Weekly Overview| Supreme Court Judgments: January 2 – January 3, 2025
1) A person can’t be deprived of his own property without him being paid adequate compensation
The Court observed that a person cannot be deprived of his property without him being paid adequate compensation in accordance with law for the same.
The Court observed thus in a Civil Appeal preferred against the Judgment of the Karnataka High Court’s Division Bench by which it dismissed the Writ Appeal against the Judgment of a Single Judge.
Cause Title- Bernard Francis Joseph Vaz and Others v. Government of Karnataka and Others (Neutral Citation: 2025 INSC 3)
Date of Judgment- January 2, 2025
Coram- Justice B.R. Gavai and Justice K.V. Viswanathan
2) APTEL failed to consider larger public interest for disposal of huge quantity of waste generated in Delhi: SC upholds MCD’s tariff adoption process for waste-to-energy project
The Court upheld the tariff and bidding process for the WTE project proposed by the MCD while observing that APTEL failed to consider the larger public interest for disposal of the huge quantity of waste generated in the city of Delhi.
The Court quashed the Appellate Tribunal for Electricity (APTEL) Judgment that set aside the orders of the Delhi Electricity Regulatory Commission (DERC). The DERC had dismissed the Petition filed by Waste to Energy Research & Technology Council (WTERT) challenging the authority of the Municipal Corporation of Delhi (MCD/Appellant) to issue the tariff-based bid and Request for Proposal for setting up the Waste to Energy (WTE) project at Narela Bawana, Delhi.
Cause Title- Municipal Corporation Of Delhi v. Gagan Narang & Ors. (Neutral Citation: 2025 INSC 2)
Date of Judgment- January 2, 2025
Coram- Justice B.R. Gavai and Justice K.V. Viswanathan
3) Cheque bounce complaint filed by POA holder maintainable when he has personal knowledge of facts of matter & has been authorized by firm’s proprietor
The Court restored a complaint in a cheque bounce case filed at the instance of a Power Of Attorney Holder of the Firm after noting that he had been duly authorized to so by the sole Proprietor and he also had the personal knowledge of the facts of the matter.
The appeal, before the Court, challenged the final order of the Single Judge of the Allahabad High Court whereby a summoning Order as well as the entire proceedings arising from the complaint case filed by the appellant under Section 138 of the Negotiable Instruments Act, 1881 was quashed.
Cause Title- M/s Naresh Potteries v. M/s Aarti Industries And Another (Neutral Citation: 2025 INSC 1)
Date of Judgment- January 2, 2025
Coram- Justice B.R. Gavai and Justice K.V. Viswanathan
4) MACT can look into police records made available before it while considering question regarding negligence in motor accident cases
The Court observed that the question regarding negligence is essential for passing an award in a motor vehicle accident claim and the same should be considered based on the evidence available before the Tribunal.
The Court made such an observation while adjudicating upon an Appeal pertaining to a motor accident case.
Cause Title- ICICI Lombard General Insurance Co. Ltd. v. Rajani Sahoo & Ors (Neutral Citation: 2025 INSC 6)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Rajesh Bindal
5) Writ jurisdiction can be invoked to quash criminal proceedings: Supreme Court quashes FIR against foreign national
The Court quashed an FIR against a foreign national in an alleged misappropriation and fraud case while observing that writ jurisdiction can be invoked to quash criminal proceedings.
The Court set aside the Order of the Allahabad High Court refusing to quash an FIR against the Project Manager (Appellant) of Hyundai Engineering & Construction India LLP (HEC India LLP) under Sections 406, 420, 323, 504, 506 and 120-B of the IPC.
Cause Title- Kim Wansoo v. State of Uttar Pradesh & Ors. (Neutral Citation: 2025 INSC 8)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Kumar
6) Mere registration of a will would not attach to it a stamp of validity
The Court reiterated that mere registration of a Will would not attach to it a stamp of validity.
The Court upheld the Madras High Court’s Judgment which dismissed an Appeal by declining to accept that the execution of the disputed Will was not proved. The Bench upheld the concurrent findings of both the Trial Court and the High Court, which found the will to be “shrouded with suspicious circumstances.”
Cause Title- Leela & Ors. v. Muruganantham & Ors. (Neutral Citation: 2025 INSC 10)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Rajesh Bindal
7) State Govt's consent not required to register FIR by CBI for offence under Central Act merely because Central Govt employee works within State's territory
The Court observed that the consent from the State Government is not required to register an FIR by the CBI in connection with an offence under a Central Act, merely because Central Government employee/Central Government Undertaking employee works within the territory of a particular State.
The Court observed thus in Criminal Appeals filed by the Central Bureau of Investigation (CBI) against the common Judgment of the Andhra Pradesh High Court.
Cause Title- The State, Central Bureau of Investigation v. A. Satish Kumar & Ors. (Neutral Citation: 2025 INSC 11)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Rajesh Bindal
8) Power to grant bail should be subject to embargo put in by specific provision under special enactment: SC sets aside bail order in MCOCA case
The Court set aside the bail order passed in favour of 2 accused persons booked under the Maharashtra Control of Organized Crime Act, 1999. It clarified that when there is an embargo put in by a specific provision under a special enactment in the matter of grant of bail in respect of offences allegedly committed thereunder, the power to grant bail should necessarily be subject to satisfaction of the conditions mentioned in such specific provision.
The widow of the victim in the Maharashtra Control of Organized Crime Act Case approached the Court with a Special Leave Petition against the Bombay High Court Order granting bail to the accused respondents.
Cause Title- Jayshree Kanabar v. State of Maharashtra & Ors (Neutral Citation: 2025 INSC 13)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Karol
9) Adoption by widow would relate back to date of husband's death: SC while holding gift deed as null & void
The Court held one Gift Deed as null void while applying the Doctrine of Relation Back or Relation Back principle which states that an adoption by a widow would relate back to the date of death of her husband.
The Court was dealing with Civil Appeals preferred against the common Judgment of the Karnataka High Court, Dharwad Bench passed in a case which emanated from Judgment and Decree of the Additional Senior Civil Judge.
Cause Title- Mahesh v. Sangram & Ors. (Neutral Citation: 2025 INSC 14)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Prashant Kumar Mishra
10) Holding that will is validly executed is not same as holding that it is genuine
The Court observed that holding that a ‘Will is validly executed’ and a ‘Will is genuine’ cannot be said to be the same.
The Court was considering an Appeal challenging the Judgment of the Division Bench of the Bombay High Court as per which it reversed the judgment of a Single Judge in a Testamentary Suit.
Cause Title- Lilian Coelho & Ors.v. Myra Philomena Coalho (Neutral Citation: 2025 INSC 7)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sudhanshu Dhulia
11) Litigant not entitled to be heard & seek any relief if he doesn’t come to Court with clean hands
The Court reiterated that a litigant is not entitled to be heard and seek any relief if he/she does not come to the Court with clean hands.
The Court reiterated thus in Civil Appeals filed against the common Judgment of the Karnataka High Court by which it dismissed the Writ Appeals.
Cause Title- M/s. Maxim India Integrated Circuit Design (P) Ltd. v. Andappa (D) By LRs. & Ors. (Neutral Citation: 2025 INSC 17)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Kumar
12) ‘Lease’ & ‘allotment’ are different; person who got possession of land via lease can’t be heard to challenge title or ownership of Panchayat
The Court reiterated that, ‘lease’ and ‘allotment’ are different and a person who got possession of a land by way of lease cannot be heard to challenge the title or ownership of the Panchayat concerned.
The Court was deciding a batch of Special Leave Petitions (SLPs) involving a common question that whether the lands were Shamlat deh, allotted (if at all allotment was there) on quasi-permanent basis to displaced person(s) or whether they were Shamlat deh otherwise transferred to any person by sale or by any other manner whatsoever after commencement of Punjab Village Common Lands (Regulation) Act, 1961.
Cause Title- Dalip Ram v. The State of Punjab & Ors. (Neutral Citation: 2025 INSC 12)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Rajesh Bindal
13) Motor accident compensation| Monthly income can be based on tax returns, provided the tax payment details are appropriately brought into evidence
The Court held that the monthly income for calculating motor accident compensation can be based on tax returns, provided the tax payment details are appropriately brought into evidence.
The Court dismissed the Appeal by the New India Assurance Co. Ltd. (Insurance Company) challenging the enhanced compensation awarded by the Madras High Court in a motor vehicle accident case involving the death of three out of four family members. The Bench said that the enhancement of compensation by the High Court for the Claimant (Legal Heir), who lost her parents and younger brother in the accident, was not excessive.
Cause Title- New India Assurance Co. Ltd. v. Sonigra Juhi Uttamchand (Neutral Citation: 2025 INSC 15)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Karol
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14) Written Complaint by Public Servant is mandatory for taking cognizance of offence u/s 186 IPC
The Court held that a written Complaint by a Public Servant is mandatory before the Court takes cognizance of an offence punishable under Section 186 of the Indian Penal Code (IPC).
The Court held thus in a Criminal Appeal filed against the Judgment of the Allahabad High Court by which a plea for quashing the chargesheet, Order taking cognizance and issuing summons, and the proceedings under Sections 353 and 186 of IPC, was rejected.
Cause Title- B.N. John v. State of U.P. & Anr. (Neutral Citation: 2024 INSC 4)
Date of Judgment- January 2, 2025
Coram- Justice B.V. Nagarathna and Justice N. Kotiswar Singh
15) Article 226 Constitution| HCs cannot reappreciate evidence or make factual findings unless authorities below exceeded their jurisdiction or acted perversely
The Court held that High Courts, under Article 226 of the Constitution, cannot reappreciate the evidence or make factual findings unless the authorities below have exceeded their jurisdiction or acted perversely.
The Court allowed the Appeal challenging the decision of the Allahabad High Court that set aside an Order based on the concurrent findings of law and facts. The Bench had to determine whether the concurrent findings recorded by the Additional District Magistrate and Additional Commissioner could be interfered with by the High Court in a Writ jurisdiction under Article 226 of the Constitution.
Cause Title- Ajay Singh v. Khacheru & Ors. (Neutral Citation: 2025 INSC 9)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Karol
16) Testimony of attesting witness stating that he had seen testator affix his mark on will would ensure compliance of Section 63(c) of Indian Succession Act
The Court observed that the testimony of the attesting witness stating that he had seen the Testator affix his mark on the Will would ensure sufficient compliance of Section 63(c) of the Indian Succession Act.
The Court was considering an Appeal against the judgment of the Punjab and Haryana High Court whereby it was held that the Will, subject matter of controversy, allegedly of one Sanjhi Ram, had not been proved, thereby finding that the Lower Appellate Court had erred in holding otherwise.
Cause Title- Gopal Krishan & Ors.v. Daulat Ram & Ors. (Neutral Citation: 2025 INSC 18)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Karol
17) Application of force must be with intent to outrage modesty of woman u/s 354 IPC: SC quashes case against accused
The Court quashed a case under Section 354 of the Indian Penal Code (IPC) against the accused, noting that an application of force must be with an intent to outrage the modesty of woman.
The Court was deciding a Criminal Appeal preferred against the Judgment of the Allahabad High Court by which the accused’s request to quash the chargesheet and proceedings under Sections 354 and 506 of IPC was turned down.
Cause Title- Naresh Aneja @ Naresh Kumar Aneja v. State of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 19)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Karol
18) Supreme Court quashes gift deed executed by senior citizen in favour of son after conditions for her maintenance were not complied with
The Court quashed a Gift Deed executed by a Senior citizen in favour of her son after conditions for her maintenance were not complied with.
The Court set aside the decision of the Division Bench of the High Court which set aside the Order of the Single Bench holding that there was no condition for maintenance of the transferor in the Gift Deed.
Cause Title- Urmila Dixit v. Sunil Sharan Dixit & Ors. (Neutral Citation: 2025 INSC 20)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Karol
19) Section 174A IPC is an independent & substantive offence that can continue even if proclamation u/s 82 CrPC is extinguished
The Court held that Section 174A of the IPC is an independent, substantive offence, that can continue even if the proclamation under Section 82 of the Cr.P.C. is extinguished.
The Court explained that while the proceedings under Section 174A of the IPC cannot be initiated independent of Section 82 of the Cr.P.C., (post the issuance of proclamation) they can continue if the said proclamation is no longer in effect.
Cause Title- Daljit Singh v. State Of Haryana & Anr. (Neutral Citation: 2025 INSC 21)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Karol
20) Sections when put into chargesheet, can’t be based on bald assertions of connivance: SC closes cheating case against M.P. Housing Board official
The Court closed an FIR registered against an Official of the Madhya Pradesh State Housing Board in a cheating & forgery case while observing that Sections when put into a chargesheet, cannot be based on bald assertions of connivance. There must be a substance.
Impugned in the Appeal, before the Court, was the judgment of the Madhya Pradesh High Court in a Criminal Case whereby a petition under Section 482 of the Code of Criminal Procedure, 1973 seeking quashing of the First Information Report registered under Sections 419, 420, 467, 468, 471 and 120B r/w 34, Indian Penal Code 1860 against an employee of the Housing Board, was dismissed.
Cause Title- Dinesh Kumar Mathur v. State of M.P. & Anr. (Neutral Citation: 2025 INSC 16)
Date of Judgment- January 2, 2025
Coram- Justice C.T. Ravikumar and Justice Sanjay Karol
21) Statutory incorporation of judicial restraint in interfering with matters relating to arbitration agreement overrides any other law
The Court observed that the statutory incorporation of judicial restraint in interfering with matters relating to an arbitration agreement overrides any other law for the time being in force.
The Court had to determine whether the High Court in its supervisory jurisdiction under Article 227 of the Constitution can grant the claimant an opportunity to cross-examine a witness, despite the Arbitral Tribunal rejecting such a prayer.
Cause Title- Serosoft Solutions Pvt. Ltd. v. Dexter Capital Advisors Pvt. Ltd. (Neutral Citation: 2025 INSC 26)
Date of Judgment- January 3, 2025
Coram- Justice Pamidighantam Sri Narasimha and Justice Manoj Misra
22) IBC is a complete code in itself, having sufficient checks & balances: SC sets aside Karnataka HC Order in Writ Petition interdicting corporate insolvency process
The Court set aside an Order of the Karnataka High Court in a writ petition interdicting the Corporate Insolvency Process. It reiterated that the Insolvency and Bankruptcy Code is a complete code in itself, having sufficient checks and balances, remedial avenues and appeals.
The Appeals before the Court were filed under Article 136 of the Constitution challenging the judgment of the Karnataka High Court exercising power of judicial review interdicting the Corporate Insolvency Process which culminated in the acceptance of a resolution plan by the Committee of Creditors.
Cause Title- Mohammed Enterprises (Tanzania) Ltd. v. Farooq Ali Khan & Ors. (Neutral Citation: 2025 INSC 25)
Date of Judgment- January 3, 2025
Coram- Justice Pamidighantam Sri Narasimha and Justice Manoj Misra
23) Recommendations to be incorporated in constitution of Hyderabad cricket association: Supreme Court refers matter to CJI for tagging it with BCCI case
The Court ordered that the matter involving recommendations made by the Single-Member Committee to be incorporated in the Constitution of Hyderabad Cricket Association be tagged with the case relating to the constitution of the Board of Control for Cricket in India (BCCI).
The Court was considering a batch of Special Leave Petitions assailing the correctness of the judgment passed by the Telangana High Court in a Civil Revision Petition.
Cause Title- M/s The Hyderabad Cricket Association v. M/s Charminar Cricket Club & Anr. (Neutral Citation: 2025 INSC 23)
Date of Judgment- January 3, 2025
Coram- Justice Vikram Nath and Justice Satish Chandra Sharma
24) SC dismisses pleas of Secretary-cum-Administrative Nodal oOfficer seeking extension of time to finalise report of Ratansara village
The Court dismissed the Miscellaneous Applications of the Secretary-cum-Administrative Nodal Officer, Claims Commission, Bhubaneswar, who sought extension of time to finalise the report of village Ratansara.
The Court was dealing with a batch of Miscellaneous Applications seeking a few directions.
Cause Title- Mahanadi Coal Fields Ltd. & Anr. v. Mathias Oram & Ors. (Neutral Citation: 2025 INSC 22)
Date of Judgment- January 3, 2025
Coram- Justice Bela M. Trivedi and Justice Satish Chandra Sharma
25) Only objective of S. 14(2) Arbitration Act 1940 is that parties are aware of award's existence
The Court reiterated that the only objective of Section 14(2) under the Arbitration Act, 1940 is that the parties are aware of the Award’s existence and suggests that this a substantive compliance.
The Court reiterated thus in a Civil Appeal in which the question for consideration was whether the time for filing a Section 17 Application commences when the party seeking to challenge the Award receives a formal notice of the making of the Award, or from the date such party is aware of the existence of the Award.
Cause Title- Krishna Devi @ Sabitri Devi (Rani) v. Union of India & Ors. (Neutral Citation: 2024 INSC 24)
Date of Judgment- January 3, 2025
Coram- Justice P.S. Narasimha and Justice Sandeep Mehta
