Facts:

The appellant, Gautam Kundu, filed a bail application under Section 439 Cr.P.C. while facing prosecution under Section 4 of the Prevention of Money Laundering Act, 2002 (PMLA). Simultaneously, proceedings under Section 24 of the Securities and Exchange Board of India Act, 1992 (SEBI Act) were pending.

Issues:

Whether the conditions for grant of bail specified in Section 45 of PMLA override the provisions of Section 439 Cr.P.C., especially when there are pending proceedings under SEBI Act.

Held:

The court held that PMLA is a special statute enacted by the Parliament to address the offence of money laundering, and its provisions prevail over the general provisions of the Code of Criminal Procedure, as per Section 5 of Cr.P.C..

Section 45 of PMLA, starting with a non-obstante clause, mandates two conditions for granting bail in cases where the accused faces imprisonment for more than three years under Part-A of the Schedule of PMLA. These conditions include giving the prosecutor an opportunity to oppose bail and satisfying the court that there are reasonable grounds to believe the accused is not guilty and will not commit an offence while on bail.

The court emphasized that the conditions specified under Section 45 of PMLA are mandatory and must be complied with, as reinforced by other provisions like Sections 65 and 71 of PMLA. Even if the bail application is made under Section 439 of Cr.P.C., these conditions apply.

Additionally, Section 24 of the SEBI Act presumes that proceeds of crime are involved in money laundering unless proved otherwise, shifting the burden of proof onto the appellant.

The court affirmed that the conditions laid down under Section 45 of PMLA bind the High Court, even when considering bail applications under Section 439 Cr.P.C..

Decision: The court dismissed the appeal, upholding the decision of the High Court to refuse bail, considering the circumstances and the mandatory conditions specified under Section 45 of PMLA.

Facts:

The case involved the acquisition of land in Vijayashreepura village under the Mysore Improvement Act, 1903. The acquisition and subsequent allotment of land to respondent No. 28 were challenged by the appellant.

Issues:

The legality and validity of the acquisition process, including procedural irregularities and the legality of the land allotment to respondent No. 28.

Held:

The Court held that the mandatory requirement of having a development scheme in place before the publication of a preliminary notification under Section 16(1) of the Mysore Improvement Act, 1903, was not followed.

Furthermore, there was a clear infringement of the mandatory requirement under Section 18 of the Act, as the acquisition process did not obtain the necessary sanction from the government.

The Court found that the sequence of events demonstrated state action that did not conform to the requirements of the law.

Despite procedural irregularities, a substantial development, including an academic campus, had taken place on the allotted land. Therefore, the Court balanced the equities by directing respondent No. 28 to surrender a minimum of 15 acres of land to MUDA.

Compensation for the remaining 40 acres of allotted land was to be determined based on the Land Acquisition Act, with the compensation date set as the midway point between relevant dates.

The Court emphasized that delay in approaching the court should not prevent the adjudication of a writ petition on its merits. The High Court's jurisdiction under Article 226 of the Constitution of India is not bound by strict rules of limitation.

Facts:

The accused confessed to killing his wife and daughter.

The Trial Court convicted him based on evidence including eyewitness testimonies and recovery of weapons.

The High Court acquitted the accused, finding the prosecution's case lacking.

Issues:

Motive: The prosecution claimed the accused had a motive to kill his wife and daughter, but the evidence presented was deemed insufficient and hearsay.

Eyewitness Testimonies: The credibility of eyewitnesses, particularly PW1 and PW4, was questioned due to inconsistencies and contradictions in their testimonies.

Ante-timed FIR: The timing and circumstances of the FIR lodged by PW1 were questioned, raising doubts about its authenticity.

Confessional FIR: The accused claimed the FIR was coerced and ante-timed, casting doubt on its reliability as evidence.

Held:

In a detailed analysis of the issues, the Court found flaws in the prosecution's case. It highlighted inconsistencies in testimonies, lack of corroborative evidence, and procedural irregularities.

The Court concluded that the prosecution failed to prove its case beyond reasonable doubt. Upholding the High Court's decision, the Supreme Court dismissed the appeals and affirmed the acquittal of the accused.

The judgment emphasizes the importance of evidence and procedural integrity in criminal cases, thus reiterating the principle that guilt must be proven beyond reasonable doubt.

Facts:

The appellant and his wife went on a honeymoon trip after four months of marriage and spent several days together.

Upon their return journey, the wife disappeared from the train.

A few days later, a dead body of a woman was found near the railway track, but it was unrecognizable.

Despite initial suspicions, further investigation revealed discrepancies, including differences in clothing and doubts from family members about the identity of the body.

Issues:

Whether the prosecution could establish beyond reasonable doubt that the dead body was that of the appellant's wife and that her death was unnatural.

Whether the prosecution could prove charges related to dowry demand and harassment under various sections of the Penal Code.

Held:

The testimony of witnesses established that the wife was seen alive with the appellant in the train till a station far away from where the dead body was found, making it unlikely that the body was hers.

The post-mortem report and other evidence cast doubt on the identity of the dead body as that of the appellant's wife.

The prosecution failed to provide evidence on how and when poison was administered to the deceased, despite finding poisonous substances in the body.

The DNA test conducted at a private laboratory lacked credibility due to procedural deficiencies.

The prosecution's case lacked direct evidence and relied heavily on circumstantial evidence, which did not meet the standard of proof beyond reasonable doubt.

The investigation process was criticized for various shortcomings, including the failure to produce crucial evidence and conduct proper tests.

Decision: The appeal was allowed, and the appellant was ordered to be set at liberty as the prosecution failed to prove the charges against him beyond reasonable doubt.

Facts:

The case pertains to a dispute regarding the Reserve Bank of India's obligation to disclose information under the Right to Information Act, 2005 (RTI Act), particularly concerning its relationship with other banks and the extent of fiduciary duty involved.

Issues:

Whether the Reserve Bank of India (RBI) is obligated to disclose certain information under the RTI Act, and if so, to what extent.

Additionally, the court addresses the concept of fiduciary relationships in the context of RBI's interactions with other banks.

Held:

The Court affirms the importance of the right to information as a fundamental right under Article 19 of the Constitution and the enactment of the RTI Act to facilitate access to information on matters of public concern.

While acknowledging that the right to information is not absolute, the Court emphasizes the necessity of transparency and accountability in governance.

Regarding fiduciary relationships, the Court clarifies that the RBI's duty primarily lies in upholding the interest of the public at large, rather than fostering a fiduciary relationship with other banks.

The Court rejects the RBI's argument that disclosing certain information would harm the economic interest of the nation, stating that transparency serves the public interest and prevents the concealment of irregularities.

It is affirmed that the RBI, as a public authority, is bound by the provisions of the RTI Act, and withholding information on grounds such as economic interest or fiduciary relationship is not justified in this case.

Facts:

Hari Shankar Vidyarthi married Savitri Vidyarthi and later married Rama Vidyarthi. Rama Vidyarthi purchased a property, which was claimed to be joint family property.

Various suits were filed regarding the property, with disputes arising over its ownership and division among family members.

The appellant, Shreya Vidyarthi, contested the claims made by Ashok Vidyarthi, the respondent, regarding the property.

Issues:

Whether the property was purchased using joint family funds or Rama Vidyarthi's personal funds.

Whether a Hindu widow can act as the manager of an HUF and look after the affairs of a minor coparcener.

The legality of the High Court's decision regarding the partition of the property and the apportionment of shares.

Held:

The Supreme Court upheld the High Court's decision that the property was purchased using joint family funds, including insurance money received by Rama Vidyarthi. Thus, it was considered joint family property.

The court clarified that while Hindu widows cannot act as Karta (head) of the HUF, they can act as managers in their capacity as legal guardians of minor coparceners. This distinction was crucial, and Rama Vidyarthi's management role was deemed legitimate.

The court found no error in the High Court's decision regarding the apportionment of shares in the property among the parties involved.

The previous litigation history did not affect the maintainability of the current suit.

The appeals were dismissed, and each party was left to bear its own costs.

Facts:

The Sri Jagannath Temple Managing Committee filed a claim for recording the lands in favor of the Temple, which were previously vested in the State Government under the Orissa Estate Abolition Act, 1951.

The Math challenged this claim, asserting that the lands were accorded the status of 'amrutamanohi' and recorded as Trust Estate under Section 2(oo) of the OEA Act. The dispute arose due to conflicting provisions of the Temple Act, 1955, and the OEA Act, 1951.

Issues:

Whether the lands belonging to the Lord Jagannath Temple at Puri were vested in the Temple Management Committee under the Sri Jagannath Temple Act, 1955?

Whether the provisions of the Orissa Estate Abolition Act, 1951, could divest the Temple Committee of its vested lands?

What was the effect of the conflicting provisions of the Temple Act, 1955, and the OEA Act, 1951, on the status of the Temple lands?

Held:

The Court struck down the first part of the proviso of Section 2(oo) of the Orissa Estate Abolition Act, 1951, which pertained to the properties of Lord Jagannath Temple at Puri.

It quashed the notification issued by the State Government under Section 3A of the OEA Act, 1951, to the extent it applied to the lands and estate of Lord Jagannath Temple at Puri.

The Court clarified that the decision in the previous case of Lord Jagannath did not bar the instant case by res judicata.

The Court also deemed the previous judgment to be per incuriam, as it was passed without considering the provisions of the Temple Act, 1955.

The Court emphasized the primacy of the Temple Act, 1955, over any other legislation concerning the Jagannath Temple lands, stating that the Temple lands were already vested in the Temple Management Committee under this Act.

The Court held that the conflicting provisions of the OEA Act, 1951, and the Temple Act, 1955, could not coexist, and struck down the first part of the proviso to maintain the effectiveness of both acts.

Additionally, the Court ruled that the lands of the Jagannath Temple at Puri were already vested in the Temple Committee under the Temple Act, 1955, and could not be divested by applying the provisions of the OEA Act, 1951.

The Court concluded that since the provisions of the OEA Act, 1951, had no application to the lands of the Lord Jagannath Temple at Puri, there was no need to pass an order in favor of the Temple under the OEA Act, 1951.

Facts:

The case involves an appeal against the acquittal of two accused persons, the husband and mother-in-law of the deceased, by the High Court of Bombay.

The deceased, Asha Hemant Chauriwal, suffered burn injuries and subsequently died due to septicemia.

The prosecution's case relied on a dying declaration made by the deceased and alleged letters written by her to her father, indicating cruelty by her in-laws.

Issues:

The Trial Court convicted the accused based on these evidences, but the High Court acquitted them, citing lack of proof beyond reasonable doubt.

The Supreme Court examined the arguments presented by both sides.

It observed several discrepancies and lapses in the investigation and handling of evidence by the prosecution.

Held:

The Court upheld the High Court's judgment of acquittal, finding no compelling reasons to interfere.

The dying declaration lacked proper corroboration, and the circumstances surrounding its recording raised doubts about its reliability.

The alleged letters were not adequately proven to be written by the deceased, and contradictions in witness testimonies further weakened the prosecution's case.

The Investigating Officer failed to conduct a thorough investigation, which could have clarified important aspects of the case.

Therefore, the appeals filed by the State of Maharashtra were dismissed.

Facts:

The incident occurred on 9th October 2002, involving the accused persons allegedly assaulting and causing the death of Ashok Kumar.

Eyewitnesses provided testimony, and circumstantial evidence was presented by the prosecution.

The Trial Court convicted the accused, but the High Court later acquitted them due to gaps and discrepancies in the evidence.

Issues:

Whether the prosecution's evidence was sufficient to prove the guilt of the accused beyond reasonable doubt.

Whether the High Court's decision to acquit the accused was justified based on the evidence presented.

Held:

The Supreme Court examined the testimonies and evidence presented before it and found that the prosecution failed to establish its case beyond reasonable doubt. Key eyewitnesses, including the complainant and another witness, turned hostile during the trial, casting doubt on the reliability of their testimonies.

The Court noted inconsistencies in witness statements and highlighted deficiencies in the medical evidence provided by the prosecution. While a motive was established through witness testimony, it was not substantive evidence and could not alone support a conviction.

Based on the above analysis, the Supreme Court upheld the High Court's decision to acquit the accused persons. It found no grounds to interfere with the judgment and dismissed the appeals.