Criminal Law – Conviction on Circumstantial Evidence – Appellant convicted for abduction, fraud, and related offences – Conviction for murder by trial court based on circumstantial evidence overturned by High Court – High Court found lack of direct evidence or conclusive proof of homicidal death – Prosecution failed to establish crucial link between appellant and the alleged murder [Paras 1-13, 28].Last Seen Theory – Insufficient to Prove Guilt – Evidence of appellant being last seen with deceased not sufficient for conviction – Proximity of time and place crucial for last seen theory to hold – Mere presence with deceased before disappearance does not conclusively prove guilt without corroborative evidence [Paras 15-18].Absence of Corpus Delicti – Importance in Murder Conviction – No recovery of the deceased’s body – Established law that murder conviction can be based on strong circumstantial evidence even without corpus delicti – In this case, evidence not strong enough to prove murder beyond reasonable doubt [Paras 9-12].Motive – Lack of Strong Motive Weakens Prosecution Case – No evidence of enmity or motive for appellant to murder deceased – Motive critical in cases relying on circumstantial evidence – Weak motive adds to doubt about appellant’s involvement in murder [Para 14].Decision: Appeal dismissed – High Court’s acquittal of appellant for murder upheld – Conviction for other offences affirmed – Prosecution’s evidence insufficient to prove murder beyond reasonable doubt – Appellant granted benefit of doubt [Paras 19-20].

Public Service Commission – Supplementary Lists – Kerala Public Service Commission (PSC) challenged High Court's directive to use supplementary list after exhaustion of main list – Supreme Court examined validity of maintaining supplementary list independently – Held that once main list is exhausted, supplementary list loses significance and cannot be operated independently [Paras 3, 9, 12].

Kerala PSC Rules – Interpretation of Supplementary List – Supplementary list intended to ensure adequate representation of reserved categories – Operates only while main list is valid – High Court's directive to operate supplementary list after main list exhausted contrary to established legal principles – Main list and supplementary list are interdependent [Paras 7-8, 10-11].

Legal Precedent – Nair Service Society Case – Reference to Supreme Court's ruling in Nair Service Society v. Kerala Public Service Commission – Court reiterated supplementary list’s lack of statutory backing and dependent status on main list – Supplementary list cannot survive independently once main list is exhausted [Paras 5, 7].

Decision: Appeal allowed – High Court's directive set aside – Supplementary list cannot be operated independently after main list exhaustion – Kerala PSC’s rules and procedures reaffirmed [Paras 12-13].

Civil Procedure – Burden of Proof – Appellants claimed money recovery based on account entries signed by respondent – Respondent denied signatures – Lower courts held signatures genuine; burden on respondent to disprove – High Court reversed, citing appellants' failure to prove signatures via handwriting expert – Supreme Court held High Court erred; burden appropriately placed by lower courts on respondent once initial burden met by appellants [Paras 15-16, 21].

Pleadings and Evidence – Variance and Specific Denial – High Court noted discrepancies between plaint and evidence – Supreme Court held discrepancies minor, did not prejudice respondent – Specific denial of signatures required; mere evasive denial insufficient under Order 8 Rules 3-5 CPC – Evasive responses taken as admissions when specific denial absent [Paras 22-24, 26].

Books of Accounts – Regular Course of Business – Books of accounts regularly maintained considered reliable unless strong reasons indicate unreliability – Respondent’s mere denial of entries insufficient to reject accounts – Supreme Court upheld reliability of accounts in absence of rebuttal evidence from respondent [Paras 28-29].

Decision: Appeal allowed – High Court’s judgment set aside – Lower courts' decrees favoring appellants restored – Costs not awarded [Para 30].

Excise Law – Settlement of Licences – Interpretation of Rules – High Court held licence fee liability starts from issuance of licence – Supreme Court reversed, holding liability starts from date of settlement – Respondent delayed advance security payment causing approval delay – Settlement date governs fee liability under Rule 24 [Paras 3, 17-18, 20, 24].

Default in Advance Security – Rule Compliance – Respondent failed to pay advance security timely as per Rule 19 – Licensing Authority recommended approval despite delay; Excise Commissioner approved – High Court erroneously applied condonation of default – Supreme Court held no condonation applicable in excise trade; fee liability begins from settlement date regardless of licence issuance delay [Paras 19-21].

Trade in Liquor – Regulatory Nature – State's control over liquor trade – No fundamental right to trade in liquor – Rules govern licence terms strictly – Judicial latitude limited in interfering with state policy on liquor regulation – Economic and public morality considerations central to regulatory framework [Paras 21-31].

Decision: Appeal allowed – High Court’s judgment set aside – Excise Commissioner’s order restored – Respondent liable for licence fee from date of settlement (5th June 2006) to date of licence issuance (5th July 2006) [Paras 31-32].

Municipal Law – Change of Land Use – Amendment of Section 173-A – Rajasthan Municipal Corporation demanded conversion charges for changing land use from residential to commercial – Respondents challenged the demand citing earlier Supreme Court judgment – High Court quashed demand relying on un-amended Section 173-A – Supreme Court held amended Section 173-A applicable, validating the demand [Paras 6-12].

Amendment Interpretation – Section 173-A – Amended provision includes restrictions on land use changes beyond state/municipal allotted lands, covers any land use changes non-conforming to Master Plan – Conversion charges applicable for change from residential to commercial use under amended rules [Paras 12-14].

Judicial Precedent – Misapplication – High Court erred applying precedent interpreting un-amended Section 173-A – Supreme Court clarified amended provision extends conversion charges to broader land use changes, aligning with urban planning objectives [Paras 13-15].

Regulated Development – Urban Planning – Legislative intent to ensure planned urban development through conversion charges for land use changes – Conversion charges part of regulatory framework under municipal law [Paras 13-14].

Decision: Appeals allowed – High Court judgments set aside – Municipal Corporation's demand for conversion charges upheld – Respondents may challenge land use classification under Master Plan before Municipal Corporation [Paras 16].

Criminal Procedure – Appeal Against Acquittal – Determining proper forum for appeal in complaint cases – High Court dismissed appeal holding Sessions Court jurisdiction for state appeals – Supreme Court reversed, holding appeals in complaint cases lie to High Court [Paras 7-8, 16-18].

Jurisdiction – Sections 378(1) and 378(4) CrPC – State may direct appeal to High Court except in cognizable and non-bailable offences by Magistrate, directed to Sessions Court – Complaint case appeals specifically under Section 378(4) to High Court – Legal interpretation affirmed by Law Commission reports and legislative amendments [Paras 12-17].

Legislative Intent – Amendment to Section 378 – 154th Law Commission Report led to 2005 amendment – Introduced district-level appeals for certain acquittals to expedite process – State appeals to High Court retained except for specific exclusions – Legislative purpose to check arbitrary acquittals acknowledged [Paras 12, 19-20].

Decision: Appeal allowed – High Court’s order quashed – Complaint-based acquittal appeals to be filed in High Court – Specific leave required for complainant’s appeal upheld – Sessions Court jurisdiction limited to non-complaint state-directed appeals [Paras 21].

Service Law – Apprenticeship and Regular Employment – Appellants contended training period as apprentices should not count towards regular service for ACP Scale – Respondents argued training period should be included – High Court ruled in favor of respondents – Supreme Court reversed, holding apprenticeships do not count towards regular service under ACP Scheme [Paras 3, 18, 27-28].

Interpretation of Apprentice Training – Apprentices Act, 1961 – Apprentices not deemed regular employees – Section 18 specifies apprentices are trainees, not workers – No statutory obligation to employ apprentices after training unless specified in contract – Appointments as Plant Attendant/Technician post-training did not equate to regular service for ACP purposes [Paras 20-24].

Clarificatory Letters and ACP Scheme – Clarificatory letters issued by Board regarding training period – Misinterpreted by High Court – Letters intended for direct recruits undergoing training in regular pay scale, not applicable to respondents – Respondents' training period on fixed stipend, not in cadre, thus not part of regular satisfactory service [Paras 13-16, 28].

Decision: Appeals allowed – High Court judgments set aside – Training period as apprentices not counted towards regular service for ACP Scale – Financial benefits received by respondents not to be recovered, but ACP Scale dates as determined by appellants stand [Para 29].

Civil Procedure – Maintainability of Appeal – Appeal challenged judgment dismissing suit for partition based on alleged forged will – Appellant, aggrieved party, filed appeal against decision of lower court – High Court dismissed appeal as non-maintainable – Supreme Court held High Court erred in dismissing appeal – Legal right of appellant was affected by lower court’s decision, making appeal maintainable [Paras 1-22].

Rights of Aggrieved Parties – Legal Injury – Supreme Court emphasized that an appeal can be maintained by any party who suffers legal injury due to a decree – Appellant's rights as co-sharer affected by the will declared void by trial court but validated by appellate court – Appeal maintainable under Sections 96 and 100 of CPC [Paras 13-21].

Cross-Objections – Order 41 Rule 22 – Supreme Court clarified cross-objection provisions post-1976 amendment – Respondents may file cross-objections to adverse findings without challenging decree – Such cross-objections are adjudicated even if main appeal is withdrawn or dismissed [Paras 18-19].

Decision: Appeal allowed – High Court judgment set aside – Matter remitted to High Court for decision on merits within six months – No opinion expressed on merits of case – Costs to be borne by respective parties [Para 22].

Criminal Law – Conspiracy and Forgery – Appellant, along with co-accused, conspired to cheat the Regional Passport Office, Trichy – Forged documents submitted for obtaining passports – Trial court convicted and sentenced appellant to RI for 2 years with a fine – High Court upheld conviction – Supreme Court reduced sentence to six months considering appellant's circumstances [Paras 1-27].

Defective Investigation – Parallel Proceedings – Appellant contended initial investigation by State Crime Branch and subsequent investigation by CBI was impermissible – Supreme Court held parallel proceedings lawful under Delhi Police Special Establishment Act – Defective investigation not a ground for acquittal unless it affects the root of prosecution case [Paras 7-13].

Evidence – Forgery – Confessional statement led to recovery of forged seals – Prosecution evidence including testimonies of officials corroborated the conspiracy – Evidence of appellant’s involvement and false information in passport applications upheld [Paras 14-24].

Reduction of Sentence – Appellant’s mitigating circumstances considered – Sentence reduced from two years to six months [Paras 26-27].

Decision: Appeal partly allowed – Conviction upheld – Sentence reduced to six months from two years [Para 27].