Criminal Law - Sections 3(1)(viii), 3(1)(ix), and 3(2)(vii) of the SC/ST Act – Quashing of Proceedings under Section 482 CrPC – High Court Order Upheld – Appellant alleged mala fide prosecution by public officials for opposing wrongful land allotment – High Court found no evidence of caste-based discrimination or mala fide intention – Held: The initiation of proceedings under the SC/ST Act lacked legal foundation – Quashing Upheld [Paras 1-4, 19-22].

Mala Fide Allegation – Intra-Caste Dispute – No Offence Attracted under SC/ST Act – Dispute involved two Scheduled Caste groups – Allegations failed to show targeting of appellant solely for caste identity – Held: Prosecution does not satisfy the essential ingredients of offences under the SC/ST Act – Criminal complaint rightly quashed [Paras 16, 21-22].

Scope of Section 482 CrPC – High Court Jurisdiction Properly Exercised – Allegations were vague, delayed, and not supported by prima facie evidence – Held: High Court correctly exercised inherent powers to prevent abuse of legal process – Interference by Supreme Court unwarranted [Paras 12, 25].

False Prosecution – Safeguards Against Abuse of SC/ST Act – Court referred to precedents warning against misuse of the Act for settling personal scores – Held: Courts must intervene where allegations do not reveal caste-based intent or are filed with oblique motives – False implication under SC/ST Act cannot be permitted [Paras 23-24].

Decision – Appeal Dismissed – High Court’s Quashing of Proceedings Upheld – Allegations found baseless and unsupported by evidence – No interference warranted by Supreme Court – All pending applications also disposed [Paras 25-27].

Criminal Law - Section 193, 406, 418, 420, 423, 468, 469 of IPC - Criminal Complaint – Second Quashing Petition – Not Maintainable – Review Impermissible – The High Court allowed a second quashing petition under Section 482 CrPC, despite an earlier petition on identical grounds having been dismissed – Held: Raising previously available pleas in a second petition constitutes a review which is barred under Section 362 CrPC – High Court exceeded jurisdiction in entertaining the subsequent petition [Paras 11-14].

Inherent Powers of High Court – Limits Under Section 482 CrPC – Bar of Section 362 CrPC Applies – The High Court cannot invoke Section 482 to do what is expressly prohibited under CrPC – Held: Inherent powers cannot be exercised to override express statutory bar – Review of earlier final order not permissible through second petition under Section 482 [Paras 13-15].

Change in Circumstances – Mandatory for Maintainability of Second Petition – No New Grounds Raised – Accused failed to show any change in circumstances or fresh cause – Held: Entertainment of successive quashing petition without new grounds amounts to abuse of process – High Court’s order quashing proceedings unjustified [Paras 12, 14, 16].

Quashing of Complaint – Order Set Aside – Criminal Proceedings Restored – The High Court’s second order dated 13.09.2022 quashing Complaint No. 1828 of 2019 found to be legally unsustainable – Held: Complaint restored before Trial Magistrate – All defences open to accused at appropriate stage [Paras 17-19].

Decision – Appeal Allowed – High Court’s Order Set Aside – Complaint Restored – The appeal succeeds – Complaint proceedings reinstated before Metropolitan Magistrate, Saidapet, Chennai – Pending applications also disposed [Paras 17-20].

Matrimonial Law - Transfer Petitions – Matrimonial Disputes – Amicable Settlement – All proceedings quashed – Multiple litigations were pending between the parties in various courts, including criminal and civil matters arising from matrimonial discord – Held: The Court exercised its power under Article 142 to quash all proceedings including FIRs, complaints, revisions, and petitions to bring an end to the litigation and restore peace between families [Paras 1-4, 11-14, 25-26].

Child Custody – Supervised Visitation – Welfare of the Minor – Custody of the 8-year-old daughter was awarded to the mother with monthly supervised visitation rights granted to the father and his family – Provisions were made for vacation sharing and future conflict resolution through designated mediators from both parties [Para 8].

Maintenance and Alimony – Voluntary Waiver – Previous Maintenance Order Quashed – The wife waived all claims to present and future alimony or maintenance and undertook to bear all expenses for the daughter – In light of this, the maintenance order of Rs. 1,50,000/- per month passed by the Allahabad High Court was quashed [Paras 9-10].

Property Transfer – Conditional Compliance – Transfer of Disputed Land – The wife’s mother was directed to gift specified agricultural land in Aligarh to the husband on an ‘as is where is’ basis – The husband to bear all future litigation and transfer-related expenses – Complete documents to be handed over within stipulated time [Para 17].

Social Conduct – Undertaking of Non-Interference – Apology Mandated – Both spouses agreed not to interfere in each other’s personal or professional lives and to refrain from using their positions to cause harm – Wife directed to publish an unconditional apology in national dailies and on social media as a step toward closure – Said apology shall not be construed as admission of liability and cannot be used to her prejudice [Paras 15, 19-21].

Article 142 – Divorce Decree – Finality to Disputes – Marriage dissolved by invoking Article 142 of the Constitution – All existing and future related litigations barred – Breach of settlement terms to amount to contempt – Divorce decree to be drawn accordingly [Para 25].

Education Law - Admission and Eligibility – Change in Admission Criteria – Unclear Prospectus and Addendums – Appellant applied under the 2020 Prospectus and was granted provisional admission in M.Sc. Environmental Management based on merit – Subsequent addendums excluded private university graduates from eligibility, resulting in her candidature being rejected – Held: Eligibility criteria was not clearly spelt out initially, and addendums created confusion warranting judicial intervention [Paras 2-9, 21-22].

Educational Rights – Degree Cancellation – Article 142 Invoked – After completing the full course with good academic performance and fulfilling all formal requirements including attendance and examinations, the appellant was awarded the degree which was later withdrawn by the university – Held: Degree withdrawal unjust after two years of valid study – Exercise of powers under Article 142 warranted to restore justice [Paras 14-26].

University Accountability – Duty to Ensure Clarity – Prospectus Terms and Delayed Addendums – Respondent University’s ambiguity and delayed amendments caused confusion in eligibility – Appellant’s rejection should have occurred at the initial stage if criteria had been clear – Held: Universities must exercise diligence in declaring eligibility criteria in time to prevent harm to students [Paras 15-17, 22].

Final Relief – Degree to be Restored – High Court Judgments Set Aside – Supreme Court set aside both the single judge and Division Bench judgments of the Himachal Pradesh High Court and ordered that the postgraduate degree conferred on 04.05.2023 be upheld – Cancellation order dated 05.08.2023 declared otiose [Paras 26-28].

Criminal Law - Murder  –Section 302 & 34 of the  IPC – Acquittal Ordered – The Trial Court and High Court had convicted the appellants based solely on the testimony of the deceased’s wife and son – Supreme Court found improbabilities in their presence at the scene, contradictions with the medical evidence, and no corroboration from other witnesses – Held: Conviction unsustainable due to serious doubts in prosecution story – Appeals allowed and appellants acquitted [Paras 1-2, 6-13, 27-34].

Credibility of Interested Witnesses – Eyewitness Testimony Scrutinized – The prosecution relied exclusively on the deceased’s close relatives as witnesses – Their account of reaching the crime scene 16 km away on a bicycle within 30 minutes was found improbable – Held: Interested testimony must be subjected to greater scrutiny – Not safe to convict without corroboration from independent witnesses [Paras 22-27].

Failure of Prosecution – Hostile Witnesses – Doubts in Medical and Ocular Evidence – All independent eyewitnesses including TASMAC shop staff turned hostile – Medical report indicated attack by multiple persons, inconsistent with prosecution claim of two assailants – Held: Glaring omissions and improbabilities raised serious doubts – Prosecution failed to prove guilt beyond reasonable doubt [Paras 30-32].

Benefit of Doubt – Improbability in Presence – No Immediate Reporting to Police – Conduct of eyewitnesses found unnatural – Travelled 16 km back home instead of informing nearby police station – Held: Circumstances raise significant doubt about presence of witnesses at crime scene – Appellants entitled to benefit of doubt [Paras 28-29].

Decision – Conviction Set Aside – Appellants Acquitted – The Supreme Court quashed the convictions passed by the Madras High Court and Trial Court – Ordered immediate release of both accused unless required in any other matter [Para 34].

Service Law – Pension Entitlement – Resignation vs. Voluntary Retirement – Regulation 22 – Pension Denied - Resigned bank employee with over 35 years of service sought pension benefits under 1995 Pension Regulations – Supreme Court held resignation and voluntary retirement are distinct service termination modes – Regulation 22 lawfully excludes pension benefits upon resignation – Held: Employee who resigned cannot claim pension – No violation of Article 14 found [Paras 4.10, 47-53, 59].

Pension Scheme – Judicial Review of Policy – Direction to Amend Regulation – Impermissible – High Court directed Bank’s Board to consider amending Regulation 22 to allow pension to resigned employees – Supreme Court ruled such direction is tantamount to mandating legislation and exceeded judicial bounds – Held: Courts cannot compel executive action in policy framing – Directions (B to D) of High Court set aside [Paras 66-68].

Service Jurisprudence – Beneficial Interpretation – Article 142 – Resignation Due to Mental Depression – Relief Granted - Despite holding resignation disentitles pension, Court exercised Article 142 to grant equitable relief considering mental health and 35+ years of unblemished service – Held: Respondent allowed to opt under 2024 Bipartite Settlement or receive Rs. 5,00,000 as ex gratia if ineligible or unable to refund PF with interest [Paras 71-73].

Precedents – Shree Lal Meena Binding – Other Contradictory Decisions Disapproved – Earlier rulings such as Sheelkumar Jain and Asger Ibrahim Amin disapproved by larger bench in Shree Lal Meena – Conceptual clarity affirmed: resignation entails forfeiture of service unlike voluntary retirement – Reliefs under resignation cannot be extended based solely on length of service [Paras 43-47].

Final Decision – High Court Judgment Modified – Division Bench’s direction (A) setting aside Single Judge's order upheld – Remaining directions (B to D) quashed – Connected appeal dismissed – Lead appeal partly allowed with relief under Article 142 extended as exceptional case [Paras 65-74].

Criminal Law - Anticipatory Bail – Cancellation of Pre-Arrest Bail – Sections 143, 147, 149, 323, 387, 427, 452, 504, 506, 406, 403, 420, 467, 468, 471, 120B, 34 of the IPC -Grave Offences of Property Trespass and Threatening Complainant – Anticipatory Bail Cancelled – The appeals arose from the grant of anticipatory bail to the accused, including the estranged husband of the complainant, in a case of criminal trespass, assault, and damage to property inherited by the complainant from her father – The Supreme Court found that the High Court erred in granting anticipatory bail despite serious allegations of forcible dispossession, concealment of facts, threats to witnesses, and multiple ongoing criminal proceedings against the accused – Held: Considering the gravity of allegations, concealment of facts, violation of bail conditions, and risk of tampering with evidence, the High Court’s order was quashed, anticipatory bail cancelled, and accused directed to surrender with liberty to apply for regular bail [Paras 1-22].

Concealment of Material Facts – Suppression of Crucial Developments – Bail Order Invalidated – The accused misled courts by concealing the setting aside of a civil injunction which was used to justify interim protection from arrest – Held: Deliberate suppression of material developments is sufficient ground to invalidate bail orders [Paras 9, 19].

Violation of Bail Conditions – Threatening of Witnesses and Tampering with Evidence – Bail Cancelled – The accused violated bail conditions by threatening hotel staff and attempting to intimidate witnesses, which amounted to interference with the process of justice – Held: Serious post-bail conduct justified immediate cancellation of bail [Paras 12, 20].

Grave Allegations Require Custodial Interrogation – Accusations of Forgery, Trespass, and Fraudulent Loan Transactions – Bail Denied – The accused faced allegations of property trespass, criminal intimidation, forgery of documents, and misuse of power of attorney for fraudulent financial transactions – Held: Such serious accusations necessitated custodial interrogation, and grant of anticipatory bail was unjustified [Paras 17-20].

Exceptional Remedy of Anticipatory Bail – Cautious Judicial Approach Mandated – Reliance on Srikant Upadhyay v. State of Bihar – The Court reiterated the principle that anticipatory bail is an exceptional remedy to be granted cautiously in serious offences, especially where there is risk of justice being obstructed – Held: The High Court overlooked the established cautionary standards while granting anticipatory bail [Paras 18-19].

Decision – Appeal Allowed – Anticipatory Bail Cancelled – High Court’s Order Set Aside – The Supreme Court allowed the appeals, quashed the High Court order dated 19/06/2024, cancelled anticipatory bail, and directed the accused to surrender within two weeks, permitting them to apply for regular bail as per law [Paras 21-22].

Civil Law - Title Dispute – Registered Will and Oral Family Settlement – Title Declared in Favour of Second Wife – The Supreme Court adjudicated upon the rival claims of legal heirs regarding agricultural land after the death of Metpalli Rajanna – The Court accepted the validity of a registered Will executed in favour of the second wife, Lasum Bai, supported by corroborative oral family settlement, holding that she had rightful ownership over the suit schedule properties – Held: Decree of the trial Court granting absolute ownership to the second wife restored; High Court’s interference set aside [Paras 1-13].

Genuineness of Will – Registered Will – Presumption of Validity – Will Upheld - The Court upheld the registered Will dated 24th July, 1974, noting that the defendant, Muthaiah, admitted the signature of the testator – Held: Registration of the Will raises presumption of genuineness, especially when the principal beneficiary (defendant) also derived substantial benefit under the same Will, negating suspicion [Paras 9-10].

Oral Family Settlement – Admissibility and Effect – Family Arrangement Recognised - The Court recognised the existence and binding nature of oral family settlement made by the father to prevent disputes among heirs, corroborated by revenue records and long-standing possession – Held: Oral family settlement supplemented by Will validly distributed property among heirs [Paras 9-11].

Possession and Unchallenged Sale – Validity of Sale Deeds – Uninterrupted Possession Confirmed Ownership - Plaintiff's possession over disputed property and valid sale deeds executed in favour of third parties (including Janardhan Reddy) were recognised – Held: Non-challenge to sale deeds by defendant and consistent possession established rightful ownership [Paras 4.6, 11].

High Court’s Error – Reversal of Decree Without Justification – Trial Court's Judgment Restored – The Supreme Court held that the High Court erred in reducing the plaintiff’s share from full ownership to 1/4th share, despite clear evidence supporting full ownership – Held: Trial Court’s decree based on sound reasoning rightly granted absolute title to Lasum Bai; High Court's judgment reversed [Paras 12-13].

Final Decision – Appeals Allowed in Favour of Plaintiff – Full Ownership Restored - Civil Appeal No. 5921 of 2015 allowed, Civil Appeal No. 5922 of 2015 dismissed; declaration of title and permanent injunction granted in favour of plaintiff, restoring the trial Court's judgment [Para 13].

Criminal Law - Bail Cancellation – Abuse of Official Position – Sections 376, 328 IPC and Sections 3/4 IT Act, SC/ST Act – Bail Cancelled - The Supreme Court considered an appeal filed by the victim against the grant of bail to respondent No.2, who was accused of serious offences including sexual exploitation and torture of female inmates under her care as Superintendent of a women’s protection home – The High Court had granted bail through a cryptic order without hearing the victim in violation of Section 15A(3) of the SC/ST Act – Held: The Supreme Court cancelled the bail on grounds of non-compliance with statutory rights of the victim and the gravity of allegations, noting the accused’s influence and possibility of witness tampering [Paras 8-29].

Victim's Right to be Heard – Section 15A(3) SC/ST Act – Violation of Victim's Rights – The High Court granted bail without issuing notice to the victim, violating her statutory right to be heard – Held: The Supreme Court quashed the High Court's bail order solely on this ground, emphasizing that non-compliance with Section 15A(3) invalidates bail orders [Paras 8, 25-26].

Grave Nature of Allegations – Custodian Turned Perpetrator – Sections 376, 328 IPC – Bail Cancelled Due to Serious Offences – Allegations involved sexual exploitation of helpless women by the very person entrusted with their protection – Held: Such breach of trust and abuse of official authority warranted cancellation of bail to prevent miscarriage of justice [Paras 20-22].

Societal Impact and Threat to Trial – Influence on Witnesses – Bail Revoked to Safeguard Fair Trial – The Court found a high possibility of the accused influencing witnesses, given her reinstatement in service and access to similar institutions – Held: Bail cancelled to prevent undermining public faith in judicial process and ensure fair trial [Paras 14, 22, 27].

Guiding Principles on Bail Cancellation – Reliance on Precedents – Application of Ajwar v. Waseem and Shabeen Ahmad v. State of UP – The Court reiterated parameters for bail cancellation including gravity of offence, impact on society, and risk to fair trial – Held: Unreasoned bail orders in grievous crimes merit judicial correction [Paras 23-24].

Final Decision – Appeal Allowed – Bail Cancelled – The Supreme Court quashed the High Court order dated 18/01/2024, cancelled the bail of respondent No.2, directed her surrender, and issued safeguards for victims – Held: Appellant's appeal allowed, bail of respondent No.2 stands cancelled [Paras 28-30].