Weekly Overview| Supreme Court Judgments: September 1 – September 5, 2025
1) Rule defining local candidate perfectly in order: Supreme Court upholds Telangana’s 4-yr-domicile rule for MBBS & BDS admissions
The Court upheld the Telangana Medical & Dental Colleges Admission (Admission into MBBS & BDS Courses) Rules, 2017, and its amendment made in the year 2024. The Court affirmed the rule defining a local candidate and mandating that a candidate who has studied in an educational institution in a local area for not less than four consecutive academic years would be entitled to seek admission as a local candidate for admission to the course of study for MBBS and BDS.
In this case, the High Court had expanded the definition to include any student who produced his residence certificate issued by a competent authority of the Government of Telangana.
Cause Title- The State of Telangana v. Kalluri Naga Narasimha Abhiram (Neutral Citation: 2025 INSC 1058)
Date of Judgment- September 1, 2025
Coram- Chief Justice of India B. R. Gavai and Justice K. Vinod Chandran
2) Agreement to sell, general power of attorney or unproved will does not confer any valid title
The Court held that an agreement to sell does not confer a valid title as it is not a deed of conveyance as per Section 54 of the Transfer of Property Act. The Court further held that a power of Attorney as well as a Will surrounded by suspicious circumstances would not confer any valid title.
The Appellants approached the Court challenging the Judgment of the Delhi High Court dismissing their Regular First Appeal. The High Court affirmed the Order whereby the decree in a suit for possession, mesne profits, declaration, and mandatory injunction filed by the Respondent (plaintiff) came to be confirmed, by dismissing the counterclaim for declaration filed by the Appellant.
Cause Title- Ramesh Chand v. Suresh Chand (Neutral Citation: 2025 INSC 1059)
Date of Judgment- September 1, 2025
Coram- Justice Aravind Kumar and Justice Sandeep Mehta
3) Misapplication of "beyond reasonable doubt" principle: Supreme Court flags "loose acquittals" based on minor inconsistencies
The Court cautioned Trial Courts and High Courts to exercise greater sensitivity and judicial awareness while adjudicating cases involving heinous offences, particularly under the Protection of Children from Sexual Offences (POCSO) Act. It stressed that acquittals should not be based solely on trivial discrepancies or procedural technicalities that do not affect the core of the prosecution’s case.
The Judgment arose from an Appeal in a POCSO matter where a High Court had overturned the Trial Court’s conviction of the accused. Restoring the Trial Court’s findings, the Bench issued broader observations aimed at strengthening procedural integrity, ensuring fairness, and safeguarding public trust in the criminal justice system.
Cause Title- ABC v. XYZ (Neutral Citation: 2025 INSC 1061)
Date of Judgment- September 1, 2025
Coram- Justice Sanjay Kumar and Justice Satish Chandra Sharma
4) Rigor of S.19(1) NGT Act can’t be stretched to abandon statutory procedure u/s 21 & 22 of Water Act
The Court held that the rigor of Section 19(1) of the National Green Tribunal Act, 2010 (NGT Act) cannot be stretched to abandon the statutory procedure laid down under Sections 21 and 22 of the Water (Prevention and Control of Pollution) Act, 1974.
The Court held thus in Civil Appeals preferred under Section 22 of the NGT Act, challenging the Orders of the NGT, Principal Bench, New Delhi.
Cause Title- M/s Triveni Engineering and Industries Ltd. v. State of Uttar Pradesh & Ors. (Neutral Citation: 2025 INSC 1060)
Date of Judgment- September 1, 2025
Coram- Justice Manoj Misra and Justice Ujjal Bhuyan
5) No bar on filing cheque bounce complaints u/s. 138 NI Act against "SICK" companies
The Court held that complaints under Section 138 of the Negotiable Instruments Act, 1881, can be filed against companies declared ‘SICK’ under the Sick Industrial Companies (Special Provisions) Act, 1985 (SICA). The Court ruled that the existence of a restraint order under Section 22A of SICA does not, by itself, bar such proceedings; rather, the effect of the restraint order has to be assessed on the facts of each case.
The Court was hearing a batch of Criminal Appeals arising from complaints filed for dishonour of cheques issued by a company declared sick by the Board for Industrial and Financial Reconstruction (BIFR). While the Magistrate had dismissed the accused’s application to recall summons, the revisional Court discharged the accused, and the High Court refused to interfere.
Cause Title- Shree Nagani Silk Mills Pvt. Ltd. v. L.D. Industries Ltd. & Ors. (Neutral Citation: 2025 INSC 1064)
Date of Judgment- September 2, 2025
Coram- Justice Manoj Misra and Justice Ujjal Bhuyan
6) NCLT has full jurisdiction to decide whether gift deed is valid or against Companies Act
The Court held that the National Company Law Tribunal (NCLT) has full jurisdiction to decide whether the gift deed is valid or not, or whether it is against the provisions of the Companies Act, 1956.
The Court was deciding Civil Appeals filed against the Judgment of the National Company Law Appellate Tribunal (NCLAT), which set aside the NCLT’s Judgment.
Cause Title- Shailja Krishna v. Satori Global Limited & Ors. (Neutral Citation: 2025 INSC 1065)
Date of Judgment- September 2, 2025
Coram- Justice Dipankar Datta and Justice K. Vinod Chandran
7) Clause barring interest on delayed payment cannot be inferred as bar to award pendente-lite interest by arbitral tribunal
The Court observed that a clause merely barring award of interest on delayed payment by itself will not be readily inferred as a bar to award pendente-lite interest by the arbitral tribunal.
An Appeal was filed against the Order of High Court whereby the Appeal of the Respondent, under Section 37 of the Arbitration and Conciliation Act, 19962, was allowed, the Judgment and Order of the District Judge under Section 34 of 1996 Act, was set aside and the arbitral award was affirmed.
Cause Title- Oil and Natural Gas Corporation Ltd. V. M/s G&T Beckfield Drilling Services Pvt. Ltd. (Neutral Citation:2025 INSC 1066)
Date of Judgment- September 2, 2025
Coram- Justice P.S. Narasimha and Justice Manoj Misra
8) Child has right to affection of both parents: Supreme Court allows father’s request to interact with minor son living abroad through video-conferencing
The Court came to the aid of a father by allowing his request to interact with his minor son, living in Ireland, through video conferencing. It held that every child has a right to the affection of both parents.
The Appeal before the Court arose from an Order passed by the Punjab & Haryana High Court. The Appellant was a father who approached the Court seeking video interaction with his minor son.
Cause Title- A v. B (Neutral Citation: 2025 INSC 1068)
Date of Judgment- September 2, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
9) Section 18 SC-ST Act creates absolute bar against grant of anticipatory bail to person facing specific accusations
The Court held that Section 18 of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) creates a bar against grant of anticipatory bail in relation to a person facing specific accusations of committing offence under the SC/ST Act.
The Court was hearing a Criminal Appeal filed against the Judgment of the Bombay High Court, Aurangabad Bench which allowed pre-arrest bail to the accused under Section 438 of the Criminal Procedure Code, 1973 (CrPC).
Cause Title- Kiran v. Rajkumar Jivraj Jain & Anr. (Neutral Citation: 2025 INSC 1067)
Date of Judgment- September 1, 2025
Coram- Chief Justice of India (CJI) B.R. Gavai, Justice K. Vinod Chandran, and Justice N.V. Anjaria
10) Jurisdiction to frame new question of law in second appeal is exceptional: Supreme Court summarizes principles regarding Section 100(5) CPC
The Court summed up principles emanating from the precedents on Section 100(5) of the Civil Procedure Code, 1908 (CPC).
The Court was deciding a Civil Appeal filed against the Judgment of the Kerala High Court, which declared a testamentary succession as void.
Cause Title- C.P. Francis v. C.P. Joseph and Others (Neutral Citation: 2025 INSC 1071)
Date of Judgment- September 3, 2025
Coram- Justice Ahsanuddin Amanullah and Justice S.V.N. Bhatti
11) Witness Protection Scheme not a substitute for bail cancellation: Supreme Court criticises Allahabad High Court for passing cyclostyled orders
The Court held that the Witness Protection Scheme, 2018 cannot be treated as an alternative remedy to cancellation of bail under Section 439(2) of the Code of Criminal Procedure, clarifying that bail cancellation is a preventive and supervisory function of the criminal court, exercised to ensure that trials remain unpolluted by intimidation of witnesses or tampering with evidence.
The Court was hearing an Appeal against an Order of the Allahabad High Court, which had declined to consider a bail cancellation application on merits and instead directed the complainant to seek recourse under the Witness Protection Scheme. The complainant had alleged that the accused, released on bail in a murder case, had threatened witnesses in violation of bail conditions.
Cause Title- Phireram v. State of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 1074)
Date of Judgment- September 2, 2025
Coram- Justice J.B. Pardiwala and Justice Sandeep Mehta
12) No direct nexus: Supreme Court dismisses motor accident claimants’ appeal where victim died due to heart attack 5 months after accident
The Court dismissed the Appeal of the claimants in a case of motor accident where the victim died due to a heart attack 5 months after the accident. The Court held that the death could have been the after effect of the surgery, given the medical parameters of the patient and it could not have any direct nexus to the accident.
The Appeals before the Court were filed by the claimants who were the wife, minor child and the mother of an Excise Guard. The Guard died allegedly as a result of a motor vehicle accident.
Cause Title- Haseena v. The United India Insurance Co. Ltd. (Neutral Citation: 2025 INSC 1075)
Date of Judgment- September 4, 2025
Coram- Justice K. Vinod Chandran and Justice N.V. Anjaria
13) Disability to be assessed for awarding motor accident compensation is functional disability which reduces earning capacity & not medical disability
The Court awarded an enhanced compensation of over Rs. 48 lakhs to a man who suffered amputation of one leg and a portion of the pelvic bone due to a motor accident. It held that the disability to be assessed for the purpose of awarding compensation is the functional disability, which reduces the earning capacity of the claimant and not strictly the medical disability.
The Appeals before the Court were filed by the claimant/injured in a motor accident, seeking enhancement of the award.
Cause Title- Anoop Maheshwari v. Oriental Insurance Company Ltd. (Neutral Citation: 2025 INSC 1076)
Date of Judgment- September 4, 2025
Coram- Justice K. Vinod Chandran and Justice N. V. Anjaria