Weekly Overview| Supreme Court Judgments: September 15 – September 19, 2025
1) Prima facie not arbitrary: Supreme Court refuses to stay Waqf (Amendment) Act provision abolishing “Waqf by User”
The Court refused to stay the Waqf (Amendment) Act, 2025 provision that abolishes the concept of “Waqf by User”.
The Court was hearing a batch of Writ Petitions, challenging the validity of several of the Sections of the Amendment Act on the ground of they being ultra vires the Constitution of India being violative of Articles 14, 15, 19, 21, 25, 26, 29, 30, and 300A of the Constitution.
Cause Title- In Re: The Waqf Amendment Act, 2025 (1) (Neutral Citation: 2025 INSC 1116)
Date of Judgment- September 15, 2025
Coram- Chief Justice of India (CJI) B.R. Gavai and Justice Augustine George Masih
2) Criminal law not platform for initiation of vindictive proceedings to settle personal scores & vendettas: Supreme Court quashes cheating case
The Court quashed an FIR registered against 2 men under Section 420 read with Section 120B of the IPC after finding that the FIR was lodged after a delay of nearly five years and suspicion was raised upon the bona fides of the complainant. It further observed that criminal law must not become a platform for the initiation of vindictive proceedings to settle personal scores and vendettas.
The Appeal before the Court arose from an Order of the Himachal Pradesh High Court dismissing the Application filed under Section 482 of the Code of Criminal Procedure, 1973 (CrPC), preferred by the accused-Appellant Paramjeet Singh. The Apex Court was also considering a Writ Petition preferred by the accused-Petitioner, Sarabjit Singh, seeking quashing of the FIR wherein both Paramjeet Singh and Sarabjit Singh were arraigned as accused and charged under Section 420 read with Section 120B of the Indian Penal Code.
Cause Title- Paramjeet Singh v. State of Himachal Pradesh (Neutral Citation: 2025 INSC 1118)
Date of Judgment- September 15, 2025
Coram- Justice B.V. Nagarathna and Justice R. Mahadevan
3) Should contents of video be reduced to transcript in words of witness who created it or noticed in it? Supreme Court answers
The Court observed that it is not the requirement of law that the contents of the video would become admissible only if it is reduced to a transcript in the words of a witness who created the video or is noticed in the video.
The Court observed thus in a Criminal Appeal filed by an accused against the Judgment of the Bombay High Court, which partly allowed his Appeal challenging the Trial Court’s Order of conviction and sentence.
Cause Title- Kailas S/o Bajirao Pawar v. The State of Maharashtra (Neutral Citation: 2025 INSC 1117)
Date of Judgment- September 15, 2025
Coram- Justice Manoj Misra and Justice Ujjal Bhuyan
4) Failure to pay upfront amount under OTS rendered application ineligible to be processed: Supreme Court allows SBI’s appeal
While allowing an Appeal of the State Bank of India, the Court held that the borrower faltered in not adhering to the express terms of the One Time Settlement scheme by not depositing 5% of the outstanding dues as up-front payment, and this rendered its application ineligible to be processed.
The Appeal before the Court was filed against the Judgment passed by a Division Bench of the Andhra Pradesh High Court dismissing an intra-Court Writ Appeal of the Assistant General Manager and the Deputy General Manager of the State Bank of India (SBI).
Cause Title- Assistant General Manager State Bank of India v. Tanya Energy Enterprises (Neutral Citation: 2025 INSC 1119)
Date of Judgment- September 15, 2025
Coram- Justice Dipankar Datta and Justice Augustine George Masih
5) Stranger-purchaser can’t be saddled with liability to prove facts which are within special knowledge of coparceners of HUF
Upholding a Karta’s decision to sell the suit land owing to legal necessity arising out of the daughter’s marriage, the Court held that the onus of proof on the stranger-purchaser cannot run counter to the principle of reverse burden enshrined in Section 106 of the Evidence Act, 1872 and saddle him with the liability to prove facts which are within the special knowledge of the coparceners of the HUF.
The Appeal before the Court was directed against the Judgment of the Karnataka High Court reversing the Judgment of the Principal Civil Judge (Senior Division), Gulbarga, decreeing partition and separate possession of the half share of the suit land in favour of one of the Plaintiff-Respondents.
Cause Title- Dastagirsab v. Sharanappa (Neutral Citation: 2025 INSC 1120)
Date of Judgment- September 16, 2025
Coram- Justice Sandeep Mehta and Justice Joymalya Bagchi
6) A view consistently upheld by courts over long period must be followed unless it is manifestly erroneous, unjust or mischievous
The Court observed that a view consistently upheld by Courts over a long period must be followed, unless it is manifestly erroneous, unjust or mischievous.
The Court observed thus in a Civil Appeal filed by the State of Haryana against the Judgment of the Punjab and Haryana High Court which partly allowed the Writ Petition of proprietors/landowners.
Cause Title- The State of Haryana v. Jai Singh and Others (Neutral Citation: 2025 INSC 1122)
Date of Judgment- September 16, 2025
Coram- Chief Justice of India (CJI) B.R. Gavai, Justice Prashant Kumar Mishra, and Justice K.V. Viswanathan
7) Sec.195-A IPC not on statute book on date of offence; holding accused guilty breach of Article 20(1) Constitution
While considering an Appeal of the claimants of a deceased Court Official, the Court observed that holding an accused guilty under Section 195-A IPC would be a clear breach of clause (1) of Article 20 of the Constitution when Section 195-A was not on the statute book on the date of the offence.
The Appeal before the Court revolved around a deceased public servant who was convicted in a case registered under Sections 305 and 506-B of the Indian Penal Code 1860. The Judgment of conviction and Order on sentence was carried in Appeal before the Madhya Pradesh High Court, but he passed away in the year 2015.
Cause Title- Jameela v. The State of Madhya Pradesh (Neutral Citation: 2025 INSC 1121)
Date of Judgment- September 15, 2025
Coram- Justice Dipankar Datta and Justice Augustine George Masih
8) Judicial system in India & UK “taken for a ride” by mother: Supreme Court upholds grant of child’s interim custody to father
The Court upheld the grant of interim custody of a child to the father, saying that the judicial system in India and United Kingdom (UK) had been taken for a ride by the mother.
The Court was deciding a case involving prolonged discord of ties between the husband and wife who got married in 2010, leading to further dispute on visitation over their two children, minor daughter and minor son.
Cause Title- ABC & Ors. v. XYZ & Ors. (Neutral Citation: 2025 INSC 1123)
Date of Judgment- September 16, 2025
Coram- Justice J.K. Maheshwari and Justice Vijay Bishnoi
9) No evidence to prove kidnapping or last seen theory: Supreme Court acquits convict in murder case
The Court acquitted a murder accused observing that there is no evidence to either prove the kidnapping of the deceased or that he was last seen in the company of the accused.
The Appellant accused was convicted under Sections 302 and 364 of the Indian Penal Code, 1860 and was sentenced to life imprisonment as well as seven years of rigorous imprisonment under Section 201 of the IPC, with the direction that both the sentences would run concurrently. This Judgment and Order of conviction was confirmed by the High Court.
Cause Title- Thammineni Bhaskar v. The State of Andhra Pradesh (Neutral Citation: 2025 INSC 1124)
Date of Judgment- September 17, 2025
Coram- Justice Pankaj Mithal and Justice Prasanna B. Varale
10) In quashing petitions, High Court should also appreciate background in which FIR was filed: Supreme Court quashes FIR u/s. 498A IPC against NRI husband
Quashing an FIR filed under Section 498-A of IPC, the Court ruled that Courts must not adopt a mechanical approach while dealing with criminal complaints, reiterating that judicial scrutiny requires application of mind to the factual background in which the FIR has been lodged, rather than treating the allegations in isolation.
The Court was hearing an Appeal filed against an Order of the Punjab and Haryana High Court, which had dismissed a plea seeking the quashing of an FIR.
Cause Title- XYZ v. The State of Punjab & Anr (Neutral Citation: 2025 INSC 1128)
Date of Judgment- September 18, 2025
Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra
11) Section 451 CrPC | Ownership of seized cash must be determined after considering claims of all victims
The Court set aside an Order of the Gujarat High Court that had directed the release of ₹50 lakh seized during an investigation to a single Complainant, holding that ownership of the money can only be determined after examining the claims of all alleged victims and upon appreciation of evidence during trial.
The Court was hearing an Appeal filed by the accused challenging the High Court’s Order, which had directed the release of the seized cash in favour of one of the complainants, holding him lawfully entitled to the amount.
Cause Title- Rajput Vijaysinh Natwarsinh Vs State Of Gujarat & Ors (Neutral Citation: 2025 INSC 1129)
Date of Judgment- September 18, 2025
Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra
12) Placing genset within steel container & fitting it with additional components for new commodity is ‘manufacture’ under Central Excise Act
The Court held that the process of placing the Genset within the steel container and fitting that container with additional components which brings into existence a new commodity, amounts to ‘manufacture’ under Section 2(f)(i) of the Central Excise Act, 1944 (CEA).
The Court was deciding Civil Appeals preferred by a company, challenging the Final Order of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Ahmedabad.
Cause Title- M/s Quippo Energy Ltd. v. Commissioner of Central Excise Ahmedabad – II (Neutral Citation: 2025 INSC 1130)
Date of Judgment- September 19, 2025
Coram- Justice J.B. Pardiwala and Justice K.V. Viswanathan
13) Will mark a new beginning for Indian football: Supreme Court directs AIFF to adopt draft constitution within 4 weeks
The Court directed the administration of All India Football Federation (AIFF) to adopt the draft Constitution within a period of four weeks.
The Court was hearing Civil Appeals filed against the Order of the Delhi High Court, which set aside the results of the AIFF’s elections on grounds of non-compliance with the sports code and other regulations. It remarked that our country is brimming with promising sporting talent which seeks suitable avenues and organisational support and we need to channelise this talent efficiently – from village fields to international platforms.
Cause Title- All India Football Federation v. Rahul Mehra & Ors. (Neutral Citation: 2025 INSC 1131)
Date of Judgment- September 19, 2025
Coram- Justice P.S. Narasimha and Justice Joymalya Bagchi
14) Cheque bounce demand notice invalid if amount mentioned is different from actual cheque amount
The Court upheld the quashing of a criminal complaint filed under Section 138 of the Negotiable Instruments Act, 1881, and held that when the cheque amount mentioned from demand notice is different from the actual cheque amount, such notice would stand invalid in the eyes of the law.
The Appeals before the Court arose from a Judgment of the Delhi High Court quashing the Criminal Complaint filed by the Respondent under Sections 138, 141 and 142 of the Negotiable Instruments Act, 1881, on the ground that the amount mentioned in the notice was not the same as per the cheque, which rendered the notice invalid.
Cause Title- Kaveri Plastics v. Mahdoom Bawa Bahrudeen Noorul (Neutral Citation: 2025 INSC 1133)
Date of Judgment- September 19, 2025
Coram- Chief Justice Of India B.R. Gavai and Justice N.V. Anjaria