Weekly Overview| Supreme Court Judgments: April 21 – April 25, 2025
1) Is there a need for sanction u/s. 17A PC Act when Magistrate orders investigation u/s. 156(3) CrPC? Supreme Court tags Yediyurappa’s corruption case for reference to larger bench
The Court referred former Karnataka Chief Minister BS Yediyurappa’s land case under Sections 13 (1)(c) and 13 (2) of the Prevention of Corruption Act to a larger Bench for consideration.
The Court deliberated on "whether the considerations under Section 17A of the PC Act are of such a nature that they are necessarily beyond the ambit or scope of consideration by a Magistrate while directing an investigation under Section 156(3) of the Cr.P.C.?"
Cause Title- BS Yeddiyurappa v. A Alam Pasha & Ors. (Neutral Citation: 2025 INSC 515)
Date of Judgment- April 21, 2025
Coram- Justice JB Pardiwala and Justice Manoj Misra
2) Compromise decree cannot be challenged by filing a fresh suit
The Court reiterated that a compromise decree cannot be challenged by filing a fresh suit and the only remedy is to file a recall application. It upheld the dismissal of a suit filed by Appellants for declaring a compromise decree entered into between the Respondents as null and void.
The Trial Court had dismissed the suit by the Appellants wherein they also sought partition of a certain share in the ancestral property, which was in the possession of the Respondents.
Cause Title- Manjunath Tirakappa Malagi & Anr. v. Gurusiddappa Tirakappa Malagi (Dead Through Lrs) (Neutral Citation: 2025 INSC 517)
Date of Judgment- April 21, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
3) Supreme Court sets aside revised POCSO sentence; restores original sentence invoking Article 142 to release convict
The Court set aside a man's revised sentencing to life imprisonment in a POCSO case by the High Court and ordered his release by restoring the original sentence invoking Article 142 of the Constitution, pointing out his over-eleven-year incarceration, which exceeded the initial sentence imposed.
The Nagpur Bench of the Bombay High Court had previously upheld the conviction of the Appellant for offences under Sections 3(a) and 4 of the Protection of Children from Sexual Offences Act, 2012 (POCSO Act) and Section 376 of the IPC.
Cause Title- Sachin v. State Of Maharashtra (Neutral Citation: 2025 INSC 518)
Date of Judgment- April 21, 2025
Coram- Justice BV Nagarathna and Justice Satish Chandra Sharma
4) Correctness of finding regarding victim’s age not to be considered u/s. 389 CrPC: Supreme Court sets aside High Court Order suspending sentence of POCSO accused
While setting aside a High Court Order suspending the sentence of a POCSO Accused, the Court observed that the correctness of finding regarding victim’s age or the correctness of the manner in which it was sought to be proved before the Trial Court are questions that are not open for consideration in the jurisdiction under section 389 of the CrPC.
The Appeal before the Court was filed at the instance of the mother of a minor, who was a victim of sexual assault.
Cause Title- Lilaben v. State of Gujarat & Anr. (Neutral Citation: 2025 INSC 519)
Date of Judgment- April 21, 2025
Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra
5) Date for determination of market value of land for acquisition must be date of Section 11 notification
The Court held that the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (RFCTLARR Act, 2013) expressly mandates that compensation/valuation of land must be determined as on the date of Notification issued under Section 11.
The Court was considering a landowner's Appeal challenging a Judgment of the Gujarat High Court.
Cause Title- Sumitraben Singabhai Gamit Vs The State of Gujarat (Neutral Citation: 2025 INSC 521)
Date of Judgment- April 21, 2025
Coram- Justice Dipankar Datta and Justice Manmohan
6) Supreme Court expresses concern about unnecessarily long oral submissions & bulky written submissions in arbitration cases
The Court expressed concern about the practice of making unnecessarily long oral submissions or bulky written submissions in Arbitration cases.
The Court was deciding Civil Appeals filed by Larsen and Toubro (L&T) Limited and others, challenging the Judgment of the Delhi High Court in the Appeals preferred under Section 37 of the Arbitration and Conciliation Act, 1996 (A&C Act).
Cause Title- Larsen and Toubro Limited v. Puri Construction Pvt. Ltd. and Others (Neutral Citation: 2025 INSC 523)
Date of Judgment- April 21, 2025
Coram- Justice Abhay S. Oka and Justice Pankaj Mithal
7) Objection to execution of arbitration award u/s. 47 CPC not dependent or contingent upon filing petition u/s 34 A&C Act
The Court held that an objection to execution of an Arbitration award under Section 47 of the Civil Procedure Code, 1908 (CPC) is not dependent or contingent upon filing a Petition under Section 34 of the Arbitration and Conciliation Act, 1996.
The Court held thus in a Civil Appeal preferred by a steel company against the Judgment of the Jharkhand High Court.
Cause Title- Electrosteel Steel Limited (Now M/s ESL Steel Limited) v. Ispat Carrier Private Limited (Neutral Citation: 2025 INSC 525)
Date of Judgment- April 21, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
8) Writ Court should not interfere with order granting deemed conveyance u/s 11(4) MOFA unless it’s manifestly illegal
The Court held that the Writ Court should not interfere with the Order granting deemed conveyance under Section 11(4) of the Maharashtra Ownership Flats (Regulation of the Promotion of Construction, Sale, Management and Transfer) Act, 1963, unless the same is manifestly illegal.
The Court held thus in a Civil Appeal filed against the Judgment of the Bombay High Court’s Single Bench.
Cause Title- Arunkumar H Shah HUF v. Avon Arcade Premises Co-operative Society Limited & Ors. (Neutral Citation: 2025 INSC 524)
Date of Judgment- April 21, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
9) Supreme Court affirms liability fastened by NCDRC upon hospital for medical negligence resulting in death of 27-year-old B.Tech graduate
The Court affirmed the liability fastened by the NCDRC upon a hospital for medical negligence resulting in the death of a 27-year-old B.Tech graduate.
The Court, however, modified the compensation awarded to the claimants by the National Consumers Dispute Redressal Commission (NCDRC) from Rs. 15 lakhs to Rs. 10 lakhs payable by Kamineni Hospitals (Appellant).
Cause Title- The Managing Director, Kamineni Hospitals v. Peddi Narayana Swami & Anr. (Neutral Citation: 2025 INSC 527)
Date of Judgment- April 22, 2025
Coram- Justice BR Gavai and Justice Augustine George Masih
10) High Court must examine accused's statement u/s. 313 CrPC at earliest stage in conviction appeal and cure any defects
The Court held that the High Court must, at the earliest stage of an Appeal against conviction, examine the accused's statement under Section 313 of the CrPC and cure any defects either by recording a further statement or directing the Trial Court to do so.
The Court upheld the High Court's decision to acquit the husband in a case involving the death of his wife and three daughters due to burn injuries. The Court noted that the evidence of prosecution regarding the dying declaration was not put to the husband in his statement under Section 313 of the CrPC.
Cause Title- Aejaz Ahmad Sheikh v. State of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 529)
Date of Judgment- April 22, 2025
Coram- Justice Abhay S Oka, Justice Pankaj Mithal, and Justice Ahsanuddin Amanullah
11) Sale instances cannot guide us to the market value of land with exactitude
The Court observed that sale instances cannot guide us to the market value of the land with exactitude.
The Court observed thus in a batch of Civil Appeals in which the dispute was related to the assessment of market value of the acquired land for the purpose of awarding compensation under the Land Acquisition Act, 1894 (LA Act).
Cause Title- Barla Ram Reddy v. The State of Telangana (Neutral Citation: 2025 INSC 531)
Date of Judgment- April 22, 2025
Coram- Justice Surya Kant and Justice Ujjal Bhuyan
12) Mere existence of sons & daughters in Joint Hindu Family doesn’t make father’s separate or self-acquired property as joint family property
The Court held that mere existence of sons and daughters in a Joint Hindu Family (JHF) does not make the father's separate or self-acquired property as joint family property.
The Court held thus in a Civil Appeal filed by a property purchaser, against the Judgment of the Karnataka High Court, which set aside the Decree passed by the Civil Judge.
Cause Title- Angadi Chandranna v. Shankar & Ors. (Neutral Citation: 2025 INSC 532)
Date of Judgment- April 22, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
13) Supreme Court issues guidelines for disbursement of unclaimed compensation lying with motor accident claims tribunals & labour courts, suggests bank transfer of amount
Taking note of the unclaimed compensation amounts lying deposited with Motor Accident Claims Tribunals & Labour Courts, the Court issued a set of procedural guidelines to be adopted by various courts for disbursal of such compensation.
The Court directed that Tribunals can pass order of transfer of the requisite amounts directly to the bank account of the persons entitled to receive compensation. It noticed that though the claimants were held entitled to the compensation amounts, however, they had not withdrawn the same.
Cause Title- In Re: Compensation Amounts Deposited With Motor Accident Claims Tribunals and Labour Courts (Neutral Citation: 2025 INSC 530)
Date of Judgment- April 22, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
14) Ex-member of Bar Council can be member of Waqf Board only if there is no serving Muslim member or Senior Muslim Advocate
The Court held that an ex-member of the Bar Council can be a Member of the Waqf Board only if there is no serving Muslim Member in the Bar Council as well as no Senior Muslim Advocate.
The Court held thus in Civil Appeals in which the short issue for consideration was – “Whether a Muslim Member of the Bar Council of the State or the Union territory, duly elected as a Member of the Waqf Board constituted under Section 14 of the Wakf Act, 1995, can continue to hold the said position, even after the expiry of his tenure in the Bar Council?”
Cause Title- Md. Firoz Ahmad Khalid v. The State of Manipur & Ors. (Neutral Citation: 2025 INSC 535)
Date of Judgment- April 22, 2025
Coram- Justice M.M. Sundresh and Justice Rajesh Bindal
15) Once probable defence on accused’s part is established, burden to establish a case beyond a reasonable doubt shifts upon complainant under NI Act
The Court clarified that once the probable defence on the part of the accused has been established, the burden shifts upon the complainant to establish a case beyond a reasonable doubt under the NI Act.
The Court set aside the decision of the Karnataka High Court that convicted the Appellant under Section 138 of the Negotiable Instruments Act, 1881 (NI Act), and restored the Trial Court's original acquittal Order.
Cause Title- N. Vijay Kumar v. Vishwanath Rao N. (Neutral Citation: 2025 INSC 537)
Date of Judgment- April 22, 2025
Coram- Justice Pankaj Mithal and Justice Sanjay Karol
16) Income assessment of deceased can be made as per income tax return; can’t reject it merely because its submission was after the date of motor accident
While restoring an award of the Tribunal in a motor accident case, the Court held that it is not legally sustainable to reject the Return on the sole ground of its submission after the date of the accident.
The Appeal before the Court was filed against the Final Judgment rendered by a Single Judge of the Delhi High Court. The High Court had reduced the compensation payable to the Appellants from Rs.31,41,000 to Rs.16,97,370, maintaining the interest awarded at the rate of 9% per annum.
Cause Title- Nidhi Bhargava & Ors. v. National Insurance Company Ltd. & Ors. (Neutral Citation: 2025 INSC 526)
Date of Judgment- April 22, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
17) Protection of S. 197(1) CrPC available only to public servants whose appointing authority is Central or State Govt
The Court reiterated that the protection of Section 197(1) of the Criminal Procedure Code, 1973 is available only to public servants whose appointing authority is Central or State Government.
The Court reiterated thus in two Criminal Appeals preferred against the common Judgment of the Punjab and Haryana High Court, which allowed a Revision Petition in which the Order of the Special Court dismissing the Application for discharge was under challenge.
Cause Title- Central Bureau of Investigation v. Ramesh Chander Diwan (Neutral Citation: 2025 INSC 539)
Date of Judgment- April 22, 2025
Coram- Justice Dipankar Datta and Justice Manmohan
18) Court can’t omit from its consideration release of offender on probation unless applicability is excluded in case where S. 4(1) Probation Act is attracted
The Court held that unless applicability is excluded, in a case where the circumstances stated in sub section (1) of Section 4 of the Probation of Offenders Act, 1958 are attracted, the Court cannot omit from its consideration release of the offender on probation.
The Court held thus in a Criminal Appeal filed against the Judgment of the Madras High Court which partly allowed the Criminal Appeal under Section 374(2) of the Criminal Procedure Code, 1973 (CrPC).
Cause Title- Chellamal and Another v. State represented by the Inspector of Police (Neutral Citation: 2025 INSC 540)
Date of Judgment- April 22, 2025
Coram- Justice Dipankar Datta and Justice Manmohan
19) Proper interpretation of Section 428 CrPC dealing with accused’s entitlement to set-off: Supreme Court refers to larger bench
Taking note of the divergent views expressed in various precedents on the interpretation of Section 428 of the CrPC, the Court referred the matter to the Chief Justice of India to consider the desirability of constituting a Bench for proper interpretation of the provision. Section 428 provides that the period of detention undergone by the accused shall be set off against the sentence of imprisonment.
The Superintendent of Prison, Central Prison – 1, Puzhal, Chennai, Tamil Nadu and the Inspector of Police, Q Branch, CID Police Station filed an Appeal against the Judgment of a Judge of the Madras High Court whereby the petition of the respondent under Section 482 of the Code of Criminal Procedure was allowed. In the petition, Venkatesan had sought that the remand period as an undertrial prisoner produced under P.T. (Prisoner Transit) warrant in S.C. No.2 of 2002, under Section 428 of the CrPC be set-off.
Cause Title- The Superintendent of Prison & Anr. v. Venkatesan @ Senu @ Srinivasan @ Baskaran @ Radio @ Prakasam (Neutral Citation: 2025 INSC 541)
Date of Judgment- April 22, 2025
Coram- Justice Dipankar Datta and Justice Manmohan
20) Defendant, set ex parte, can’t produce evidence in defence; his limited right is confined to cross-examining Plaintiff’s witnesses
While setting aside a High Court judgment resurrecting a property dispute between the brothers, which was decided over 3 decades back, the Court explained that once the pleadings are complete but the defendant is set exparte, the defendant’s rights suffer a curtailment and he cannot produce evidence in defence.
The Court was considering a Civil Appeal against a Judgment of the Allahabad High Court allowing a writ petition under Article 227 of the Constitution of India filed by the respondents. The impugned Order also allowed multiple interlocutory applications, viz. application for condonation of delay in filing a recall application; application for recall/restoration, an application for amendment prior to the writ petition being allowed.
Cause Title- Kanchhu v. Prakash Chand & Ors. (Neutral Citation: 2025 INSC 542)
Date of Judgment- April 22, 2025
Coram- Justice Dipankar Datta and Justice Manmohan
21) Lived separate lives for over a decade, complete absence of marital ties: Supreme Court dissolves marriage invoking power under Article 142 of Constitution
The Court invoked its power under Article 142 of the Constitution and dissolved the marriage of a couple, citing the fact that they lived separately for over a decade and there was a complete absence of marital ties.
The Appeal before the Court was filed against the Judgment of the Jharkhand High Court whereby the Appellant/husband’s Appeal was dismissed, affirming the Judgment of the Family Court dismissing the Appellant’s Petition for dissolution of marriage under Sections 13(1)(ia) and (iii) of the Hindu Marriage Act, 1955.
Cause Title- ABC v. XYZ (Neutral Citation: 2025 INSC 543)
Date of Judgment- April 22, 2025
Coram- Justice Vikram Nath, Justice Sanjay Karol and Justice Sandeep Mehta
22) Difficulties in mental health; good conduct for 16-17 years: Supreme Court commutes death sentence of man convicted for killing wife, children & raping daughter
The Court commuted the death penalty of a man who killed his wife, four children and raped his minor daughter after noting his good conduct for the past 16-17 years of incarceration and difficulties in his mental health. The Appeal before the Court was filed by the Appellant accused of killing his wife and four children.
The Appellant challenged the Judgment imposing a death sentence upon him and convicting him in the case registered under Sections 302, 376, 297 and 201 of the Indian Penal Code, 1860.
Cause Title- Reji Kumar Alias Reji v. State of Kerala (Neutral Citation: 2025 INSC 538)
Date of Judgment- April 22, 2025
Coram- Justice Vikram Nath, Justice Sanjay Karol and Justice Sandeep Mehta
23) Modifying conviction by changing entire reasoning cannot be termed as correction of clerical error u/s. 362 CrPC
The Court directed the murder accused to surrender, saying that the High Court committed error in spite of plain and unambiguous words used in Section 362 of the Criminal Procedure Code, 1973 (CrPC).
The Court was dealing with Criminal Appeals challenging the Judgment of the Allahabad High Court in a Criminal Miscellaneous Correction Application which was preferred by the accused persons.
Cause Title- Ramyash @ Lal Bahadur v. The State of Uttar Pradesh and Another Etc. Etc. (Neutral Citation: 2025 INSC 544)
Date of Judgment- April 23, 2025
Coram- Justice B.R. Gavai and Justice Augustine George Masih
24) Seniority reckoned from date of appointment: Supreme Court places 2012 batch of candidates for Civil Judges (Junior Division) in retrospective seniority than another group recruited in same year
The Court placed the 2012 batch of candidates for Civil Judges (Junior Division) higher in seniority than another group recruited in the same year while clarifying that seniority is reckoned from the date of appointment.
The Court partly allowed an Appeal concerning the seniority among Civil Judges in Chhattisgarh (appointed by the Order of the High Court in May, 2012), directing the authorities to place them in seniority to those appointed in July 2012. The Appellants challenged their seniority placement below those appointed in subsequent years (2006, 2008, and 2012).
Cause Title- Pawan Kumar Agrawal & Anr. v. State Of Chhattisgarh & Ors. (Neutral Citation: 2025 INSC 545)
Date of Judgment- April 23, 2025
Coram- Justice B.R. Gavai and Justice Augustine George Masih
25) When one judge has held litigant to be guilty of contempt, another judge of same court can’t hold that no case of contempt was made
The Court observed that when one Judge of the same Court had taken a particular view holding a litigant to be guilty of contempt, it was not permissible for another Single Judge to have revisited the issue as to whether contempt was committed or not.
The Court was considering an Appeal filed against the Judgment passed by a Single Judge of the Delhi High Court whereby the Contempt Petition filed by the Appellants came to be dismissed.
Cause Title- Rajan Chadha & Anr. v. Sanjay Arora (Neutral Citation: 2025 INSC 546)
Date of Judgment- April 23, 2025
Coram- Justice B.R. Gavai and Justice Augustine George Masih
26) Absence of gunshot injury on rioters not a ground to assume inaction: Supreme Court grants relief to police official against disciplinary action in 1984 riots case
The Court granted relief to a police official against the disciplinary action in a case relating to the Anti-Sikh Riots 1984.
The Court was deciding a Civil Appeal filed against the Judgment of the Delhi High Court by which though the Writ Petition was allowed against the Central Administrative Tribunal’s (CAT) Order, liberty was given to the disciplinary authority to issue a fresh note of disagreement within four weeks and pass appropriate orders.
Cause Title- Durga Prasad v. Govt. of NCT of Delhi & Ors. (Neutral Citation: 2025 INSC 548)
Date of Judgment- April 23, 2025
Coram- Justice P.S. Narasimha and Justice Manoj Misra
27) Delay not a reason to deny land losers their just, fair & reasonable compensation
The Court allowed the Appeals filed by the landowners in an acquisition case and observed that delay is not a reason to deny the land losers their compensation, which is just, fair and reasonable for the land they have lost.
The Appeals before the Court were filed challenging the final Judgment passed by the Punjab and Haryana High Court, whereby the delay in preferring the appeals before the High Court was not condoned.
Cause Title- Suresh Kumar v. State of Haryana & Ors. (Neutral Citation: 2025 INSC 550)
Date of Judgment- April 23, 2025
Coram- Justice Sanjay Karol and Justice Manmohan
28) Burden of proving that disease is not attributable to or aggravated by military service rests entirely on employer
The Court held that the burden of proving that the disease is not attributable to or aggravated by military service rests entirely on the employer.
The Court held thus in Civil Appeals preferred against the Order of the Armed Forces Tribunal (AFT), Chandigarh.
Cause Title- Bijender Singh v. Union of India & Ors. (Neutral Citation: 2025 INSC 549)
Date of Judgment- April 23, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
29) First Appellate Court, while examining validity of order rejecting plaint, can see to the contents of plaint & nothing beyond
While dealing with the law relating to rejection of plaint under Order VII Rule 11 of the CPC, the Court explained that in a Regular Appeal pending before the First Appellate Court, the Appellate Court can only examine the validity of the Trial Court's order rejecting the plaint and for the said purpose, the Appellate Court will see to the contents of the plaint and nothing beyond.
The Appeals before the Court were filed by the defendants calling in question the order passed by the High Court rejecting their writ petition under Article 227 of the Constitution which in turn was preferred against the First Appellate Court's common order allowing an application under Order 11 Rule 14 of the Code of Civil Procedure, 1908 and the application seeking permission to raise additional grounds in the first appeal.
Cause Title- Sri Shrikanth Ns & Ors. v. K. Munivenkatappa & Anr. (Neutral Citation: 2025 INSC 557)
Date of Judgment- April 23, 2025
Coram- Justice Dipankar Datta and Justice Prashant Kumar Mishra
30) CBI investigation not open to challenge by prospective suspect: Supreme Court orders CBI investigation into alleged murder of K Raghunath
The Court directed the Central Bureau of Investigation (CBI) to conduct further investigation into the “mysterious death” of K. Raghunath, who was closely related to D.K. Adikeshavalu, a member of Parliament, following allegations of murder made by the deceased’s wife.
The Court held that once an FIR is registered and an investigation has taken place, direction for an investigation by the CBI is not open to challenge by the prospective suspect or accused. The deceased allegedly owned multiple properties and after D.K. Adikeshavalu's death, disputes arose concerning the properties, with allegations that the deceased was pressured to transfer ownership by the close associates of the Appellant.
Cause Title- Ramachandraiah & Anr. v. M. Manjula & Ors. (Neutral Citation: 2025 INSC 556)
Date of Judgment- April 23, 2025
Coram- Justice Dipankar Datta and Justice Prashant Kumar Mishra
31) A person who is not a party to a decree or a document, is not obligated to sue for its cancellation
The Court clarified that a person who is not a party to a decree or a document, is not obligated to sue for its cancellation.
The Court set aside the decision of the Guwahati High Court, which, although it agreed with the Trial Court that the Gift Deed was validly executed, still allowed Appeals dismissing the Appellants' suit. This dismissal was due to the Appellants' absence of challenge against the subsequent sale deed.
Cause Title- Hussain Ahmed Choudhury & Ors. v. Habibur Rahman (Dead) Through Lrs & Ors. (Neutral Citation: 2025 INSC 553)
Date of Judgment- April 23, 2025
Coram- Justice JB Pardiwala and Justice R Mahadevan
32) Employee’s right to receive report is part of reasonable opportunity of defending himself in first stage of enquiry
The Court held that the employee’s right to receive the report is a part of the reasonable opportunity of defending himself/herself in the first stage of the enquiry.
The Court held thus in a Civil Appeal filed by the Uttar Pradesh State against the Judgment of the Allahabad High Court which dismissed its Writ Petition challenging the Uttar Pradesh State Public Services Tribunal’s Order.
Cause Title- State of Uttar Pradesh v. Ram Prakash Singh (Neutral Citation: 2025 INSC 555)
Date of Judgment- April 23, 2025
Coram- Justice Dipankar Datta and Justice Prashant Kumar Mishra
33) Mere suspicion should not be allowed to take the place of proof even in domestic enquiries
The Court reiterated that mere suspicion should not be allowed to take the place of proof even in domestic enquiries.
The Court reiterated thus in a Civil Appeal preferred against the Judgment of the Patna High Court, which allowed an Intra-Court Appeal arising from a Writ Petition presented before the High Court.
Cause Title- Maharana Pratap Singh v. The State of Bihar & Ors. (Neutral Citation: 2025 INSC 554)
Date of Judgment- April 23, 2025
Coram- Justice Dipankar Datta and Justice Prashant Kumar Mishra
34) Plaintiff needs to file suit for declaration where his title is under a cloud & he is not in possession
The Court reiterated that the Plaintiff is required to file a Suit for declaration, possession, and injunction where his title is under a cloud and he is not in possession.
The Court reiterated thus in a Civil Appeal filed by the Defendants in a Suit for cancellation of Sale Deeds, recovery of possession and injunction, challenging the Judgment of the Allahabad High Court.
Cause Title- Rajeev Gupta & Ors. v. Prashant Garg & Ors. (Neutral Citation: 2025 INSC 552)
Date of Judgment- April 23, 2025
Coram- Justice Dipankar Datta and Justice Prashant Kumar Mishra
35) Sikkim employee who had availed leave encashment benefit maximum of 300 days not entitled for it again on relieving after re-employment
The Court held that an employee of the Sikkim State who had availed the benefit of leave encashment maximum of 300 days cannot further be entitled for leave encashment again on relieving after the period of re-employment.
The Court held thus in Civil Appeals preferred against the Order of the Sikkim High Court in which there was a discord between the parties regarding grant of leave encashment benefit second time for the period of re-employment after attaining the age of superannuation.
Cause Title- State of Sikkim and Others v. Dr. Mool Raj Kotwal (Neutral Citation: 2025 INSC 559)
Date of Judgment- April 23, 2025
Coram- Justice J.K. Maheshwari and Justice Rajesh Bindal
36) He was not the authorized officer at the relevant time: Supreme Court quashes cheating case against HDFC Bank manager
The Court quashed a case of cheating against a man working as a Manager at HDFC Bank after finding that the sale certificate was issued by a predecessor employee and the accused had no role to play in the transaction leading to the FIR as he was not an authorized officer at the time of the incident.
The Appeals before the Court were preferred by the accused-appellant against the common judgment passed by the Madras High Court dismissing the appellant’s petition under Section 482 of the Code of Criminal Procedure, 1973 to quash the chargesheet and consequential proceedings arising out of a criminal case.
Cause Title- Sivakumar v. The Inspector of Police & Anr. (Neutral Citation: 2025 INSC 558)
Date of Judgment- April 23, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
37) Cognizance order by Magistrate cannot be faulted only because it’s not a reasoned order
The Court reiterated that the Order of the Magistrate taking cognizance cannot be faulted only because it is not a reasoned Order.
The Court set aside the Order of the Jharkhand High Court that had set aside a cognizance Order under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) by the Additional Judicial Commissioner.
Cause Title- Pramila Devi & Ors. v. The State Of Jharkhand & Anr. (Neutral Citation: 2025 INSC 560)
Date of Judgment- April 23, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
38) Material contradiction in statement of prosecutrix as to the date of commission of rape: Supreme Court upholds acquittal of 2 men
The Court upheld the Order of acquittal passed in favour of two rape accused after noting the material contradiction in the statement of the Prosecutrix as to the date of commission of rape. It also considered the fact that no allegations of rape were made against one out of the two accused persons.
The Appeals before the Court called into question the impugned Judgment of acquittal passed by the Himachal Pradesh High Court, setting aside the conviction and sentence of accused Sanjay Kumar under Sections 363, 366, 376 and 201 read with Section 34 of the Indian Penal Code, 1860, and accused Chaman Shukla under Section 201 read with Section 34 IPC.
Cause Title- State of Himachal Pradesh v. Sanjay Kumar (Neutral Citation: 2025 INSC 561)
Date of Judgment- April 23, 2025
Coram- Justice Ahsanuddin Amanullah and Justice Prashant Kumar Mishra
39) Supreme Court highlights growing trend of dowry victims arraigning relatives of husband, quashes case against sister-in-law & other family members
While quashing a case filed by a woman against her sister-in-law and other family members, the Court highlighted the growing trend of the dowry victim arraigning the relatives of the husband in dowry-related matters.
The Appeal before the Court was filed by the Appellants challenging the Order passed by the High Court whereby their Petition under Section 482 CrPC for quashing proceedings on the file of the Special Judicial Magistrate, Ist Class for Prohibition & Excise Cases was dismissed.
Cause Title- Muppidi Lakshmi Narayana Reddy & Ors. v. The State of Andhra Pradesh & Anr. (Neutral Citation: 2025 INSC 562)
Date of Judgment- April 23, 2025
Coram- Justice Ahsanuddin Amanullah and Justice Prashant Kumar Mishra
40) Individual excellence may sometimes lead to superiority complex: Supreme Court dismisses IAS Officer Raju Narayana Swamy's plea for promotion
The Court dismissed an Appeal by Raju Narayana Swamy, an IAS officer, challenging his non-promotion to the grade of Chief Secretary in Kerala, while remarking that “Individual excellence may sometimes lead to superiority complex and hinder commitment to discipline, decorum and collegiality.” While noting that the essential requisite of collective leadership in the highest echelons of civil service, the Court stated that “the Committee was justified in giving due weightage to lack of adherence to discipline and collegiality.”
The Court refused to interfere with the decision of the Kerala High Court, which noted that 90% of the Appellant’s Annual Confidential Reports (ACR) were not available and the Screening Committee was “handicapped” in considering his case.
Cause Title- Raju Narayana Swamy v. State of Kerala & Ors. (Neutral Citation: 2025 INSC 563)
Date of Judgment- April 23, 2025
Coram- Justice Pamidighantam Sri Narasimha and Justice Joymalya Bagchi
41) In absence of provision for making representation against final orders, remedy of aggrieved public servant challenging adverse action of authorities would lie directly before CAT
While considering a service matter concerning a retired TV News and Film Librarian at Doordarshan Kendra, the Court held that if the relevant service rules do not provide for making of a representation against final orders, the remedy of the aggrieved applicant-public servant would lie directly before the CAT in challenging the adverse order/action of the authorities. In such a case, an original application can’t be rejected mechanically on the ground that all “remedies” have not been exhausted.
The challenge in the Appeal was made to a short Order of the Karnataka High Court dismissing a Writ Petition challenging a Judgment of the Central Administrative Tribunal, Bengaluru whereby it allowed an original application of the Respondent.
Cause Title- The Chief Executive Officer & Others v. S. Lalitha & Others (Neutral Citation: 2025 INSC 565)
Date of Judgment- April 24, 2025
Coram- Justice Dipankar Datta and Justice Rajesh Bindal
42) Bona fide requirement for occupation of landlord must be liberally construed; requirement of family members also covered
The Court reiterated that the bona fide requirement for occupation of the landlord must be liberally construed and the requirement of the family members is also covered.
The Court was hearing a Civil Appeal filed against the Judgment of the Allahabad High Court which confirmed the Appellate Authority’s Order directing eviction on the ground of bona fide need.
Cause Title- Murlidhar Aggarwal (D.) Thr. His LR. Atul Kumar Aggarwal v. Mahendra Pratap Kakan (D.) Thr. LRs. and Ors. (Neutral Citation: 2025 INSC 564)
Date of Judgment- April 24, 2025
Coram- Justice M.M. Sundresh and Justice K.V. Viswanathan
43) Order of dismissal of suit in default cannot operate as Res Judicata
The Court explained that an Order of dismissal of a suit under Rule 2 or Rule 3 of Order IX of the C.P.C. does not fulfil the requirement of the term “judgment” or “decree”, since there is no adjudication. Thus, if a fresh suit is filed, then such an order of dismissal cannot and shall not operate as res judicata.
The Petition before the Court was filed against the Judgment of the Chhattisgarh High Court by which the Second Appeal filed by the respondents (original plaintiffs) came to be allowed, and the judgment passed by the First Appellate Court reversing the decree passed by the Trial Court came to be set aside.
Cause Title- Amruddin Ansari (Dead)through Lrs & Ors. v. Afajal Ali & Ors (Neutral Citation: 2025 INSC 566)
Date of Judgment- April 22, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
44) Misguiding Court to obtain an order with no intention of compliance amounts to contempt of court
The Court observed that misleading the Court to obtain an order with no intention to comply with it constitutes an act of overawing the due process of law, thus amounting to contempt of Court.
The Court found the Respondent guilty of Civil Contempt for non-compliance of its previous Order and imposed a punishment of simple imprisonment for three months along with fine of Rs. 20K. It said that misusing the process of Court to tarnish the judiciary's image and threaten its integrity and efficiency cannot be overlooked in the garb of non-fulfilment of its directions due to claimed financial constraints.
Cause Title- M/S Chithra Woods Manors Welfare Association v. Shaji Augustine (Neutral Citation: 2025 INSC 567)
Date of Judgment- April 24, 2025
Coram- Justice Abhay S Oka and Justice Augustine George Masih
45) Supreme Court sets aside order quashing FIR u/s. 420 IPC; says company establishing shell companies & circulating monetary transaction through them suggests intent to deceive
The Court set aside an Order quashing the FIR under Sections 420, 406 and 120B of the IPC, stating that a company establishing shell companies and circulating monetary transactions through them is an indicator of an intention of deceit.
The Court allowed an Appeal challenging the decision of the Rajasthan High Court, which quashed an FIR registered under Sections 420, 406 and 120B of the IPC by the Appellant seeking investigation into alleged dishonest and fraudulent acts of the accused Company and its concerned Directors/Decision makers.
Cause Title- Dinesh Sharma v. Emgee Cables And Communication Ltd. & Anr. (Neutral Citation: 2025 INSC 571)
Date of Judgment- April 23, 2025
Coram- Justice Bela M Trivedi and Justice Prasanna B Varale
46) Order XLIII Rule 1A CPC doesn’t create independent Appeal; party to suit who denies the compromise must first approach Trial Court
The Court observed that Order XLIII Rule 1-A does not create a new right of appeal. It merely enables an appellant, already before the Appellate Court, to attack the decree on the ground that the compromise should not have been recorded.
The Appeals before the Court were filed by the appellant assailing the judgment rendered by a Larger Bench of the Gujarat High Court on a reference arising out of an Appeal. The High Court concluded that a litigant who was already a party to the suit, but disputes the existence or validity of a compromise recorded under Order XXIII Rule 3 of the Code of Civil Procedure, 19082 must first approach the Trial Court; a First Appeal under Section 96 of the CPC, it held, is available only to a person who was not on the record of the suit.
Cause Title- Sakina Sultanali Sunesara (Momin) v. Shia Imami Ismaili Momin Jamat Samaj & Ors. (Neutral Citation: 2025 INSC 570)
Date of Judgment- April 23, 2025
Coram- Justice Vikram Nath and Justice Prasanna B. Varale
47) Setting aside administrative action on grounds of violation of natural justice principles doesn’t bar authorities from proceeding afresh
The Court held that setting aside of an administrative action on the grounds of violation of the principles of natural justice does not bar the administrative authorities from proceeding afresh.
The Court held thus in a batch of Criminal Appeals preferred against the Orders of the High Courts which quashed the administrative actions initiated in pursuance of the Master Directions as well as FIRs and subsequent criminal proceedings.
Cause Title- Central Bureau of Investigation v. Surendra Patwa & Ors. (Neutral Citation: 2025 INSC 572)
Date of Judgment- April 25, 2025
Coram- Justice M.M. Sundresh and Justice Rajesh Bindal
48) Govt. has every right to cancel & call for fresh tender if it protects financial interests of the State
The Court held that since the Government is the protector of financial resources of the state, it thus has every right to cancel and call for fresh tender if it is in the nature of protecting the financial interests of the State.
The Court set aside the decision of the Kerala High Court, which set aside the re-tender notification issued by the Divisional Forest Officer ( DFO). The Court pointed out that the e-Government procurement notice inviting tender for works explicitly stated that the tender inviting authority or other sanctioning authority reserved the right to reject any tender or all the tenders without assigning any reason.
Cause Title- The Principal Chief Conservator of Forest & Ors. v. Suresh Mathew & Ors. (Neutral Citation: 2025 INSC 569)
Date of Judgment- April 25, 2025
Coram- Justice Bela M Trivedi and Justice Prasanna B Varale
49) Demarcate plots & public facilities in feasible way to ensure that maximum allottees can be accommodated: Supreme Court directs State of Haryana
The Court in a case directed the Haryana State to demarcate plots and public facilities in a feasible way to ensure that maximum number of allottees can be accommodated.
The Court was dealing with a batch of Miscellaneous Applications along with a Writ Petition filed by Okhla Enclave Plot Holders Welfare Association and others.
Cause Title- Okhla Enclave Plot Holders Welfare Association v. Union of India through Secretary & Ors. (Neutral Citation: 2025 INSC 573)
Date of Judgment- April 25, 2025
Coram- Justice Vikram Nath and Justice Prasanna B. Varale
50) POCSO Act- Inappropriate behaviour like asking invasive questions, sending vulgar images sufficient to infer sexual intent
While slamming the High Court for denying justice to the victims of offences under the Protection of Children from Sexual Offences Act, 2012 (POCSO Act), the Court restored the case against a teacher accused of holding the hands of the students in the computer lab and acting inappropriately.
The Court was considering an Appeal challenging the Order quashing the criminal charges against the accused teacher.
Cause Title- X Etc. v. Rajesh Kumar & Ors. (Neutral Citation: 2025 INSC 579)
Date of Judgment- April 23, 2025
Coram- Justice Surya Kant and Justice Nongmeikapam Kotiswar Singh
51) State exchequer could have benefited by accepting tender: Supreme Court sets aside Orissa High Court Order directing fresh issuance of sand quarry tender
The Court set aside an Order of the Orissa High Court directing the issuance of a fresh Tender in respect of Karangadihi Sand Quarry and observed that there was no reason for the revenue authorities to turn down the selected bid as the state exchequer could have been benefitted by accepting the tender.
The challenge in the Appeals before the Court was made to the Order whereby the Orissa High Court directed for fresh tender in respect of Karangadihi Sand Quarry.
Cause Title- M/S Sri Venkateswara Constructions v. State of Odisha & Ors. (Neutral Citation: 2025 INSC 580)
Date of Judgment- April 25, 2025
Coram- Justice Bela M. Trivedi and Justice Prasanna B. Varale
52) Rare case where complainant has not unnecessarily implicated other family members: Supreme Court upholds mother-in-law’s conviction for abetment to suicide
The Court upheld the conviction of an elderly woman for abetting her pregnant daughter-in-law’s suicide and highlighted that the matter at hand was one of the rare cases where the complainant had displayed honesty and not unnecessarily implicated other family members of the husband of the deceased by making omnibus allegations against all of them.
The Appeal before the Court was preferred by the sole accused against the Order of the Allahabad High Court in a Criminal Appeal wherein the Appellant’s conviction under Sections 304B and 498A of the Indian Penal Code, 1860 and Sections 3 and 4 of the Dowry Prohibition Act, 1961 was converted into that under Section 306 of the IPC with sentence of 3 years rigorous imprisonment.
Cause Title- Shakuntla Devi v. The State of Uttar Pradesh (Neutral Citation: 2025 INSC 581)
Date of Judgment- April 25, 2025
Coram- Justice Vikram Nath and Justice Sanjay Karol
53) Jurisdictional issue can't be raised before Revisional Court when it was not raised before Small Causes Court: Supreme Court upholds eviction order
The Court upheld an eviction order observing that the jurisdictional issue could not be raised before the Revisional Court when it was not raised before the Small Causes Court. The Revisional Court had only to note whether the decree granted by the Trial Court was just and proper or not, it said.
The Court was considering a matter relating to a landlord-tenant dispute.
Cause Title- Amit Kumar v. Nihal Singh & Ors. (Neutral Citation: 2025 INSC 584)
Date of Judgment- April 23, 2025
Coram- Justice B.V. Nagarathna and Justice Sanjay Karol
