Employment Law - Termination without retrenchment compensation - Respondent, a peon, terminated after irregular daily-wage employment from July 1, 1994, to March 4, 1996, at the appellant’s Parbhani unit - Labour Court awarded reinstatement with continuity but without back wages - High Court affirmed - Supreme Court found reinstatement inappropriate due to the closure of the employment unit and the irregular nature of employment - Ordered compensation of Rs. 2 lakhs instead of reinstatement, overturning High Court’s decision - No retrenchment compensation was originally provided; however, compensation deemed just under the circumstances - Respondent also granted permission to withdraw Rs. 25,000 in costs from the court registry. [Paras 3-12]

Decision: The Supreme Court set aside the High Court judgment that affirmed the Labour Court’s decision to reinstate the respondent, opting instead to award a lump sum compensation considering the respondent's short service duration, irregular appointment, and closure of the employment unit.

Tax Law - Classification for VAT Purposes – Battery chargers sold with cell phones considered accessories, not a part of the cell phone itself – Appeals from State of Punjab challenging High Court's order that classified battery chargers as part of composite cell phone package thus eligible for concessional tax rate – Supreme Court reverses High Court's decision, holding battery chargers as taxable separately at a higher standard rate – Reinforces battery chargers are accessories, sold with phones but not integral to phones, hence not subject to concessional tax rate of 4% under Punjab VAT Act applicable to cell phones – Tribunal and lower assessing authorities found battery chargers to be accessories, subject to 12.5% tax rate, not part of the cell phone itself under Entry 60(6)(g) of Schedule 'B' of the Act – Clarifies that battery chargers do not come under cell phone's HSN Code 8525.20.17, which relates only to cell phones – Upholds Tribunal's and lower assessing authorities' decisions, setting aside contrary High Court judgment. [Paras 1-20]

Criminal Procedure and Evidence: Special Court dismissed discharge plea; High Court reversed, finding insufficient evidence for framing charges; Supreme Court reinstated Special Court's decision, pointing to discrepancies in shipping documents that raised grave suspicions against the respondents – Material presented, including manipulated shipping bills and GR forms, demonstrated potential misconduct sufficient to resume trial [Paras 2-10].

Interpretation of Charges: Supreme Court clarified the application of Sections 227 and 228 CrPC to the facts, stressing necessity of prima facie case based on documents presented; charges under IPC, Customs Act, and Prevention of Corruption Act found appropriately framed by Special Court based on evidence suggesting fraudulent attempts to inflate duty drawback claims [Paras 7-10].

Legal Principles: Supreme Court reiterates principles for framing charges, emphasizing the need for sufficient ground based on strong suspicion, supported by material evidence that could lead to conviction if unchallenged in trial; highlighted errors in High Court's interpretation of scope of charges under Prevention of Corruption Act, specifically the misapplication of Section 15 related to attempted offenses [Para 8].

Criminal Law - NI Act, Section 138 - Dispute over director's responsibility for dishonoured cheques issued two years after her resignation - The appellant, a former non-executive director who had resigned before the cheques were issued, was implicated in multiple complaints filed by a finance company under the NI Act - Initially granted interim relief by High Court which was later overturned leading to this appeal - Supreme Court examined whether the appellant was "in charge of" and "responsible for" the company at the time the offences were committed - Found no evidence suggesting the appellant was involved in day-to-day activities or decision-making regarding the issuance of the cheques - Appeals allowed, quashing proceedings against the appellant.

Corporate Law - Role and Liability of Directors - Examination of a director's specific role essential for imposing liability under Section 141 of the NI Act - Merely holding the position of director, without evidence of involvement in the specific act constituting the offence, is insufficient for liability - Appellant's non-executive role and resignation substantiated by documents including minutes of board meeting and filings with the Registrar of Companies firmly established non-involvement in the relevant transactions.

Judicial Process - Abuse of Process of Law - Initiation of criminal proceedings against former director characterized as an abuse of the judicial process - Supreme Court criticized the lower court’s decision for lacking in examination of critical facts and legal positions, highlighting the necessity to prevent misuse of criminal proceedings in business disputes that could be settled as civil matters.

Legal Proceedings Against Retired Public Servants – Criminal charges were framed against retired public servants, challenging the necessity of sanction under Section 197 CrPC and Section 19 of the Prevention of Corruption Act post-retirement - The Supreme Court clarified that no sanction is required under the Prevention of Corruption Act for retired officials at the time of taking cognizance, aligning with precedent set in S.A. Venkataraman v. State - However, for IPC offences, sanction remains necessary even post-retirement under Section 197 CrPC, which was upheld by the High Court and the Supreme Court - The appeal was allowed in part, dismissing charges under the IPC while upholding the possibility of prosecution under the Prevention of Corruption Act for acts committed during tenure [Paras 6-10].

Arbitration Proceedings - Jurisdiction and Arbitration Agreement - Despite the absence of a signed agreement, correspondence and actions implied consent to arbitration terms included in the contract facilitated by the Singapore Commodity Exchange - Held that arbitration clause need not be signed if evidenced by exchange of communications affirming the agreement [Paras 12-17].

Enforcement of Foreign Arbitration Award - Appellant contested the jurisdiction of the Singapore Commodity Exchange's Arbitration - Tribunal's jurisdiction was upheld based on implied acceptance through subsequent requests for contract amendments and making a counterclaim during arbitration proceedings - Supreme Court upholds the decision enforcing the foreign award as per Section 46 of the Arbitration & Conciliation Act, 1996, finding no valid grounds to challenge the award's enforceability [Paras 18-25].

Initial Acquittal and High Court Conviction - Trial court acquitted all accused, citing unidentifiable body and lack of evidence of cruelty or harassment related to dowry - On appeal by the State, the High Court reversed, convicting under Sections 304B read with Section 34, 498A, and 201 of the IPC, sentencing each accused to various terms - High Court found overwhelming evidence of dowry demands, cruelty, and subsequent murder and disposal of the body to manipulate evidence. [Paras 1-11]

Medical and Investigative Evidence - Postmortem reported asphyxia due to strangulation as cause of death - Injuries indicated murder, with subsequent burning of the body to hinder identification - High Court noted failure of trial court to adequately consider medical evidence linking death to dowry-related cruelty. [Paras 14-15, 33]

Supreme Court Review - Confirmed High Court's conviction of two main accused, Vijay Pal Singh and Narendra Singh, under Sections 304B, 498A, and 201 of IPC - Acquitted Rakesh Singh and Gyan Chandra, citing insufficient evidence of their involvement in dowry demands and direct cruelty. [Paras 37-39]

Sentence Upheld - All sentences to run concurrently, with the mandatory minimum for dowry death imposed, recognizing the seriousness of the offenses and aligning with the legislative intent to deter such crimes. [Paras 38-39]

This decision underscores the judiciary's stance on handling dowry-related deaths and cruelty, emphasizing stringent scrutiny at both trial and appellate levels to ensure justice for victims of such societal evils.

Juvenile Justice - Entitlement under Juvenile Justice Act for crimes committed as a juvenile - Petitioner claimed juvenile status on the date of the offense (18th June 1997) based on birthdate (14th April 1980) - Confirmed through school records and testimonies; found to be 17 years, 2 months, and 4 days old at the time of the crime - Held, entitled to benefits under the Act as per precedents even if conviction occurred prior to Act's enforcement - Convictions under juvenile considerations to be reassessed in light of new evidence confirming age. [Paras 1-5]

Application of Juvenile Justice Act Retrospectively - Established precedent by Hariram v. State of Rajasthan (2009) 13 SCC 193 and other subsequent cases confirming retrospective applicability of Juvenile Justice Act, 2000 to those juveniles who committed offenses prior to the Act but were convicted thereafter - Petitioner's continued detention ruled improper following verification of juvenile status at the time of the offense. [Paras 5-6]

Release Ordered - Petitioner to be released immediately, having already served 11 years of imprisonment - Release ordered based on juvenile status at the time of offense and retrospective application of the Juvenile Justice Act, 2000 - Bail bonds and sureties discharged as petitioner already on bail since 15th July 2013. [Paras 7-8]

Juvenile Justice - Age determination - Appeal against the decision on appellant's age at the time of the offence in 1985 - Sessions Judge determined appellant was over 16 but under 18 years at the time of offence - Supreme Court holds that under the Juvenile Justice Act, 2000, the age for juvenility raised to 18 years, hence appellant considered juvenile despite previous age limit of 16 years - Appellant entitled to benefits of Juvenile Justice Act, 2000, although conviction upheld, sentencing requires re-assessment under juvenile norms - Sentencing referred back to Juvenile Justice Board for appropriate orders under Section 15 of the Act. [Paras 1-11]