Criminal Law - Prevention of Corruption Act – Appeal Against Conviction - Demand and Acceptance – Contradictory Evidence – Conviction Set Aside – The accused, a Revenue Inspector, was alleged to have demanded and accepted a bribe of ₹2,000 for conducting a drought damage inspection – The Supreme Court found contradictions in the testimonies of key witnesses including PW1 (complainant) and his wife (DW1), lack of corroboration, and absence of pH reaction on the accused’s hands – Held: The prosecution failed to establish demand and acceptance beyond reasonable doubt [Paras 6, 13, 17, 19-20].

Trap Cases – Standard of Proof – No Independent Corroboration – Benefit of Doubt Given – The Court noted the absence of shadow witness corroboration during the alleged bribe transaction and inconsistencies regarding how the money was placed in the accused's motorcycle bag – Held: Guilt not proved beyond reasonable doubt, and benefit of doubt must be extended to the accused [Paras 17-20].

Presumption under Section 20 – Inapplicability Due to Lack of Proven Demand – Although money was recovered, the Court reiterated that the statutory presumption under Section 20 does not arise unless prior demand is proved – Held: The presumption is not attracted where the foundational fact of demand is missing [Paras 21].

Final Decision – Conviction Reversed – Appeal Allowed – The Supreme Court quashed the judgments of both the Trial Court and the High Court – Held: Conviction and sentence under Sections 7 and 13(1)(d) r/w 13(2) of the Prevention of Corruption Act are set aside, and fine, if deposited, shall be refunded [Paras 22-23].

Civil Law - Contempt of Court – Sub Judice Principle – Freedom of Speech vs. Judicial Sensitivity – Take-Down Order Set Aside – The Supreme Court quashed the Delhi High Court’s interim order directing Wikimedia Foundation to take down certain Wikipedia pages and discussion threads commenting on a pending defamation suit – Held: There was no real or substantial risk of prejudice to the ongoing trial; order was disproportionate and violated constitutional guarantees – Criticism of judicial decisions by media or public, even if robust, is not contempt unless it scandalizes the court or obstructs justice – Judges must avoid hypersensitivity and uphold free speech and public debate on judicial proceedings [Paras 19–35].

Freedom of Expression – Right to Know – Role of Media and Digital Platforms – Judicial Prudence Emphasized – The Court reaffirmed that public debate on sub judice matters is not per se contemptuous – Media and digital platforms like Wikipedia are intermediaries facilitating public knowledge and should not be muzzled through overbroad censorship – Freedom of expression includes criticism of courts and is vital for a healthy democracy – Cited: Sahara India Real Estate, Naresh Shridhar Mirajkar, Swapnil Tripathi, Imran Pratapgadhi [Paras 22–29, 31–34].

Intermediary Liability – Section 79 IT Act – Not Adjudicated – The Court declined to rule on whether Wikimedia qualified for safe harbor protection as an intermediary under IT Act, as it may affect pending trial – Nonetheless, reaffirmed that mere hosting of content not authored by the intermediary is not enough to infer culpability [Para 32].

Decision – Appeal Allowed – High Court Direction to Delete Wikipedia Content Quashed – The Supreme Court allowed the appeal, setting aside the Delhi High Court’s interim direction that Wikimedia take down user-generated pages and discussions – Held: Courts must uphold free speech and not be seen as suppressing critique of judicial actions unless there is real prejudice to justice administration [Paras 33–34].

Criminal Law - Quashing of Criminal Proceedings – Abuse of Process – Sections 186, 353 IPC – Proceedings Quashed – Appellants, associated with anti-trafficking NGO, were charged with obstructing public servants during a rescue operation at a brick kiln – Held: Uncontroverted allegations did not disclose use of force or mens rea required under Sections 186 or 353 IPC – Mere removal of labourers to police station did not constitute obstruction or assault – High Court erred in dismissing petition mechanically without examining legal bars and facts – Proceedings amounted to abuse of court process and were liable to be quashed [Paras 10–29].

Section 186 IPC – Procedural Bar – Registration and Cognizance Impermissible Without Sanction and Complaint by Public Servant – FIR registered without Magistrate’s permission under Section 155(2) CrPC and cognizance taken on police report contrary to Section 195 CrPC – Held: Prosecution under Section 186 IPC simplicitor was legally untenable and vitiated on procedural grounds [Paras 30–32].

Decision – Criminal Proceedings Quashed – Appeal Allowed – Prosecution Declared Malicious and Unlawful – Supreme Court quashed proceedings under Sections 186 and 353 IPC – Found prosecution to be motivated by malice and departmental vendetta – Reiterated wider scope of High Court’s power under Section 482 CrPC to prevent abuse of process and protect individual liberty [Paras 28–36].
 

Environmental Law – Sand Mining – Mandatory Nature of Valid District Survey Report (DSR) – Appeals Dismissed – The State of U.P. and LOI holders challenged NGT’s order quashing e-auction notice dated 13.02.2023 for sand mining in Saharanpur due to lack of a valid DSR – Supreme Court upheld NGT’s view that a draft DSR cannot form the basis for environmental clearance under the EIA Notification, 2006, and guidelines of 2016 and 2020 – Held: Only a valid, finalized DSR can support EC and e-auction processes; draft DSR is a non-starter for legal compliance [Paras 1.2, 3.2, 19.2, 21–22].

District Survey Report – Legal Status and Importance – Judicial Affirmation – The Court declared DSR as a “document of seminal importance” essential for informed decision-making, environmental clearance, and project appraisal – Emphasized strict adherence to procedure in Appendix X of the EIA Notification – Mandated five-year validity and compulsory public consultation – Reaffirmed decisions in Deepak Kumar and Pawan Kumar cases [Paras 1.2, 10, 11, 14–15, 21].

Decision – E-auction Quashed – Appeals Dismissed – NGT Order Affirmed – The Supreme Court dismissed the civil appeals, affirming the NGT’s quashing of the e-auction for violating mandatory environmental safeguards and DSR requirements – Directed strict enforcement of the regulatory framework and held that absence of a valid DSR invalidates the auction process [Paras 20–22].
 

Motor Accident Claim – Enhancement of Compensation – Syme’s Amputation – Appeal Allowed – Appellant suffered permanent disability due to a road accident and initially awarded Rs. 12.65 lakhs by the High Court – Supreme Court reassessed evidence, enhanced income estimation, and awarded Rs. 17,06,486/- with 9% interest per annum – Detailed reassessment included validated medical expenses, increased amount for pain and suffering, and inclusion of future prospects [Paras 2-7].

Permanent Disability – Assessment of Future Income – Adoption of Reasonable Minimum Wage – Appeal Allowed – Supreme Court held that the income should be reassessed at Rs.10,000/- per month in 2015 for an unskilled worker with 40% future prospects – Previous underestimation by Tribunal and High Court was corrected – Loss of future income recalculated accordingly [Paras 5-6].

Just Compensation – Pain, Suffering, and Medical Costs – Award Enhanced – In view of Syme’s amputation and multiple fractures, compensation for pain and suffering was increased from Rs.1.2 lakhs to Rs.1.5 lakhs – Full reimbursement of medical expenses was allowed based on produced bills, and a separate amount for attendant charges and special diet was granted [Paras 4-5].

Decision – Compensation Enhanced – Appeal Allowed – The total compensation was increased from Rs.12.65 lakhs to Rs.17,06,486/- with interest @ 9% p.a. – The Insurance Company was directed to pay the amount within two months after adjusting already paid amounts [Para 7-8].
 

Civil law – Mark Unregistered Agreement of Sale – Admissibility under Section 49 of the Registration Act – Appeal Allowed – The appellant sought to mark a document dated 01.01.2000 in a suit for specific performance – Trial Court and High Court rejected the plea on the ground that the document was unstamped and unregistered – Held: The proviso to Section 49 of the Registration Act permits admission of such document as evidence of a contract in a suit for specific performance – Reliance placed on S. Kaladevi v. V.R. Somasundaram – The Court clarified the appellant is permitted to introduce the document, subject to objections on relevancy and validity to be decided by the Trial Court [Paras 9–12].

Criminal Law – Quashing - Matrimonial Disputes – Abuse of Process – Quashing of Criminal Proceedings – Petition Dismissed – Allegations of dowry harassment and physical assault made by wife were contradicted by her own statements and affidavit filed in related matrimonial proceedings – High Court rightly quashed the proceedings under Section 482 CrPC as an abuse of process – Supreme Court upheld the quashing order and dismissed the Special Leave Petition [Paras 1, 8-11].

Contradictory Statements – Inconsistencies in Complaint and Evidence – No Medical Proof – No Specific Allegation – Petition Dismissed – Complaint made under Section 156(3) CrPC was found to have vague and inconsistent allegations, lacking medical evidence despite claims of physical assault – Admissions in matrimonial affidavits contradicted claims of abuse – Court held inconsistencies undermined the credibility of the accusations [Paras 8-10].

Judicial Approach – Precaution in Matrimonial Offences – Need to Prevent Misuse – Cautious Scrutiny Mandated – Courts must exercise caution in matrimonial cases to prevent misuse of criminal law against extended family members – Supreme Court reiterated need to distinguish genuine cases from abuse of process to protect both victims and innocents [Paras 2-3].

Decision – Invocation of Section 482 CrPC Justified – Special Leave Petition Dismissed – Supreme Court found no error in the High Court’s invocation of its inherent powers to quash the criminal case – Proceedings held to be an abuse of process – Special Leave Petition dismissed [Para 11-12].

Civil Suit – Suo Motu Dismissal of Declaratory Relief – Improper Exercise of Appellate Jurisdiction – Appeal Allowed – The High Court, while hearing an appeal against denial of interim relief, dismissed plaintiffs’ substantive declaratory prayers based on unregistered agreements under Section 49 of the Registration Act – Held: The High Court could not have summarily disposed of substantive reliefs in the suit or transferred remaining reliefs to be agitated in a different suit – Legality, admissibility, and validity of documents must be determined during trial – The order was unsustainable in law and suit restored to original number [Paras 9–13].

Possession Protection – Injunction Against Dispossession – Relief Granted – Based on concession by respondent that dispossession would not be attempted without due process of law, the Supreme Court directed continuation of injunction restraining respondents from dispossessing appellants pending suit – Clarified that no view was expressed on merits [Paras 6, 13–14].

Decision – Suit Restored – Injunction Granted – Appeal Allowed – The Supreme Court allowed the appeals, set aside the High Court's judgment dated 14.08.2013, and restored Civil Suit (L) No. 2217 of 2012 to its original number before the Bombay City Civil Court – Directed that respondents be restrained from dispossessing appellants during pendency of the suit – No opinion expressed on merits of the matter [Paras 13–14].
 

Criminal Law – PC Act – Appeal Against Conviction - Disproportionate Assets – Abetment by Spouse – Divergent Views – Acquittal by One Judge, Conviction Upheld by Another – Justice Ahsanuddin Amanullah held that mere possession of properties by the wife of a public servant, without direct evidence of knowledge or conspiracy, was insufficient for conviction under Section 109 IPC – Justice Sudhanshu Dhulia, dissenting, found active participation and intentional aid established, warranting conviction – Matter referred to Hon'ble Chief Justice for final decision [Paras 1, 27, 36–41].

Burden of Proof – Presumption under Section 13(1)(e) PC Act – Clarified – The burden initially lies on the prosecution to establish possession of disproportionate assets, after which the onus shifts to the accused – Both courts below found that the accused failed to credibly account for the assets, with vague and uncorroborated explanations regarding agricultural income and gifts [Paras 12–16, 35].

Role of Non-Public Servants – Applicability of Abetment under PC Act – Upheld – The judgment reaffirmed that non-public servants can be prosecuted under Section 109 IPC read with PC Act for aiding illicit accumulation of assets by public officials – Reference made to P. Nallammal v. State (1999), where such prosecution was explicitly permitted [Paras 22, 24, 29–30].

Evaluation of Evidence – Standard of Proof for Abetment – Differentiated – Justice Amanullah held that proximity to the public servant alone does not suffice to establish abetment unless active participation or mens rea is proved – Emphasised the presumption of innocence and constitutional protections under Articles 14 and 21 – Mere suspicion cannot substitute evidence [Paras 36–39].

Fresh Hearing of Appeal – Validity of Re-Listing – Upheld – Challenge to High Court’s administrative order for fresh hearing after alleged missing judgment of 2013 was rejected – Court held there was no record of the judgment, and the re-listing was justified – No fault found with Chief Justice’s administrative action [Paras 10, 40].

Attachment of Properties – Partial Modification – Affirmed – Attachment order against properties standing in name of accused confirmed, with recalculation reducing recoverable amount from Rs. 35.25 lakhs to Rs. 33.25 lakhs – Despite acquittal of Accused No.2 in one opinion, attachment not disturbed as it was based on unexplained assets [Paras 7, 11, 40].

Decision – Appeals Disposed – Conviction of P. Nallammal under challenge – Split verdict resulted in referral to the Chief Justice for appropriate orders – Appeals related to attachment and administrative listing were dismissed unanimously [Paras 1–3].