Weekly Overview| Supreme Court Judgments: April 15 – April 17, 2025
1) Licence of hospital must be suspended if any newborn infant is trafficked from there
The Court observed that the licence of the hospital must be suspended if any newborn infant is trafficked from such hospital.
The Court observed thus in a batch of Criminal Appeals arising from various Orders of the Allahabad High Court which released 13 accused persons on bail in connection with the offence punishable under Sections 363, 311, and 370(5) of the Indian Penal Code, 1860 (IPC).
Cause Title- Pinki v. State of Uttar Pradesh and Anr. (Neutral Citation: 2025 INSC 482)
Date of Judgment- April 15, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
2) Copyright v. Design protection: Supreme Court formulates two-pronged approach to address the conundrum by Section 15(2) Copyright Act
The Court formulated a two-pronged approach in order to crack open the conundrum caused by Section 15(2) of the Copyright Act so as to ascertain whether a work is qualified to be protected by the Designs Act. It examined the legal complexities surrounding the intersection of the Copyright Act, 1957 and the Designs Act, 2000, particularly concerning the protection of industrial designs.
The Court dismissed Appeals against the decision of the Gujarat High Court, which rejected the application under Order VII Rule 11 of the CPC. The parties to the Appeal were embroiled in a dispute concerning the purported infringement of intellectual property (IP) rights in relation to the designing and manufacturing of the internal parts of Cryogenic Storage Tanks and Distribution Systems.
Cause Title- Cryogas Equipment Private Limited v. Inox India Limited & Ors. (Neutral Citation: 2025 INSC 483)
Date of Judgment- April 15, 2025
Coram- Justice Surya Kant and Justice Nongmeikapam Kotiswar Singh
3) Fallacy to make distinction between ‘knowledge’ & ‘full knowledge’ when determining cause of action to ascertain limitation
The Court said that it is a “complete fallacy” to make any distinction between ‘knowledge’ and ‘full knowledge’ to determine whether the limitation has to run from the date when the cause of action first accrued and not any subsequent date for the cause of action.
The Court set aside the decision of the High Court and restored the decision of the Trial Court which rejected a plaint of the Plaintiff in exercise of powers under Order VII Rule 11 of the CPC as it was barred by limitation. The plaintiff instituted a suit seeking a declaration that a Will and a Codicil were null and void.
Cause Title- Nikhila Divyang Mehta & Anr. v. Hitesh P. Sanghvi & Ors. (Neutral Citation: 2025 INSC 485)
Date of Judgment- April 15, 2025
Coram- Justice Pankaj Mithal and Justice SVN Bhatti
4) Let us make friends with every language: Supreme Court rejects plea challenging Municipal Council’s signboard in Urdu
The Court rejected the Civil Appeals preferred by a woman who was not pleased with the use of Urdu on the signboard of the new building of the Municipal Council, Patur in District Akola, Maharashtra.
The said board displayed "Municipal Council, Patur", in Marathi at the top, with its translation below in Urdu language.
Cause Title- Varshatai W/o. Sanjay Bagade v. The State of Maharashtra through its Secretary, Ministry of Law and Judiciary, Mantralaya, Mumbai and Ors. Etc. (Neutral Citation: 2025 INSC 486)
Date of Judgment- April 15, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
5) Insurer is bound to indemnify owner of vehicle who has vicarious liability as against negligence of his employee-driver
While upholding the Judgment fixing the entire liability on the offending vehicle in a motor accident case, the Court observed that the insurer, who has insured the vehicle, is bound to indemnify the owner of the vehicle, who has the vicarious liability as against the negligence of his employee driver.
The Petition before the Court was filed by the Insurance Company, raising the issue of contributory negligence.
Cause Title- Reliance General Insurance Company Limited v. Swati Sharma and Ors (Neutral Citation: 2025 INSC 487)
Date of Judgment- April 16, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
6) Knowledge that attack is likely to cause death can be pinned down: Supreme Court upholds conviction of Ex-CPI(M) leader in Congress activist’s murder case
The Court upheld the conviction of R. Baiju, a former CPI(M) [Communist Party of India (Marxist)] local leader and Chairman of the Cherthala Municipal Standing Committee in a case involving the murder of a Congress activist.
The Court was deciding a Special Leave Petition (SLP) filed by Baiju, challenging the Judgment of the Kerala High Court, by which he was convicted under Sections 323, 324, 427, 450, and 304 Part II of the Indian Penal Code, 1860 (IPC) read with Section 120B of the IPC.
Cause Title- R. Baiju v. The State of Kerala (Neutral Citation: 2025 INSC 488)
Date of Judgment- April 16, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
7) Writ Petition can’t be maintained against e-tender: Supreme Court dismisses Housing Corporation’s Appeal challenging MHADA’s jurisdiction to proceed with GTB Nagar redevelopment
While observing that a Writ Petition cannot be maintained against the e-tender issued by the Maharashtra Housing and Area Development Authority when the Societies support the development initiative for GTB Nagar, the Court dismissed an Appeal filed by a Developer, Lakhani Housing Corporation, challenging the Authority's jurisdiction to proceed with such redevelopment.
The Court was considering the issue of whether the e-tender issued by the Maharashtra Housing and Area Development Authority in pursuance of a Cabinet decision, followed up with a government resolution, interferes with the contractual rights of the Appellants.
Cause Title- Lakhani Housing Corporation Pvt. Ltd. & Anr. v. The State of Maharashtra & Ors. (Neutral Citation: 2025 INSC 489)
Date of Judgment- April 16, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
8) Courts must notify Income Tax Dept. of Rs. 2 lakh and above cash transaction claims in suits
To verify violation of Section 269ST of the Income Tax Act involving cash transactions of Rs. 2,00,000 and above, the Court directed Courts to intimate the jurisdictional Income Tax Department upon the filing of such suits.
The Court set aside the Order of the Karnataka High Court, which dismissed the Revision Petition filed by the Appellant against the Order of the Trial Court rejecting an Application filed under Order VII Rule 11(a) and (d) of the CPC for rejection of the plaint.
Cause Title- The Correspondence, RBANMS Educational Institution v. B. Gunashekar & Anr. (Neutral Citation: 2025 INSC 490)
Date of Judgment- April 16, 2025
Coram- Justice JB Pardiwala and Justice R Mahadevan
9) Supreme Court’s decision at stage of SLP or post grant of leave cannot be assailed directly or collaterally under Article 32
The Court reiterated that its decision at the stage of Special Leave Petition (SLP) or post grant of leave, cannot be assailed directly or collaterally under Article 32 of the Constitution.
The Court reiterated thus in a Writ Petition filed by three retired officers of the Himachal Pradesh State Forest Development Corporation Limited under Article 32, who were aggrieved by denial of pensionary benefits to them in terms of the Himachal Pradesh Corporate Sector Employees (Pension, Family Pension, Commutation of Pension and Gratuity) Scheme, 1999 discontinued vide a notification.
Cause Title- Satish Chander Sharma & Ors. v. State of Himachal Pradesh & Ors. (Neutral Citation: 2025 INSC 491)
Date of Judgment- April 16, 2025
Coram- Justice Surya Kant, Justice Dipankar Datta, and Justice Ujjal Bhuyan
10) Jurisdictional Criminal Court’s finding in S. 138 NI Act proceedings is binding to both parties in subsequent proceedings involving same issue
The Court observed that the finding recorded by the jurisdictional Criminal Court in proceedings under Section 138 of the Negotiable Instruments Act, 1881 (NI Act), is binding to both the parties in any subsequent proceedings involving the same issue.
The Court observed thus in a Criminal Appeal preferred against the Judgment of the Allahabad High Court by which the Petition seeking quashment of a criminal case under Section 420 of the Indian Penal Code, 1860 (IPC), was dismissed.
Cause Title- S.C. Garg v. State of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 493)
Date of Judgment- April 16, 2025
Coram- Justice Pankaj Mithal and Justice Prashant Kumar Mishra
11) High Court ignored shadow witness's version that village accountant counted bribe amount & kept it: Supreme Court upholds conviction in 30-year-old corruption case
The Court upheld the conviction of a village Accountant in a corruption case which came to light in the year 1995 and held that the Karnataka High Court totally ignored the version of the Shadow Witness and erroneously observed that the prosecution failed to establish the demand raised by the accused.
The Criminal Appeal before the Court was filed against the Judgment of the Karnataka High Court whereby the judgment of conviction rendered by the Trial Court under the Prevention of Corruption Act, 1988 was reversed and an acquittal order was passed by the High Court.
Cause Title- State of Karnataka v. Nagesh (Neutral Citation: 2025 INSC 492)
Date of Judgment- April 16, 2025
Coram- Justice Bela M. Trivedi and Justice Prasanna B. Varale
12) Indian military nursing service personnel not excluded from category of “ex-servicemen” under Punjab Recruitment of Ex-Servicemen Rules
Highlighting the fact that Indian Military Nursing Service has been constituted as a 'part of the Indian military' and 'part of the armed forces of the Union', the Court held that there is no reason to exclude Indian Military Nursing Service personnel from the category of 'ex-servicemen' under the Punjab Recruitment of Ex-Servicemen Rules, 1982.
The Court was considering an Appeal filed by an ex-serviceman, having worked as a Captain in the Medical Core of the Indian Army.
Cause Title- Irwan Kour v. Punjab Public Service Commission & Ors. (Neutral Citation: 2025 INSC 494)
Date of Judgment- April 16, 2025
Coram- Justice Pamidighantam Sri Narasimha and Justice Manoj Misra
13) Dispute predominantly has overtures of civil dispute: Supreme Court quashes FIR involving financial dispute with bank
The Court quashed an FIR involving a financial dispute with a bank while remarking that the said dispute predominantly has overtures of a civil dispute.
The Court set aside the decision of the Gujarat High Court, which dismissed a Writ Petition under Article 226 of the Constitution seeking quashing of an FIR as well as the charge sheet for offences punishable under Section 420, 467, 468 and 471 and 120B of the IPC.
Cause Title- Suresh C. Singal & Ors. v. The State Of Gujarat & Ors. (Neutral Citation: 2025 INSC 495)
Date of Judgment- April 16, 2025
Coram- Justice Abhay S Oka and Justice Augustine George Masih
14) Memo of arrest didn’t mention her name as accused: Supreme Court quashes NDPS case against woman alleging false implication
The Court quashed an NDPS case registered against a woman who alleged that she was not the same lady who was arrested on the day of the incident.
The Court noted that all the contemporary documents, including the memo of arrest of the same date, did not mention the name of the appellant as the accused. The Appellant was arraigned as an accused along with three other accused persons in a case registered under Sections 8 and 20(b)(ii)(C) of the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act).
Cause Title- K. Shikha Barman v. State of Madhya Pradesh (Neutral Citation: 2025 INSC 497)
Date of Judgment- April 16, 2025
Coram- Justice Abhay S Oka and Justice Ujjal Bhuyan
15) State Govt. can’t frame rules which will be inconsistent with rules framed by Central Govt. U/S. 13(1) Central Sales Tax Act
The Court held that the State Government cannot frame rules in exercise of power under Section 13(3) which will be inconsistent with the rules framed by the Central Government in exercise of powers under Section 13(1) of the CST Act.
The Court upheld the decision by the Rajasthan High Court, wherein the validity of a specific sub-rule within the Central Sales Tax (Rajasthan) Rules, 1957 (Rules) came to be challenged. The High Court held that the State had no rule-making power to frame a rule providing for the cancellation of validly issued declarations/forms under the Central Sales Tax Act, 1956 (CST Act).
Cause Title- The State Of Rajasthan & Ors. v. Combined Traders (Neutral Citation: 2025 INSC 496)
Date of Judgment- April 16, 2025
Coram- Justice Abhay S Oka and Justice Ujjal Bhuyan
16) Mere mention of psychotropic substances under D&C regime won’t take them away from purview of NDPS Act
The Court held that mere mention of certain psychotropic substances under the D&C (Drugs and Cosmetics) regime would not take them away from the purview of the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act), if they are also mentioned under the Schedule to the NDPS Act.
The Court held thus in Criminal Appeals filed against the Judgment of the Delhi High Court, which rejected the respective Petitions having found no legal infirmity in the Orders of the Trial Court arriving at the conclusion that no offence under Sections 8, 22 and 29, and under Section 8(c) and 22(c) of the NDPS Act could be said to have been made out since the psychotropic substance in question do not figure in Schedule I of the NDPS Rules, 1985.
Cause Title- Directorate of Revenue Intelligence v. Raj Kumar Arora & Ors. (Neutral Citation: 2025 INSC 498)
Date of Judgment- April 17, 2025
Coram- Justice J.B. Pardiwala and Justice Manoj Misra
17) Peaceful protest by consumer a corresponding right to commercial speech by seller: Supreme Court quashes defamation case against homebuyers
The Court quashed a defamation case filed against a group of homebuyers by a builder, M/s A. Surti Developers Pvt. Ltd., while remarking that a right to protest peacefully without falling foul of the law is a corresponding right, which the consumers ought to possess just as the seller enjoys his right to commercial speech.
The Court allowed the Appeal against the decision of the Bombay High Court, which upheld the issuance of summons against the homebuyers for an offence punishable under Section 500 of the IPC. The Court noted that the homebuyers, in a “mild and temperate language,” only aired certain issues, which they perceived as their grievances against the builder.
Cause Title- Shahed Kamal & Ors. v. M/S A. Surti Developers Pvt. Ltd. & Anr. (Neutral Citation: 2025 INSC 502)
Date of Judgment- April 17, 2025
Coram- Justice KV Viswanathan and Justice N Kotiswar Singh
18) Consideration for cancellation of anticipatory bail given by High Court has to be tested on anvil as to whether serious error in law is committed while granting the same
While upholding the Order granting anticipatory bail to an alleged habitual offender, the Court observed that once the benefit of anticipatory bail has been given by the High Court, the consideration for its cancellation has to be tested on the anvil as to whether the High Court has committed any serious error in law while granting such bail.
The Appellant/de facto complainant challenged the Judgment and final Order allowing the anticipatory bail filed under Section 438 of the Code of Criminal Procedure, 1973, to the second respondent (Abdul Razzak) in connection with an FIR registered under Sections 195 A, 294 and 506 of the Indian Penal Code, 1860.
Cause Title- Ankit Mishra v. The State of Madhya Pradesh & Anr. (Neutral Citation: 2025 INSC 501)
Date of Judgment- April 17, 2025
Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra
19) Despite contributions deducted from employees’ salaries, they weren’t deposited with ESIC: Supreme Court upholds conviction u/s 85(a) ESI Act
The Court upheld the conviction of a company's general manager under Section 85(a) of the ESI Act, remarking that despite contributions deducted from the employees’ salaries, they were not deposited with the ESIC.
The Court dismissed an Appeal against the decision of the Karnataka High Court, which dismissed the Criminal Revision Petition filed by the Appellant challenging the conviction under Section 85(a) of the Employees’ State Insurance Act, 1948 (ESI Act) for allegedly deducting ESI contribution from the employees, but not remitting it to the Employees' State Insurance Corporation (ESIC).
Cause Title- Ajay Raj Shetty v. Director & Anr. (Neutral Citation: 2025 INSC 500)
Date of Judgment- April 17, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
20) Just as strong motive doesn’t by itself result in conviction, absence of motive on that sole ground can’t result in acquittal
The Court observed that just as a strong motive does not by itself result in a conviction, the absence of motive on that sole ground cannot result in an acquittal.
The Court observed thus in a Criminal Appeal filed by an accused father was tried and convicted under Section 302 of the Indian Penal Code, 1860 (IPC) read with Sections 25 and 27 of the Arms Act, 1959, for allegedly killing his son.
Cause Title- Subhash Aggarwal v. The State of NCT of Delhi (Neutral Citation: 2025 INSC 499)
Date of Judgment- April 17, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
21) Non-issuance of notice u/s. 21 A&C Act to parties to arbitration agreement doesn't bar Arbitral Tribunal from impleading them during proceedings
The Court held that merely because a notice under Section 21 of the Arbitration and Conciliation Act is not issued to certain persons who are parties to the arbitration agreement does not denude the arbitral tribunal of its jurisdiction to implead them as parties during the arbitral proceedings.
The Court set aside the impugned Judgment of the Delhi High Court, which upheld the decision of the Arbitral Tribunal that allowed the application under Section 16 of the Arbitration and Conciliation Act, 1996 (the Act) and held that the arbitral proceedings against certain parties was not maintainable. The Court clarified that while a notice invoking arbitration under Section 21 is mandatory and fulfils various purposes by fixing the date of commencement of arbitral proceedings, non-service of such notice on a person does not preclude his impleadment in the arbitral proceedings.
Cause Title- Adavya Projects Pvt. Ltd. v. M/S Vishal Structurals Pvt. Ltd. & Ors. (Neutral Citation: 2025 INSC 507)
Date of Judgment- April 17, 2025
Coram- Justice Pamidighantam Sri Narasimha and Justice Manoj Misra
22) Sec. 307 IPC attracted if hurt of any nature is caused & intention or knowledge to cause death is proved: Supreme Court reduces punishment of Army Constable
While reducing the punishment imposed upon an Army Constable who had opened fire with his service rifle, the Court observed that Section 307 IPC would stand attracted if hurt of any nature is caused and it is proved that there was intention or knowledge to cause death.
The Criminal Appeal before the Court was preferred by the State of Himachal Pradesh against the judgment reversing the order of conviction passed by the trial court and acquitting the accused-respondent from the offence under Section 307 of the India Penal Code read with Section 27 of the Arms Act, 1959 but maintaining conviction under Section 326 IPC.
Cause Title- The State of Himachal Pradesh v. Shamsher Singh (Neutral Citation: 2025 INSC 503)
Date of Judgment- April 17, 2025
Coram- Justice Pankaj Mithal and Justice S.V.N. Bhatti
23) Supreme Court expresses divergent opinions on issue of accepting apology of Advocates in contempt case; places matter before CJI
The Court expressed divergent opinions on the issue of acceptance of the apology tendered by the concerned Advocates, and has, therefore, placed the case before the Chief Justice of India (CJI) for appropriate Orders.
The two-Judge Bench was dealing with a Special Leave Petition (SLP) filed by the Petitioner-accused namely N. Eswaranathan who along with his Advocates i.e., AOR P. Soma Sundaram, and Advocate S. Muthukrishnan, were accused of committing Contempt of Court.
Cause Title- N. Eswaranathan v. State represented by the Deputy Superintendent of Police (Neutral Citation: 2025 INSC 509)
Date of Judgment- April 17, 2025
Coram- Justice Bela M. Trivedi and Justice Satish Chandra Sharma
24) Incident happened after relationship of husband & wife came to end: Supreme Court quashes case registered u/s. 498A IPC against man’s relatives
The Court quashed a criminal complaint registered against the relatives of the husband under the IPC and the Dowry Prohibition Act after noting that the incident complained of took place after the divorce decree was passed and the relationship of husband and wife had come to an end by then.
The Appellants approached the Court challenging the impugned order whereby the High Court had disposed of the appellants’ prayer for quashing of the summoning order issued by the Trial Court in a case registered under Sections 498A, 323, 504, 506 of the Indian Pernal Code, 1860 and Section 4 of the Dowry Prohibition Act, 1961 without deciding the quashing petition on merits.
Cause Title- Sushila & Ors. v. State of U.P. & Ors (Neutral Citation: 2025 INSC 505)
Date of Judgment- April 16, 2025
Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra
25) Judgment doesn’t conform to scope of Section 100 CPC: Supreme Court sets aside Madras High Court Order passed in Second Appeal ignoring material evidence
The Court set aside an Order passed by the Madras High Court in a second appeal in a property dispute matter after noting that the same was passed without conforming to the scope of Section 100 of the Code of Civil Procedure and without considering the material evidence.
The Appeal before the Court was filed by the Defendants assailing the correctness of the judgment of the Madras High Court whereby the Second Appeal filed by the plaintiff was allowed and the concurrent judgments of the Trial Court and the Sub-Judge dismissing the suit of the Plaintiff-Respondents were set aside and the suit was decreed.
Cause Title- Rajendhiran v. Muthaiammal @ Muthayee & Ors. (Neutral Citation: 2025 INSC 508)
Date of Judgment- April 15, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
26) High Court ought not to have quashed FIR when it disclosed the commission of offence: Supreme Court restores cheating case
The Court set aside a Judgment quashing an FIR in a criminal case and held that, as the FIR disclosed the commission of an offence, the High Court ought not to have quashed it solely on the ground that the complainant sought to prosecute the Adhyaksha of the Grama Panchayat primarily because of his position.
The Appeal before the Court was filed against the Judgment quashing an FIR in a criminal case registered under Sections 420, 468, 465 and 471 of the Indian Penal Code, 1860.
Cause Title- D.B. Ravikumar v. G.S. Suresh & Anr. (Neutral Citation: 2025 INSC 514)
Date of Judgment- April 17, 2025
Coram- Chief Justice Of India Sanjiv Khanna and Justice Sanjay Kumar
27) Do not have any emotional connect: Supreme Court grants divorce on ground of irretrievable breakdown of marriage
Highlighting the fact that the husband and wife do not have any emotional connect with each other, the Court exercised its jurisdiction under Article 142 of the Constitution of India and directed the dissolution of their marriage on the ground of irretrievable breakdown of marriage.
The Court was considering an Appeal against the Judgment setting aside the decree of divorce.
Cause Title- A v. B (Neutral Citation: 2025 INSC 513)
Date of Judgment- April 16, 2025
Coram- Chief Justice of India Sanjiv Khanna and Justice Sanjay Kumar
28) We are flooded with cases of civil wrongs being made subject matter of criminal proceedings: Supreme Court imposes ₹50k cost on UP State
The Court imposed a cost of ₹50,000/- on the Uttar Pradesh State saying that it is flooded with cases of civil wrongs being made subject matter of criminal proceedings.
The Court was dealing with a Criminal Appeal preferred against the Judgment of the Allahabad High Court which dismissed a Petition filed under Section 482 of the Criminal Procedure Code, 1973 (CrPC).
Cause Title- Rikhab Birani & Anr. v. State of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 512)
Date of Judgment- April 16, 2025
Coram- Chief Justice of India (CJI) Sanjiv Khanna and Justice Sanjay Kumar
