Contempt of Court – Non-Compliance with Undertaking – State of Bihar committed to recruiting trained primary school teachers but failed to honor its undertaking, resulting in multiple contempt petitions – Supreme Court had directed the state to prioritize trained teachers for vacancies – Discrepancies in the number of vacancies and candidates led to appointing a Special Officer to finalize the list [Paras 1-7].

Appointment Process – Ensuring Fairness and Compliance – Justice V.A. Mohta and later Justice S.K. Chattopadhyay appointed to oversee and finalize the list of eligible candidates – 34,540 candidates appointed based on the finalized list – Further discrepancies and individual grievances led to modifications in the Court's earlier orders to address all legitimate claims [Paras 6-8].

Jurisdiction of High Court – Redressal of Grievances – Supreme Court allowed candidates to approach the High Court to address individual grievances regarding the final select list – Ensured that the appointments already made would not be disturbed – Directed the state to consider remaining vacancies while disposing of pending applications [Para 9].

Decision – Special Leave Petition and associated applications disposed of – Supreme Court modified its previous order, allowing applicants to seek relief from the High Court without affecting the appointments already made – Directed the state to consider filling the remaining 2,413 vacancies [Paras 9].

Juvenile Justice – Definition and Treatment of Juveniles – Petitions challenged the constitutionality of the Juvenile Justice Act, 2000, arguing for changes to handle juveniles committing heinous crimes under normal laws rather than juvenile justice provisions – Supreme Court upheld the current definition of juveniles under the Act, affirming it was in line with international standards and constitutional provisions – Emphasized the rehabilitative and reformative approach of the Juvenile Justice Act over punitive measures [Paras 1-50].

Constitutional Validity – Articles 14 and 21 – Upheld the Juvenile Justice Act as compliant with Articles 14 and 21 – Rejected the argument that the Act violated fundamental rights by allowing lenient treatment of juveniles involved in serious crimes – Emphasized the Act’s alignment with international conventions and the policy decision to treat individuals below 18 years as juveniles [Paras 27-31].

International Standards and National Policy – Referenced international instruments like the UN Convention on the Rights of the Child, Beijing Rules, and the Havana Rules – Confirmed that the age limit of 18 for juveniles is consistent with these standards – Recognized the legislative intent and policy considerations behind the Juvenile Justice Act, supporting the current age threshold for juvenile classification [Paras 41-45].

Role of Rehabilitation – Highlighted the Act’s focus on the rehabilitation and reintegration of juvenile offenders into society – Recognized that juveniles committing heinous crimes represent exceptions rather than the norm – Affirmed the necessity of a rehabilitative approach to prevent juveniles from becoming hardened criminals [Paras 48-49].

Decision – Writ Petitions and Transferred Case dismissed – Upheld the constitutionality of the Juvenile Justice (Care and Protection of Children) Act, 2000 – Emphasized the need for effective implementation of the Act rather than amending it based on isolated incidents [Para 50].

Criminal Law – Murder Conviction – Appellant convicted for the murder of Iqbal – Trial court and High Court found the appellant guilty under Section 302 read with Section 34 IPC – High Court acquitted co-accused Muzaffar and Shahjad based on their alibi, raising doubts about the prosecution's case against the appellant – Supreme Court found that the evidence against the appellant was insufficient and unreliable [Paras 1-20].

Right of Private Defense – Appellant argued the deceased was a known criminal who threatened his family – Although the claim of private defense was not accepted, the Court found the prosecution had failed to establish the circumstances of the incident convincingly – Evidence showed inconsistencies, particularly regarding the presence of co-accused and the recovery of the weapon [Paras 4-19].

Evidence and Prosecution Case – Inconsistencies and Doubts – FIR and witness testimonies indicated the involvement of co-accused who were later acquitted – Discrepancies in the recovery of the weapon and the ballistic evidence raised further doubts – Prosecution's failure to recover scooters allegedly present at the scene questioned the credibility of the case [Paras 8-17].

Decision – Appeal allowed – Conviction and sentence of the appellant set aside – Appellant to be released forthwith if not required in any other case – The prosecution's case found unreliable, granting the appellant the benefit of doubt [Paras 19-20].

Criminal Law – Conviction under Section 302 read with Section 34 IPC – Appellant (A-3) convicted for murder along with co-accused – Conviction based on the evidence of two eyewitnesses who were relatives of the deceased – Supreme Court finds inconsistencies in their testimonies and lack of corroborative medical evidence – Appeal allowed, conviction and sentence set aside [Paras 1-11].

Evidence Law – Interested Witnesses – Evidence provided by relatives of the deceased scrutinized – No absolute bar on considering such evidence, but requires careful analysis – Court finds that evidence of PW-1 and PW-3 lacked clarity regarding the specific role of the appellant (A-3) – Insufficient to sustain conviction [Paras 7-8].

Medical Evidence – Post-mortem report examined – Doctor (PW-10) confirms multiple head injuries as cause of death – No direct link established between injuries and appellant’s actions as alleged by eyewitnesses – Discrepancy in eyewitness account and medical findings critical in setting aside conviction [Paras 9-10].

Decision: Appeal allowed – Conviction and sentence under Section 302 read with Section 34 IPC set aside – Appellant ordered to be released forthwith if not required in any other case [Para 11].

Education Law – Binding Nature of UGC Regulations – Whether the UGC regulations regarding pay scales and retirement age have mandatory effect on state-run institutions – Supreme Court analyzes constitutional provisions and the statutory framework governing UGC – Determines the extent to which state laws can diverge from UGC guidelines – Holds that UGC regulations, while recommendatory, gain binding effect upon acceptance by state governments as part of a composite scheme involving financial assistance from the central government [Paras 1-44].

Constitutional Law – Legislative Competence – Conflict between state laws and central regulations – Examination of legislative entries in Seventh Schedule, particularly Entry 66 of List I and Entry 25 of List III – Court asserts primacy of central legislation in matters of coordination and determination of standards in higher education – State regulations must align with central norms where conflict arises [Paras 28-38].

Administrative Law – Conditions of Service – Age of Superannuation – State amendments enhancing age of superannuation analyzed – Court considers state discretion in adopting UGC guidelines – Determines that while states have autonomy, acceptance of central financial assistance mandates adherence to comprehensive UGC scheme, including revised retirement age [Paras 9-19].

Decision: Appeals partly allowed – States directed to implement UGC guidelines as accepted in composite schemes – UGC regulations on pay scales and retirement age to be adopted uniformly by states receiving central financial aid – States granted liberty to modify other service conditions within legislative competence [Paras 42-44].

Criminal Law – Conviction for Dacoity – Appellant convicted under Sections 395/397 IPC, Section 25(1A)(b) of the Arms Act, and Sections 3 and 5 of the Explosive Substances Act – Evidence by prosecution witnesses and taxi owner identifying appellant as an accomplice in the dacoity – Appellant claimed limited involvement, only facilitating escape in a taxi – Supreme Court upheld conviction but altered sentence considering appellant’s limited role [Paras 1-11].

Evidence Law – Identification and Testimony – Witnesses identified appellant as standing near the taxi used by dacoits – Taxi owner confirmed appellant was the driver – Consistent testimonies from multiple witnesses, no contradictions – Supreme Court found no reason to disbelieve evidence presented by prosecution [Paras 6-9].

Sentencing – Consideration of Role and Circumstances – Appellant sentenced to 10 years by lower courts – Supreme Court acknowledged appellant’s role was limited to facilitating escape, not directly participating in the dacoity – Sentence reduced to period already undergone (7 years and 6 months) – Directed immediate release of appellant [Paras 10-11].

Decision: Appeal disposed of – Conviction confirmed, sentence reduced to time already served – Appellant to be released forthwith if not required in any other case [Para 11].

Civil Procedure – Withdrawal of Appeal – Interim Relief – High Court allowed withdrawal of appeal but extended interim relief until 10th May 2010 – Appellants challenged continuation of interim relief after appeal withdrawal – Supreme Court held High Court did not err, interim relief extension was justified to facilitate appellants' alternative legal remedy [Paras 1-20].

Judicial Process – Functus Officio – High Court’s jurisdiction post-disposal – High Court retains limited jurisdiction to extend interim relief even after permitting withdrawal of an appeal – Ensures no prejudice to parties seeking alternative remedy – Supreme Court finds High Court acted within its powers, dismisses appeal [Paras 12-19].

Constitutional Law – Article 226 – Interim Relief – Court’s power to grant interim relief ancillary to main relief – Supreme Court reiterates interim relief can be continued post-disposal to aid justice – High Court’s decision to extend relief upheld [Paras 16-18].

Decision: Appeals dismissed – High Court’s order extending interim relief upheld – Interim relief by Supreme Court stands vacated – No costs awarded [Paras 20-21].

Preventive Detention – Pre-Execution Challenge – Detention orders challenged at pre-execution stage on grounds beyond the five exceptions in Alka Subhash Gadia – Supreme Court held right of proposed detenue to challenge preventive detention orders on grounds other than five exceptions – Matters listed for final hearing on all grounds of challenge [Paras 1-7, 52-58].

Staleness of Detention Orders – Long interval between passing and execution of detention order – Detention order loses purpose if not executed timely – No material indicating continued prejudicial activity by detenue – Orders quashed as stale [Paras 9-11, 53].

Right to Freedom and Preventive Detention – Right to challenge detention at pre-execution stage – Importance of right to freedom – Examination of new grounds of challenge not considered in Alka Subhash Gadia – Preventive detention as a measure of caution not punishment [Paras 3-5, 7, 57-58].

Decision:

Writ Petitions allowed, detention orders quashed – Orders of preventive detention must be timely executed and relevant – Long delay erodes purpose – Absconding detenue cannot use delay to challenge detention [Para 53].

Criminal Procedure – Jurisdiction of Magistrate vs. Sessions Court – Appeal involves the hierarchy of courts concerning the committal of cases – The issue is whether the Additional Chief Metropolitan Magistrate could commit the case to the Sessions Court for trial when the offences are not exclusively triable by the Sessions Court [Paras 1-10].

Section 306 CrPC – Tender of Pardon to Accomplice – Analysis of the procedures under Section 306 of the CrPC for granting pardon to an accomplice and the subsequent commitment of the case to the appropriate court – Court emphasized proper application of Section 306(5) CrPC, delineating the circumstances under which a case should be committed to the Sessions Court or Chief Judicial Magistrate [Paras 8-10].

Judicial Interpretation – Committal Orders – The Supreme Court critiqued the High Court's interpretation of committal orders, holding that the Additional Chief Metropolitan Magistrate improperly committed the case to the Sessions Court – Reinforced that offences not exclusively triable by the Sessions Court should remain with the Chief Metropolitan Magistrate for trial [Paras 11-13].

Decision:

Appeal allowed – High Court's order set aside – Case restored to the file of the Chief Metropolitan Magistrate for trial – Appellants granted liberty to apply for cancellation of the pardon granted to the approver, to be decided by the Magistrate [Paras 13-15].