Weekly Overview| Supreme Court Judgments: July 21 – July 25, 2025
1) One of the most barbaric instances of police atrocity: Supreme Court grants ₹50L compensation to police constable in custodial torture case; directs CBI probe
The Court granted Rs. 50 lakhs compensation to a police constable who was allegedly tortured when he was in custody and also directed the Central Bureau of Investigation (CBI) to conduct probe into this.
The Court was deciding Criminal Appeals filed against the Judgment of the Jammu and Kashmir and Ladakh High Court, Srinagar, which dismissed the inter-connected Petitions of the victim seeking registration of the FIR against the police personnel, transfer of investigation to CBI, and quashing of FIR against him. Allegedly, the victim's genital organs and testicles were amputated, pepper was sprinkled on his private parts, and he was given electric shocks which led to a fracture of his foot.
Cause Title- Khursheed Ahmad Chohan v. Union Territory of Jammu and Kashmir & Ors. Etc. (Neutral Citation: 2025 INSC 876)
Date of Judgment- July 21, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
2) Supreme Court cancels bail of women’s protection home officer for involvement in sexual exploitation case; says savior turned into devil
The Court cancelled the bail of an Officer in-charge of a women’s protection home in Patna, accused of administering intoxicating medicines to female inmates and subjecting them to sexual exploitation. It also remarked that the person put in the role of a savior had turned into a devil.
The Appeal by special leave emanated from an Order passed by the Patna High Court whereby, the Appeal preferred by Respondent (second accused) under Section 14(A)(2) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 was allowed and she was granted bail in connection with a case registered under Sections 341, 323, 328, 376, 120- B read with Section 34 of the Indian Penal Code, 1860 and Sections 3,4 of the Immoral Traffic (Prevention) Act, 1956 as well as Sections 3(1)(w), 3(2)(va) of the SC/ST Act. The Appellant-victim herein was the informant in the said FIR.
Cause Title- Victim ‘x’ v. State of Bihar And Anr. (Neutral Citation: 2025 INSC 877)
Date of Judgment- July 21, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
3) Anticipatory bail is an exceptional remedy, ought not to be granted routinely
While cancelling the pre-arrest bail of a man for allegedly dispossessing his wife of her lawfully inherited property, the Court reiterated that anticipatory bail is an exceptional remedy and ought not to be granted in a routine manner.
The Appeals before the Court were filed against the Order whereby the accused persons were granted pre-arrest bail in a case registered under Sections 143, 147, 149, 323, 387, 427, 452, 504 and 506 of the Indian Penal Code, 1860.
Cause Title- Nikita Jagganath Shetty @ Nikita Vishwajeet Jadhav v. The State of Maharashtra and another (Neutral Citation: 2025 INSC 878)
Date of Judgment- July 21, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
4) If will is a registered document, there is a presumption regarding its genuineness
The Court held that if a Will is a registered document, there is a presumption regarding genuineness thereof.
The Court held thus in Civil Appeals arising out of rival claims of the legal representatives of the deceased over a chunk of land admeasuring 4 acres and 16 guntas located at village Dasnapur.
Cause Title- Metpalli Lasum Bai (since dead) and Others v. Metapalli Muthaih(D) By LRs. (Neutral Citation: 2025 INSC 879)
Date of Judgment- July 21, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
5) Testimonies of interested witnesses to be met with stricter standard of proof: Supreme Court grants acquittal in murder case
The Court granted acquittal to two accused persons in a case of murder after noting that the presence of the two key witnesses, who were the son and wife of the deceased, at the place of crime was highly contentious. It also observed that the testimonies of the interested witnesses are to be treated with great caution and required to be met with a stricter standard of proof.
The Appeals before the Court were preferred by the accused Appellants against the Judgment of the Madras High Court dismissing the Criminal Appeals preferred by the Appellants and confirming their conviction and sentence in a matter involving Sections 302 and 34 of the Indian Penal Code, 1860.
Cause Title- Esakkimuthu v. State Represented by the Inspector of Police (Neutral Citation: 2025 INSC 880)
Date of Judgment- July 22, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
6) Some confusion at university’s end, required clarity at different stages: Supreme Court upholds conferring of postgraduate degree
The Court regularized the admission of a student to M.Sc. Environmental Management course and asked Dr. Yashwant Singh Parmar, University of Horticulture & Forestry in Himachal Pradesh, to confer the candidate with a postgraduate degree.
The Court noted that there appeared to be some confusion even at the end of the University, which required clarity at different stages. The Appeal was filed by a candidate who had fulfilled the course curriculum, including the minimum required attendance.
Cause Title- Sakshi Chauhan v. Dr. Yashwant Singh Parmar University of Horticulture & Forestry, Nauni & Anr. (Neutral Citation: 2025 INSC 882)
Date of Judgment- July 22, 2025
Coram- Chief Justice Of India B. R. Gavai and Justice Augustine George Masih
7) Supreme Court dissolves marriage of woman IPS officer; orders unconditional apology to be tendered for harassment suffered by husband & his family
While passing an Order for dissolution of marriage, the Supreme Court asked a woman IPS Officer and her parents to tender an unconditional apology to the husband and his family members for the physical and mental harassment caused to them. It noted that due to cases filed by the wife, the husband remained in jail for 109 days and his father for 103 days.
The Transfer Petition before the Court was filed by the wife for the transfer of a case from the Principal Judge, Family Court, Rohini Court, Delhi to the Court of competent jurisdiction at Hapur (Uttar Pradesh). Another Petition was filed by the husband for transfer of the case pending before the CJM, Hapur Court, UP to the competent District Court Rohini in Delhi.
Cause Title- A v. B (Neutral Citation: 2025 INSC 883)
Date of Judgment- July 22, 2025
Coram- Chief Justice Of India B. R. Gavai and Justice Augustine George Masih
8) Doctrine of merger must be accompanied by awareness of its limitations; not to be wielded to close avenues for addressing genuine concerns
The Court emphasized that the application of the Doctrine of Merger, in every case, should be accompanied by an awareness of its limitations and should not be wielded to close avenues for addressing genuine concerns.
The Court emphasized thus in a Civil Appeal filed against the Judgment of the Allahabad High Court, which allowed a Writ Petition.
Cause Title- Vishnu Vardhan @ Vishnu Pradhan v. The State of Uttar Pradesh & Ors. (Neutral Citation: 2025 INSC 884)
Date of Judgment- July 23, 2025
Coram- Justice Surya Kant, Justice Dipankar Datta, and Justice Ujjal Bhuyan
9) Plea of juvenility can be raised before any court at any stage: Supreme Court reiterates
While reiterating that the plea of juvenility can be raised before any Court, the Court upheld the conviction of a rape accused but set aside the sentence imposed by the Trial Court and upheld by the High Court. It referred the matter to the Juvenile Justice Board.
The Appeal before the Court was preferred against an Order passed in the year 1993, whereby the Appellant-accused stood convicted and sentenced under Section 342 of the IPC (wrongful confinement) for a period of 6 months' rigorous imprisonment and under Section 376 (rape) for rigorous imprisonment of 5 years.
Cause Title- Sua v. The State of Rajasthan (Neutral Citation: 2025 INSC 887)
Date of Judgment- July 23, 2025
Coram- Chief Justice of India B. R. Gavai and Justice Augustine George Masih
10) Merely because complainant belongs to scheduled castes or scheduled tribes cannot be the sole ground for prosecution under SC-ST (Prevention of Atrocities) Act
The Court reiterated that merely because the complainant belongs to the Scheduled Castes or Scheduled Tribes cannot be the sole ground for prosecution under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act.
The Appeal before the Court was filed against the Judgment of the Telangana High Court whereby the Petition under Section 482 of Code of Criminal Procedure (CrPC) preferred by Respondents-Accused in a case registered under Section 3(1)(viii), (ix) & (3)(2)(vii) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, (SC/ST Act) was allowed by quashing the said proceedings against them.
Cause Title- Konde Nageshwar Rao v. A. Srirama Chandra Murty & Anr. (Neutral Citation: 2025 INSC 886)
Date of Judgment- July 23, 2025
Coram- Chief Justice of India B. R. Gavai and Justice Augustine George Masih
11) Second quashing petition not maintainable on the same ground that were available to be raised at the time of first petition
The Court observed that the failure of the accused to raise a pertinent ground/plea which was tangibly available to them at the time of adjudication of the first quashing Petition cannot give them a right to file a subsequent quashing Petition.
The Appeal before the Court was filed against the final Judgment of the Madras High Court quashing the complaint registered under Sections 193, 406, 418, 420, 423, 468, 469 read with 34 and 120 of the Indian Penal Code, 1860.
Cause Title- M.C. Ravikumar v. D.S. Velmurugan & Ors. (Neutral Citation: 2025 INSC 888)
Date of Judgment- July 23, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
12) Tamil Nadu Housing Board is custodian of public property: Supreme Court asks litigant to vacate property occupied for over 3 decades without paying balance sum
While observing that the Tamil Nadu Housing Board is a custodian of public property, the Court ordered a litigant to vacate a property occupied for over 3 decades without paying the balance sum.
The Court also affirmed the stand of the Board that the indulgences granted to the litigant had resulted in loss of revenue to the public exchequer. The Appeal before the Court was filed by the Tamil Nadu Housing Board against the Order directing the execution of the sale agreement in the Respondent’s favour.
Cause Title- Tamil Nadu Housing Board, Rep. By Its Managing Director and Ors. v. S. Ganesan (Neutral Citation: 2025 INSC 889)
Date of Judgment- July 21, 2025
Coram- Justice Dipankar Datta and Justice N.V. Anjaria
13) Proper officer is mandatorily required to pass reasoned order under CGST Act regardless of payment of tax & penalty by assessee
The Court held that the Proper Officer is mandatorily required to pass a reasoned Order under the Central Goods and Services Tax Act, 2017 (CGST Act), regardless of payment of tax and penalty by the assessee.
The Court held thus in a Civil Appeal filed by a dealer against the Judgment of the Allahabad High Court.
Cause Title- M/s ASP Traders v. State of Uttar Pradesh & Ors. (Neutral Citation: 2025 INSC 890)
Date of Judgment- July 24, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
14) Under DTAAs, taxing rights of source state over business profits of foreign enterprise are contingent upon existence of permanent establishment
The Court explained that under DTAAs (Double Taxation Avoidance Agreements), the taxing rights of the source State over the business profits of a foreign enterprise are contingent upon the existence of a Permanent Establishment (PE) in the source country.
The Court explained thus in Civil Appeals arising out of a common Judgment of the Delhi High Court in the Income Tax Appeals filed by the assessee in respect of the Assessment Years (AYs).
Cause Title- Hyatt International Southwest Asia Ltd. v. Additional Director of Income Tax (Neutral Citation: 2025 INSC 891)
Date of Judgment- July 24, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
15) Constitutional bar against retrospective imposition of harsher penalty is absolute: Supreme Court sets aside sentence under amended POCSO provision
While upholding the conviction of a man under section 6 of the POCSO Act, the Court set aside the enhanced sentence of imprisonment for the remainder of natural life and modified it to rigorous imprisonment for life. It ruled that the constitutional bar against retrospective imposition of a harsher penalty under Article 20(1) is clear and absolute.
The Appeal before the Court was filed against the Judgment passed by the Chhattisgarh High Court, whereby the Appellant’s Appeal challenging the Judgment of conviction rendered by the Trial Court was dismissed. By the impugned Judgment, the Appellant was convicted under Section 376AB of the Indian Penal Code, 1860 and Section 6 of the Protection of Children from Sexual Offences Act, 2012 and sentenced to imprisonment for life, which meant imprisonment for the remainder of his natural life.
Cause Title- Satauram Mandavi v. The State of Chhattisgarh & Anr. (Neutral Citation: 2025 INSC 892)
Date of Judgment- July 25, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
16) Mental health an integral component of right to life: Supreme Court transfers case involving alleged suicidal death of NEET student at hostel to CBI
The Court transferred a case to the Central Bureau of Investigation (CBI), involving the alleged suicidal death of a 17-year-old female student at a hostel in Vishakhapatnam, Andhra Pradesh, who was preparing for the National Eligibility-cum-Entrance Test (NEET) examination.
The Court also emphasised upon the right to mental health under Article 21 of the Constitution. A Criminal Appeal was preferred by the father of the deceased student, challenging the Judgment of the Andhra Pradesh High Court, which rejected his prayer seeking transfer of investigation to the CBI.
Cause Title- Sukdeb Saha v. The State of Andhra Pradesh & Ors. (Neutral Citation: 2025 INSC 893)
Date of Judgment- July 25, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
17) Proviso to Article 170(3) bars readjustment in legislative assembly seats until first census after 2026: Supreme Court while dismissing petition seeking delimitation for Telangana, Andhra Pradesh
The Court dismissed the Petitions seeking early delimitation for the states of Telangana and Andhra Pradesh while observing that the proviso to Article 170(3) expressly bars any readjustment in the total number of seats in the Legislative Assemblies of States until the first census after the year 2026.
The Court also made it clear that Article 170 has no application to Union Territories, including the Union Territory of Jammu and Kashmir, and one cannot claim parity between the position of Jammu and Kashmir and that of the States of Andhra Pradesh and Telangana.
Cause Title- K. Purushottam Reddy v. Union of India and Ors. (Neutral Citation: 2025 INSC 894)
Date of Judgment- July 25, 2025
Coram- Justice Surya Kant and Justice Nongmeikapam Kotiswar Singh
18) Magistrate can direct registration of FIR u/s. 156(3) CrPC even if informant has not exhausted remedies
The Court held that a Magistrate is competent under Section 156(3) CrPC to direct the registration of an FIR if the allegations in the application/complaint disclose the commission of a cognizable offence, even if the informant has not exhausted the remedies provided under the said provision.
The Court also held that ignoring the remedy under Section 154(3) of the CrPC amounts to a mere procedural irregularity. It was considering Special Leave Petitions challenging the Judgment whereby the petitions seeking quashing of the order of the Metropolitan Magistrate, New Delhi, as well as the criminal proceedings, were dismissed.
Cause Title- Anurag Bhatnagar & Anr. v. State (Nct of Delhi) & Anr. (Neutral Citation: 2025 INSC 895)
Date of Judgment- July 25, 2025
Coram- Justice Pankaj Mithal and Justice S.V.N. Bhatti
19) Proof can't be offered without specific pleadings: Supreme Court reverses finding of High Court based on document produced without pleadings
The Court reiterated that the pleadings and proof of such pleadings by valid evidence is the crux and core of any adjudicatory process.
The SLP was filed by the family of the deceased under the Motor Vehicle Compensation Act, 1988, challenging the finding of the High Court on the "limited liability" of the insurance company based on the policy document, even though there was no pleading to that effect.
Cause Title- Manjudha & Ors. V. United India Assurance Company Ltd. & Anr. (Neutral Citation: 2025 INSC 896)
Date of Judgment- July 25, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
20) Offence u/s. 138 NI Act should be tried by court where cheque is delivered for collection through branch of payee's bank: Supreme Court reiterates
The Court reiterated that an offence under Section 138 of the Negotiable Instruments Act can be inquired into and tried only by a local Court in jurisdiction of which the cheque is delivered for collection through an account in the Branch of the Bank where the payee maintains that account.
The Court was considering a Petition for Special Leave to Appeal against an order of the High Court affirming the Magistrate Court's order returning cases registered for cheque dishonour on the grounds of lack of jurisdiction to entertain the complaint cases.
Cause Title- Prakash Chimanlal Sheth v. Jagruti Keyur Rajpopat (Neutral Citation: 2025 INSC 897)
Date of Judgment- July 25, 2025
Coram- Justice Sanjay Kumar and Justice Satish Chandra Sharma
21) CCS CCA Rules| Disciplinary authority empowered to inflict minor penalties can issue charge-sheet even for imposition of major penalties
The Court held that, under Central Civil Services (Classification, Control & Appeal) Rules, 1965, the Disciplinary Authority empowered to inflict minor penalties can issue a charge-sheet even for imposition of major penalties.
The Court was considering an Appeal against an Order of the High Court by way of which it set-aside the Order of the Central Administrative Tribunal wherein Disciplinary Proceedings against the Respondent was sustained.
Cause Title- Union of India & Ors. v. R. Shankarappa (Neutral Citation: 2025 INSC 898)
Date of Judgment- July 25, 2025
Coram- Justice Sanjay Kumar and Justice Satish Chandra Sharma
22) Complaint can be amended even after cognizance is taken: Supreme Court upholds amendment in NI Act case
While upholding an Order of the Trial Court allowing the amendment application in a complaint under the Negotiable Instruments Act, 1881, the Court held that it is fallacious to contend that in no circumstance can amendments to complaints be allowed after cognisance is taken.
The Court took note of the fact that a simple issue of an amendment to a complaint had held up a trial under Section 138 of the Negotiable Instruments Act, 1881 (NI Act) for nearly two years.
Cause Title- Bansal Milk Chilling Centre v. Rana Milk Food Private Ltd. & Anr. (Neutral Citation: 2025 INSC 899)
Date of Judgment- July 25, 2025
Coram- Justice B.V. Nagarathna and Justice K. V. Viswanathan
