In the matter of M/s Knots India Carpets Private Limited v. State of Uttar Pradesh and 2 others, the Court was called upon to consider a writ petition seeking a No Objection Certificate for the construction of a hotel on a parcel of land. The State had objected to the proposed construction on the ground that the land in question constituted a pond, thereby attracting restrictions under relevant land‑use regulations. The Bench examined the foundation of the State’s contention and observed that the assertion of the land being a pond could not be sustained merely on the basis of administrative records or revenue entries.
The Court noted that the land had been the subject of a sale deed executed 113 years prior to the present proceedings. That deed, which transferred title to the private party, remained unchallenged by the State. The Bench held that, in order to assert that the land is a pond, the State must first contest the validity or effect of that historic sale deed. Without such a challenge, the State’s reliance on the pond characterisation is legally untenable. The judgment emphasised that a claim altering the nature of the property cannot be made collaterally; it must be grounded in a direct challenge to the instrument that established the existing title.
Consequently, the Court rejected the State’s objection and allowed the petitioner’s request for the No Objection Certificate, subject to any other statutory clearances that may be required. The decision reinforces the principle that administrative assertions affecting private property must be backed by substantive legal challenges to existing title documents, particularly where those documents have endured for over a century.
In Ram Autar And Others Vs. State, a Division Bench comprising Justice Siddhartha Varma and Justice Jai Krishna Upadhyay considered an appeal against a conviction rendered in 1989 for an offence involving alleged poisoning. The prosecution had relied heavily on a viscera report to establish the cause of death. During the trial, the accused were examined under Section 313 CrPC, but the viscera report was not specifically placed before them for their explanation.
The Bench held that the non‑disclosure of the viscera report to the accused at the stage of their Section 313 examination vitiated the fairness of the trial. It clarified that merely asking the accused whether poison had been administered to the deceased does not satisfy the statutory obligation when the primary scientific evidence linking the accused to the offence is withheld. The Court observed that Section 313 CrPC mandates that the accused be given an opportunity to explain any incriminating material that the prosecution intends to rely upon, and that the viscera report constitutes such material.
Accordingly, the Court set aside the conviction and remanded the matter for a fresh trial, directing that the viscera report be duly presented to the accused during their Section 313 examination before any reliance thereon is permitted. The ruling underscores the safeguard that scientific evidence, however reliable, cannot be used to secure a conviction unless the accused have been afforded a meaningful chance to respond to it, thereby preserving the core tenet of a fair trial under Indian criminal jurisprudence.