Criminal Law  – Supplementary Evidence – Production of CDs at Trial – Permissible Omission – Upheld – CDs seized before filing of original chargesheet but not produced due to inadvertence – Supplementary chargesheet filed with forensic report but without CDs – Supreme Court held omission not fatal – CDs could be produced later with court’s permission without prejudice to accused, following precedent in R.S. Pai – Held: Such production is not barred under CrPC Section 173(5), as the provision is directory, not mandatory [Paras 10-15].

Further Investigation – Section 173(8) CrPC – Scope – Supplementary Chargesheet Valid – Even without “new” evidence – Held: Supplementary chargesheet referring to CDs and CFSL report valid, as CDs were already sent for analysis and referenced therein – Court clarified “further investigation” includes procedural completion of existing evidence, not necessarily discovery of new facts [Paras 11-13].

Evidence – Electronic Evidence – Section 65B Certificate – Admissibility and Authenticity – Kept Open – Court refused to adjudicate admissibility and genuineness of CDs or certificates under Section 65B at preliminary stage – Left open for trial court determination – Appellant permitted to cross-examine witnesses with regard to CDs [Paras 17-18].

Decision – Appeal Dismissed – High Court and Special Court Orders Affirmed – Supreme Court upheld production of CDs and denied relief to appellant – Held: No reason to reconsider precedent in R.S. Pai; no prejudice caused – However, left open issues of authenticity and admissibility for trial [Paras 15, 19].

Civil Law - Impleadment – Deletion of Name – Order I Rule 10 CPC – Deletion Denied – Appellant impleaded as legal heir during execution but raised no objection at that stage – Later attempt to seek deletion held barred by res judicata – The Court held that once a party has been impleaded after due inquiry without objection, it is not open to them to challenge it years later, particularly where they participated in proceedings without protest – The power under Order I Rule 10 cannot be used to reopen concluded decisions [Paras 46–55].

Res Judicata – Subsequent Objection to Impleadment – Barred – Doctrine Applied to Different Stages of Same Proceeding – Once impleadment order attained finality, re-agitating the issue by Order I Rule 10 application was impermissible – Trial Court's decision deemed binding absent appellate interference – Doctrine ensures finality and avoids procedural abuse [Paras 53–57].

Tenancy Rights – Protection Under Kerala Rent Control Act – Claim Rejected – Appellant claimed tenancy derived from father and sought protection from eviction – Court found no credible evidence of tenancy or possession and held such claim to be an afterthought aimed at obstructing execution – Concurrent findings below upheld [Paras 61–63].

Specific Performance – Possession Implicit in Decree – Relief of Possession Not Expressly Granted – Still Executable – Where seller was in possession, court held that decree for specific performance implicitly included delivery of possession – Follows established law under Section 55 of the Transfer of Property Act and precedents like Babu Lal v. Hazari Lal – Thus, execution could proceed without separate possession order [Paras 64–65].

Decision – Appeal Dismissed – Supreme Court affirmed High Court and Trial Court decisions – Deletion application found frivolous and part of a dilatory strategy – Decree-holder entitled to possession – Appellant directed to pay Rs 25,000 in costs – Executing Court instructed to hand over vacant possession within two months [Paras 67–68].

Civil Law - Rejection of Plaint  – Order 7 Rule 11 CPC – Existence of Cause of Action – Rejection Set Aside – The appellant challenged the High Court’s order which had rejected the plaint under Order VII Rule 11 CPC – Held: The plaint disclosed triable issues including whether the sale deeds executed after the revocation of an unregistered power of attorney were valid – The High Court erred in rejecting the plaint by failing to appreciate that the suit was based on two distinct causes of action, particularly the one arising after the revocation of the power of attorney [Paras 8-9.6].

Registration Act – Unregistered Agreement to Sell and Power of Attorney – Effect on Title – No Title Passed – Documents executed by Respondent No.1 including an unregistered agreement to sell and power of attorney do not confer ownership or title under Sections 17 and 49 of the Registration Act – Such documents are inadmissible in evidence for transfer of ownership and can only be used for collateral purposes or in a suit for specific performance – In this case, no such suit for specific performance was ever filed by the respondents – Hence, Respondent No.1 had no authority to execute the sale deeds [Paras 9-9.2].

Transfer of Property – Sale of Immovable Property – Section 54 of Transfer of Property Act – Agreement to Sell Does Not Create Title – It was reaffirmed that an agreement to sell does not create any interest in or charge on the immovable property – Execution of the sale deed without a valid, registered power of attorney was invalid in law [Paras 9.2-9.3].

Jurisdiction of Civil Court – Section 207 of Rajasthan Tenancy Act – Applicability – Civil Jurisdiction Upheld – The dispute relates to ownership and title of immovable property, which is triable by civil courts – Revenue records and mutation entries do not confer title – Hence, the bar under Section 207 of the Rajasthan Tenancy Act does not apply to this case [Paras 10].

Court Fee Deficiency – Opportunity to Rectify – Rejection Improper – It was held that a plaint cannot be rejected solely for insufficient court fees without first affording the plaintiff an opportunity to correct the deficiency – This principle was reaffirmed in line with settled precedents [Para 11].

Decision – Appeal Allowed – Impugned order of the High Court rejecting the plaint is set aside – Order of the trial court refusing to reject the plaint is restored – Trial court directed to proceed with the suit on merits uninfluenced by any observations in this judgment – No order as to costs [Paras 14-15].

Criminal Law  – Sections 303, 307 & 34 of the IPC – Appeal Against Conviction - Suppression of Exculpatory Evidence – Violation of Fair Trial – Acquittal Ordered – Appellants convicted of murder and attempted murder under IPC Sections 302 and 307 based on eyewitness testimonies of PW-4, PW-5, and PW-6 – However, affidavits submitted by PW-5, PW-6, and injured PW-7 during bail proceedings contradicted their court testimonies and exonerated the accused – Investigating Officer admitted knowledge of these affidavits but failed to record supplementary statements or conduct verification – Such non-investigation and suppression violated the right to fair trial guaranteed under Article 21 of the Constitution – Held: Conviction based solely on PW-4's testimony, in absence of corroboration and amid investigative lapses, is unsafe – Conviction and sentence set aside; appellants acquitted [Paras 17-24].

Investigation – Duty of Police – Failure to Conduct Supplementary Investigation – Despite knowledge of contradictory affidavits by eyewitnesses, Investigating Officer did not take steps to verify or rebut them nor documented any attempts to locate the witnesses – This omission compromised the integrity of the investigation and prosecution – The suppression of material evidence affected the fairness of the trial and cast doubt on the credibility of key witnesses [Paras 18-20].

Judicial Practice – Reference to Lower Court Records – Directive Issued – Supreme Court reaffirms that trial court records must not be referred to as “Lower Court Record” – High Courts directed to comply with earlier circular replacing such terminology in court documentation and communication [Para 25].

Decision – Appeal allowed – Judgments of Trial Court and High Court set aside – Appellants acquitted of all charges – Bail bonds cancelled [Para 26].

Criminal Law - Bail – Custodial Period Considered – Serious Charges under IPC and IT Act – Bail Granted - Petitioner in custody since 05.03.2024 in relation to offences under IPC, IT Act, and Public Examination Act – Supreme Court considered prolonged custody and allowed bail with conditions – Trial Court directed to impose appropriate terms [Paras 2–4].

Conditions of Bail – Cooperation and Conduct Mandated – Petitioner Directed to Comply - Petitioner to cooperate with investigation, avoid influencing witnesses, and not seek adjournments – Directed to provide residence and contact details, and report monthly to Investigating Officer until filing of charge sheet [Paras 5–8].

Request to Restrict Residency – Rejected – No Ban on Staying in Rajasthan - State requested court to prohibit petitioner from residing in Rajasthan during trial – Supreme Court declined to impose such restriction [Para 11].

Final Relief – Bail Granted – SLP Disposed – Court interfered with High Court’s denial of bail and directed release of petitioner on terms set by the Trial Court – SLP disposed accordingly [Paras 4, 12].

Civil Law - Rejection of Plaint – Order 7 Rule 11 CPC – Triable Issues Exist – Rejection Improper – High Court erroneously rejected the plaint holding that it disclosed no cause of action – Supreme Court held that revocation of power of attorney and dispute over subsequent sale deeds raised serious triable issues – Held: Rejection of plaint unwarranted at preliminary stage where pleadings disclosed a cause of action regarding title and invalidity of transactions [Paras 6-14].

Unregistered Documents – Effect on Title Transfer – Agreement to Sell and GPA – No Transfer of Ownership – Sale deeds executed on basis of an unregistered and revoked power of attorney were challenged – Supreme Court reiterated settled law that unregistered agreements to sell or GPA do not create title or transfer rights in immovable property – Held: Respondent could not rely on such documents to validate conveyance [Paras 9-9.4].

Jurisdiction of Civil Court – Dispute Over Title – Not Barred by Revenue Law – Appellants sought declaratory reliefs including title and possession – Revenue court jurisdiction under Section 207 of Rajasthan Tenancy Act held inapplicable – Held: Title disputes lie within exclusive jurisdiction of civil courts; mutation entries do not confer ownership [Paras 10-10.1].

Cause of Action – Distinct Reliefs – Partial Defect Does Not Warrant Full Rejection – Supreme Court reiterated that if even one cause of action is maintainable, the plaint must be tried – High Court erred in treating secondary reliefs as academic and rejecting entire suit – Held: Proper approach is to proceed with suit on triable issues rather than reject in entirety [Para 9.6, 9.7].

Final Decision – High Court Order Set Aside – Plaint Restored – Appeal allowed – Impugned High Court order rejecting plaint quashed – Order of Additional District Judge, Jodhpur restored – Trial Court directed to proceed with suit on merits [Para 14].

Criminal Law – Quashing - POCSO Conviction – Role of High Court under Article 226 r/w Section 482 CrPC – High Court Overreach – High Court’s setting aside of the conviction under the POCSO Act and IPC held unsustainable – Supreme Court observed that the High Court misapplied its inherent powers, as serious offences like those under the POCSO Act cannot be quashed merely due to settlement or continued cohabitation between victim and accused – Held: Conviction restored for offences under Section 6 POCSO Act and Section 376(2)(n) & (3) IPC; acquittal for Sections 363 and 366 IPC confirmed [Paras 3, 23-23.1].

Victim Rehabilitation – State Responsibility under Article 21 and JJ Act – Constitutional Mandate Reaffirmed – Supreme Court held that the failure of the State to provide timely rehabilitation and care to a 14-year-old rape victim amounted to a violation of her fundamental right to life with dignity – Directed immediate constitution of expert committee for informed choice of victim, and mandated State to offer financial, educational, and housing support – Held: Non-compliance with Section 19(6) of POCSO Act results in denial of statutory and constitutional rights [Paras 24-26, 37-38, 44].

Sentencing – Article 142 – Complete Justice – Sentence Suspended – Despite confirmation of conviction, Supreme Court refrained from sentencing the accused, invoking powers under Article 142 to avoid further victim trauma and family disruption – Held: Though minimum sentencing under POCSO Act is mandatory, extraordinary circumstances warranted departure – Accused not to undergo further imprisonment; State to act as guardian of victim’s family and ensure rehabilitation [Paras 25-27, 31(a)].

Societal and Systemic Failure – Legal and Social Apathy Noted – Apex Court found a systemic breakdown in child protection measures – Highlighted inadequacies in local Child Protection Committees, lack of counselling and legal aid, and widespread exploitation of victims in the judicial process – Directed Centre to explore implementation of adolescent sexual health education and real-time data tracking mechanisms [Paras 12-13, 18-20, 30-31].

Decision – Conviction Maintained, Sentence Waived – In light of victim’s desire, Committee reports, and victim’s family interest, Court held that sentencing the accused would perpetuate injustice – Ordered permanent rehabilitation framework and periodic compliance reports from State – Union directed to respond with national implementation plan on adolescent protection measures [Paras 31(a)-(f), 32].

Mining Leases – Validity of DMF Contribution Policy – Sections 9B & 15A of MMDR Act – Demand Upheld – The appellant, a sand mining lessee, challenged a Demand Notice requiring payment of 10% of the bid amount to the DMF Trust, asserting violation of Section 9B of the 1957 Act – The Supreme Court held that Section 9B is inapplicable to minor minerals due to Section 14 – Further, State power under Sections 15 and 15A to prescribe DMF contributions is valid – The 2017 State Policy was properly exercised under Rule 68 of the 1963 Rules and was binding – Demand found to be in conformity with Rule 10(2) of the 2017 DMF Rules – Appeals dismissed [Paras 5–26].

Maternity Leave – Section 5 and 27 of the Maternity Benefit Act, 1961 - FR 101(a) and Constitutional Interpretation – Maternity Leave Granted – The appellant, a government teacher in Tamil Nadu, sought maternity leave for her first child born from her second marriage – The leave was denied on the ground that she already had two children from her first marriage – Supreme Court held that since the two children are in custody of her ex-husband and the present childbirth is from her subsisting marriage, the appellant is entitled to maternity benefits – Restriction under FR 101(a) must be interpreted liberally in light of constitutional rights and reproductive autonomy [Paras 4.1, 6, 9-11, 34-37].

Reproductive Rights – Article 21 of the Constitution – Maternity Leave as Reproductive Right – Recognized as a facet of the right to life – The Court emphasized that reproductive autonomy includes the right to bear children and access maternity benefits – Maternity leave is not merely a statutory right but part of the broader right to dignity and health under Article 21 [Paras 13-14, 28-31].

Maternity Benefit Act – Guidance in State Service Rules – Though not directly applicable to State Government employees, the provisions of the Maternity Benefit Act provide beneficial guidance – Supreme Court acknowledged that the Act allows maternity benefits even for more than two children, though with a reduced leave period, reinforcing the liberal interpretation required for FR 101(a) [Paras 18-20, 33].

International Norms – Relevance of CEDAW and International Covenants – The judgment draws heavily on international instruments such as CEDAW and the Universal Declaration of Human Rights to underscore that maternity protection is a human right – Reinforces the obligation of the State to provide maternity benefits as part of respect for international law [Paras 22-27].

Final Decision – Division Bench Judgment Set Aside – Maternity Leave Granted – Supreme Court set aside the Division Bench’s judgment of the Madras High Court and directed the State to release maternity benefits under FR 101(a) to the appellant within two months [Paras 36-38].