Constitutional Law – Recovery of excess payments – In cases where government employees received overpayments due to administrative errors, the Supreme Court considers the conditions under which recovery should be deemed permissible or impermissible - The core determination focuses on the impact of such recovery on employees, and whether it outweighs the employer's right to recover, considering factors like duration of overpayment and the status of employees (e.g., nearing retirement). [Paras 2-14]

Equitable Consideration in Recovery – The Court held recovery should not be made when: (i) It would cause undue hardship to employees, particularly lower-grade or those nearing retirement. (ii) The overpayments have been received for a period extending beyond five years. (iii) Employees are not at fault for the overpayments due to administrative errors. (iv) Recovery actions are deemed iniquitous, harsh, arbitrary, or disproportionately disadvantageous compared to the employer's recovery right. [Paras 6, 12-13]

Application of Article 142 – Utilization of the Supreme Court's extraordinary powers to prevent injustice, ensuring that recovery orders are equitable and do not violate constitutional protections against arbitrary actions under Article 14. [Paras 7, 11]

Decision:

The Supreme Court upheld the High Court of Punjab and Haryana's decision to quash the recovery orders, aligning with the principles that prevent iniquitous and arbitrary recoveries, thus providing relief to employees who received excess payments due to non-fraudulent administrative errors.

Judicial Discipline and Forum-Shopping – High Court set aside the anticipatory bail granted by an Additional Sessions Judge where subsequent application was entertained by a different Judge without significant change in circumstances or facts, conflicting with the principle of judicial consistency and discipline - Emphasizes adherence to the convention of placing successive bail applications before the same judge to avoid forum-shopping and ensure consistency in judicial orders - [Para 9-14].

Appellate Intervention Upheld – Supreme Court concurs with the High Court's reasoning on the improper grant of anticipatory bail by a different judge; however, on account of the nature of the offenses charged (related to property transaction under Section 420/34 IPC), it chooses not to set aside the bail but upholds it with strict conditions imposed on the appellants to adhere to the terms of bail - [Para 16-17].

Criminal Law – Dowry Death and Cruelty – Appellant originally acquitted under Section 304B but convicted under Section 498A by trial court – High Court reversed acquittal, convicting under both Sections 498A and 304B – Supreme Court reassessed the evidence, especially the dying declaration and medical testimonies, concluding the death was due to septicemia, not direct result of burns – Conviction under Section 304B set aside; conviction under Section 498A upheld for some appellants - [Para 1-27].

Dying Declaration – Evidentiary Value – High Court found dying declaration under Section 32(1) of Evidence Act credible, leading to conviction – Supreme Court found declaration did not satisfy criteria for relevance under the said section as it did not directly pertain to cause of death or circumstances of transaction leading to death – Death occurred due to septicemia, not burns, and declaration was recorded when death was not imminent - [Para 14-18].

Medical Evidence – Crucial to case outcome – Burns covered 45% of body, initially non-fatal – Inadequate treatment led to septicemia and death, not the injuries themselves – This contradicted the direct link between the accused's alleged actions and the victim's death - [Para 10, 12, 22].

Sentencing – Due to the peculiar facts of the case and the setting aside of Section 304B conviction, the sentence for appellants under Section 498A was adjusted to the period already served – Additional compensation directed towards the victim's parents - [Para 24-26].

Decision: The Supreme Court allowed the appeals in part by setting aside the convictions under Section 304B IPC and modifying the sentences under Section 498A IPC. Directed compensation to the deceased's family, emphasizing the lack of direct causation between the accused’s actions and the victim’s death.

Judicial Interpretation of Arbitration Agreement – Finality of judicial decisions under Section 8(1) of the Arbitration and Conciliation Act, 1996 not to refer disputes to arbitration upheld – Respondents previously opposed application for arbitration in lower court which became final; later invocation of Section 11(6) by Respondents considered an abuse of process of law and hit by issue estoppel - Supreme Court set aside High Court's order appointing arbitrator. [Paras 2, 11, 17]

Role of Section 11(6) after Final Court Decisions – Supreme Court clarifies that after a judicial authority's final decision under Section 8(1), no party can invoke Section 11(6) for appointing an arbitrator – Emphasizes the finality of judicial decisions to prevent re-litigation of same issues, guided by principles of res judicata. [Paras 12, 14, 17]

Principles of Res Judicata Applied – Consistent application in both stages of litigation to ensure finality and prevent repeated litigation over the same issues – Application of res judicata principles upheld in the context of arbitration clauses when judicial decisions are final. [Paras 15, 16, 17]

Costs Awarded – Supreme Court allows appeal, sets aside the order of the High Court, and awards costs of Rs. 25,000 against the respondents for improper invocation of arbitration under Section 11(6). [Para 19]

Judicial Inquiry & Procedure - Allegations of sexual harassment by a High Court judge; challenged on procedural and ethical grounds; necessitated examination under the "in-house procedure" - The Supreme Court identifies procedural irregularities and missteps by the Chief Justice of the High Court in constituting a two-Judge committee contrary to the established "in-house procedure," exceeding his authority and initiating a deeper probe without appropriate jurisdiction.

Administrative Control and Influence - The Supreme Court emphasizes the necessity to remove the accused Judge from any administrative roles that might influence the testimony of witnesses or the handling of evidence in matters related to the complaint.

Reassessment of "In-House Procedures" - Calls for the Chief Justice of India to reassess the initiation of investigative processes, ensuring that they are fair, just, and devoid of any influence from those directly involved in the allegations, suggesting the assignment of initial inquiry duties to a Chief Justice from another High Court or taking over by the Chief Justice of India directly.

Decision: The Supreme Court set aside the proceedings initiated by the Chief Justice of the High Court and directed the Chief Justice of India to reassess and possibly reinitiate the investigative process under the "in-house procedure," with the possibility of assigning the inquiry responsibilities to another Chief Justice or managing them directly to safeguard fairness and judicial integrity. The petition also granted liberty to the petitioner to pursue other issues not resolved in the current proceedings through separate petitions.

Criminal Law - Murder and Conspiracy – Supreme Court reviews High Court judgment acquitting five and upholding conviction of two under IPC Section 302 and Arms Act Section 25 for murder using firearms - Eyewitnesses, including the deceased's mother and wife, identified the accused; their testimonies, corroborated by medical and forensic evidence, were crucial in upholding convictions - Fingerprint analysis on tea glasses from the crime scene linked the accused to the murder, reinforcing the prosecution's case [Paras 2-14].

Evidence and Procedure - Eyewitness reliability and forensic evidence under scrutiny - Supreme Court finds eyewitness accounts by family members credible and consistent; forensic evidence, particularly fingerprints matching the accused, pivotal in confirming their presence at the crime scene and involvement in the crime - Admissibility of fingerprints upheld, taken in compliance with legal standards [Paras 9-13].

Legal Principles - Confirmation of conviction based on cogent, consistent eyewitness testimony and robust forensic evidence - Acquittal of five co-accused upheld due to insufficiency of evidence regarding their involvement and absence of corroboration for extrajudicial confessions [Paras 16-18].

Decision - Dismissal of all criminal appeals - Convictions of Charanjit Singh and Surjit Singh upheld; sentences of life imprisonment confirmed - Acquittal of five co-accused upheld due to insufficient evidence - Directive for the apprehension of Surjit Singh to serve remaining sentence issued [Para 18].

Electrocution of Minor - Severe injuries leading to triple amputation of a minor due to exposed electric wires - Appellant sought compensation under Article 226 - Electricity authority found liable under "strict liability" for negligence in ensuring safety, as mandated by Electricity Act, 2003, and associated rules - Initial compensation awarded by Single Judge modified by Division Bench, prompting this appeal. [Paras 1-9]

Negligence and Liability - High Court's Single Judge recognized the electricity board's failure to adhere to safety standards, applying principles of strict liability for damages - Bench referred extensively to legal precedents under both Electricity and Motor Vehicles Acts to justify compensation - Despite board's denials, responsibility for safety lapse and resultant life-altering injuries to the minor established. [Paras 5-7]

Compensation Awarded - Single Judge awarded Rs. 60 lakhs, accounting for permanent disability and future hardships, including loss of livelihood and need for lifelong care - Division Bench modified the award, reducing monthly payments and altering conditions for fund access - Supreme Court critiqued modifications, emphasizing need for full compensation reflecting the child's severe lifelong disability. [Paras 8-20]

Civil Procedure – Writ Petition maintainability – Appeal against Patna High Court's judgment dismissing writ petition based on non-usage of arbitration clause in contract despite contract's completion and payment – Supreme Court finds that completed contracts and resolved payments negate the requirement of arbitration, especially where no objection regarding alternative dispute resolution was raised in prior or current litigation – Writ petition maintainability reaffirmed where alternative remedy was not objected to by respondents at any litigation stage – Supreme Court sets aside Division Bench order, restoring Single Judge’s decision granting relief to appellant. [Paras 2-14]

Decision: The Supreme Court allowed the appeal, setting aside the order of the Division Bench of the Patna High Court and restoring the order of the Single Judge with a direction for the respondents to pay costs of Rs. 25,000 to the appellant within two months. [Para 14]

Criminal Law - Murder and Arms Act Violation - Appellant convicted for the murder of Suraj Mal and Shri Ram using a licensed firearm and sentenced to life imprisonment - Conviction affirmed by the High Court - Co-accused acquitted; another co-accused, a juvenile, tried separately - Appeal claims shooting in self-defense during a violent altercation post-Holi celebration involving multiple parties [Paras 1-2] - Prosecution asserts appellant shot the deceased as part of an escalated quarrel where the appellant escalated force using his firearm - Defense contests the narrative, suggesting firing occurred amidst a chaotic fight where all parties were armed and aggressive, advocating a self-defense argument - FSL report confirms the fatal shots could have only been fired from appellant's gun [Paras 4-6] - Supreme Court finds merit in appellant's self-defense claim, noting inconsistencies and gaps in prosecution's narrative and evidence - Recognizes the fight took place near appellant's residence, suggesting possible provocation by the deceased [Paras 7-12] - Conviction modified from murder under Section 302 IPC to culpable homicide not amounting to murder under Section 304 Part II IPC due to the sudden and provoked nature of the altercation - Sentence adjusted to time already served, appellant ordered to be released unless required for another offense [Paras 13-14].