Facts:

The Appellant husband sought divorce from the Respondent wife citing cruelty.

Allegations of cruelty included baseless accusations of extramarital affair, threats of suicide, and insistence on separation from the husband's family.

The trial court granted the divorce decree, but it was set aside by the High Court on appeal by the Respondent wife.

Issues:

Whether the actions of the Respondent wife constituted cruelty under Section 13(1)(ia) of the Hindu Marriage Act, 1955.

Whether the trial court's decision granting divorce was justified.

Held:

The Supreme Court, after thorough consideration of the evidence and arguments, held that the trial court's decision to grant divorce on the grounds of cruelty was justified. The Court found multiple instances of cruelty perpetrated by the Respondent wife, including her attempt to commit suicide, insistence on separation from the husband's family for monetary reasons, and baseless allegations of an extramarital affair. These actions were deemed as forms of mental cruelty, warranting the dissolution of the marriage. The Court referenced previous judgments to support its findings on mental cruelty.

The Court, therefore, allowed the appeal, quashed the High Court's judgment, and restored the divorce decree granted by the trial court. No costs were awarded in the matter.

Facts:

The case involved a criminal appeal by special leave, originally filed by eight accused.

Allegations included assault within a shop premises resulting in the death of the deceased, Laxman.

Five appellants were accused of preventing individuals from entering the shop and moving on the street in front of the shop.

Eyewitness accounts were the primary evidence, with discrepancies noted in their statements.

Issues:

Whether the five appellants were directly involved in the assault.

Whether the inclusion of certain individuals prevented from entering the shop premises was an afterthought.

Whether there was sufficient evidence to convict the appellants beyond reasonable doubt.

Held:

The court found discrepancies in the eyewitness accounts and noted that the five appellants were not directly involved in the assault within the shop premises.

The inclusion of additional individuals prevented from entering the shop premises appeared to be an afterthought, lacking in initial documentation.

Given the lack of concrete evidence and the possibility of enmity leading to innocent family members being implicated, the court concluded that it was difficult to establish the appellants' involvement beyond a reasonable doubt.

Consequently, the appellants were acquitted of the charges leveled against them, and their bail bonds were discharged.

Facts:

The appellant questioned the maintainability of the suit, arguing that the parties had agreed to settle the dispute through arbitration.

The application under Section 8 of the Arbitration and Conciliation Act, 1996 was dismissed, asserting that the suit was maintainable due to serious allegations of fraud and malpractices.

The High Court affirmed the lower court's decision.

Issues:

Whether the allegations of fraud in the present case were serious and complex enough to render the dispute non-arbitrable.

Whether the lower courts erred in rejecting the application under Section 8 of the Arbitration and Conciliation Act, 1996.

Held:

The court emphasized that while the Arbitration and Conciliation Act, 1996 doesn't explicitly exclude any category of disputes from arbitration, certain disputes like those involving serious allegations of fraud may be considered non-arbitrable (Para 9).

Fraud was defined as a knowing misrepresentation of the truth or concealment of a material fact to induce another to act to their detriment. The court highlighted that mere allegations of fraud may not be sufficient to nullify the effect of an arbitration agreement (Para 10).

The court differentiated between serious allegations of fraud, which may constitute a criminal offense or require extensive evidence, and simple allegations of fraud, which may not render the dispute non-arbitrable (Para 13).

It was emphasized that the focus of the court should be on whether the nature of the dispute is such that it cannot be referred to arbitration, even if there's an arbitration agreement between the parties (Para 20).

In the present case, the court found that the allegations of fraud were not so serious or complex as to render the dispute non-arbitrable. Therefore, the rejection of the application under Section 8 of the Act was deemed incorrect, and the matter should have been referred to arbitration (Para 21).

Facts:

The case involved the murder of one individual and injuries to six others. The trial court acquitted all accused individuals, citing various reasons such as contradictions in witness statements, improvements in the version of events, and inconsistencies in the evidence regarding the manner of assault and the weapon used.

Issues:

The credibility of witness statements, the application of vicarious liability under Section 149 of the Indian Penal Code, and the appropriate role of appellate authorities in reviewing trial court decisions.

Held:

The trial court adopted a perverse approach in rejecting the evidence of injured eyewitnesses. Despite some contradictions, the consistent testimony of eyewitnesses PWs 10, 11, 15, 12, and 18 provided a credible account of the events. Rejecting their evidence solely based on minor discrepancies was unwarranted .

Vicarious liability under Section 149 of the IPC was upheld, affirming that members of an unlawful assembly sharing a common object are liable for offences committed in furtherance of that object. The common object must be ascertained from the acts and language of the assembly members and surrounding circumstances .

The appellate court has the authority to review trial court decisions but should do so cautiously. If two reasonable conclusions can be reached, the appellate court should not disturb the trial court's finding. However, if the trial court's decision is unreasonable or perverse, the appellate court may reverse it .

Decision: The appeal was partly allowed. The conviction and sentence of accused individuals A-1 to A-7 were upheld, as they were consistently named by eyewitnesses and assigned specific roles in the assault. However, accused individuals A-10 and A-11 were acquitted due to the absence of their names in the eyewitness accounts and the attribution of specific roles only to A-1 to A-7 .

Facts:

The prosecutrix alleged gang rape by the appellants. Inconsistencies were noted between the FIR and the prosecutrix's deposition. The trial court acquitted the appellants, which was reversed by the High Court.

Issues:

Whether the view taken by the trial court or the High Court is more plausible regarding the prosecution's case.

The reliability of the prosecutrix's testimony and the evidence presented.

Held:

Inconsistencies in Prosecutrix's Testimony: The Supreme Court found discrepancies in the prosecutrix's behavior and statements. Her actions post-incident and the testimony of witnesses indicated a possible motive for false implication. The medical evidence raised doubts about the allegation of gang rape. The testimony of a hostile witness supported the defense's plea of false implication.

Judicial Scrutiny of Prosecutrix's Testimony: While the testimony of a victim should generally be accepted as true, it must undergo judicial scrutiny to prevent wrongful convictions.

Scope of Interference with Acquittal: The appellate court should not interfere with the trial court's judgment of acquittal unless there are compelling reasons to do so, such as perverse findings or irrational conclusions.

Decision: The Supreme Court upheld the trial court's acquittal of the appellants. The prosecution failed to prove the charges beyond a reasonable doubt, considering the inconsistencies and anomalies in the case. The view taken by the trial court was more plausible, and the appellants were entitled to the benefit of doubt.

Facts:

The case involves the brutal rape and murder of Jayashri, a widow living with her son in Bangalore. The petitioner, B.A. Umesh, was convicted based on circumstantial evidence. The prosecution presented witnesses and evidence establishing Umesh's involvement in the crime, including his escape from custody and subsequent involvement in another robbery within two days of the murder.

Issues:

Whether the death sentence awarded to the petitioner should be affirmed or commuted to life imprisonment.

Held:

The Supreme Court, after considering both mitigating and aggravating circumstances, upheld the death sentence. The bench emphasized the severity of the crime, including the violent rape and murder of a defenseless woman, along with Umesh's criminal history and his escape from custody. The Court found no compelling reason to modify the earlier judgment affirming the death sentence.

The Court cited previous judgments and legal principles, including the rarest of rare doctrine established in Bachan Singh v. State of Punjab and Machhi Singh v. State of Punjab. It also addressed procedural arguments raised by Umesh's counsel regarding the hearing on the sentence, stating that while there is no mandate for a separate date for hearing on sentence, parties must be given an opportunity to present their arguments.

Ultimately, the Supreme Court dismissed Umesh's review petitions and affirmed the death sentence, concluding that the aggravating circumstances outweighed the mitigating factors presented by the petitioner.

Facts:

The appellant, Benson, was charged with multiple offenses of theft on different occasions and was separately tried and convicted. The appeals against these convictions were dismissed by the Sessions Judge, Thrissur, and subsequent Criminal Revision Petitions filed in the High Court were also dismissed.

Issues:

The Supreme Court was regarding the concurrent running of sentences for the offenses committed by the appellant, considering the provisions of Section 427 of the Code of Criminal Procedure, 1973.

Held:

The Court noted the discretionary power conferred upon it by Section 427(1) to direct whether subsequent sentences shall run concurrently with the previous sentences. It emphasized that such discretion should be exercised judiciously and not in a mechanical manner. After examining the records and considering the submissions, the Court decided to modify the sentences. It directed that the sentences imposed in each of the cases against the appellant should run concurrently with the sentence imposed in a specific preceding case, which was currently operative.

The Court granted the benefit of concurrent running of sentences in respect of substantive sentences to the appellant, while maintaining the sentences of fine and default sentences. It clarified that if the fines were not deposited, the default sentences would run consecutively. Ultimately, the appeals were allowed in part, and the orders of sentences were modified accordingly.

Facts:

The court had previously issued directions to address overcrowding in prisons and improve living conditions for prisoners. However, despite these orders, overcrowding persisted, and little progress was made in addressing the issue. The Ministry of Women and Child Development was tasked with preparing a manual for juveniles in custody, but it had not been completed within the specified timeframe. Similarly, states and union territories had not prepared a Plan of Action to reduce prison population or improve infrastructure.

Issues:

Overcrowding in prisons and its impact on prisoners' rights.

Delay in the preparation of a manual for juveniles in custody.

Failure of states and union territories to prepare a Plan of Action to address prison overcrowding.

Held:

The court emphasized the importance of upholding the fundamental rights and human rights of prisoners, citing previous decisions reaffirming these rights. It directed the Ministry of Women and Child Development to expedite the preparation of the manual for juveniles in custody, setting a deadline of November 30, 2016. Additionally, states and union territories were ordered to prepare a Plan of Action within six months, by March 31, 2017, to address prison overcrowding. The court also directed the Union of India, through the Ministry of Home Affairs, to obtain and collate compliance status of previous orders by September 30, 2016, to ensure the rights of prisoners are given due importance.

Facts:

The appellant was convicted under Section 302 of the IPC for the death of his wife by hanging. The prosecution alleged that the appellant, along with his brother, murdered his wife. However, the evidence presented by the prosecution was challenged by the appellant. The case lacked eyewitnesses to the incident, and the testimony of witnesses and medical evidence did not conclusively link the appellant to the crime.

Issues:

Whether the evidence presented by the prosecution was sufficient to establish the guilt of the appellant beyond a reasonable doubt.

Whether the circumstantial evidence supported the conviction of the appellant under Section 302 of the IPC.

Whether the benefit of doubt should be extended to the appellant based on the evaluation of evidence and circumstances.

Held:

The evidence presented by the prosecution, when considered along with the testimony of witnesses and medical evidence, did not directly or indirectly link the appellant to the actual act leading to the death of the deceased.

The circumstantial evidence adduced by the prosecution fell short of the requirement in law to return a finding of guilt against the appellant without any element of doubt whatsoever.

The absence of eyewitnesses and the inconsistencies in the testimony of witnesses weakened the prosecution's case against the appellant.

The appellant's resignation from the police department and alleged intention to move abroad were not definitively proven, and the letters written by the deceased to the appellant did not suggest any bitterness or frustration.

In a criminal prosecution, mere suspicion cannot replace legal proof, and the benefit of doubt must be extended to the accused when reasonable doubt exists.

Decision: The court allowed the appeal and acquitted the appellant of the charge of murder under Section 302 of the IPC. The lack of conclusive evidence and the presence of reasonable doubt necessitated the acquittal of the appellant.