Criminal Procedure – Power of Court to Review Judgments – Section 362 Cr.P.C – Judgment Modification Not Permissible – High Court’s Correction Order Quashed - The High Court’s modification of its final judgment on grounds of “clerical error” was found to be impermissible under Section 362 Cr.P.C. – The Supreme Court held that once a judgment is signed, it cannot be altered or reviewed except to correct clerical or arithmetical errors – The changes made were substantive in nature and amounted to judicial review, not correction [Paras 9-20].

Appreciation of Evidence – Conviction Based on Eyewitness Testimony – Evidence Supported by Medical Reports – Conviction Under Section 302 IPC Upheld – The original conviction of the accused under Section 302 IPC was sustained by the trial court and affirmed by the High Court in its initial judgment – The SC noted that medical and ocular evidence corroborated each other and supported the conviction beyond reasonable doubt [Paras 11-12].

High Court Procedure – Correction Application Misused – Conversion to Section 304 Part II IPC Invalid – Held: Review of merits not allowed under correction mechanism – The High Court incorrectly treated substantive judicial reassessment as a clerical correction – Such review falls outside the ambit of Section 362 Cr.P.C and is ultra vires [Paras 13-20].

Final Decision – Supreme Court Sets Aside Modified Judgment – Appeals by Complainant Allowed – Original Conviction Restored – The apex court quashed the impugned correction judgment dated 08/02/2019 and restored the original judgment dated 21/05/2018 convicting the accused under Section 302 IPC – Directions issued for surrender and compliance [Paras 20-21].
 

Service Law - Civil Services – Promotion to Chief Secretary Grade – Incomplete ACRs and Review Committee Assessment – Denial of Promotion Upheld – The appellant, a 1991-batch IAS officer, was denied promotion to the Chief Secretary grade on the ground of incomplete ACRs and adverse remarks – Held: Though considered as a ‘special case’ with less than 90% ACRs, Screening Committee found his record below noteworthy; Review Committee affirmed the decision based on absenteeism, poor leadership, and disciplinary concerns [Paras 1-10, 20-21].

Review of Promotion Denial – Scope and Legitimacy – No Illegality Found – The Review Committee did not expand beyond the Screening Committee’s reasoning but merely amplified it with supporting material including post-2016 conduct – Held: Prior adverse entries not relating to dishonesty are weak material post-promotion but can be reinforced by subsequent similar behavior – No case for procedural impropriety or mala fide made out [Paras 14-19, 22].

Screening Criteria – No Benchmark Required – Clause 7.2 of Guidelines – Appellant’s Argument Rejected – Held: Absence of benchmark does not render assessment arbitrary, especially where candidate was given special consideration despite incomplete ACRs – Screening was not vitiated by this reason [Para 23].

Judicial Interference – Wednesbury Principle – Not Attracted – The Court found that decisions of the Screening and Review Committees were based on objective evaluation, fairness, and relevant material – Held: No irrationality or mala fides – Appeal dismissed [Paras 24-25].

*Decision – Appeal Dismissed – Promotion Denial Upheld – The Supreme Court upheld the Review Committee’s decision rejecting promotion – Held: Screening Committee had rightly considered post-promotion conduct and incomplete ACRs – Appellant permitted by High Court to take steps for future reconsideration upon completion of ACRs, but no grounds for judicial interference presently exist [Paras 24-25].

Criminal Procedural Law - Cognizance – Sufficiency of Reasoning – Recording of Prima Facie Case – Cognizance Restored - The High Court remanded the matter to the Trial Court stating that the cognizance order lacked disclosure of prima facie material – Held: The approach of the High Court was erroneous – It is settled law that a Magistrate is not required to record detailed reasoning while taking cognizance as long as judicial mind has been applied – Cognizance order of 13.06.2019 was valid and required no interference – Bhushan Kumar and other precedents reiterated [Paras 15-17].

Quashing of FIR – Civil Dispute Camouflaged as Criminal – Mala Fide Allegation – Not Entertained - Appellants contended that the FIR was a misuse of criminal law to settle civil disputes relating to property ownership and harassment post-relationship breakdown – Held: Without categorical assertion that no material existed in the chargesheet, such challenge could not be sustained – The matter raised factual questions to be evaluated during trial – The plea to quash proceedings was not accepted [Paras 18-21].

Application of Judicial Mind – Material in Police Papers – Enquiry Scope – Cognizance Upheld - Court reaffirmed that at the stage of taking cognizance, the focus is on presence of prima facie material and not its probative value – Judicial application of mind noted in the cognizance order – Chargesheet corroborated allegations – Court held there was no infirmity warranting High Court interference [Paras 20-21].

Relief Beyond Cross-Appeal – Complete Justice – Impugned Judgment Set Aside – Despite no cross-appeal by Respondent No. 2, the Supreme Court exercised jurisdiction to set aside the High Court's remand order to correct legal error on the need for detailed reasoning in cognizance orders – Held: Cognizance was valid and proceedings must continue from that stage [Para 22].

Decision – Appeal Allowed – Cognizance Order Restored – Trial to Proceed - Supreme Court allowed the appeal, set aside the High Court judgment, and restored the cognizance order – Directed the appellants to appear before the Trial Court on next hearing – Liberty granted to appellants to press for discharge or other remedies at the appropriate stage – No costs awarded [Paras 23-25].

Criminal Law – Murder – Appeal Against Conviction - Section 313 CrPC – Inadequate Examination of Accused – Prejudice Caused – Conviction Set Aside – Appellant’s examination under Section 313 CrPC merely summarized the prosecution's case rather than presenting specific evidence against him – Supreme Court held this as fatal irregularity causing inherent prejudice – Trial court failed to present material circumstances for the accused to respond meaningfully [Paras 7–13].

Conviction Under Section 302 IPC – Defective Trial – No Effective Defence Opportunity – Acquittal Granted – Appellant’s right to fair trial violated due to non-compliance with mandatory requirements under Section 313(1) CrPC – Court held that prosecution must put each incriminating circumstance specifically to the accused – In absence of such examination, appeal allowed and appellant acquitted [Paras 10–15].

Remand – Not Feasible Due to Passage of Time – 14 Years Elapsed – Acquittal Ordered – Although such procedural defects are curable, Supreme Court declined remand due to long delay since incident (2011) and prolonged custody (14 years served) – Appellant ordered to be released forthwith unless required in another case [Paras 14–17].

Decision – Appeal Allowed – Conviction under Section 302 IPC set aside – Appellant acquitted of all charges – Supreme Court directed his immediate release [Paras 15–17].
 

Criminal Law - SARFAESI Act - Quashing of Criminal Proceedings – Lack of Prima Facie Role – Criminal Process Misused – Allegations Baseless – Appellant held not to be involved in the auction process or issuance of sale certificate under SARFAESI Act – At relevant time, he was not the authorized officer under Rule 2(a) of the Enforcement Rules – Held: Criminal proceedings against the appellant amounted to abuse of process and must be quashed [Paras 10–13, 17–19].

Good Faith Protection – Applicability of Section 32 SARFAESI Act – No Criminal Intent Found – Appellant’s actions unrelated to the transaction challenged in the FIR – Held: No criminal liability as he had not acted in bad faith – FIR quashed on grounds of lack of mens rea and nexus to alleged acts [Paras 13, 18–19].

Overlapping Civil and Criminal Remedies – Civil Nature Disguised as Criminal Offence – Consumer Complaint Already Dismissed – Court held that criminal complaint was filed after failure in consumer forum – Held: Continuation of proceedings would result in harassment and miscarriage of justice [Paras 12, 19].

Decision – Criminal Proceedings Quashed – Abuse of Judicial Process Prevented – Supreme Court allowed the appeals and quashed the FIR and all consequential proceedings in CC No. 50 of 2015 – Held: Appellant’s prosecution was without basis in law or fact; continuation would be unjust [Para 20].
 

Civil Law - Gift Deed – Validity under Muslim Law – Deed Upheld – A registered Gift Deed dated 26.04.1958 executed by the plaintiff’s grandfather was found to be valid under Mahomedan Law, where the grandfather transferred land to his grandson who otherwise would not have inherited – Delivery of possession was proven and misdescription of dag numbers held to be immaterial to the identity of the property – Held: Gift Deed valid, delivery of possession accepted through plaintiff’s mother [Paras 4(viii), 4(x), 4(xii), 4(xiii)].

Declaratory Relief – Necessity of Seeking Cancellation of Void Sale Deed – Not Mandatory – The High Court erred in holding that the plaintiff’s failure to seek cancellation of a subsequent sale deed disentitled him from obtaining declaration of title – Supreme Court clarified that a person not party to a void document (like the plaintiff here) need not seek its cancellation under Section 31 – Mere declaration of non-binding nature is sufficient [Paras 24–36].

Right to Seek Declaration – Plaintiff as Non-Executant – Legal Right Recognized – The plaintiff, not being party to the subsequent sale deed, was held entitled to a declaration of title and recovery of possession – Courts below rightly entertained suit without insistence on cancellation relief – Held: Declaration of title includes implicit negation of rights under void sale deed by third parties [Paras 34–37].

High Court Judgment – Improper Reversal – High Court concurred on validity of Gift Deed but reversed decree solely on technical omission – Supreme Court held that such omission did not defeat the suit and trial court findings should be restored – Appeal allowed, decree of trial court restored [Paras 36, 46].

Criminal Law – Rape – Kidnapping – Appeal Against Acquittal - Appreciation of Evidence – Statement of Prosecutrix – Material Contradictions – Acquittal Upheld – The prosecution case was based primarily on the testimony of the prosecutrix – Contradictions in her statements regarding date and place of rape undermined credibility – The prosecutrix failed to disclose the incident to any person she met after the alleged occurrence – Held: High Court rightly disbelieved the prosecutrix's version as inconsistent and uncorroborated [Paras 7–10].

Medical and Scientific Evidence – Lack of DNA Profiling – No Conclusive Link to Accused – The semen found on the prosecutrix’s clothes was not subjected to DNA analysis – No forensic link established between the accused and the offence – Held: Prosecution failed to prove guilt beyond reasonable doubt [Para 8].

Witness Testimony – Hostile Witness – Key Witness Denied Allegations – PW-6, in whose house rape allegedly occurred, did not support the prosecution case – No evidence of communication between PW-6 and accused – Held: Hostile testimony weakened prosecution case materially [Paras 7–8].

Criminal Jurisprudence – Benefit of Doubt – Presumption of Innocence Reinforced – The High Court’s view found to be a plausible one based on the contradictions and lack of corroboration – Held: In absence of compelling evidence, presumption of innocence must prevail – No ground for appellate interference with acquittal [Paras 10–11].

Decision: Appeal Dismissed – High Court’s Acquittal Sustained – The Supreme Court held that the view taken by the High Court was plausible and supported by evidence – Material inconsistencies in the prosecutrix’s statements, absence of forensic corroboration, and failure of key witness to support allegations were critical – Held: No interference warranted with acquittal – Appeals by State dismissed [Paras 11–12].
 

Criminal Law – Murder – Appeal Against Acquittal - Dying Declarations – Non-compliance with Section 313 CrPC – Acquittal Upheld – The Supreme Court held that the prosecution’s failure to put the contents of the dying declarations to the accused during examination under Section 313 CrPC prejudiced the accused – As such, the declarations could not be relied upon for conviction – Further remand to rectify this defect after 14 years would cause undue prejudice – Appeals dismissed [Paras 16–23, 27].

Minor Witness – Competency of Child Witness – Procedural Lapse – The minor son of the deceased, who was presented as an eyewitness, was not subjected to preliminary questioning by the Trial Court to assess competence – Major contradictions in testimony led the Court to hold the evidence unreliable – Testimony not considered safe to rely on for conviction [Paras 10–14].

Contradictory Evidence – Medical Evidence and Dying Declarations – Burn Injuries on Co-Accused and Accused – The prosecution failed to explain injuries on the co-accused who later died and the accused who sustained 20% burns – This weakened the prosecution case and added to reasonable doubt about their role in the incident [Paras 24–25].

Appeal Against Acquittal – Judicial Review – Principles Reiterated – The Court reiterated that if the High Court’s view is a possible one based on evidence, even if another view is possible, the acquittal should not be interfered with – High Court's decision upheld despite some differences in interpretation [Paras 26–27].

Judicial Directions – Compliance with Section 313 CrPC – Procedural Safeguards Suggested – The Court directed that High Courts must verify the adequacy of Section 313 statements at the appellate stage to prevent prejudice and suggested trial courts seek assistance from counsels to ensure proper questioning under Section 313 CrPC [Para 28].

Decision – Appeals dismissed – Acquittal confirmed – No interference warranted as prosecution failed to establish guilt beyond reasonable doubt due to procedural and evidentiary lapses [Para 30].
 

Civil Law - Land Acquisition Compensation – Reliance on Auction Sale Exemplar – High Court Erred – The High Court’s compensation of ₹1.35 crore per acre based on Golden Mile project auction rates was held excessive – Supreme Court found such post-notification sales and auction-based exemplars unreliable due to enhanced prices from public project awareness – Set aside High Court’s reliance on auction rates [Paras 10–29].

Comparable Sales – Pre-notification Sale Instances Preferred – Compensation Recomputed – Supreme Court relied on two 2004 pre-notification sale deeds (Ex.A1 and A2) at ₹31 lakhs per acre, adding 20% compounding annual escalation for two years to determine market value at ₹44.64 lakhs per acre [Paras 35–44].

Statutory Benefits – Interest and Solatium – Correct Interpretation of Section 34 – Held: Landowners entitled to solatium at 30%, additional amount at 12% p.a., and interest on enhanced compensation at 9% for first year and 15% thereafter – High Court erred in granting a flat 12% interest rate [Paras 47–51].

Post-Notification Sales and Auction Instances – Not Reliable – Sale deeds executed more than 16 months after Section 4 notifications were held tainted due to acquisition’s impact on land value – Reaffirmed settled principle that post-notification sales cannot reliably reflect pre-notification market value [Paras 24–28, 31–33].

Final Decision – Appeals by State Allowed in Part, Landowners Dismissed – Market value reduced to ₹44.64 lakhs per acre from ₹1.35 crore – Clarification issued on applicable interest rates – Compensation with statutory benefits to be paid within 8 weeks [Paras 52–53].