List of Current Affairs

Source: Allahabad High Court 

Why in News? 

Justice Shekhar Kumar Yadav of the Allahabad High Court in the case of Rahul Gupta and 6 Others v. State of U.P. and Another (2025) quashed criminal proceedings under the SC/ST Act after parties entered into a verified compromise, ruling that the offence was primarily private in nature and not committed on account of caste. 

What was the Background of Rahul Gupta and 6 Others v. State of U.P. and Another (2025) Case? 

• The criminal appeal was filed to quash proceedings in S.T. No.892 of 2024 arising out of Case Crime No.0126 of 2024. 
• The case was registered under Sections 147, 323, 500, 504 and 506 of the Indian Penal Code and Section 3(2)(va) of the SC/ST Act at Police Station Brahampuri, District Meerut. 
• A charge sheet was filed on 30.04.2024 and summoning order was passed on 19.07.2024 by the Special Judge, SC/ST Act, Meerut. 
• The parties informed the Court that they had entered into a compromise and settled all disputes between them. 
• The Court directed the Special Judge SC/ST Act Meerut to verify the compromise, which was done vide order dated 4.12.2024. 
• The Court also directed inquiry into whether the opposite party no.2 (informant) had returned the compensation amount received from authorities. 
• The District Magistrate, Meerut submitted a report dated 4.12.2024 stating that the compensation amount had not been returned by the opposite party no.2. 
• The appellants' counsel submitted that the compromise was made without any coercion or undue influence and was result of free will and consent. 

What were the Court's Observations? 

• The Court found that the present case had the nature of a purely private dispute. 
• The Court observed that prima facie the alleged offence had not been committed on account of the caste of the victim. 
• The Court noted that except for the offence under SC/ST Act, only minor offences had been levelled against the accused. 
• The Court found that the compromise was the result of free will and consent of the informant without any undue influence. 
• The Court relied on the Supreme Court judgment in Ramawatar v. State of M.P. (2022), which held that where an offence under SC/ST Act is primarily private or civil in nature, or where the alleged offence has not been committed on account of caste, or where continuation of proceedings would be abuse of process, the Court can exercise powers to quash proceedings. 
• The Court emphasized the principle from Ramawatar that if the Court is satisfied that the underlying objective of the Act would not be contravened even if the offence goes unpunished, the fact that it is covered under a special statute would not prevent exercise of quashing powers. 
• The Court highlighted the need for vigilance to ensure complainants from Scheduled Castes and Scheduled Tribes enter compromises voluntarily without any duress, noting they belong to weaker sections and are more prone to coercion. 
• The Court referred to the Full Bench judgment in Ghulam Rasool Khan and Others v. State of U.P and Another (2022), which held that matters under SC/ST Act may be compounded in criminal appeal under Section 14-A(1) of SC/ST Act without need to take recourse under Section 482 CrPC. 
• The Court quashed the entire criminal proceedings including the summoning order dated 19.07.2024 and allowed the criminal appeal in terms of the compromise. 
• The Court directed the opposite party no.2 to return the compensation amount received from authorities within one week.

What is the ST/SC (Prevention of Atrocities) Act, 1989? 

About the SC/ST Act: 

• SC/ST Act 1989 is an Act of Parliament enacted to prohibit discrimination against SC & ST communities' members and prevent atrocities against them. 
• The Act was passed in Parliament of India on 11th September 1989 and notified on 30 January 1990. 
• The Act is also a recognition of the depressing reality that despite undertaking several measures, the Scheduled Castes/Scheduled Tribes continue to be subjected to various atrocities at the hands of upper castes. 
• The Act has been enacted keeping in view the express constitutional safeguards enumerated in Articles 15, 17 and 21 of the Constitution of India, 1950 (COI), with a twin-fold objective of protecting the members of these vulnerable communities as well as to provide relief and rehabilitation to the victims of caste-based atrocities. 

SC/ST (Amendment) Act, 2015: 

• This Act was amended in the year 2015 for the purpose of making the act more stringent with the following provisions: 
  • Recognition was given to more instances of atrocities as crimes against SCs and STs. 
  • It added several new offences in Section 3 and renumbered the entire section since the recognized crime almost doubled. 
  • The Act added Chapter IVA Section 15A (the rights of victims and witnesses), and defined dereliction of duty by officials and accountability mechanisms more precisely. 
  • It provided for the establishment of exclusive special courts and special public prosecutors. 
  • In the context of public servants at all levels this Act defined the term willful negligence. 

SC/ST (Amendment) Act, 2018: 

• In the case of Prithvi Raj Chauhan v. Union of India (2020), the Supreme Court upheld the constitutional validity of Parliament’s 2018 Amendment to the Prevention of Atrocities Act. The Salient features of this Amendment Act are as follows: 
  • It added Section 18A to the original Act. 
  • It delineates specific crimes against Scheduled Castes and Scheduled Tribes as atrocities and describes strategies and prescribes punishments to counter these acts. 
  • It identifies what acts constitute “atrocities” and all offences listed in the Act are cognizable. The police can arrest the offender without a warrant and start an investigation into the case without taking any orders from the court. 
  • The Act calls upon all the states to convert an existing sessions court in each district into a Special Court to try cases registered under it and provides for the appointment of Public Prosecutors/Special Public Prosecutors for conducting cases in special courts. 
  • It creates provisions for states to declare areas with high levels of caste violence to be “atrocity-prone” and to appoint qualified officers to monitor and maintain law and order. 
  • It provides for the punishment for willful neglect of duties by non-SC/ST public servants. 
  • It is implemented by the State Governments and Union Territory Administrations, which are provided due central assistance. 

Source: Supreme Court 

Why in News? 

The bench of Chief Justice Surya Kant and Justices Ujjal Bhuyan and N Kotiswar Singh in the case of State of Himachal Pradesh & Anr. v. M/s OASYS Cybernatics Pvt. Ltd. (2025) upheld the Himachal Pradesh government's decision to cancel a Letter of Interest issued to a private company for supply of electronic Point-of-Sale devices for the Public Distribution System.

What was the Background of State of Himachal Pradesh & Anr. v. M/s OASYS Cybernatics Pvt. Ltd. (2025) Case? 

• The Himachal Pradesh government issued a Letter of Interest (LoI) in September 2022 to a private company for supplying electronic Point-of-Sale (ePoS) devices for its Public Distribution System (PDS). 
• The LoI remained in effect for eight months before being cancelled in June 2023. 
• The company challenged the cancellation before the High Court, arguing it was arbitrary and citing substantial investments made in preparing for the contract. 
• The High Court interfered with the State's decision and restored the contractual obligations of the company. 
• The LoI contained several pre-conditions including successful compatibility testing with National Informatics Centre (NIC) software and live demonstration requirements. 
• The company failed to conclusively meet these technical preconditions stipulated in the LoI. 
• Aggrieved by the High Court's intervention, the State of Himachal Pradesh appealed to the Supreme Court.

What were the Court's Observations? 

• The Court observed that a Letter of Interest (LoI) is merely a "promise in embryo" that can mature into a contract only upon satisfaction of stipulated preconditions or upon issuance of a Letter of Acceptance (LoA). 
• Referencing Dresser Rand S.A. v. Bindal Agro Chem Ltd. (2006), the Court stated that a letter of intent merely indicates a party's intention to enter into a contract in future and is not intended to bind either party ultimately. 
• The Court acknowledged that the cancellation letter was "laconic" and lacked stated reasons, but held that these deficiencies were only procedural and did not render the decision arbitrary. 
• Since the company failed to conclusively meet technical preconditions such as NIC software compatibility testing and live demonstration, no binding contractual rights accrued to the vendor. 
• The Court found no improper motive, favouritism, or collateral purpose in the cancellation decision, noting that it led to a fresh tender open to all rather than an award to another bidder. 
• Referencing Tata Cellular v. Union of India (1994), the Court recognized that the State's decision to cancel a tender or restart the process is itself an aspect of public interest, and the decision to re-tender fell within the zone of permissible discretion. 
• The Court rejected the company's legitimate expectation argument, stating that the doctrine presupposes a clear and unambiguous representation by the State, while the conditional terms of the LoI expressly warned that the process was still provisional.

Court's Directions: 

The Supreme Court allowed the appeal and issued the following directions: 

• The High Court's judgment was set aside and the State's decision cancelling the Letter of Intent dated September 2, 2022 was upheld, though the Expression of Interest issued immediately after cancellation was also set aside. 
• The State was granted liberty to issue a fresh tender for supply, installation and maintenance of ePoS devices, and the respondent company shall be free to participate subject to uniform eligibility and prescribed conditions. 
• The State was directed to hold a Fact-Finding Enquiry in association with the respondent company to ascertain details of ePoS machines, components, or allied services supplied, and reimburse verified costs on the principle of quantum meruit within three months. 
• All machinery, devices, technology, or software infrastructure handed over or used during pilot or demonstration stages shall vest in the State free of encumbrances, subject to payment of cost and installation expenditure to the company. 
• No further claim for loss of profit, expectation, or consequential damages shall survive, with relief confined to equitable reimbursement for tangible assets or work actually appropriated by the State.

What is a Letter of Interest (LoI)? 

About: 

• A Letter of Interest (LoI) is a preliminary document in the procurement process that indicates a party's intention to enter into a contract with another party in future. 
• It is not intended to bind either party ultimately to enter into any contract. 
• An LoI is essentially a "promise in embryo" that requires fulfillment of certain conditions before it can mature into a binding contract. 
• The issuance of an LoI does not create any vested or enforceable rights in favor of the recipient. 

LoI vs Letter of Acceptance (LoA): 

• A Letter of Interest represents only a conditional and provisional stage in the contracting process. 
• It typically contains pre-conditions that must be satisfied before any binding obligation arises. 
• A Letter of Acceptance (LoA), on the other hand, represents final and unconditional acceptance. 
• Only upon issuance of an LoA or satisfaction of all stipulated preconditions does an LoI mature into an enforceable contract. 
• Until the threshold of final acceptance is crossed, the recipient of an LoI has no vested contractual rights. 

Legitimate Expectation in Context of LoI: 

• The doctrine of legitimate expectation presupposes a clear and unambiguous representation by the State, followed by reliance and detriment. 
• When an LoI contains conditional terms and explicit disclaimers, it negates the existence of any clear assurance that a contract will be finalized. 
• Investments made by a party after receiving an LoI, when the LoI expressly warns of provisional nature, cannot give rise to legitimate expectation. 
• The doctrine cannot be invoked to override explicit conditional terms in an LoI. 

State's Right to Cancel LoI: 

• The State has discretion to cancel a Letter of Interest when pre-conditions are not met. 
• The decision to cancel and re-tender is an aspect of public interest, particularly in public procurement. 
• Cancellation is permissible when prompted by non-compliance with technical requirements or policy considerations. 
• The absence of improper motive, favouritism, or collateral purpose supports the validity of cancellation. 
• Procedural deficiencies in the cancellation letter (such as lack of detailed reasons) do not necessarily render the cancellation arbitrary if substantive grounds exist. 

Quantum Meruit Principle: 

• Even when an LoI is validly cancelled, the principle of quantum meruit may apply to prevent unjust enrichment. 
• Quantum meruit allows for equitable reimbursement for tangible assets or work actually appropriated by the State. 
• This reimbursement is limited to verified costs and expenses for goods or services actually supplied and used. 
• However, claims for loss of profit, expectation damages, or consequential damages do not survive under this principle.