Weekly Overview| Supreme Court Judgments: February 24 – February 28, 2025
1) Supreme Court summarizes principles to deal with cases involving child as witnesses
The Court summarized the principles to deal with the cases in which a child is involved as a witness.
The Court was deciding a Criminal Appeal preferred by the Madhya Pradesh State against the High Court’s Judgment by which it allowed an Appeal of the accused and acquitted him of the offence under Sections 302, 201, and 34 of the Indian Penal Code, 1860 (IPC).
Cause Title- The State of Madhya Pradesh v. Balveer Singh (Neutral Citation: 2025 INSC 261)
Date of Judgment- February 24, 2025
Coram- Justice J.B. Pardiwala and Justice Manoj Misra
2) Motive assumes great significance in a case based on circumstantial evidence: Supreme Court acquits man
The Court while acquitting a man, reiterated that the motive assumes great significance in a case based on circumstantial evidence.
The Court was dealing with a Criminal Appeal filed by the accused against the Judgment of the Gauhati High Court by which his Appeal was dismissed.
Cause Title- Md. Bani Alam Mazid @ Dhan v. State of Assam (Neutral Citation: 2025 INSC 260)
Date of Judgment- February 24, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
3) No absolute bar on Constitutional Courts to examine proportionality of punishment imposed on Member of Legislative Council
The Court while setting aside the expulsion of RJD (Rashtriya Janata Dal) leader Sunil Kumar Singh from the Bihar Legislative Council (BLC), held that there is no absolute bar on the Constitutional Courts to examine the proportionality of the punishment imposed on a member while reviewing the validity of the action taken by the House.
The Court held thus in a Writ Petition filed by Singh, challenging the Report submitted by the Ethics Committee of the BLC, recommending his expulsion as a Member of Legislative Council (MLC). The consequential notification relieving him from the membership of BLC issued by the Secretariat was also assailed.
Cause Title- Dr. Sunil Kumar Singh v. Bihar Legislative Council (Through Secretary) and Ors. (Neutral Citation: 2025 INSC 264)
Date of Judgment- February 25, 2025
Coram- Justice Surya Kant and Justice N. Kotiswar Singh
4) Land reservation shall be deemed to have lapsed if no steps are taken for acquisition within prescribed period under MRTP Act
The Court clarified that if the State does not take steps to acquire reserved land within 10 years of publishing the development plan, and the landowner serves a purchase notice under Section 127 of the MRTP Act, the State must act within one year, or the reservation will lapse.
The Court set aside the impugned Order of the Bombay High Court which held that a person intending to develop their property at the earliest can take recourse of Section 49 otherwise they would have to wait for a period of 10 years as envisaged under Section 127(1) of the Maharashtra Regional and Town Planning Act, 1966 (MRTP Act).
Cause Title- Nirmiti Developers Through Its Partners & Anr. v. The State Of Maharashtra & Ors. (Neutral Citation: 2025 INSC 265)
Date of Judgment- February 25, 2025
Coram- Justice JB Pardiwala and Justice R Mahadevan
5) Invocation of Section 114 Evidence Act not permissible when possibility of mistaken identification cannot be ruled out
The Court held that invocation of Section 114 of the Evidence Act is not permissible when the possibility of mistaken identification cannot be ruled out.
The Court allowed the Appeal filed by the Appellant (Accused no. 3) and set aside his conviction under Sections 120B and 411 of the IPC by the Trial Court. The Court held that the prosecution failed to establish beyond reasonable doubt that the seized 205 gold bars were linked to the fraudulent transactions. It directed that the gold bars be returned to the Appellant.
Cause Title- Hiralal Babulal Soni v. The State Of Maharashtra & Ors. and Connected Matters (Neutral Citation: 2025 INSC 266)
Date of Judgment- February 25, 2025
Coram- Justice BR Gavai, Justice Prashant Kumar Mishra and Justice KV Viswanathan
6) No mandatory minimum procurement right for individual MSE; bodies under MSME Act subject to judicial review
The Court clarified that while an individual MSE does not have a mandatory minimum procurement ‘right,’ authorities under the MSMED Act and the Procurement Order 2012 have a statutorily recognised obligation to implement the mandate, which is subject to judicial review.
The Court had to determine the existence of a ‘right’ of Micro and Small Enterprises (MSE) to supply 25% of goods and services to be procured by the Government and its instrumentalities under its Public Procurement Policy for Micro and Small Enterprises (MSME) Order, 2012 (Procurement Policy).
Cause Title- Lifecare Innovations Pvt. Ltd. & Anr. v. Union Of India & Ors. (Neutral Citation: 2025 INSC 269)
Date of Judgment- February 25, 2025
Coram- Justice Pamidighantam Sri Narasimha and Justice Sandeep Mehta
7) Failure to mention other policies does not amount to material fact in relation to life insurance policy availed: Supreme Court directs insurance company to release all benefits to claimant
The Court directed Exide Life Insurance Company to release all benefits under the life insurance policy to the son of a deceased policyholder and held that failure to mention other policies does not amount to a material fact in relation to the policy availed.
The Appeal before the Court arose out of an order passed by the National Consumer Disputes Redressal Commission, New Delhi, (National Commission) upholding the order the Consumer Disputes Redressal Commission, Rajasthan, Jaipur (State Commission) by which the claim of the appellant was rejected on account of suppression of material facts.
Cause Title- Mahaveer Sharma v. Exide Life Insurance Company Limited & Anr. (Neutral Citation: 2025 INSC 268)
Date of Judgment- February 25, 2025
Coram- Justice B.V. Nagarathna and Justice Satish Chandra Sharma
8) When employee’s services were regularized by granting extraordinary leave, it can’t be then treated as unauthorised leave for denying pensionary benefits
The Court granted pensionary benefits to a Government employee and held that having once regularized her service during the period of absence by granting extraordinary leave, it cannot be held that the said period can be treated as a break in service.
The Court was considering the Appeals arising from the Judgment whereby the High Court dismissed the Writ Petition as well as the Review Application of the Appellant-employee on account of non-prosecution.
Cause Title- Jaya Bhattacharya v. The State of West Bengal & Ors. (Neutral Citation: 2025 INSC 270)
Date of Judgment- February 25, 2025
Coram- Justice B.R. Gavai and Justice Prashant Kumar Mishra
9) S. 197 CrPC does not envisage concept of ‘deemed sanction’- Supreme Court quashes case against public servant
The Court while quashing a case against a public servant, observed that Section 197 of the Criminal Procedure Code, 1973 (CrPC) does not envisage the concept of ‘deemed sanction’.
The Court observed thus in a Criminal Appeal filed by an accused public servant against the Order of the Allahabad High Court which dismissed her Petition seeking to quash a Summoning Order.
Cause Title- Suneeti Toteja v. State of U.P. & Another (Neutral Citation: 2025 INSC 267)
Date of Judgment- February 25, 2025
Coram- Justice B.V. Nagarathna and Justice Satish Chandra Sharma
10) Landlord is the best judge to decide which of his properties should be vacated for his bonafide need; tenant can’t dictate the same
The Court allowed an Appeal of a landlord in an eviction suit and observed that the landlord is the best judge to decide which of his properties should be vacated for satisfying his particular need as alleged in the suit.
The dispute in the Appeal was related to the eviction of the respondents-tenants from the premises in dispute i.e., a house existing in Jharkhand’s Chatra Municipality.
Cause Title- Kanahaiya Lal Arya v. Md. Ehshan & Ors. (Neutral Citation: 2025 INSC 271)
Date of Judgment- February 25, 2025
Coram- Justice Pankaj Mithal and Justice Nongmeikapam Kotiswar Singh
11) Supreme Court upholds Constitutional validity of "power to arrest" provisions under Customs Act & GST Acts
The Court upheld the Constitutional Validity of the provisions regarding the right of the authorised officers to arrest under the Customs Act, 1962 and the Central Goods and Services Tax Act, 2017 (GST Act).
The Court was dealing with a Writ Petition along with connected cases in which the fountainhead of legal controversy regarding the power to arrest under the aforesaid Statutes arose from a decision of the Apex Court in the case of Om Prakash and Another v. Union of India and Another (2011).
Cause Title- Radhika Agarwal v. Union of India and Others (Neutral Citation: 2025 INSC 272)
Date of Judgment- February 27, 2025
Coram- CJI Sanjiv Khanna, Justice M.M. Sundresh, and Justice Bela M. Trivedi
12) Once property is brought into a partnership as capital, it ceases to be trading asset of individual & becomes an asset of the firm
The Court reiterated that once property is contributed as capital in a partnership, it ceases to be the trading asset of the individual partner and becomes the trading asset of the firm, with all partners holding interest in proportion to their share in the joint venture.
The Court dismissed an Appeal filed by the Appellant against the Judgment of the Allahabad High Court which had upheld the decision of the Trial Court declaring that the Property in dispute was solely owned by the partnership firm and its present partners, and not the deceased partner, who had brought it in the property, but had relinquished his rights from the partnership.
Cause Title- Sachin Jaiswal v. M/S Hotel Alka Raje & Ors. (Neutral Citation: 2025 INSC 275)
Date of Judgment- February 27, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
13) Direction of complaint u/s. 156(3) CrPC accompanying affidavit in 'Priyanka Srivastava' Judgment has no retrospective effect
The Court held that the direction in Priyanka Srivastava v. State of UP (2015) requiring a complaint under Section 156(3) of the CrPC to be accompanied by an affidavit is prospective in nature and will not have any retrospective application.
The Court dismissed the Appeals challenging the Order of the Calcutta High Court which dismissed the Criminal Revisions filed by the Appellant for quashing the FIRs registered against them under Sections 120B, 420, 467, 468, 469 and 471 of the IPC read with Section 66A (a)(b)(c) of the Information Technology Act, 2000 (IT Act). The Court upheld the High Court's view that the directions in Priyanka Srivastava (supra) regarding affidavits under Section 156(3) of the CrPC apply prospectively unless expressly stated otherwise.
Cause Title- Kanishk Sinha & Anr. v. The State Of West Bengal & Anr. (Neutral Citation: 2025 INSC 278)
Date of Judgment- February 27, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
14) Mere existence of disputed question of fact won’t take away jurisdiction of Writ Court in granting appropriate relief
The Court held that mere existence of the disputed question of fact, by itself, does not take away the jurisdiction of the Writ Court in granting an appropriate relief.
The Court held thus in Civil Appeals preferred against the common Judgment of the Telangana High Court by which the Writ Appeals of the State were allowed and the Single Judge’s decision was set aside.
Cause Title- M/S A.P. Electrical Equipment Corporation v. The Tahsildar & Ors. Etc. (Neutral Citation: 2025 INSC 274)
Date of Judgment- February 27, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
15) Will findings on title in suit of injunction simpliciter operate as res judicata in subsequent suit?: Supreme Court explains
The Court observed that where a finding on an issue of title is not necessary for deciding the question of possession and the grant of an injunction, or where no issue on title has been framed to decide a suit for injunction, any observation or decision on title would be incidental and collateral and will not operate as res judicata.
The Court observed thus in Civil Appeals challenging the Judgment of the Karnataka High Court which affirmed the Common Judgment of the Sessions Court.
Cause Title- M.S. Ananthamurthy & Anr. v. J. Manjula Etc. (Neutral Citation: 2025 INSC 273)
Date of Judgment- February 27, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
16) Presumption u/s. 20 PC Act cannot arise on mere allegation of demand & acceptance of illegal gratification
The Court reiterated that the presumption under Section 20 of the PC Act cannot arise on the mere allegation of a demand and acceptance of illegal gratification.
The Court allowed the Appeal filed by Dileepbhai Nanubhai Sanghani (Appellant), a former Minister in the Government of Gujarat, setting aside the criminal proceedings initiated against him under the Sections 7, 8, 13(1)(a), 13(1)(d) and 13(2) of the Prevention of Corruption Act, 1988 (the Act). The Court held that proof of demand (or an offer) and acceptance of illegal gratification by a public servant is a fact in issue in the criminal proceeding and is a sine qua non to establish the guilt of the accused public servant under Sections 7 and 13 of the Act.
Cause Title- Dileepbhai Nanubhai Sanghani v. State of Gujarat & Anr. (Neutral Citation: 2025 INSC 280)
Date of Judgment- February 27, 2025
Coram- Justice Sudhanshu Dhulia and Justice K Vinod Chandran
17) Supreme Court dismisses MSRTC’s Appeal; upholds Industrial Court's Order declaring 2015 pay revision unfair
The Court dismissed Maharashtra State Road Transport Corporation’s (MSRTC) Appeal, upholding the Industrial Court’s decision that the 2015 wage revision for workmen amounted to an unfair labour practice by canceling benefits granted in 2010.
The Complaints were based on the claim that the wage revision Order had canceled the earlier wage fixation and constituted an unfair labour practice under the Maharashtra Recognition of Trade Union and Prevention of Unfair Labour Practices Act, 1971. The Appeal stemmed from the Bombay High Court’s refusal to interfere with the Industrial Court’s Order, which had allowed the Complaints filed by the workmen. The Court dismissed the Appeals, upholding the decisions of the Industrial Court and the High Court.
Cause Title- Maharashtra State Road Transport Corporation v. Subhash & Connected Matters (Neutral Citation: 2025 INSC 279)
Date of Judgment- February 27, 2025
Coram- Justice Sudhanshu Dhulia and Justice K Vinod Chandran
18) All necessary parties must be heard before decision is taken: SC upholds Order allowing deceased plaintiff’s daughter to be impleaded as defendant in suit for possession
The Court upheld the Orders of the Trial Court and the High Court allowing the deceased plaintiff’s daughter to be impleaded as a party defendant in a civil suit for recovery of possession and observed that all necessary parties must be heard before a decision is taken by the Court.
The Appeal before the Court was filed at the instance of the Appellant, who appeared in person and was aggrieved by the Judgment of the Madras High Court.
Cause Title- Pappammal (Died) Through Lr R. Krsna Murtii v. Jothi & Anr (Neutral Citation: 2025 INSC 277)
Date of Judgment- February 27, 2025
Coram- Justice Sudhanshu Dhulia and Justice Prashant Kumar Mishra
19) No separate notification u/s.4 of Maharashtra Slum Act required for censused slum: Supreme Court dismisses Appeal filed by transit camp tenants occupying slum area
The Court dismissed the Appeals filed by transit camp tenants occupying a slum area which is in the redevelopment process and held that the project related to a ‘censused slum’ and no notification declaring it to be a slum area was required to be issued under section 4 of the Maharashtra Slum Areas (Improvement, Clearance and Redevelopment) Act, 1971. It held that the Appellants had only been using dilatory tactics to delay the project as they were found to be ineligible slum dwellers since they were transit camp tenants who were given transit accommodation during the widening of the Western Express Highway.
The Appeals before the Apex Court challenged the Order of the Bombay High Court dismissing a Writ Petition filed against a notice issued by the Slum Rehabilitation Authority (SRA), directing the Appellants to vacate their respective premises located in the plot of land in question as the same was to be redeveloped.
Cause Title- Mansoor Ali Farida Irshad Ali & Others v. The Tahsildar¬i, Special Cell & Others (Neutral Citation :2025 INSC 276)
Date of Judgment- February 27, 2025
Coram- Justice Sudhanshu Dhulia and Justice Krishnan Vinod Chandran
20) Consequences very drastic: Supreme Court sets aside ‘illegal’ ex-parte stay on discharge order against Sikh leader in ex-MLC Trilochan Wazir's murder case
The Court quashed the “illegal” ex-parte stay on the discharge Order against Sudershan Singh Wazir in Ex-MLC Trilochan Wazir’s murder case. The Court set aside the Order passed by the Delhi High Court wherein the State’s Application under Section 390 of the Cr.P.C. was allowed.
The High Court had held that as the Order of discharge was no longer operative, the status of the Appellant as an accused had been restored, and therefore, could be taken into custody.
Cause Title- Sudershan Singh Wazir v. State (NCT of Delhi) & Ors. (Neutral Citation: 2025 INSC 281)
Date of Judgment- February 28, 2025
Coram- Justice Abhay S Oka and Justice Ujjal Bhuyan
21) Borrower of a project loan for a profit generating activity does not qualify as a consumer under Consumer Protection Act
The Court held that the borrower of a project loan for a profit generating activity does not qualify as a consumer under the Consumer Protection Act.
The Court set aside the Order of the National Consumer Disputes Redressal Commission (NCDRC) which had held that the Central Bank of India (Appellant/Bank) was “grossly negligent and deficient in providing banking services” to M/S Ad Bureau Advertising Pvt. Ltd. (Respondent/Company) which had availed the loan to engage in the post-¬production of the movie ‘Kochadaiyaan’.
Cause Title- Chief Manager, Central Bank Of India & Ors. v. M/S Ad Bureau Advertising Pvt. Ltd & Anr. (Neutral Citation: 2025 INSC 288)
Date of Judgment- February 28, 2025
Coram- Justice Sudhanshu Dhulia and Justice Prashant Kumar Mishra
22) Prima facie case should be looked into by HC while considering grant of leave u/s. 378(3) CrPC
The Court held that a prima facie case should be looked into by a High Court at the stage of considering grant of leave under Section 378(3) of the CrPC. The Court set aside the Bombay High Court’s Order that had declined to grant leave under sub-section (3) of Section 378 of the CrPC to appeal against the Acquittal of the accused in a Murder Case.
The Court granted leave to the brother of the deceased (Appellant) to Appeal against the Judgment of the High Court that held, “We do not notice any perversity in the reasoning of the trial court, to warrant any interference in this Appeal against Acquittal.”
Cause Title- Manoj Rameshlal Chhabriya v. Mahesh Prakash Ahuja & Anr. (Neutral Citation: 2025 INSC 282)
Date of Judgment- February 27, 2025
Coram- Justice JB Pardiwala and Justice R Mahadevan
23) Not enough to find comfort solely in growing number of female judicial officers if unable to secure sensitive work environment for them
The Court while setting aside the termination Orders against female Civil Judges from the Madhya Pradesh State, remarked that it is not enough to find comfort solely in the growing number of female Judicial Officers if we are unable to secure a sensitive work environment for them.
The Court was deciding a batch of Writ Petitions filed by two female Judicial Officers namely Sarita Choudhary and Aditi Kumar Sharma who were terminated from service during their probation period.
Cause Title- Sarita Choudhary v. High Court of Madhya Pradesh & Another (Neutral Citation: 2025 INSC 289)
Date of Judgment- February 28, 2025
Coram- Justice B.V. Nagarathna and Justice N. Kotiswar Singh
24) No proof linking minor as actual driver of offending vehicle: Supreme Court upholds motor accident compensation
Finding no substantive or direct evidence establishing the involvement of a minor in a road accident case, the Court absolved him and asked the Insurance Company to the pay the quantum of compensation to the claimants.
The Court was considering an Appeal against the Judgment arising out of an Application filed by the Respondents-Claimants seeking enhancement of compensation and another application filed by the Appellants/Owner of Vehicle. The Karnataka High Court partly allowed the Appeal filed by the Respondents-Claimants and dismissed the Appeal filed by the Appellants/Owner.
Cause Title- Sachin Yallappa Usulkar & Ors. v. Vijayata & Ors. (Neutral Citation: 2025 INSC 290)
Date of Judgment- February 28, 2025
Coram- Justice B. V. Nagarathna and Justice Satish Chandra Sharma
25) Serious allegations of misuse of official position: Supreme Court refuses to quash FIR against former IAS Officer
The Court dismissed former IAS Officer Pradeep N. Sharma’s Appeal seeking quashing of the FIR but allowed his Appeal for anticipatory bail in the land allotment case noting the serious allegations of misuse of official position against him.
The Court upheld Gujarat High Court’s Order dismissing the Appellant’s prayer for quashing the FIR registered against him under Sections 409, 219 and 114 of the IPC. The FIR was lodged by the Mamlatdar Office (complainant), alleging that Sharma, in his capacity as District Collector, had wrongfully restored government land to private allottees despite their ineligibility.
Cause Title- Pradip N. Sharma v. State Of Gujarat & Anr. (Neutral Citation: 2025 INSC 291)
Date of Judgment- February 28, 2025
Coram- Justice Vikram Nath and Justice Prasanna B Varale
26) Jurisdiction u/s. 439 CrPC is limited to grant or refusal of bail: Supreme Court sets aside Allahabad HC Order directing NCB to pay 5l compensation to NDPS accused
The Court set aside an Order of the Allahabad High Court whereby the Director of Narcotics Control Bureau was asked to pay a sum of Rs 5 lakh as compensation to the respondent for the alleged wrongful confinement.
The Court reiterated that the jurisdiction conferred upon a Court under Section 439 CrPC is limited to grant or refusal of bail pending trial. The Appeal before the Court was filed by the Union of India, through NCB, challenging the Order of the Allahabad High Court.
Cause Title- Union of India Thr. I.O. Narcotics Control Bureau v. Man Singh Verma (Neutral Citation: 2025 INSC 292)
Date of Judgment- February 28, 2025
Coram- Justice Sanjay Karol and Justice Manmohan
27) In motor accident compensation cases, strict rules of evidence used in criminal trials do not apply
The Court awarded enhanced compensation in a motor accident case and reiterated that in such cases, strict rules of evidence used in criminal trials do not apply.
The Court was considering the Appeals challenging the Judgment of the Karnataka High Court, which in turn, was preferred against the Judgment and Order of MACT (Motor Accident Claims Tribunal), Bangalore.
Cause Title- Prabhavathi & Ors. v. The Managing Director, Bangalore Metropolitan, Transport Corporation (Neutral Citation: 2025 INSC 293)
Date of Judgment- February 28, 2025
Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra
28) Section 24A Consumer Protection Act prescribes two years limitation period; but delay can be condoned by recording its reasons
The Court set aside an Order of the National Consumer Disputes Redressal Commission (NCDRC) whereby a Complaint was dismissed on the ground of limitation and explained that the proviso to Section 24-A of the Consumer Protection Act, 1986, provides for the possibility of the Commission condoning delays beyond the period of 2 years by recording its reasons.
The Appeal before the Court was filed under Section 67 of the Consumer Protection Act, 2019, against the Judgment of the NCDRC, New Delhi.
Cause Title- Pushpa Jagannath v. M/s. Sahaj Ankur Realtors & Ors. (Neutral Citation: 2025 INSC 294)
Date of Judgment- February 28, 2025
Coram- Justice Sanjay Karol and Justice Manmohan
29) "No credible evidence at all": Supreme Court sets aside conviction in 1988 murder case
The Court set aside a conviction in murder case, saying that there is no credible evidence at all to connect the accused persons with the death of the deceased.
The Court was dealing with Criminal Appeals filed by the accused persons against the Judgment of the Rajasthan High Court by which it upheld their conviction under Section 302 of the Indian Penal Code, 1860 (IPC).
Cause Title- Abdul Wahid & Anr. v. State of Rajasthan (Neutral Citation: 2025 INSC 295)
Date of Judgment- February 28, 2025
Coram- Justice Pankaj Mithal and Justice Ujjal Bhuyan
30) Supreme Court directs consolidation of FIRs against YouTuber Savukku Shankar; allows investigation to continue
The Court directed that multiple FIRs filed against YouTuber Savukku Shankar be consolidated for investigation while allowing the probe to proceed in the primary FIR registered on May 3, 2024, at the Cyber Crime Police Station, Coimbatore.
The Bench clarified that while the investigation will continue in the May 3 FIR, material and evidence from other FIRs, except for Crime No. 10, should be transferred to the investigating officer handling the primary case. The Court also noted that Crime No. 10 will proceed independently.
Cause Title- A Shankar @ Savukku Shankar v. State of Tamil Nadu (Neutral Citation: 2025 INSC 284)
Date of Judgment- February 24, 2025
Coram- CJI Sanjiv Khanna and Justice Sanjay Kumar
