Criminal Law – Dowry Death – Appeals challenging the conviction for dowry death – Supreme Court reviewed evidence including witness testimonies, post-mortem reports, and forensic analysis – Held that the prosecution established the necessary ingredients for the application of Section 304B IPC – Appeal dismissed [Paras 1-19].

Evidence Law – Presumption under Section 113B – Court analyzed the applicability of the presumption under Section 113B of the Evidence Act – Emphasized that once the prosecution establishes the essential ingredients, the burden shifts to the accused to rebut the presumption – Found that the accused failed to provide a satisfactory explanation for the circumstances leading to the death [Paras 10-17].

Judicial Discretion – Review of Circumstantial Evidence – Supreme Court stressed the importance of evaluating the chain of circumstances in dowry death cases – Highlighted the unexplained presence of "Organo Phosphorus Pesticide" in the deceased's vomit and the hurried cremation as key factors supporting the conviction [Paras 14-18].

Decision – Appeals dismissed – Conviction and sentence under Sections 498A, 304B, and 201 read with Section 34 IPC upheld – Accused directed to surrender to serve the remaining sentence [Para 19].

Criminal Law – Dowry Death – Appeal against the conviction for dowry death under Sections 304B and 498A IPC – Supreme Court reviewed evidence including witness testimonies, post-mortem reports, and the sequence of events leading to the death – Held that the prosecution established the necessary ingredients for the application of Section 304B IPC – Appeal partly allowed by reducing the sentence [Paras 1-25].

Evidence Law – Presumption under Section 113B – Court analyzed the applicability of the presumption under Section 113B of the Evidence Act – Emphasized that once the prosecution establishes the essential ingredients, the burden shifts to the accused to rebut the presumption – Found that the accused failed to provide a satisfactory explanation for the circumstances leading to the death [Paras 22-23].

Judicial Discretion – Evaluation of Circumstantial Evidence – Supreme Court stressed the importance of evaluating the chain of circumstances in dowry death cases – Highlighted the presence of injuries and the hurried cremation as key factors supporting the conviction – Reduced the sentence considering the appellant’s personal circumstances [Paras 14-25].

Decision – Appeal partly allowed – Conviction under Sections 304B and 498A IPC upheld – Sentence under Section 304B IPC reduced to seven years rigorous imprisonment – Sentence under Section 498A IPC remains two years with a fine of Rs. 2000 – Sentences to run concurrently – Appellant directed to surrender to serve the remaining sentence [Para 25].

Constitutional Law – Amendment Challenge – Petitioner university challenged amendments introduced by Amendment Act No. 5 of 2000 to the Maharshi Mahesh Yogi Vedic Vishwavidyalaya Adhiniyam, 1995 – High Court upheld amendments to Sections 4(1), 9(2), 31-A(1), (2), 31-B, 31-C, 37-B(a), (b), (d), (e) as intra-vires, while Section 37-A and proviso to Section 4 on conducting courses without State Government's approval held ultra-vires – Supreme Court examined legislative intent and statutory interpretation principles, concluding proper application of disjunctive reading of 'and' in Section 4(1) [Paras 1-95].

Education – Role of Vedic Knowledge – Court underscored the importance of Vedic education, interpreting its holistic approach encompassing various aspects of life and human physiology – Reiterated the ancient knowledge in Vedas pertinent to modern education and scientific learning [Paras 17-19, 27-43].

Decision – Appeal Allowed in Part – Supreme Court upheld most of the High Court’s findings, confirming the validity of State's regulatory measures, emphasizing the autonomy of educational institutions within reasonable State control [Para 68].

Service Law – Seniority and Promotion – Appeal involving the validity of granting retrospective seniority to Supervisors promoted to Junior Engineers – High Court decision upheld, confirming that retrospective seniority violated Article 14 – Retrospective seniority adversely impacted existing Junior Engineers, creating unreasonableness and unfairness – Weightage of service for Supervisors to be considered only for eligibility, not for seniority purposes [Paras 1-69].

Constitutional Law – Article 14 and 16 – Retrospective operation of rules and their impact on seniority – Supreme Court held that retrospective seniority cannot be granted from a date when the employee was not part of the cadre – Emphasis on the principle that seniority is determined by the date of entry into the service [Paras 57-64].

Decision – Appeals Dismissed – Supreme Court dismissed the appeals, holding that retrospective seniority granted to Supervisors is unconstitutional – Confirmed the High Court's decision and reinforced the principle that seniority must be reckoned from the date of satisfying procedural requirements and not retrospectively [Paras 66-69].

Criminal Law – Conviction for Dowry Death – Appeal against High Court's reversal of acquittal – Trial court acquitted accused based on contradictory statements and lack of evidence – High Court convicted accused relying on presumption under Sections 113A and 113B of the Evidence Act – Supreme Court set aside High Court's decision, restoring trial court's acquittal – Emphasized presumption of innocence and requirement of compelling reasons to interfere with acquittal [Paras 1-15].

Evidence – Presumption under Sections 113A and 113B – High Court's reliance on presumption without substantive evidence – Supreme Court held presumption cannot override the necessity for proving basic ingredients of harassment or dowry demand – Restoration of acquittal due to lack of compelling evidence and presence of reasonable doubt [Paras 8-14].

Decision – Appeal Allowed – Supreme Court allowed the appeal, restoring the trial court's judgment of acquittal – Emphasized principles of presumption of innocence and requirement for compelling circumstances to overturn acquittal [Paras 14-15].

Criminal Law – Conviction for Murder – Appeal against conviction under Sections 302 read with 34 IPC and 324 read with 34 IPC – Accused involved in a dispute over a pathway leading to the murder of Ramachandra Lagad – Conviction based on the testimony of the injured eyewitness (P.W. 4) and corroborated by medical evidence – Supreme Court upheld the conviction, emphasizing consistency and credibility of eyewitness testimony supported by medical evidence [Paras 1-34].

Evidence – Eyewitness Testimony – Sole testimony of an injured eyewitness (P.W. 4) sufficient for conviction – Discrepancies in minor details do not discredit the core narrative – Testimony supported by another eyewitness (P.W. 5) and medical evidence, including postmortem and injury reports [Paras 16-22].

Evidence – Forensic Evidence – Presence of human blood on the accused’s clothes not satisfactorily explained – Supported by chemical analysis reports – Rejection of the defense's contention regarding lack of supporting expert evidence [Paras 29-30].

Decision – Appeal Dismissed – Supreme Court dismissed the appeal, confirming the conviction and life sentence imposed by the lower courts – Emphasized the role of corroborative evidence and the lack of any substantial ground for interference [Paras 34].

Arbitration – Jurisdiction Clause – Appeal concerning the interpretation of a jurisdiction clause in a consignment agency agreement – Clause 18 stating “The Agreement shall be subject to jurisdiction of the courts at Kolkata” – Supreme Court held that such a clause, even without words like 'alone,' 'only,' 'exclusive,' indicates an intention to confer exclusive jurisdiction to the courts at Kolkata – Rajasthan High Court's jurisdiction ousted [Paras 1-34].

Contract Law – Ouster Clauses – The use of a jurisdiction clause in a contract implies the exclusion of all other jurisdictions – The maxim "expressio unius est exclusio alterius" (expression of one is the exclusion of another) applies, indicating the clear intention of the parties to restrict jurisdiction to the specified courts – Supported by previous decisions of the Supreme Court [Paras 31-32, 61-62].

Decision – Appeal Dismissed – Supreme Court dismissed the appeal, confirming that the Calcutta High Court has exclusive jurisdiction – The appellant directed to pursue remedies under Section 11 of the Arbitration and Conciliation Act 1996 in the Calcutta High Court [Paras 33-34, 63].

Constitutional Law – Validity of Section 364A IPC – Death Penalty:The Supreme Court examined the constitutional validity of Section 364A of the IPC, which prescribes the death penalty for kidnapping for ransom, arguing it is harsh and violates Articles 14 and 21 of the Constitution. The Court reviewed whether the law is just and fair, adhering to the procedure established by law and societal expectations for deterrent punishment​​.Judicial Review – Scope and Limitations:The Court acknowledged that judicial review of legislative enactments is confined to assessing legislative competence and violation of fundamental rights. The petitioners' challenge was based solely on the ground of violation of Article 21, asserting that the death penalty for kidnapping for ransom is excessive and unjust​​.International Conventions – Legislative Intent:The Court discussed the historical context of Section 364A, noting its alignment with the International Convention Against the Taking of Hostages (1979), to which India is a party. This provision aimed to combat the rising incidence of kidnapping for ransom, considered a serious and heinous crime demanding stringent punishment​​.Previous Judicial Pronouncements – Doctrine of Rarest of Rare:The Court referred to earlier judgments, including Machhi Singh v. State of Punjab, which elucidated the doctrine of the "rarest of rare" cases. The Court noted that while Section 364A prescribes the death penalty, its application must consider the circumstances of each case and adhere to the doctrine established for awarding capital punishment​​.Decision:The Court, recognizing the gravity of the issue and its implications, referred the matter to a larger Bench of three Judges for an authoritative determination on the constitutional validity of Section 364A IPC. The appellants were granted permission to present additional documents within four weeks, emphasizing the need for an expedited hearing given the death sentence context​​.

Mining Lease – Termination and Renewal – The original lessee granted a mining lease in 1966, died in 1982 – State Government terminated the lease for breaches – Legal heirs sought to continue lease – High Court of Madhya Pradesh set aside termination, but legal heirs did not act for years – New lease granted to State Mining Corporation – Legal heirs’ challenges succeeded in Delhi High Court – Supreme Court held lease ended with original lessee's death, subsequent claims by heirs invalid [Paras 1-22].Rule Application – Legal Representation and Mining Leases – Discussed Rule 25A of Mineral Concession Rules 1960 and its non-applicability to the case since rule was added post lessee's death – Legal heirs’ inaction led to lapse of claims – High Court's jurisdiction questioned for entertaining the writ against lease granted by State Government [Paras 18-22].Jurisdiction – Appropriate Forum – Highlighted Delhi High Court's lack of jurisdiction as the matter related to orders by Madhya Pradesh High Court – Legal heirs advised to seek relief from appropriate jurisdiction [Para 22].Decision: Appeals allowed – High Court orders set aside – Rights created in favour of State Mining Corporation upheld – No costs [Para 23].