Weekly Overview| Supreme Court Judgments: April 7 – April 11, 2025
1) Initially recording offending vehicle in motor accident cases as ‘unknown' in FIR not fatal to claimant's case
In cases of motor accidents, the Court held that it is not fatal to the prosecution's case merely if the FIR initially records the offending vehicle as unknown.
The Court set aside the Impugned Order of the Telangana High Court, which had allowed an Appeal by the insurance company (Respondent), by setting aside the Award passed by the Motor Accidents Claims Tribunal (MACT) regarding the liability of the insurance company. The MACT’s Award had fastened liability jointly and severally on the owner of the vehicle and the insurance company, which was set aside vide the Impugned Order.
Cause Title- Kuncham Lavanya & Ors. v. The Bajaj Allianz General Insurance Co. Ltd. & Anr. (Neutral Citation: 2025 INSC 452)
Date of Judgment- April 7, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
2) SEBI cannot pass multiple final orders on same cause of action
The Court held that the Securities and Exchange Board of India (SEBI) cannot pass multiple Final Orders on the same cause of action.
The Court held thus in a Civil Appeal filed by the SEBI against the Judgment of the Securities Appellate Tribunal (SAT).
Cause Title- Securities and Exchange Board of India v. Ram Kishori Gupta & Anr. (Neutral Citation: 2025 INSC 454)
Date of Judgment- April 7, 2025
Coram- Justice Sanjay Kumar and Justice K.V. Viswanathan
3) NCDRC did not independently apply its mind to the quantification of the claim: Supreme Court allows insurance company’s Appeal
The Court remitted a matter to the NCDRC for fresh consideration, where United India Insurance Company was asked to pay over Rs 46 lakh for the loss suffered by the claimant company due to the collapse of the factory shed.
The Court noted that the Commission blindly acted upon the Insurance Company’s failure to deny assessment in the surveyor’s report produced by the claimant. The Appeal before the Court was filed by the United India Insurance Company under Section 23 of the Consumer Protection Act, 1986, against the judgment passed by the National Consumer Disputes Redressal Commission, New Delhi (NCDRC), in a Consumer Complaint filed by the respondent, viz., M/s. Park Leather Industries Ltd., Agra.
Cause Title- United India Insurance Co. Ltd. And Another v. M/s. Park Leather Industries Ltd (Neutral Citation: 2025 INSC 455)
Date of Judgment- April 7, 2025
Coram- Justice Sanjay Kumar and Justice Augustine George Masih
4) ‘Contra proferentum’ rule only applies to cases of real ambiguity where clause is ambiguous irrespective of any external considerations
The Court observed that the Rule of ‘Contra Proferentum’ only applies to cases of real ambiguity where the clause is ambiguous irrespective of any external considerations.
The Court observed thus in a Civil Appeal preferred by a company under Section 67 of the Consumer Protection Act, 2019 (CPA) against the Judgment of the National Consumer Disputes Redressal Commission, New Delhi (NCDRC) which dismissed a Consumer Complaint on account of the Doctrine of Uberrima Fidei being compromised.
Cause Title- Sohom Shipping Pvt. Ltd. v. M/s. The New India Assurance Co. Ltd. & Anr. (Neutral Citation: 2025 INSC 453)
Date of Judgment- April 7, 2025
Coram- Justice B.V. Nagarathna and Justice Satish Chandra Sharma
5) Offence u/s. 3 SC-ST Act not made out when no one other than complainant’s family members were present in vicinity of alleged scene of occurrence
The Court passed an Order of acquittal in a case registered under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, after finding no evidence to indicate that there was anybody present in the vicinity of the alleged scene of occurrence other than the complainant’s family members.
The Appeal before the Court was filed by five accused persons against the judgment of conviction passed under Section 447 of the Indian Penal Code, 1860 and Section 3 of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.
Cause Title- Hutu Ansari @ Futu Ansar & Ors. v. The State of Jharkhand (Neutral Citation: 2025 INSC 459)
Date of Judgment- April 7, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
6) Mere suspicion cannot lead to a finding of guilt: Supreme Court acquits man accused of killing his wife
The Court acquitted a man who was accused of killing his wife, reiterating that mere suspicion cannot lead to a finding of guilt.
The Court was deciding a Criminal Appeal filed by the accused-husband against the Judgment of the High Court which convicted him under Section 302 of the Indian Penal Code, 1860 (IPC).
Cause Title- Jagdish Gond v. The State of Chhattisgarh and Ors. (Neutral Citation: 2025 INSC 460)
Date of Judgment- April 7, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
7) Bland allegation of connivance: Supreme Court upholds Order quashing FIR against ex-MD of J&K Cooperative Housing Corporation for corruption
The Court upheld an Order quashing a criminal case of illegal land allotment registered against the former MD of J&K Cooperative Housing Corporation Brij Bhushan, after finding that only a bland allegation of connivance with the officers of the State was made against him.
The Court was considering a Special Leave Petition against the Order quashing the FIR registered under Section 5(2) of the Jammu and Kashmir Prevention of Corruption Act, 2006, read with Section 120-B of the Indian Penal Code, 1860 in the year 2021 against the ex- Managing Director.
Cause Title- Union Territory of Jammu and Kashmir v. Brij Bhushan (Neutral Citation: 2025 INSC 461)
Date of Judgment- April 7, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
8) Prosecutrix was in relationship with accused while being in subsisting marriage: Supreme Court quashes rape case
The Court quashed the criminal proceedings in a case registered under sections 376 and 506 of the IPC after noting that the complainant was in a relationship with the accused while being in a subsisting marriage and the physical relationship between the two was consensual from the very beginning.
The appellant-accused approached the Court challenging the impugned Order passed by the Delhi High Court whereby the Order discharging the Appellant in a case registered under sections 376, 506 of the IPC was set aside.
Cause Title- Jaspal Singh Kaural v. The State of Nct of Delhi & Anr. (Neutral Citation: 2025 INSC 457)
Date of Judgment- April 7, 2025
Coram- Justice B. V. Nagarathna and Justice Satish Chandra Sharma
9) Every consensual relationship, where possibility of marriage may exist, can’t be given colour of false pretext to marry, in the event of a fall out
The Court remarked that every consensual relationship, where a possibility of marriage may exist, cannot be given a colour of a false pretext to marry, in the event of a fall out.
The Court allowed the Appeal by a former Judicial Officer (Appellant) challenging the dismissal of his discharge Petition by the Calcutta High Court for offences under Sections 376, 417 and 506 of the IPC. The Court set aside the Order of the High Court while stating that the physical relationship between the Complainant and the Appellant was consensual, and cannot be said to be without her consent or against her will.
Cause Title- Biswajyoti Chatterjee v. State Of West Bengal & Anr. (Neutral Citation: 2025 INSC 458)
Date of Judgment- April 7, 2025
Coram- Justice BV Nagarathna and Justice Satish Chandra Sharma
10) Registration cannot be refused on ground that vendor's title is not established: Supreme Court declares Rule 55a(i) Registration Rules invalid
The Court declared Rule 55A(i) of the Registration Rules invalid observing that no provision under the the Registration Act 1908 confers power on any authority to refuse registration of a transfer document on the ground that the documents regarding the title of the vendor are not produced, or if his title is not established.
The Court set aside the Order of the Madras High Court, which dismissed the Writ Petition filed by the Appellant relying on Rule 55A(i) of the Registration Rules under the Registration Act, 1908 (the Act).
Cause Title- K. Gopi v. The Sub-Registrar & Ors. (Neutral Citation: 2025 INSC 462)
Date of Judgment- April 7, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
11) No relaxation can be granted: Supreme Court rejects plea of Rajasthan Civil Judge candidates who were not called for interview due to lack of reserved category certificates
The Court dismissed the Civil Appeals of the candidates for the post of Civil Judge in the Rajasthan State, who were not called to appear for the interview due to lack of reserved category certificates.
The batch of Appeals was before the three-Judge Bench as a result of the split verdict delivered through a Judgment in May 2023.
Cause Title- Sakshi Arha v. The Rajasthan High Court & Ors. (Neutral Citation: 2025 INSC 463)
Date of Judgment- April 8, 2025
Coram- Justice Abhay S. Oka, Justice Ahsanuddin Amanullah, and Justice Augustine George Masih
12) Supreme Court summarises guide to the construction of deeds and tools adopted
The Court summarised the guide to the construction of deeds and tools adopted.
The Court was hearing a Civil Appeal filed against the Order of the Bombay High Court which confirmed the Judgment of the Appellate Bench.
Cause Title- Annaya Kocha Shetty (Dead) through LRs v. Laxmibai Narayan Satose since deceased through LRs & Others (Neutral Citation: 2025 INSC 466)
Date of Judgment- April 8, 2025
Coram- Justice Pankaj Mithal and Justice S.V.N. Bhatti
13) Court can pass Judgment on the basis of admissions made by parties not only on pleadings but also dehors pleadings
The Court held that the Courts are empowered to pass Judgments based on admissions made by parties, even if such admissions are dehors the pleadings.
Interpreting the term “otherwise” in the context of Order 12 Rule 6 of the Code of Civil Procedure (CPC), the Bench observed that statements recorded under Order 10 Rules 1 and 2 CPC, whether made in documents or during proceedings, can be treated as admissions if they clarify the real dispute between the parties. Such admissions, the Court emphasized, are conclusive and may form the sole basis for a Judgment.
Cause Title- Rajiv Ghosh v. Satya Naryan Jaiswal (Neutral Citation No. 2025 INSC 467)
Date of Judgment- April 7, 2025
Coram- Justice JB Pardiwala and Justice R. Mahadevan
14) Not undergoing training course to upskill driving can’t be brushed aside as technical breach in motor accident case
The Court observed that not undergoing a training course to upskill the driving cannot be brushed aside as a technical breach not contributing to the motor accident.
The Court observed thus in Civil Appeals preferred against the Orders of the Punjab and Haryana High Court which upheld the Orders of the Motor Accidents Claims Tribunal (MACT).
Cause Title- M/s. Chatha Service Station v. Lalmati Devi & Ors. (Neutral Citation: 2025 INSC 468)
Date of Judgment- April 8, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
15) Following contrary Judgment of High Court despite noticing dictum of Apex Court is per-se violation of Article 141 of Constitution
The Court set aside a Judgment of the High Court in light of the fact that it failed to follow the dictum of the Apex Court and followed a contrary judgment of the High Court. The same was held to be in violation of Article 141 of the Constitution of India.
The matter at hand revolved around the compensation payable under the Haryana Compassionate Assistance to the Dependents of Deceased Government Employees Rules, 2006.
Cause Title- New India Assurance Co. Ltd. v. Smt. Sunita Sharma and Ors (Neutral Citation: 2025 INSC 469)
Date of Judgment- April 8, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
16) Additional Collector assigned powers under M.P. Land Revenue Code: Supreme Court upholds permission for sale of land granted by Additional Collector
While upholding a judgment of the Madhya Pradesh High Court whereby the Revisional Order passed by the Commissioner was set aside, the Court observed that the Additional Collector rightly exercised power under section (6) (ii) of the M. P. Land Revenue Code, 1959 in granting permission for the sale of the land.
The Appeal before the Court was filed against the impugned order of the Single Judge of the High Court, which interfered with the Revisional Order passed by the Commissioner, Ujjain Division, Ujjain, exercising suo motu powers under Section 50 of the M. P. Land Revenue Code.
Cause Title- The State of Madhya Pradesh v. Dinesh Kumar and Ors (Neutral Citation: 2025 INSC 470)
Date of Judgment- April 8, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
17) Requirement of preliminary enquiry in corruption cases can be relaxed where superior officer passes order for registration of FIR based on detailed source report
While setting aside an order quashing an FIR in a corruption case, the Supreme Court has reaffirmed that the requirement of preliminary enquiry can be relaxed if a superior officer, based on a detailed source report, passes an order for registration of FIR.
The Appeal before the Court was filed by the State of Karnataka challenging the order passed by the Karnataka High Court where the Single Judge had quashed the entire proceedings initiated by the State against the first respondent (Sri Channakeshava. H.D.) for offences under Section 13(1)(b) read with Section 13(2) of the Prevention of Corruption Act, 1988 (PC Act), in a case of Disproportionate Assets (DA case).
Cause Title- State of Karnataka v. Sri Channakeshava.H.D & Anr. (Neutral Citation: 2025 INSC 471)
Date of Judgment- April 8, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
18) Section 28 Contract Act does not bar exclusive jurisdiction clauses
The Court held that Section 28 of the Indian Contract Act, 1872 (ICA) does not bar exclusive jurisdiction clauses.
The Court held thus in a batch of two Civil Appeals in which the lead Appeal was filed against the Judgment of the Patna High Court, which allowed a Civil Revisional Application of the HDFC Bank. In the connected Appeal, HDFC Bank challenged the Judgment of the Delhi High Court which dismissed its Civil Revisional Application.
Cause Title- Rakesh Kumar Verma v. HDFC Bank Ltd. (Neutral Citation: 2025 INSC 473)
Date of Judgment- April 8, 2025
Coram- Justice Dipankar Datta and Justice Manmohan
19) Rule of law has responsibility to protect investments of foreign investors: Supreme Court revives proceedings in cheating case against Korean National
The Court revived the proceedings in a case of GST fraud and cheating against a foreign national while highlighting that the rule of law has a responsibility to protect the investments of foreign investors.
The Appeal before the Court was filed at the instance of the complainant-Company aggrieved by the final judgment of the Karnataka High Court whereby the criminal proceedings as well as the chargesheet in a case registered under Sections 406, 408, 409, 418, 420, 120B read with section 34 of the Indian Penal Code, 1860 was quashed.
Cause Title- Hyeoksoo Son Authorized Representative for Daechang Seat Automotive Pvt. Ltd. v. Moon June Seok & Anr. (Neutral Citation: 2025 INSC 474)
Date of Judgment- April 8, 2025
Coram- Justice Sanjay Karol and Justice Ahsanuddin Amanullah
20) Accused who creates hindrances in execution of warrant or is concealing himself should not be granted anticipatory bail
The Court while directing the accused persons to surrender, remarked that the accused who creates hindrances in the execution of warrant or is concealing himself should not be granted anticipatory bail.
The Court was deciding a batch of 16 Appeals filed by the Serious Fraud Investigation Office (SFIO) against the accused persons who were granted anticipatory bail by the High Court.
Cause Title- Serious Fraud Investigation Office v. Aditya Sarda (Neutral Citation: 2025 INSC 477)
Date of Judgment- April 9, 2025
Coram- Justice Bela M. Trivedi and Justice Prasanna B. Varale
21) Sentence already undergone would subserve ends of justice: Supreme Court directs release of murder convict who failed to surrender on time
The Court allowed the Appeal of a murder convict who failed to report within the specified period after his parole.
The Court noted that he had already been granted remission for the main offence of murder and suffered an additional incarceration of approximately 10 months. The Appellant approached the Court with an Appeal challenging the order of the Single Judge of the Punjab and Haryana High Court dismissing the revision petition filed by him.
Cause Title- Karan Singh v. The State of Haryana (Neutral Citation: 2025 INSC 475)
Date of Judgment- April 8, 2025
Coram- Justice B.R. Gavai and Justice Augustine George Masih
22) No input tax credit for sales exempt under Section 7(c) UP VAT Act
The Court held that no input tax credit can be claimed for sales exempt under Section 7(c) of the Uttar Pradesh Value Added Tax Act.
The Court had to determine whether a dealer is entitled to the input tax credit for purchase tax paid on sales turnover made to the manufacturer-exporter.
Cause Title- Neha Enterprises v. Commissioner, Commercial Tax, Lucknow, Uttar Pradesh (Neutral Citation: 2025 INSC 480)
Date of Judgment- April 9, 2025
Coram- Justice Pankaj Mithal and Justice SVN Bhatti
23) Limitation is a matter of statute & must be strictly enforced more so when earlier transaction is well within parties’ knowledge
The Court reiterated that limitation is a matter of statute and must be strictly enforced, more so when the earlier transaction or sale is well within the knowledge of the parties.
The Court reiterated thus in a Civil Appeal filed against the Judgment of the Madras High Court which remitted the case to the Trial Court for framing additional issues in respect of limitation.
Cause Title- R. Nagaraj (Dead) through LRs. and Another v. Rajmani and Others (Neutral Citation: 2025 INSC 478)
Date of Judgment- April 9, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
24) Eligibility criteria declared in fresh advertisement can’t be changed midway through recruitment process
The Court observed that once the eligibility criteria are declared by means of a fresh Advertisement, the same cannot be changed midway through the recruitment process, as the same would tantamount to ‘changing the rules of the game, after the game is played’.
The Appeal before the Court involved the question of reservations of posts in the government services of the State of Punjab, including reservations for women.
Cause Title- Prabhjot Kaur v. State of Punjab and Ors. (Neutral Citation: 2025 INSC 479)
Date of Judgment- April 9, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
25) Where President exhibits inaction in decision when bill is presented to him by Governor, State can seek mandamus
The Court in a landmark Judgment, held that where the President exhibits inaction in making a decision when a Bill is presented to him for assent under Article 201 of the Constitution, the State Government can seek a Writ of Mandamus from the Court.
The Court held thus in a Writ Petition filed by the Tamil Nadu State being aggrieved by the action of the Governor on few issues of prime public importance, seeking appropriate reliefs.
Cause Title- The State of Tamil Nadu v. The Governor of Tamil Nadu & Anr. (Neutral Citation: 2025 INSC 481)
Date of Judgment- April 8, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
