The Supreme Court explained the doctrine of ratification in Delhi Technological University v. B.S. Rawat, holding that a subsequent approval by the competent authority can validate an earlier act performed without proper authority. The Court relied upon the principle Ratihabitio mandato aequiparatur, meaning that subsequent ratification is generally equivalent to prior authorization. The doctrine operates retrospectively where the original act was legally capable of being performed and the authority providing ratification possessed the necessary power. However, ratification cannot cure an act that was inherently illegal or beyond the statutory powers of the competent authority. In the case, Delhi Technological University’s competent Board of Management subsequently ratified the acceptance of an employee’s resignation. The Supreme Court held that this ratification operated from the original date of the resignation and consequently made the employee’s later withdrawal ineffective. The Court therefore allowed the University’s appeal and set aside the Delhi High Court’s direction requiring reinstatement.
The Supreme Court, in Karnataka Power Transmission Corporation Limited v. Rekha & Ors., clarified the liability of electricity authorities in cases involving electrocution. The Court distinguished between “strict liability” and “absolute liability” and held that electricity transmission is inherently dangerous, making the doctrine of strict liability applicable to electricity boards. However, absolute liability, which does not permit exceptions, was considered inappropriate in such cases. The Court also held that High Courts should generally avoid deciding compensation claims through writ jurisdiction under Article 226 where complex disputed questions of fact, such as contributory negligence, require detailed examination. The Supreme Court further rejected the automatic application of the multiplier method under the Motor Vehicles Act for calculating compensation in electrocution cases. Compensation must instead be determined on the basis of what is just and reasonable in the particular circumstances. The Court set aside the Karnataka High Court’s judgments while allowing the victims to pursue civil remedies. Interim compensation already paid was directed not to be recovered.
The Gauhati High Court, in Sh. P. Rohmingsanga v. The State of Mizoram & Anr., set aside a rape conviction and held that mental disability alone does not automatically establish a woman’s incapacity to provide valid consent. The case concerned a 24-year-old woman with a certified mental disability. The trial court had convicted the accused under Section 376(2)(l) of the IPC, substantially relying on the victim’s disability and her assessed mental age. The High Court held that a mentally challenged adult cannot automatically be equated with a child merely because an assessment indicates a lower mental age. The Court stressed that the prosecution must establish, through evidence, that the woman was actually incapable of understanding the nature and consequences of the sexual act. It also considered procedural safeguards concerning the recording of statements of disabled victims under Section 164(5A) CrPC. The judgment emphasized both the autonomy of disabled adults and strict compliance with statutory safeguards governing their evidence.
The Supreme Court, in Ram Singh v. The State of Himachal Pradesh, restored the acquittal of an accused in a rape case after finding significant contradictions between the prosecution’s oral evidence and forensic material. The accused had been convicted by the Himachal Pradesh High Court after the trial court had originally acquitted him. The Supreme Court examined the medical examination and forensic reports and noted that the victim had no injuries, while scientific tests conducted on her clothes did not detect blood or semen. The Court also noticed inconsistencies regarding the alleged place of occurrence. Considering these circumstances collectively, the Court held that the prosecution evidence did not provide a safe basis for sustaining the conviction. The Supreme Court emphasized that while a conviction can ordinarily rest on reliable testimony, courts must carefully evaluate such testimony when it is materially contradicted by objective scientific evidence. The High Court’s conviction was therefore set aside and the original acquittal was restored.
The Supreme Court of India considered the rights of homebuyers under the Insolvency and Bankruptcy Code, 2016. The Court distinguished genuine homebuyers from speculative investors, examining factors such as buyback arrangements, assured returns, multiple-unit purchases and absence of genuine intention to obtain possession. It held that actual possession of a dwelling unit is central to determining a genuine homebuyer. The Court also emphasized that housing and shelter form part of the right to life under Article 21. The 2019 IBC amendment requiring the statutory threshold for homebuyer insolvency applications was considered applicable. The judgment is important for IBC, homebuyers, speculative investment, Article 21, right to shelter, Section 7 IBC and insolvency proceedings.
The Supreme Court of India clarified the distinction between void and voidable documents under the Limitation Act, 1963. It held that Article 59, providing a three-year limitation period, applies to cancellation of voidable instruments, while Article 65, providing twelve years for possession based on title, applies where the document is void ab initio. Fraud relating to the very character of a document makes it void, whereas fraud concerning its contents may make it voidable. The Court further held that a void document is a nullity and does not require a separate cancellation decree. Under Section 54 of the Transfer of Property Act, a sale without consideration is legally ineffective. Therefore, a plaintiff can seek possession under Article 65 without first seeking cancellation of the void document. The ruling is significant for limitation, fraudulent sale deeds, void transactions, Article 59, Article 65 and Section 54 TPA.
The Supreme Court of India directed all High Courts and trial courts to dispose of bail and anticipatory bail applications within two months. The case involved allegations of fraudulent transfer of land based on forged Powers of Attorney and subsequent mutation entries. The Court upheld rejection of anticipatory bail, observing that the seriousness of allegations, alleged abuse of official position and existence of a prima facie case justified investigation. At the same time, the Court expressed concern over prolonged pendency of bail applications and emphasized that personal liberty under Article 21 requires timely judicial consideration. High Courts were directed to establish mechanisms to prevent accumulation of bail matters, while investigating agencies were asked to expedite long-pending investigations. The judgment is important for bail jurisprudence, anticipatory bail, Article 21, personal liberty, speedy justice, prima facie case and judicial delay.
The Supreme Court of India issued nationwide directions to ensure humane and dignified conditions in beggars' homes. The Court emphasized that such institutions must be restorative rather than retributive, reflecting constitutional values of dignity and social justice. Referring to Article 21, the Court held that the right to life includes the right to live with dignity. Directions included medical screening, regular health check-ups, sanitation, potable water, adequate accommodation, nutrition and disease surveillance. The Court also directed provision of vocational training, rehabilitation and legal aid, with State Legal Services Authorities providing assistance. Separate facilities were directed for women and children, while children found begging should be dealt with under the juvenile justice framework. Monitoring committees and accountability mechanisms were also mandated. The decision highlights Article 21, dignity, social justice, rehabilitation, legal aid and State responsibility.
The Supreme Court of India held that delayed death does not automatically reduce a murder conviction to attempt to murder. The victim suffered serious head and spinal injuries during the assault and died approximately nine months later from complications including septic shock, pneumonia and post-traumatic spinal injury. The Court held that where such complications are the natural or probable consequences of the original injuries and the causal chain is not broken by an independent intervening cause, the accused remains liable for the resulting death. The Court examined the distinction between Section 302 IPC and Section 307 IPC, emphasizing intention, nature of weapon, manner of assault, part of body targeted and seriousness of injuries. The possibility that better medical treatment could have prevented death does not necessarily break causation. The ruling is important for murder, causation, mens rea, Section 300 IPC, Section 302 IPC and delayed death.