause notice to be filed within three weeks with relevant documents [Paras 13–15].

Decision: Orders passed by High Court in Crl.MC No. 6178/2025 and Crl.M.A. No. 1/2025 modifying bail conditions stayed – Show cause notice issued to respondent regarding cancellation of anticipatory bail – Case listed for further orders on 26.09.2025.

PIL - Anand Karaj marriages—Section 6, Anand Marriage Act—States/UTs directed to notify rules within 4 months—Till then, registration to be facilitated under existing marriage registration frameworks without discrimination—Union of India to coordinate and file compliance report—Petition disposed with time-bound directions [Paras 11–16].

Constitutional Duty – Registration of Marriages – Section 6 of the Anand Marriage Act imposes a positive duty on States to establish registration machinery for Anand Karaj marriages – Duty not optional or contingent on population size – Non-notification frustrates legislative intent of 2012 amendment [Paras 7–8].

Civil Consequences of Registration – Marriage certificates enable proof of status for residence, maintenance, inheritance, succession, and enforcement of monogamy – Particularly safeguard rights of women and children – Unequal access across jurisdictions violates equal treatment [Para 9].

Harmonisation with Existing Frameworks – Until rules are notified, general marriage registration frameworks must accept Anand Karaj marriages on the same footing as other marriages – Certificate to record that marriage was solemnised by Anand Karaj where parties so request [Para 10].

General Directions – (i) All States/UTs without rules to notify within 4 months; (ii) immediate registration under existing laws without discrimination; (iii) States with rules to issue clarifications within 3 months; (iv) Nodal officer to be designated within 2 months; (v) Union of India to coordinate and circulate model rules, and file consolidated status report in 6 months [Para 12].

Special Directions – Goa: Interim registration under civil registration offices; Union to extend Anand Marriage Act within 4 months; Goa to frame rules within 4 months thereafter [Para 13]. – Sikkim: Interim registration under 1963 Rules; Union to consider extension under Article 371F(n); Sikkim to notify rules within 4 months after extension [Para 14].

Decision – Writ petition disposed of with directions—Time-bound rule-making mandated—Interim facilitation under existing frameworks ordered—Compliance affidavits to be filed by States/UTs; Union to file consolidated status report in 6 months [Paras 15–16].

Anticipatory Bail – Allegations of Rape and Sexual Assault – IPC Sections 376(1), 377, 354A – Bail Granted - The appellant, alleged to be a spiritual leader, was accused of sexually exploiting a married woman and others – The FIR was lodged after delay, and the High Court had rejected anticipatory bail – Supreme Court noted earlier grant of interim protection and found the case suitable for anticipatory bail – Held: Order of High Court set aside; anticipatory bail granted with conditions including cooperation in investigation and restraint from tampering with evidence [Paras 1-3].

False Implication – Allegations of Conspiracy and Blackmail – Delay in Filing FIR - Appellant contended that the complainant and her husband fabricated the case using videos to create false evidence for ulterior motives – Further claimed the relationship was consensual – Held: Without commenting on merits, Supreme Court found grounds sufficient for anticipatory bail as the FIR was belated and under suspicious circumstances [Paras 2-3].

Serious Allegations – Accused as Spiritual Leader – Court Balances Liberty and Investigation – The complainant alleged that the appellant misused his position as a godman to exploit women – The Court recognized the seriousness but emphasized liberty and fair process – Held: Conditional anticipatory bail appropriate; liberty not to be misused, and any breach would lead to cancellation [Paras 2-3].

Decision – Appeal Allowed – Anticipatory Bail Granted – The Supreme Court set aside the Bombay High Court’s order and granted anticipatory bail on furnishing ₹25,000 cash security with two sureties – Directions issued for cooperation and non-interference with evidence – Held: Non-compliance would lead to cancellation of bail [Para 3].

Motor Accident Claim – Causal Connection Between Accident and Death – Claim Rejected - The deceased, an Excise Guard, died of pulmonary embolism five months after sustaining leg and finger fractures in a road accident – Supreme Court upheld High Court’s finding that there was no proximate or direct causal link between the accident and death – Held: Death not attributable to accident injuries; post-surgical complications with pre-existing diabetes and hypertension more likely cause [Paras 1-11].

Expert Evidence – Doctor’s Testimony Inconclusive – Medical Opinion Favoured Natural Cause - PW-1, the plastic surgeon, opined the death was due to myocardial infarction, and though stated long bed rest could trigger embolism, he admitted to no post-mortem and acknowledged cardiac risk factors – Held: Absence of conclusive medical evidence and lack of post-mortem weakens claimants’ case; expert's deposition supported natural medical cause [Paras 6-7].

Preponderance of Probability – Not Established – No Clear Nexus Between Injury and Death - Supreme Court reiterated that even in civil cases requiring lesser standard of proof, the causal connection must meet preponderance of probability – Held: Injuries were not serious; death occurred after successful skin grafting – No evidence of extended immobility or bed rest [Paras 8-11].

Final Disposition – High Court Judgment Affirmed – Claim for Death Compensation Denied - Tribunal’s finding of causality reversed by High Court based on medical evidence – Supreme Court declined to interfere, holding the reasoning sound and based on expert medical testimony – Held: No compensation payable for death; claimants still entitled to compensation for injuries [Paras 11-12].

Service Law – Recruitment – Medical Examination – Candidate (ST woman) qualified prelims, mains, interview and document verification – Rejected for not appearing in medical test scheduled for “next day” after interview – Ambiguity in advertisement regarding date of medical test and no penal consequence prescribed – Held: Rejection disproportionate – Procedure is handmaiden of justice, not a tool for injustice – Non-appearance cannot nullify candidature [Paras 6.2–13, 17].

Constitutional Law – Equality – Indirect Discrimination – Neutral rule prescribing medical test immediately after interview caused disproportionate hardship to marginalised ST candidate – Court applies principle of indirect discrimination (Nitisha v. Union of India) – State duty-bound to prevent such exclusionary impact [Paras 13–15].

Administrative Law – Procedural Fairness – No mechanism for condoning absence or giving opportunity of hearing in case of missed medical test – Candidate’s omission not deliberate – Strict exclusion held arbitrary and unfair [Paras 9–11, 16–17].

Relief – One-time relaxation granted – Supreme Court directs Commission to conduct appellant’s medical examination – If found fit, respondents to create supernumerary post and appoint her with continuity of service and seniority but without back wages [Paras 18–19].

Decision: Appeal allowed – High Court’s orders dated 10.04.2024 and 03.09.2024 set aside – Appellant directed to be medically examined; on clearance, to be appointed against supernumerary post with continuity of service but no financial arrears [Paras 18–20].

Limitation Law - Motor Accident Claim – Disbursement of Compensation – Review Rejected – Delay Not Condoned – Appellant sought review of Tribunal's disbursement order alleging unfair distribution of compensation among legal heirs – Tribunal rejected review on grounds of delay (6 months, 22 days) and absence of medical evidence – High Court affirmed dismissal – Supreme Court upheld findings – Held: Appellant signed joint application and accepted cheque without protest – Review rightly dismissed [Paras 1–7].

Limitation – Review Application – Sufficient Cause Not Proved – Tribunal and High Court found no credible explanation for delay – Appellant failed to produce medical records to support claim of illness or surgery – Delay appeared to be afterthought – Courts below correctly applied settled principles of limitation law [Paras 3.4, 5, 6.4].

Estoppel – Approbat and Reprobat – Conduct Precludes Challenge – Appellant signed joint disbursal application and received ₹1,00,000/- without demur – Later attempt to challenge disbursement order treated as reversal of conscious conduct – Held: A party who voluntarily accepts benefits under a court order cannot later dispute its validity – No question of fraud or suppression arose [Paras 5.4, 6.1–6.3].

Final Decision – Appeal Dismissed – No Interference Warranted – Supreme Court found no error in decisions of Tribunal or High Court – Appellant’s challenge to disbursement treated as legally unsustainable – Appeal dismissed with observations on conduct [Para 7].

Civil Law - Will – Testamentary Succession – Section 67 of Indian Succession Act – High Court’s Finding Set Aside – Appellant claimed rights under joint will by parents – Trial and Appellate Courts upheld validity of will – High Court invoked Section 67 to void bequest due to attestation by beneficiary’s wife – Held: High Court framed additional substantial question of law without pleadings, issues, or suggestions in evidence – Introduction of Section 67 changed nature of case from factual to legal without procedural safeguards – Judgment set aside, testamentary succession upheld [Paras 1–23].

Section 100 CPC – Additional Substantial Question of Law – High Threshold – Proviso Invoked Improperly – High Court invoked proviso to Section 100(5) to frame new legal issue under Section 67 – Supreme Court held such invocation must be exceptional, with strong reasons recorded and based on pleadings – Found no foundation in plaint for applying Section 67 – Application of Section 67 in Second Appeal was legally unsustainable [Paras 16–20].

Evidence – Absence of Cross-Examination Suggestion – Application of Browne v. Dunn Principle – Court emphasized that where a party relies on new legal issue, contradiction must be suggested in cross-examination – No suggestion made to attesting witness (DW5) about disqualification – Held: Entire line of attack on will based on assumed relationship was contrary to fair procedure – Admission in pleadings or suggestion in evidence is essential [Paras 21–22].

Execution of Will – Validity Upheld – Free Will and Sound Disposing State – Trial Court and Appellate Court found will duly executed, with attestation proved under Section 63 – Medical evidence confirmed testator’s mental capacity – Held: No suspicion or infirmity in execution – Findings of lower courts reinstated [Paras 13–14].

Final Relief – Appeal Allowed – Monetary Obligations Under Will Enhanced – Though testamentary succession upheld, Supreme Court enhanced the monetary amounts payable to legal heirs under the will from ₹1 lakh / ₹50,000 to ₹10 lakhs / ₹5 lakhs respectively – Directed Appellant to pay within 3 months with interest @6% on default – Charge to be created over schedule properties [Para 24–25].

Anticipatory Bail – Cryptic High Court Order – Supreme Court Intervention – The petitioner sought anticipatory bail in relation to a 2021 FIR for offences under the Prevention of Corruption Act – The High Court instead of deciding the bail application on merits, adjourned the matter directing the DGP to file an affidavit explaining non-arrest of the petitioner for four years – Held: High Court erred in not deciding the application on merits – The fact that the petitioner was not arrested for four years itself was a good ground to consider anticipatory bail – Supreme Court exercised its discretion and granted protection [Paras 2-5, 7-8].

Judicial Duty – Anticipatory Bail Application – Manner of Disposal – Held: High Court ought to have either granted or rejected anticipatory bail on merits – Asking irrelevant questions to the investigating agency reflected improper exercise of jurisdiction – Supreme Court disapproved the High Court’s approach [Paras 5-6].

Bail Principles – Delay in Arrest – Significance – Held: Non-arrest of the petitioner for four years was by itself a strong ground to grant anticipatory bail – Discretion under Section 438 CrPC must be exercised to protect liberty when there is no bona fide attempt to arrest during investigation [Para 7].

Final Decision – Appeal Allowed – Supreme Court ordered that in the event of arrest, the petitioner shall be released on bail subject to conditions imposed by the Investigating Officer – SLP disposed of [Para 8-9].