Criminal Law - Juvenile Justice Act – Determination of Age – School Certificate and Birth Certificate Take Precedence – The JJB had wrongly rejected documentary evidence and ordered medical examination despite availability of school and municipal birth records – Held: Section 94(2) of JJ Act mandates preference for documentary proof – Medical opinion can only be considered in their absence – Order of JJB declaring respondent an adult was invalid – Reversal by Appellate Court and High Court upheld [Paras 26-28].

Juvenility – Review of Previous JJB Decision – Not Permissible – JJB had previously accepted the respondent’s date of birth as 08.09.2003 – In subsequent proceedings, JJB took contrary view – Held: JJB lacks statutory power to review earlier declaration of age – Its contrary action was legally untenable – High Court rightly affirmed appellate reversal [Paras 29-30, 34].

Juvenility – Preliminary Assessment Under Section 15 – Respondent Aged Above 16 Years – JJB Conducted Assessment – Found Respondent Fit to Undergo Trial as Adult – As per JJ Act, in heinous offences involving minors aged 16–18, a preliminary assessment is mandatory – Respondent was assessed as mentally and physically capable and trial ordered before POCSO Court – Valid exercise of jurisdiction [Paras 35-39].

Bail – Juvenile in Conflict with Law – Grant of Bail Upheld – Though bail was initially denied by JJB and Sessions Court, High Court granted bail after finding no risk of moral or physical danger or criminal association – No evidence of misuse of liberty during three years of bail – Held: No interference warranted – Appellant or State free to seek cancellation if liberty is misused [Paras 41-42].

Decision – Appeals Dismissed – Declaration of Juvenility and Grant of Bail Upheld – Supreme Court found no legal error in impugned orders – Dismissed both criminal appeals with liberty to apply for bail cancellation if needed – No costs imposed [Para 43].

Criminal Law  – Framing of Charges – Prima Facie Case Under IPC – Not Under PC Act – Allegation that appellant inserted forged notes above Minister’s signature to avoid newspaper publication of tenders – CFSL confirmed handwriting match – PWD Minister denied issuing such instructions – Held: Prima facie case exists under Sections 409 and 468 IPC – However, no material on record suggesting personal gain or gratification – Charges under Section 13(1)(d) read with Section 13(2) of PC Act quashed [Paras 10-14].

Scope of Discharge – Limited Review Permissible – Charges Based on Material in Chargesheet – Held: At the discharge stage, court cannot evaluate evidence in depth or rely on findings of departmental inquiries – Only contents of chargesheet are relevant – Discharge permissible only if no offence is made out even prima facie [Paras 9-10].

Disciplinary Proceedings vs Criminal Trial – Exoneration Not Conclusive – The appellant was exonerated in departmental inquiry – Held: Standards of proof differ – Departmental exoneration based on preponderance of probabilities does not negate prima facie evidence for criminal prosecution – Criminal proceedings can continue independently [Paras 7-8].

Decision – Partial Relief Granted – Charges under Prevention of Corruption Act Set Aside – Charges under Sections 409 and 468 IPC Maintained – Appeal partly allowed – Trial to proceed only for offences under IPC – Observations not binding at final trial [Paras 15-17].

Service Law - Disciplinary Proceedings – Requirement of CVC Advice – Charge Sheet Issued Without Mandatory Consultation – Regulation 19 of the 1976 Regulations requires consultation with CVC wherever vigilance angle is involved – Respondent Bank admitted the case involved vigilance angle and sought CVC advice but issued charge sheet before receiving it – Held: Once the Bank accepted the necessity of CVC advice, it was not open to proceed without it – Charge sheet and proceedings quashed [Paras 16-21].

Administrative Fairness – Delay and Timing of Proceedings – Mala Fide Inference – Suspension initiated ten months before superannuation after 34 years of unblemished service – Charge sheet served just days before retirement without awaiting CVC advice – Held: Action arbitrary, mala fide, and designed to deprive the appellant of retiral benefits – Disciplinary process set aside [Paras 15, 20-21].

Interpretation of Regulation – Discretion vs. Obligation – Not a General Rule – Respondent Bank’s conduct rendered academic the debate on whether Regulation 19 is mandatory or directory – Having voluntarily opted for CVC consultation, Bank bound to await advice – High Court erred in treating it as discretionary in this case [Paras 16, 22].

Decision: Disciplinary Proceedings Quashed – Retiral Benefits Directed – Charge sheet dated 10th June 2019 and proceedings set aside – Appellant entitled to all retirement benefits as if superannuated on 30th June 2019 – No back wages allowed – Benefits to be paid within three months [Paras 24-25].

Motor Accident Claim – Compensation Assessment – Evidentiary Weight of Salary Certificate – Income Restored - The High Court reduced the compensation by reassessing the deceased's monthly income at ₹15,000 despite a salary certificate (Exh. 5) produced by the claimants evidencing ₹35,000 – The Supreme Court held the salary certificate to be uncontroverted and thus binding – Held: High Court erred in discarding unrebutted evidence; Tribunal’s finding on income restored [Paras 8-12].

Future Prospects and Deductions – Application of Legal Multiplier – Conventional Heads – Upheld and Enhanced - The Court upheld the High Court's use of 40% addition for future prospects, multiplier of 15, and deduction of 1/4th for personal expenses – Additionally, enhanced conventional heads (loss of estate, consortium, and funeral expenses) by 10% per Pranay Sethi – Final compensation calculated at ₹68,93,300 [Paras 13-14].

Final Relief – Compensation Restored and Modified – Interest Retained - The Supreme Court restored the compensation originally awarded by the Tribunal with minor modifications and ordered interest at 9% p.a. as originally directed – Directed remittance within four weeks [Paras 14-16].

Services Law - Judicial Services - LDCE Quota for District Judge Promotions – Quota Restored from 10% to 25% – Meritorious Officers Incentivized – Original 25% quota (Third AIJA) was reduced to 10% in 2010 due to low participation – Court held changed conditions warranted restoration – Directed unfilled LDCE seats to revert to regular promotion – Held: 25% LDCE quota reinstated [Paras 13–29, 89(i), 89(iv)].

Eligibility for LDCE – Experience Threshold Reduced – Access Broadened – Required service reduced to 3 years as Civil Judge (Senior Division) and 7 years total judicial experience – Ensures meaningful opportunity for meritorious candidates – Held: All High Courts must amend rules accordingly [Paras 30–42, 89(ii)].

Merit-Based Promotion to Senior Division – New 10% LDCE Quota Introduced – Enhancing Early Career Incentives – Introduced merit promotion from Junior to Senior Division via LDCE – Requires 3 years' experience as Junior Division Judge – Held: Quota and eligibility rules to be updated nationwide [Paras 43–46, 89(iii)].

Vacancy Calculation – LDCE Quota to Be Based on Cadre Strength – Promotes Uniformity – Court held that basing quota on annual vacancies leads to inconsistencies – Held: All States must use total cadre strength as the basis for calculating LDCE quota [Paras 47–48, 89(v)].

Suitability Assessment – Mandatory for Merit-Cum-Seniority Promotions – Standardized Evaluation Introduced – Directed High Courts to frame or revise rules for assessing suitability based on legal acumen, ACRs, disposal rates, and viva voce – Held: High Courts and States must ensure objective criteria [Paras 49–52, 89(vi)].

Bar Practice Requirement – 3-Year Minimum Experience Reinstated – Practical Exposure Mandated – Overturning 2002 ruling, Court restored 3-year Bar practice requirement for Civil Judge (Junior Division) applicants – Allowed clerkship experience to count – Practice calculated from provisional enrolment – Held: Rules to be amended accordingly [Paras 53–88, 89(vii), 89(viii)].

Decision – Directions Issued to All High Courts and State Governments – Court directed amendment of service rules within 3 months to implement new quotas, experience requirements, and suitability tests – Ongoing recruitment to follow existing rules – Held: All reforms apply prospectively from the next recruitment cycle [Paras 89–91].

Taxation Law - Income Tax Act – Deductions under Chapter VI-A – Interpretation of Section 80-IA(9) – Clarified Scope of Restriction – Section 80-IA(9) restricts allowance of deduction under other provisions to the extent profits are already claimed under Section 80-IA – Held: The Section does not bar computation of deductions under other sections; rather, it limits the aggregate deduction allowed, preventing duplication – Deduction under each section may be computed separately, but the total cannot exceed profits from eligible business [Paras 19-21, 23-24].

Legislative Interpretation – Meaning of “Allowed” vs “Computed” – Different Stages of Deduction – The Court distinguished between ‘computation’ and ‘allowance’ of deduction – Held: Section 80-IA(9) affects the stage of allowing deductions, not their computation – As long as aggregate deductions do not exceed profits of the business, computation under multiple sections is permissible – Bombay High Court’s view upheld [Paras 22-24].

Judicial Consensus – Approval of Bombay High Court View – Rejection of Contrary Interpretations – Supreme Court endorsed reasoning of Bombay High Court in Associated Capsules Pvt. Ltd. case – Declined to follow Delhi and Kerala High Court decisions that interpreted Section 80-IA(9) restrictively – Harmonious construction preferred to avoid anomalous results [Paras 22-24].

Decision – Reference Answered – Interpretation Settled – Held: Deduction under Section 80-HHC should not be reduced by the amount allowed under Section 80-IA – Both deductions to be computed independently – However, aggregate deduction under heading ‘C’ of Chapter VI-A must not exceed profits and gains of eligible business – Reference concluded accordingly [Paras 23-25].

Civil Law – Partition Suit – Rejection of Plaint – Plaintiffs (mother and son) filed a suit for partition, possession, declaration, injunction, and accounting in respect of properties allegedly purchased from joint family funds – Defendant No.2 (Shaifali Gupta) and Defendant No.5 (subsequent purchaser) filed applications under Order VII Rule 11 CPC for rejection of plaint alleging bar under Benami Transactions (Prohibition) Act, 1988 – Trial Court and High Court rejected the applications – Supreme Court upheld the decision, holding that the issues were mixed questions of fact and law requiring trial [Paras 1–14, 19, 29].

Benami Transactions – Bar under Section 4 of Benami Act – Defendants argued that suit properties stood in names of individuals, hence benami and suit barred – Plaint averred properties were Joint Hindu Family properties purchased from joint family business income – Court held plaint did not disclose properties as benami ex facie – Whether properties were benami is a factual issue requiring evidence – Suit not barred under Section 4 [Paras 23–28].

Civil Procedure – Order VII Rule 11 CPC – Application for rejection of plaint must show suit is barred by law based solely on plaint averments – Defendants failed to establish bar under Benami Act based on plaint alone – Application rightly dismissed – Reliance placed on precedent from Pawan Kumar v. Babu Lal, (2019) 4 SCC 367 [Paras 13, 28–29].

Plea of Female Hindu Ownership – Section 14 Hindu Succession Act – Defendant raised argument of absolute ownership by female Hindu under Section 14 for the first time before Supreme Court – Court declined to entertain as not pleaded or argued before courts below – Also held Section 14 does not bar such a suit [Paras 30–31].

Decision: Special Leave Petitions dismissed – Applications under Order VII Rule 11 CPC rightly rejected – Suit to proceed on merits – No interference warranted under Article 136 of the Constitution [Paras 32–33].

Service Law – Dismissal from Service - Disciplinary Proceedings – Validity of Dismissal – Principles of Natural Justice Not Violated – The appellant alleged procedural violations including non-supply of documents and prolonged inquiry – Held: No prejudice shown to have been caused by these omissions – Rules of natural justice require real, not technical, prejudice – Departmental inquiry conducted with due process – No interference warranted [Paras 17-24].

Chargesheet – Vagueness and Clarity – Allegation of Fake Transfer Order – Charge Clearly Established – The appellant argued the chargesheet was vague – Held: The charge was specific and intelligible to a reasonable person – Allegation was she was the sole beneficiary of a forged transfer order – Plea of vagueness rejected [Para 18].

Rule 15(2), CCS (CCA) Rules – Compliance with Procedural Requirements – Disciplinary Authority Followed Due Process – It was argued that disagreement with inquiry findings was not properly communicated – Held: Inquiry report and reasons for disagreement were provided and opportunity to respond was granted – Rule 15(2) duly complied with [Paras 27-28].

Evidence – Standard in Departmental Proceedings – Preponderance of Probability Satisfied – The appellant contended there was no direct evidence linking her to the fake transfer order – Held: Departmental inquiries rely on preponderance, not proof beyond doubt – Author of transfer order denied signature – Appellant the sole beneficiary – Misconduct proved [Paras 29-30].

Delay – Prolonged Inquiry Proceedings – No Prejudice Proved – The inquiry lasted nine years – Held: Delay explained and justified by logistics and multiple jurisdictions – No claim of prejudice or denial of participation – Delay alone insufficient to invalidate the proceedings [Paras 25-26].

Allegations of Mala Fide – Not Raised in Pleadings – Cannot Be Entertained – Plea that transfer was manipulated to benefit another individual was raised for the first time during appeal – Held: Such plea not considered without specific pleading and parties being impleaded – Rejected on grounds of procedural impropriety [Paras 30-31].

Decision – Dismissal Upheld – Appeal Dismissed – The Court found no violation of natural justice or statutory procedure – Findings of guilt based on evidence – Appeal dismissed with no costs [Paras 32-34].

Service Law – Redesignation of Posts – Distinction Between Schemes – Appeal Dismissed – Appellant was appointed as Junior Field Officer (JFO), Group B, but was redesignated as Carpet Training Officer (CTO), Group C, in 1978 – Claimed entitlement to be treated as Handicrafts Promotion Officer (HPO) like other JFOs – Held: JFOs in Carpet Scheme and Marketing Scheme were in distinct cadres – Only JFOs in the Marketing Scheme were redesignated as HPOs – The appellant belonged to the Carpet Scheme – Thus, redesignation as CTO was valid [Paras 3, 12-14, 27].

Regularisation – Ad-hoc Service and Departmental Proceedings – Service Regularised – Appellant served on an ad-hoc basis from 1976 – By 2006, regularised as CTO with UPSC concurrence – CAT’s 1999 order directed regularisation in CTO vacancies – Held: The appellant accepted regularisation as CTO and did not challenge the order – Therefore, he cannot claim HPO status later [Paras 5, 19-20, 24-25].

Promotional Avenues – MACP and Scheme Closure – Financial Benefits Accorded – Appellant sought promotion within HPO cadre – However, CTO promotional channel was unavailable due to closure of Carpet Scheme – Held: Financial upgradation under MACP was correctly applied – The appellant was given pay benefits equivalent to the highest promotional post – No further relief warranted [Paras 13, 22, 28].

Judicial Review – Finality of Tribunal Orders – No Challenge Raised – CAT order of 1999 regularised appellant in CTO cadre – Appellant did not appeal this order and accepted regularisation – Held: He is estopped from seeking HPO designation or promotional benefits through that channel – Tribunal and High Court correctly declined relief [Paras 19, 26, 28].

Final Decision – Appeal Dismissed – The Supreme Court held there was no merit in the claim for redesignation or promotion as HPO – Appellant’s grievance was sufficiently addressed through MACP benefits – Appeal was dismissed [Para 30].