Weekly Overview| Supreme Court Judgments: December 15 – December 19, 2025

Update: 2025-12-22 10:30 GMT

1) S. 44C Income Tax Act applies to “head office expenditure” regardless of whether it’s incurred exclusively for Indian branches

The Court held that Section 44C of the Income Tax Act, 1961 (ITA) applies to "head office expenditure" regardless of whether it is common expenditure or expenditure incurred exclusively for the Indian branches.

The Court held thus in Civil Appeals in which the central issue was related to the interpretation of Section 44C of ITA, more particularly whether it merely covers ‘common expenditure’ incurred by the head office attributable to an assessee’s business in India or would also include ‘exclusive expenditure’ incurred by the head office for the Indian branches.

Cause Title- Director of Income Tax (IT)-I, Mumbai v. M/s. American Express Bank Ltd. (Neutral Citation: 2025 INSC 1431)

Date of Judgment- December 15, 2025

Coram- Justice J.B. Pardiwala and Justice K.V. Viswanathan

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2) Doctrine of lis pendens can’t be blindly made inapplicable to suits in which plaint contains averment that mortgaged property be attached & sold

The Court held that the Doctrine of Lis Pendens cannot blindly be made inapplicable to suits in which the plaint contains a specific averment that the mortgaged property be attached and sold in lieu of the decree or a charge be created on the property.

The Court held thus in a Civil Appeal arising from the Judgment of the Punjab and Haryana High Court by which the second Appeal was dismissed and the Judgment of the Appellate Court was affirmed.

Cause Title- Danesh Singh & Ors v. Har Pyari (Dead) Thr. LRs. & Ors. (Neutral Citation: 2025 INSC 1434)

Date of Judgment- December 15, 2025

Coram- Justice J.B. Pardiwala and Justice R. Mahadevan

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3) Section 103 MSCS Act does not automatically convert state cooperative society into multi-state society upon reorganisation of a state

The Court held that a society registered under a State Cooperative Societies Act does not become a multi-State cooperative society under Section 103 of the Multi-State Cooperative Societies Act, 2002, upon reorganisation of the State, unless its objects, as reflected in its bye-laws, extend to more than one State.

The Court was hearing Civil Appeals filed by the State of Uttar Pradesh challenging a Judgment of the Allahabad High Court which had treated certain cooperative sugar factories as multi-State cooperative societies after the bifurcation of the erstwhile State into Uttar Pradesh and Uttarakhand.

Cause Title- The State Of Uttar Pradesh Through Principal Secretary & Ors. v. Milkiyat Singh & Ors. Etc. (Neutral Citation: 2025 INSC 1427)

Date of Judgment- December 15, 2025

Coram- Justice Vikram Nath and Justice Sandeep Mehta

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4) It's a common practice for landowners to keep original title deeds in bank lockers for security purposes: Supreme Court restores order allowing buyer to realize paid amount from seller

In a case where there was a concealment of the fact of a mortgage pertaining to a property which was contracted to be sold, the Court restored the Order entitling the buyer to realise the paid amount from the seller. The Court found that the seller’s culpable intent was reflected in concealing the material factum of encumbrance on the suit schedule property.

The Court was considering an Appeal challenging the Judgment passed by the Kerala High Court holding that the Appellant was in breach of the agreement and remanding the matter to the Trial Court for the limited purpose of examining whether the defendant-respondent had suffered any compensable loss.

Cause Title- Moideenkutty v. Abraham George (Neutral Citation: 2025 INSC 1428)

Date of Judgment- December 15, 2025

Coram- Justice Vikram Nath and Justice Sandeep Mehta

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5) Follow standardized format for cataloguing witnesses, documentary evidence & material objects: Supreme Court issues directions to trial courts

The Court has issued necessary directions to the Trial Courts to institutionalize a standardized format for cataloguing witnesses, documentary evidence, and material objects.

The Court was hearing a Criminal Appeal filed by an accused challenging the Judgment of the Gujarat High Court, which upheld his conviction for the offences punishable under Sections 363, 376(2)(i), and 201 of the Indian Penal Code, 1860 (IPC) and Sections 3 and 4 of the Protection of Children from Sexual Offences Act, 2012 (POCSO Act).

Cause Title- Manojbhai Jethabhai Parmar (Rohit) v. State of Gujarat (Neutral Citation: 2025 INSC 1433)

Date of Judgment- December 15, 2025

Coram- Justice Vikram Nath and Justice Sandeep Mehta

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6) "Eradication of dowry is a constitutional and social necessity": Supreme Court issues nationwide directions to combat dowry practices

While issuing a series of nationwide directions to address the continuing prevalence of dowry-related cruelty and deaths across the country, the Court observed that the eradication of dowry is an urgent constitutional and social necessity.

The Court was hearing Criminal Appeals filed by the State of Uttar Pradesh challenging the Judgment of the Allahabad High Court, which had set aside the findings recorded by the Trial Court in a case arising out of allegations of cruelty and death of a woman in connection with dowry demands. The Appeals arose from proceedings in which the prosecution alleged persistent harassment and cruelty linked to dowry demands, leading to the unnatural death of the victim.

Cause Title- State of Uttar Pradesh v. Ajmal Beg & Ors. (Neutral Citation: 2025 INSC 1435)

Date of Judgment- December 15, 2025

Coram- Justice Sanjay Karol and Justice N Kotiswar Singh

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7) Motor accident compensation claim by parents of deceased child stands on different footing from disabled child’s claim

The Court observed that the claim of compensation by the parents of a dead child would stand on a different footing from that of a claim filed by a disabled child, destined to live the rest of his/her life with a debilitating condition of mental retardation.

The Court granted enhanced compensation of over Rs. 8 lakhs to the parents of a 14-year-old boy who died in a motor accident.

Cause Title- Devendra Kumar Tripathi v. The Oriental Insurance Company Ltd. (Neutral Citation: 2025 INSC 1429)

Date of Judgment- December 15, 2025

Coram- Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran

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8) Refusal to accommodate each other amounts to cruelty: Supreme Court dissolves marriage

The Court observed that, in exercise of power to do “complete justice” under Article 142(1) of the Constitution of India, it has the discretion to dissolve the marriage on the ground of irretrievable breakdown. The Court also held that the parties' refusal to accommodate each other amounted to cruelty to one another.

The Court was considering an Appeal filed against the Judgment of the Gauhati High Court (Shillong Bench), whereby the Appeal filed by the Respondent-wife was allowed, and the Judgment dissolving the marriage on the ground of desertion by the Respondent-wife was set aside.

Cause Title- PQ v. YZ (Neutral Citation: 2025 INSC 1436)

Date of Judgment- December 15, 2025

Coram- Justice Manmohan and Justice Joymalya Bagchi

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9) PPA can only be read in manner as to be aligned with state regulations: Supreme Court rejects plea against APTEL’s Decision

The Court dismissed a Civil Appeal filed by Tamil Nadu Generation and Distribution Corporation Ltd. (TNGDCL) against the Judgment of the Appellate Tribunal for Electricity (APTEL).

The Court said that Power Purchase Agreement (PPA) can only be read in manner as to be aligned with State Regulations.

Cause Title- Tamil Nadu Generation and Distribution Corporation Ltd. v. M/s Penna Electricity Limited (Neutral Citation: 2025 INSC 1439)

Date of Judgment- December 16, 2025

Coram- Justice J.B. Pardiwala and Justice K.V. Viswanathan

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10) Supreme Court quashes FIR and criminal proceedings against Karnataka Leader of Opposition R Ashoka in land allotment case

The Court quashed the First Information Report (FIR) and all criminal proceedings initiated against R. Ashoka, Leader of the Opposition in the Karnataka Assembly, in connection with alleged irregularities in the allotment of government land by a committee for the regularisation of unauthorised occupation in the State of Karnataka.

The Court was hearing Criminal Appeals arising out of writ proceedings in which the Appellant had sought quashing of an FIR registered by the Anti-Corruption Bureau following complaints alleging arbitrary and illegal grant of land to ineligible persons. The Appeals challenged the Judgment of the Karnataka High Court, which had declined to interfere with the FIR and the investigation initiated thereunder.

Cause Title- R. Ashoka v. State of Karnataka & Ors. (Neutral Citation: 2025 INSC 1441)

Date of Judgment- December 16, 2025

Coram- Justice Sanjay Karol and Justice Vipul M. Pancholi

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11) "Evidence suffered from material discrepancies": Supreme Court upholds acquittal in 1996 murder of army captain

The Court upheld the acquittal of three accused persons in a 1996 murder case involving an Indian Army officer, holding that the prosecution evidence suffered from material discrepancies and that the High Court had taken a plausible view while reversing the conviction.

The Court was hearing an Appeal filed by the original complainant challenging the Judgment of the Allahabad High Court, which had set aside the conviction and life sentence imposed on the accused for the murder of an Army Captain during a family property dispute. The Appeal arose from the acquittal of the accused persons, who the Trial Court had earlier convicted under Section 302, read with Section 34 of the Indian Penal Code, for the murder of Captain Praveen Kumar.

Cause Title- Raj Pal Singh v. Rajveer & Ors. (Neutral Citation: 2025 INSC 1442)

Date of Judgment- December 16, 2025

Coram- Justice K. Vinod Chandran and Justice N.V. Anjaria

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12) Victim as well as medical evidence didn't support prosecution case: Supreme Court acquits doctor in 2001 rape case

The Court acquitted a doctor in an alleged case of rape after noting that the main witness of the prosecution, i.e. the victim herself and the medical evidence do not support the case of the prosecution.

The Court also noted that the victim and her husband had not supported the case of the prosecution, and were declared hostile. The Appellant approached the Court, challenging the Judgment of the Gujarat High Court dismissing the Appeal preferred by the Appellant-accused and allowing the Appeal preferred by the State for enhancement of the sentence awarded to the Appellant-accused.

Cause Title- Jayantibhai Chaturbhai Patel v. State of Gujarat (Neutral Citation: 2025 INSC 1443)

Date of Judgment- December 16, 2025

Coram- Justice Sanjay Karol and Justice Vipul M. Pancholi

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13) Exclusion clause must be construed strictly in insurance contracts; any ambiguity between clauses must be interpreted in favour of insured

The Court observed that the exclusion clause must be construed strictly and wherever there is any ambiguity between two or more clauses in the contract, it must be interpreted in favour of the insured.

The Court observed thus in a Civil Appeal preferred by Cement Corporation of India against the Judgment of the National Consumer Disputes Redressal Commission, New Delhi (NCDRC).

Cause Title- Cement Corporation of India v. ICICI Lombard General Insurance Company Limited (Neutral Citation: 2025 INSC 1444)

Date of Judgment- December 16, 2025

Coram- Justice J.K. Maheshwari and Justice Vijay Bishnoi

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14) Judicial orders of Patna High Court would bind successor state: Supreme Court grants relief to officer whose services were allocated to State of Jharkhand

While granting relief to an Industries Extension Officer whose services were allocated to the State of Jharkhand after the promulgation of the Bihar Reorganisation Act, 2003, the Court held that the statutory provisions of the Act, particularly Section 34(4), mandate that judicial Orders of the Patna High Court continue to bind the Successor State.

The Court was considering an Appeal filed by an employee challenging the Judgment of the Jharkhand High Court. The dispute between the parties related to the grant of a higher pay scale to the Employee after the removal of anomalies in the pay scale, on parity with other similarly situated persons who had already been granted the said benefit by the Respondent–Employer.

Cause Title- Sanjay Kumar Upadhyay v. State of Jharkhand (Neutral Citation: 2025 INSC 1445)

Date of Judgment- December 16, 2025

Coram- Justice J.K. Maheshwari and Justice Vijay Bishnoi

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15) Section 35 of SARFAESI Act cannot override any constitutional provision

The Court held that the overriding clause contained in Section 35 of the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI Act), does not and cannot override any provision of the Constitution.

The Court was examining whether an action initiated by a financial corporation under the SARFAESI Act could be sustained in a situation where the constitutional framework governing the subject matter operated in a distinct and overriding manner.

Cause Title- North Eastern Development Finance Corporation Ltd. v. M/s L. Doulo Builders and Suppliers Co. Pvt. Ltd (Neutral Citation: 2025 INSC 1446)

Date of Judgment- December 16, 2025

Coram- Justice Dipankar Datta and Justice Aravind Kumar

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16) Whether a member of consortium itself can invoke Section 11 A&C Act?: Supreme Court answers

The Court answered whether a member of a consortium can itself invoke Section 11 of the Arbitration and Conciliation Act, 1996 (A&C Act).

The Court was deciding two Civil Appeals arising from an Order of the Telangana High Court passed under Section 11(6) of A&C Act, constituting an Arbitral Tribunal (AT) for resolution of dispute as per the arbitration clause in General Conditions of Contract (GCC).

Cause Title- M/s Andhra Pradesh Power Generation Corporation Limited (APGENCO) v. M/s Tecpro Systems Limited & Ors. (Neutral Citation: 2025 INSC 1447)

Date of Judgment- December 17, 2025

Coram- Justice P.S. Narasimha and Justice Atul S. Chandurkar

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17) Recovery from body of accused cannot be converted into disclosure u/s 27 Evidence Act

While upholding the conviction of the accused in a rape and murder case, the Court held that recoveries effected from the person of an accused at the time of arrest cannot be treated as recoveries under Section 27 of the Indian Evidence Act.

The Court was hearing a Criminal Appeal arising from a Judgment of the Telangana High Court which had upheld the conviction of the accused for offences of rape and murder, relying inter alia on recoveries claimed to be admissible under Section 27 of the Evidence Act.

Cause Title- Shaik Shabuddin v. State of Telangana (Neutral Citation: 2025 INSC 1449)

Date of Judgment- December 17, 2025

Coram- Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran

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18) Site not identified on the ground & title not proved: Supreme Court upholds dismissal of injunction suit

The Court restored an Order of the Trial Court dismissing a suit for injunction after finding that there was no seal or a clear signature on the letter purportedly written by the Land Acquisition Officer of the BDA, and the Plaintiff failed to prove the title.

A suit for permanent injunction filed by the Respondent Plaintiffs was dismissed. This Order was reversed by the High Court and decreed in First Appeal, against which the Appellants/Defendants filed an Appeal before the Court.

Cause Title- Obalappa v. Pawan Kumar Bhihani (Neutral Citation: 2025 INSC 1450)

Date of Judgment- December 17, 2025

Coram- Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran

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19) Can’t substitute our opinions in place of that of testator: Supreme Court upholds 1988 will

While upholding a 1988 Will, the Court said that it cannot substitute its opinions in place of that of Testator.

The Civil Appeals before the Court challenged the concurrent findings; disbelieving a will, excluding one out of nine children, who married out of the community, holding the estate of the testator partible.

Cause Title- K. S. Dinachandran v. Shyla Joseph & Ors. (Neutral Citation: 2025 INSC 1451)

Date of Judgment- December 17, 2025

Coram- Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran

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20) Interested or related witness testimony cannot be discarded mechanically; must be closely scrutinised

The Court held that merely because a witness is interested or related to the victim, their deposition cannot be discarded, though it must be scrutinised closely before being relied upon for conviction.

The Court was hearing Criminal Appeals filed by accused persons challenging the dismissal of their Appeals by the Chhattisgarh High Court, which had affirmed their conviction and sentence for offences including murder and rioting.

Cause Title- Punimati & Anr. v. The State of Chhattisgarh & Ors.; Dayalu & Ors. v. State of Chhattisgarh (Neutral Citation: 2025 INSC 1454)

Date of Judgment- December 18, 2025

Coram- Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi

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21) Mere inadequacy of record won’t confer jurisdiction upon corporation to invoke Section 45A ESI Act

The Court held that mere inadequacy of the record would not confer jurisdiction upon the Corporation to invoke Section 45A of the Employees State Insurance Act, 1948 (ESI Act).

The Court held thus in a Civil Appeal preferred by M/S. Carborandum Universal Ltd. against the Judgment of the Madras High Court.

Cause Title- M/S. Carborandum Universal Ltd. v. ESI Corporation (Neutral Citation: 2025 INSC 1455)

Date of Judgment- December 18, 2025

Coram- Justice Manoj Misra and Justice Ujjal Bhuyan

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22) If interpretation of tender inviting authority is vitiated by mala fides, constitutional court can't show deference to it

The Court observed that if the interpretation of the tender inviting authority or its understanding of the tender conditions is vitiated by mala fides or perversity, there is no question of a Constitutional Court showing deference to such understanding.

The Court observed thus in a Civil Appeal challenging the Judgment of the Chhattisgarh High Court’s Division Bench in a Writ Petition filed by a company.

Cause Title- M/s. Surguja Bricks Industries Company v. State of Chhattisgarh & Ors. (Neutral Citation: 2025 INSC 1456)

Date of Judgment- December 18, 2025

Coram- Justice Manoj Misra and Justice Ujjal Bhuyan

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23) Driving not merely a qualification on paper but also involves hands-on experience coupled with regular practice

The Court emphasized that driving is not merely a qualification on paper but also involves hands-on experience coupled with regular practice.

The Court was hearing a batch of Civil Appeals filed against the common Judgment of the Telangana High Court’s Division Bench, by which the Appeals filed by the Telangana State Level Police Recruitment Board (TSLPRB) were dismissed.

Cause Title- Telangana State Level Police Recruitment Board v. Penjarla Vijay Kumar & Ors. Etc. (Neutral Citation: 2025 INSC 1452)

Date of Judgment- December 18, 2025

Coram- Justice Ahsanuddin Amanullah and Justice S.V.N. Bhatti

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24) Rajasthan State on its own acted in haste: Supreme Court regularizes admissions of BDS students under relaxed NEET criteria

The Court regularized the admissions of Rajasthan students in Bachelor of Dental Surgery (BDS) course under the relaxed National Entrance-cum-Eligibility Test (NEET) criteria.

The Court was deciding a batch of Civil Appeals concerning the legality of BDS course admissions granted in the State of Rajasthan for the academic year 2016-17 after lowering of the minimum percentile as prescribed for NEET UG examinations.

Cause Title- Siddhant Mahajan and Ors. v. The State of Rajasthan and Ors. (Neutral Citation: 2025 INSC 1458)

Date of Judgment- December 18, 2025

Coram- Justice J.K. Maheshwari and Justice Vijay Bishnoi

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25) Sessions courts cannot curtail statutory remission or impose life sentence till natural life; such power vests only in constitutional courts

The Court held that a Sessions Court cannot direct that a sentence of life imprisonment shall operate till the end of the convict’s natural life, nor can it curtail the statutory powers of remission and commutation conferred upon the State under the Code of Criminal Procedure.

The Court observed that while life imprisonment ordinarily means imprisonment for the entirety of a person’s life, the power to restrict remission or impose alternate sentencing beyond statutory limits vests only in Constitutional Courts and not in Sessions Courts. It was hearing a Criminal Appeal arising from a Judgment of the Karnataka High Court, which had affirmed the conviction of the Appellant for murder under Section 302 of the Indian Penal Code, while upholding the sentence imposed by the Trial Court.

Cause Title- Kiran v. State of Karnataka (Neutral Citation: 2025 INSC 1453)

Date of Judgment- December 18, 2025

Coram- Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran

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26) Forest land cannot be used for non-forestry purposes including agriculture without central government's prior approval

The Court reiterated that forest land cannot be diverted or used for non-forestry purposes, including agricultural cultivation, without prior approval of the Central Government as mandated under the Forest (Conservation) Act, 1980. The Court observed that granting or continuing agricultural activity on forest land necessarily involves clearing of forest cover, which is directly prohibited under the statutory framework governing forest conservation.

The Court was hearing an Appeal filed by the State of Karnataka challenging a Judgment of the Karnataka High Court, which had permitted a cooperative society to make a representation for the continuation of a lease over forest land for agricultural purposes.

Cause Title- State of Karnataka & Ors. v. Gandhi Jeevan Collective Farming Cooperative Society Limited (Neutral Citation: 2025 INSC 1461)

Date of Judgment- December 18, 2025

Coram- Justice Vikram Nath and Justice Sandeep Mehta

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27) Supreme Court grants divorce to couple living separately for two decades invoking Article 142 despite wife's objection

The Court granted divorce to a couple living separately for over two decades on the grounds of irretrievable breakdown of marriage, exercising powers under Article 142 of the Constitution of India.

The Court was considering an Appeal against an Order of the Punjab & Haryana High Court affirming the dismissal of Petition filed by Husband seeking dissolution of marriage.

Cause Title- Jatinder Kumar v. Jeewan Lata (Neutral Citation: 2025 INSC 1463)

Date of Judgment- December 18, 2025

Coram- Justice Vikram Nath and Justice Sandeep Mehta

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28) Supreme Court invokes Article 142 to convert divorce granted due to desertion to divorce by mutual consent

The Court, while considering the case of a Wife employed abroad, converted the grounds of divorce from desertion to mutual consent.

The Court was considering an Appeal filed by the wife against an Order whereby the High Court had affirmed the decree of divorce granted by the Family Court to Husband on the ground of desertion.

Cause Title- Bhagyashree Bisi v. Animesh Padhee (Neutral Citation: 2025 INSC 1464)

Date of Judgment- December 18, 2025

Coram- Justice Vikram Nath and Justice Sandeep Mehta

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29) Article 227| High Court can & should interfere with findings of fact arrived at by subordinate court if not based on evidence or its manifest misreading

The Court reemphasized that the High Court can and should interfere with findings of fact arrived at by the Subordinate Court, if they are not based on evidence or based on a manifest misreading of evidence.

A Civil Appeal was filed before the Court, challenging the legality of the Order passed by the Forest Settlement Officer (FSO) under Sections 4 and 6, read with Section 10 of the Telangana Forest Act, 1967.

Cause Title- The State of Telangana v. Mir Jaffar Ali Khan (Dead) Thr. LRs. & Ors. (Neutral Citation: 2025 INSC 1465)

Date of Judgment- December 18, 2025

Coram- Justice Pankaj Mithal and Justice S.V.N. Bhatti

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30) Section 106 Evidence Act does not shift prosecution’s primary burden; adverse inference arises only after case is proved beyond reasonable doubt

The Court reiterated that Section 106 of the Indian Evidence Act, 1872, does not relieve the prosecution of its primary obligation to prove the guilt of the accused beyond a reasonable doubt in a criminal trial.

The Court clarified that while Section 106 places a burden on an accused to explain facts that lie especially within his knowledge, such burden arises only after the prosecution has successfully established the foundational facts forming the chain of circumstances.

Cause Title- Manoj @ Munna v. State of Chhattisgarh (Neutral Citation: 2025 INSC 1466)

Date of Judgment- December 18, 2025

Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra

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31) Arbitral Tribunal can interpret implied terms or fill contractual gaps where contract is silent

The Court held that arbitral tribunals may interpret implied terms or fill contractual gaps where the agreement is silent, so long as such interpretation does not contradict any express stipulation. The Court also underscored that arbitration law recognises the tribunal as the master of evidence, and Courts exercising jurisdiction under Sections 34 and 37 of the Arbitration and Conciliation Act, 1996, cannot interfere merely because another view is possible.

The ruling came while examining the correctness of a Judgment of the Chhattisgarh High Court, which had set aside an arbitral award affirmed by the Commercial Court, on the ground of 'patent illegality'.

Cause Title- Ramesh Kumar Jain v. Bharat Aluminium Company Limited (BALCO) (Neutral Citation: 2025 INSC 1457)

Date of Judgment- December 18, 2025

Coram- Justice Aravind Kumar and Justice NV Anjaria

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32) Can appellate deposit u/s.148 NI Act be directed against convicted director of company?: Supreme Court refers issue to larger bench

The Court referred the question to a Larger Bench regarding: Whether, upon a conviction under Section 138 read with Section 141 of the Negotiable Instruments Act, 1881 (NI Act), the appellate deposit contemplated by Section 148 may be directed against a convicted director/authorized signatory, or whether such deposit is confined to the juristic “drawer/company” alone in all scenarios?

The Court was hearing a Criminal Appeal filed by an accused against the Judgment of the Rajasthan High Court, by which his Petition was dismissed on the ground that, under Section 141 of the NI Act, directors in charge of the company at the relevant time can be held vicariously liable.

Cause Title- Bharat Mittal v. State of Rajasthan and Ors. (Neutral Citation: 2025 INSC 1459)

Date of Judgment- December 18, 2025

Coram- Justice Aravind Kumar and Justice N.V. Anjaria

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33) Chief Justice of High Court empowered to appoint additional places of sitting: Supreme Court upholds Bombay HC notification declaring Kolhapur as a place of sitting

The Court upheld an administrative notification issued by the Bombay High Court appointing Kolhapur as a place at which Judges and Division Courts of the High Court may sit, holding that the exercise of power under Section 51(3) of the States Reorganisation Act, 1956, falls squarely within the administrative domain of the Chief Justice.

The Court was hearing a Writ Petition under Article 32 of the Constitution challenging an administrative notification issued by the Bombay High Court appointing Kolhapur as a place where Judges and Division Courts may sit, asserting that the decision effectively created a permanent additional Bench by using Section 51(3), and alleged infirmities relating to the decision-making process, consultation, and arbitrariness.

Cause Title- Ranjeet Baburao Nimbalkar v. State of Maharashtra & Anr. (Neutral Citation: 2025 INSC 1460)

Date of Judgment- December 18, 2025

Coram- Justice Aravind Kumar and Justice NV Anjaria

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34) Candidate placed in wait list has no vested right to invariably claim appointment therefrom

The Court reiterated that a candidate placed in the wait list has no vested right to invariably claim appointment therefrom.

Two Appeals were preferred by the original Petitioner assailing the Judgments and Orders passed in the Writ Appeal and Review Petition passed by the Division Bench of the Kerala High Court, whereby the High Court had dismissed both and upheld the Single Bench's dismissal Order.

Cause Title- Radhika T. v. Cochin University and Science and Technology & Ors. (Neutral Citation:2025 INSC 1462)

Date of Judgment- December 18, 2025

Coram- Justice Aravind Kumar and Justice NV Anjaria

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35) Presumption of innocence ends after conviction; suspension of sentence in murder cases to be granted only in exceptional circumstances

The Court reiterated that the presumption of innocence does not survive once an accused stands convicted after trial, emphasising that suspension of sentence in cases involving murder convictions must be an exception rather than the rule.

The Court was dealing with an Appeal challenging Orders of the Patna High Court, which had suspended the sentences of two convicts, each sentenced to life imprisonment under Section 302 read with Section 149 of the Indian Penal Code, during the pendency of their Criminal Appeals.

Cause Title- Rajesh Upadhyay v. The State of Bihar & Anr (Neutral Citation: 2025 INSC 1468)

Date of Judgment- December 18, 2025

Coram- Justice Manmohan and Justice NV Anjaria

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36) Dominant nature of duties determines ‘workman’ status under Industrial Disputes Act, not designation

The Court held that the status of an employee as a “workman” under Section 2(s) of the Industrial Disputes Act, 1947, must be decided by applying the dominant nature test, which focuses on the principal duties performed and not on the designation assigned by the employer.

The Court was hearing an Appeal challenging the Judgment of the Orissa High Court, which had set aside an award of the Labour Court reinstating the appellant with back wages after holding his termination to be illegal under the Industrial Disputes Act.

Cause Title- Srinibas Goradia v. Arvind Kumar Sahu & Ors. (Neutral Citation: 2025 INSC 1467)

Date of Judgment- December 17, 2025

Coram- Justice Prashant Kumar Mishra and Justice N. V. Anjaria

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37) Supreme Court issues directions for conservation of Great Indian Bustard; approves restrictions on future renewable energy projects in Rajasthan

The Court issued certain directions for the conservation of Great Indian Bustard (GIB) i.e., ‘Godawan’, the State bird of Rajasthan.

GIB is one of the heaviest flying birds in the world and a flagship species of the arid and semi-arid grasslands of the Indian subcontinent and is a majestic, long-legged bird that symbolizes the health of the fragile grassland ecosystem, as its presence indicates a balanced environment.

Cause Title- M.K. Ranjitsinh & Others v. Union of India & Others (Neutral Citation: 2025 INSC 1472)

Date of Judgment- December 19, 2025

Coram- Justice P.S. Narasimha and Justice Atul S. Chandurkar

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38) Child trafficking & sexual exploitation strike at very foundation of state’s constitutional promise: Supreme Court lays down parameters to assess victim’s evidence

While upholding the conviction of a man and his wife in a case of child trafficking and sexual exploitation, the Court laid down guidelines and parameters for the Courts to follow while appreciating the evidence of a minor victim of trafficking.

The Court also held that such offences strike at the very foundations of dignity, bodily integrity and the State’s constitutional promise of protection to every child against exploitation leading to moral and material abandonment. The Court was considering an Appeal challenging the conviction of a man and his wife under the IPC & Immoral Traffic (Prevention) Act, 1956.

Cause Title- K.P. Kirankumar @ Kiran v. State by Peenya Police (Neutral Citation: 2025 INSC 1473)

Date of Judgment- December 19, 2025

Coram- Justice Manoj Misra and Justice Joymalya Bagchi

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39) High Court u/s 482 CrPC cannot conduct roving enquiry at pre-trial stage to ascertain whether cheque was issued for discharge of debt not merited

While restoring a cheque bounce complaint on the file of the concerned Magistrate, the Court held that the High Court’s roving enquiry, at the pre-trial stage to ascertain whether the cheque was issued for the discharge of debt or liability is not merited in exercise of power under Section 482 of the Code of Criminal Procedure.

The Court was considering an Appeal filed against an Order of the Patna High Court quashing the entire proceedings arising out of a criminal complaint case registered under the Negotiable Instruments Act, 1881.

Cause Title- M/S Sri Om Sales v. Abhay Kumar @ Abhay Patel (Neutral Citation: 2025 INSC 1474)

Date of Judgment- December 19, 2025

Coram- Justice Manoj Misra and Justice Ujjal Bhuyan

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40) High Courts must uphold principles of equality and fairness in their administrative actions

The Court held that High Courts, being Constitutional Courts entrusted with upholding equality, fairness and the rule of law, are expected to exemplify these values in their own administrative functioning.

The Court was hearing a batch of Appeals arising from the denial of regularisation and consequent discontinuance of services of several employees engaged as Operator-cum-Data Entry Assistants and Routine Grade Clerks in the Allahabad High Court, despite similarly placed employees having been regularised.

Cause Title- Ratnank Mishra & Ors. v. High Court of Judicature at Allahabad Through Registrar General (Neutral Citation: 2025 INSC 1477)

Date of Judgment- December 19, 2025

Coram- Justice J.K. Maheshwari and Justice Vijay Bishnoi

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41) Any embroidery found on witness testimony can’t be a ground for throwing prosecution case overboard: Supreme Court upholds murder conviction

While upholding the conviction in 2007 murder case, the Court reiterated that any embroidery found cannot per se be a ground for throwing the prosecution case overboard, if there is a ring of truth in the main.

The Court was hearing a batch of Criminal Appeals challenging the Judgment of the Madras High Court, by which the accused persons were convicted under Section 302 read with Sections 34, 148, and 341 of the Indian Penal Code, 1860 (IPC).

Cause Title- Patchaiperumal @ Patchikutti & Anr. v. State Rep. by Inspector of Police & Anr. (Neutral Citation: 2025 INSC 1478)

Date of Judgment- December 19, 2025

Coram- Justice Dipankar Datta and Justice Augustine George Masih

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42) Directing time-bound investigation must remain exception rather than norm

The Court set aside a direction granting protection from arrest to the accused persons till the taking of cognisance by the concerned court. This direction of the Allahabad High Court was passed while disposing of a Petition for quashing. The Court also reaffirmed that directing a time-bound investigation must remain the exception rather than the norm.

The State of Uttar Pradesh filed an Appeal challenging the Judgment and Orders of the Allahabad High Court in Petitions for quashing preferred by the accused persons in a case registered under Sections 420, 467, 468, and 471 of the Indian Penal Code, 1860 and Sections 3, 25, and 30 of the Arms Act 1959.

Cause Title- State of U.P. v. Mohd Arshad Khan (Neutral Citation: 2025 INSC 1480)

Date of Judgment- December 19, 2025

Coram- Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh

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43) May adversely impact operational efficacy: Supreme Court upholds dismissal of CISF constable for his second marriage during subsistence of first marriage

While observing that the possibility of domestic discord, financial vulnerability or divided responsibilities has the potential to adversely impact operational efficacy, the Court restored the Order of the disciplinary authority dismissing a CISF Constable for contracting a second marriage during the subsistence of the first one.

The Court was considering an Appeal filed by the Union of India.

Cause Title- Union of India v. Pranab Kumar Nath (Neutral Citation: 2025 INSC 1479)

Date of Judgment- December 19, 2025

Coram- Justice Sanjay Karol and Justice Vipul M. Pancholi

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44) Non-compete fee paid by assessee is allowable revenue expenditure u/s 37(1) Income Tax Act

The Court held that a non-compete fee paid by an assessee is an allowable revenue expenditure under Section 37(1) of the Income Tax Act, 1961 (ITA).

The Court held thus in a batch of Civil Appeals in which the perennial question that arose was whether an expenditure incurred by an assessee is capital or revenue. The core issue which arose for consideration was whether non-compete fee paid by the assessee is a revenue expenditure or capital expenditure.

Cause Title- Sharp Business System v. Commissioner of Income Tax-III N.D. (Neutral Citation: 2025 INSC 1481)

Date of Judgment- December 19, 2025

Coram- Justice Manoj Misra and Justice Ujjal Bhuyan

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45) Policy decisions in form of circulars bind government though executive in nature

The Court held that any action taken in derogation of a policy, without amendment or valid justification, is arbitrary and violative of Article 14 of the Constitution of India.

The Court was considering an Appeal against an Order passed by a Division Bench of the High Court by which the Order passed by the Single Judge was set aside. The Single Judge had quashed a notification by which two newly created revenue villages were named after the individuals who donated land.

Cause Title- Bhika Ram & Anr. v. State of Rajasthan & Ors. (Neutral Citation: 2025 INSC 1482)

Date of Judgment- December 19, 2025

Coram- Justice Sanjay Kumar and Justice Alok Aradhe

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46) Monetary and financial dominance of husband cannot qualify as cruelty: Supreme Court quashes criminal proceedings u/s. 498A IPC

The Court observed that the monetary and financial dominance of the husband cannot qualify as an instance of cruelty, especially in the absence of any tangible mental or physical harm caused.

The Court said that the allegation that the husband forced his wife to maintain an Excel sheet of all the expenses cannot come under the definition of cruelty.

Cause Title- XXXX v. State of Telangana and Anr. (Neutral Citation: 2025 INSC 1471)

Date of Judgment- December 19, 2025

Coram- Justice BV Nagarathna and Justice R Mahadevan

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47) Section 15A SC-ST Act guarantees opportunity to be heard, not a right to favourable outcome of every objection raised by victim

The Court held that Section 15A of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 ('SC/ST Act') guarantees an opportunity to be heard, not a right to a favourable outcome or to a detailed adjudication of every objection raised by the victim.

The Court also observed that by issuing a direction for a joint trial at the stage of consideration of bail, the High Court pre-empted and curtailed the statutory discretion vested in the trial Court, and the grant of such a substantive procedural direction at the bail stage travels beyond the limited scope of bail jurisdiction.

Cause Title- Lakshmanan v. State Through The Deputy Superintendent of Police & Ors. (Neutral Citation: 2025 INSC 1483)

Date of Judgment- December 19, 2025

Coram- Justice BV Nagarathna and Justice R Mahadevan

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48) Power u/s. 311 CrPC to be exercised only when evidence sought is indispensable for arriving at truth: Supreme Court disallows examination of minor witness at advanced stage of trial

The Court reiterated that the power under Section 311 of the Criminal Procedure Code should be exercised only when evidence sought is indispensable for arriving at truth.

The Court was considering an Appeal against a judgement of the High Court whereby it allowed the Application filed under Section 311 of the Code of Criminal Procedure,1973, permitting the prosecution to examine the minor child as a witness.

Cause Title- Mayankkumar Natwarlal Kankana Patel & Anr. v. State of Gujarat and Anr. (Neutral Citation: 2025 INSC 1475)

Date of Judgment- December 19, 2025

Coram- Justice Vikram Nath and Justice Augustine George Masih

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49) Passport renewal cannot be denied solely due to pending criminal proceedings when courts permit it

The Court held that a passport authority cannot refuse to renew a passport merely because criminal proceedings are pending, when the concerned criminal courts have permitted renewal while retaining supervision over the individual's foreign travel.

The ruling came while allowing an Appeal filed against the Regional Passport Office, Kolkata's refusal to renew the Appellant’s passport for the normal ten-year period, despite “no objection” orders passed by the Delhi High Court and the NIA Court, Ranchi.

Cause Title- Mahesh Kumar Agarwal v. Union of India & Anr. (Neutral Citation: 2025 INSC 1476)

Date of Judgment- December 19, 2025

Coram- Justice Vikram Nath and Justice Augustine George Masih

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50) Non-payment of balance sale consideration within time period fixed by trial court doesn't amount to abandonment of contract

The Court asked an Executing Court to proceed in accordance with the law to execute the decree of specific performance pertaining to an agreement to sell. The Court also reiterated that non-payment of balance sale consideration within the time period fixed by the Trial Court does not amount to abandonment of the contract and consequent rescinding of the same.

The Appeal before the Court was filed against a Judgment of the Punjab & Haryana High Court. The dispute pertained to the execution of an agreement to sell between the parties regarding a property located in the District of Panchkula.

Cause Title- Dr. Amit Arya v. Kamlesh Kumari (Neutral Citation: 2025 INSC 1486)

Date of Judgment- December 19, 2025

Coram- Justice Sanjay Karol and Justice Manoj Misra

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51) When criminal revision is at the instance of informant or complainant, proceedings will not abate upon his death

The Court observed that revision proceedings will not abate at the instance of the death of the informant/complainant, but where the revision is at the instance of an accused/convict, the Revisional Court may refuse to continue the proceedings on his death.

The main issue for the consideration of the Court was whether, on the death of the revisionist, the revision proceeding under Section 397 read with Section 401 of CrPC would abate.

Cause Title- Syed Shahnawaz Ali v. The State of Madhya Pradesh & Ors. (Neutral Citation: 2025 INSC 1484)

Date of Judgment- December 19, 2025

Coram- Justice Sanjay Karol and Justice Manoj Misra

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52) Power to grant compensation is separate from power of state medical council to examine medical negligence

The Court clarified that the power to grant compensation is separate and distinct from the power of the State Medical Council (SMC) to examine the presence or absence of medical negligence on the part of a professional.

The Court was deciding a Civil Appeal preferred against the Judgment of Calcutta High Court’s Division Bench, which held that the Commission did not have the jurisdiction to adjudicate issues of negligence and alleged deficiency in practice.

Cause Title- Kousik Pal v. B.M. Birla Heart Research Centre & Ors. (Neutral Citation: 2025 INSC 1487)

Date of Judgment- December 19, 2025

Coram- Justice Sanjay Karol and Justice Manoj Misra

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53) Application seeking mutation cannot be rejected merely because it is based on a will

The Court observed that, under M.P. Land Revenue Code, 1959, an application for mutation based on a will have to be considered on merits and it cannot be rejected merely because it is based on a will.

The Appellant, claiming as a legatee under a registered will, following the death of tenure holder Roda alias Rodilal, sought land mutation for 5.580 hectares under Section 110 of the M.P. Land Revenue Code, 1959.

Cause Title- Tarachandra v. Bhawarlal & Anr. (Neutral Citation: 2025 INSC 1485)

Date of Judgment- December 19, 2025

Coram- Justice Sanjay Karol and Justice Manoj Misra

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