Criminal Procedure – Quashing of Complaint – Appeal against dismissal of application for quashing a complaint – Complaint lodged alleging tampering with medical reports and documents in judicial proceedings – High Court dismissed the application, holding that provisions of Sections 195 and 340 CrPC were not applicable – Supreme Court upheld the High Court’s decision, emphasizing that if tampering occurs outside the court, Sections 195 and 340 CrPC are not attracted [Paras 1-12].

Forgery – Documents Produced in Court – Allegation of forgery of medical reports used in court – Supreme Court noted that forgery must occur while documents are in custodia legis for Sections 195 and 340 CrPC to apply – Court reiterated that forgery committed outside court before submission is not protected by Section 195 CrPC [Paras 7-12].

Precedents – Application of Law – Cited cases include M.S. Ahlawat v. State of Haryana, Iqbal Singh Marwah v. Meenakshi Marwah, and Mohan Singh v. Late Amar Singh Thr. Lrs – Court applied principles from these cases to conclude the High Court’s decision was correct and no interference was warranted [Paras 8-12].

Decision: Appeal dismissed – High Court’s decision affirmed – Complaint not quashed – Supreme Court confirmed that tampering alleged to have occurred outside court does not invoke protections under Sections 195 and 340 CrPC [Para 12].

Education Law – UGC's Authority to Set Qualifying Criteria – Appeals against High Court ruling that UGC lacked competence to fix aggregate marks as final qualifying criteria after candidates obtained minimum marks in NET examination – Supreme Court upheld UGC’s authority under UGC Act to determine and maintain standards of education, including setting qualifying criteria for NET – Decision to set aggregate percentage as qualifying criteria before declaration of results deemed within UGC’s powers [Paras 1-30].

Statutory Interpretation – Role of UGC – Examination of UGC Act, Regulations, and powers – Court affirmed UGC’s duty to maintain standards in higher education, including setting criteria for eligibility of lectureship and JRF – Notification for NET examination clearly indicated requirement for final qualifying criteria – No arbitrary or discriminatory action found in UGC’s decision-making process [Paras 20-29].

Judicial Review – Academic Decisions – Limited scope for judicial review in academic matters – Court reiterated principle of non-interference in decisions of expert academic bodies unless clear statutory violation – UGC’s criteria for NET upheld as rational and necessary for maintaining educational standards [Para 29].

Decision: Appeals allowed – High Court judgment set aside – UGC’s criteria for NET upheld as valid and within statutory authority [Para 30].

Criminal Law – Rape Conviction – Appellant convicted for rape under Section 376 IPC – Allegation that sexual intercourse was initially non-consensual and subsequent acts were based on false promise of marriage – Supreme Court scrutinized the evidence and circumstances, including delay in lodging FIR and lack of independent corroboration – Conviction based solely on prosecutrix’s testimony found unsafe [Paras 1-20].

Consent – Misconception of Fact – Examination of consent under Section 375 IPC and its validity when obtained under promise of marriage – Court held that mere promise to marry does not constitute misconception of fact unless proven that promise was false from inception – Reference to Deelip Singh v. State of Bihar and other precedents [Paras 12-14].

Evidentiary Standards – Testimony of Prosecutrix – While prosecutrix's testimony commands respect, court emphasized need for corroboration in presence of doubtful circumstances – Lack of injuries, delay in filing complaint, and behavior of prosecutrix’s family considered – Court reiterated principles from Ramdas v. State of Maharashtra and similar cases [Paras 15-19].

Decision: Appeal allowed – Conviction and sentence under Section 376 IPC set aside – Supreme Court found the evidence insufficient to support conviction beyond reasonable doubt [Para 20].

Criminal Law – Death Penalty – Appeals against confirmation of death sentence for offences under Sections 120B, 148, 302 read with 149, 307 read with 149, 326, 429, 436, and 452 IPC – Examination of statutory requirements for "special reasons" under Section 354(3) CrPC – Supreme Court upheld death sentence, affirming that reasons recorded by lower courts satisfied statutory mandate – Consideration of brutality, premeditation, and impact on society as criteria for rarest of rare cases [Paras 1-50].

Sentencing – Special Reasons for Death Penalty – Detailed scrutiny of legislative mandate under Section 354(3) CrPC requiring "special reasons" for death penalty – Court emphasized necessity of recording specific reasons in judgment – Reference to landmark cases like Bachan Singh v. State of Punjab and Machhi Singh v. State of Punjab for principles of sentencing in capital cases [Paras 29-50].

Evidentiary Standards – Balancing Aggravating and Mitigating Circumstances – Court evaluated both aggravating and mitigating factors in deciding appropriateness of death penalty – Highlighted that procedural compliance alone not sufficient; substantive reasoning essential – Examination of evidence on record including testimonies, motive, and manner of crime [Paras 46-52].

Decision: Appeals dismissed – Death sentence upheld – Supreme Court found lower courts' reasoning adequate and aligned with statutory and judicially evolved principles for imposing death penalty [Para 52].

Criminal Law – Detention in Borstal School – Appellant convicted under Section 302 IPC and sentenced to life imprisonment for murder at the age of 19 years 8 months – Contention that appellant should have been detained in Borstal School under Tamil Nadu Borstal Schools Act – Supreme Court examined applicability of Borstal Schools Act and Juvenile Justice Act – Found that appellant was not entitled to Borstal School detention as he was over 21 years old at the time of conviction and thus not an 'adolescent offender' under the Act [Paras 1-6].

Statutory Interpretation – Adolescent Offender – Court clarified definition of 'adolescent offender' under Section 2(1) of Borstal Schools Act and distinction from 'juvenile' under Juvenile Justice Act – Appellant over 21 years old at time of conviction, hence Borstal School detention not applicable – Emphasized need for legislative amendment to align age definitions with current juvenile laws [Para 2].

Procedural Requirements – Consideration of Reports – Discussion on procedural requirements under Section 8 of Borstal Schools Act – Court noted absence of consideration by lower courts but found no relief available retrospectively under Juvenile Justice Act for appellant – Held no procedural impropriety in sentencing to regular imprisonment given appellant’s age at conviction [Paras 3-5].

Decision: Application for bail dismissed – Supreme Court upheld life imprisonment sentence, rejecting plea for Borstal School detention due to age criteria not being met under Tamil Nadu Borstal Schools Act [Para 6].

Constitutional Law – Equality before Law – Petitioners challenged Corrigendum confining benefits of Regulations 2013 to government medical colleges, arguing it violated Article 14 by discriminating against private medical colleges – Supreme Court examined procedural and substantive compliance – Held no violation of Article 14 as decision taken in public interest and within statutory powers [Paras 1-6].

Administrative Law – Statutory Authority – Examination of powers under Indian Medical Council Act and related regulations – Supreme Court upheld Central Government’s authority to modify time schedule for receipt of applications in respect of specific categories of institutions under Regulations 2013 – Found modification in compliance with statutory requirements and court’s previous directions [Paras 9-21].

Judicial Review – Reasonableness of Administrative Actions – Court reviewed reasonableness and necessity of restricting Regulations 2013 to government colleges due to limited time for processing applications – Held that the decision was not arbitrary or unreasonable and was taken to ensure timely admissions and quality education [Paras 15-21].

Decision: Petitions dismissed – Supreme Court upheld the Corrigendum issued by Central Government, confining Regulations 2013 to government medical colleges, finding no discrimination or violation of Article 14 [Para 22].

Limitation Law – Applicability in Pondicherry – Appellant contested applicability of Indian Limitation Act, 1963 vis-à-vis Article 2262 of French Code Civil in Union Territory of Pondicherry – Supreme Court confirmed Indian Limitation Act governs limitation in Pondicherry post-merger with India – Article 54 of Limitation Act applicable, not Article 2262 of French Code Civil – Suit for specific performance barred by limitation as per Indian Limitation Act [Paras 1-14].

Statutory Interpretation – Continuance and Adaptation of Laws – Examination of Pondicherry (Administration) Act, 1962 – Section 4 provided for continuance of existing laws until amended or repealed – Supreme Court held that Indian Limitation Act, 1963, extends to Pondicherry, repealing contrary provisions of French Code Civil – Reference to Syndicate Bank v. Mr. Prabha D. Naik and Another for similar interpretation involving Portuguese Civil Code [Paras 8-12].

Judicial Precedent – Relevance of Prior Decisions – Citing Syndicate Bank case, Court reiterated principle of Indian Limitation Act overriding local laws upon extension – Decision aligns with precedent ensuring uniform application of Limitation Act across India [Para 12].

Decision: Appeal dismissed – Supreme Court upheld High Court's ruling applying Indian Limitation Act, 1963, and finding suit barred by limitation – Other substantial questions of law not addressed due to suit being time-barred [Para 14].

Income Tax – Interest on Refunds – Supreme Court examined correctness of decision in Sandvik Asia Ltd. v. Commissioner of Income Tax-I Pune – Clarified that Sandvik did not mandate payment of interest on interest – Legislature provided for interest on refunds under Section 244A of Income Tax Act – Assessee entitled only to statutory interest, no interest on such statutory interest [Paras 1-9].

Judicial Interpretation – Clarification on Misinterpretation – Court noted misinterpretation of Sandvik judgment by Assessees and Revenue – Sandvik case intended compensation for inordinate delay, not interest on statutory interest – Clarified appropriate understanding of legislative intent behind Section 244A [Paras 6-8].

Statutory Provisions – Scope and Application – Detailed discussion on Section 244A introduced by Act No. 4 of 1988 – Emphasized statutory interest provisions are exhaustive – Court discouraged claims beyond statutory interest as provided by law [Paras 8-9].

Decision: Clarification issued – Matters referred back to Two Judge Bench for independent consideration – Supreme Court clarified scope of interest entitlement under Section 244A, aligning with legislative provisions [Para 9].

Electricity Law – Capital Expenditure Approval – Appeal against CERC and Appellate Tribunal's approval of additional capital expenditure without CEA's sanction – Supreme Court examined Regulation 2.5 requiring CEA or independent agency approval for excess expenditure – Held CERC entitled to prudent check, excess expenditure acknowledged as capital in nature – Affirmed CERC's and Tribunal's findings [Paras 1-16].

Statutory Interpretation – Post-2003 Act Framework – Analyzed impact of Electricity Act, 2003 repealing prior acts – Noted 2003 Act diminished CEA’s role, Regulation 2.5 rendered redundant – CERC empowered to fix tariffs independently post-2003 Act – Reference to CEA deemed unnecessary post-enactment [Paras 17-22].

Judicial Review – Role of CEA – Discussed CEA’s historical and current roles under amended legislative framework – Clarified CERC's authority post-2003 Act for capitalisation approvals without CEA intervention – Dismissed appeal due to no miscarriage of justice or prejudice from lack of CEA reference [Paras 18-22].

Decision: Appeals dismissed – Supreme Court upheld additional capital expenditure approvals by CERC without CEA's sanction – Affirmed CERC’s authority under new legislative framework – Costs assessed at Rs. 50,000/- [Paras 22-23].