Weekly Overview| Supreme Court Judgments: January 20 – January 24, 2025
1) Certain Punjab Govt. officials stooped low to punish a senior doctor nearing retirement for challenging the executive in Court: SC deprecates ‘vile acts’ of State officials
The Court deprecated “vile acts” of State Officials while observing that certain officials of the Government of Punjab have stooped too low to punish a senior doctor, on the verge of retirement, for daring to take them to the Court.
The Court set aside the dismissal Order and the disciplinary proceedings initiated against a Senior Medical Officer (Appellant) eleven days before his retirement. It held that even though the Division Bench of the Punjab and Haryana High Court set aside the penalty of a 2% permanent cut in pension imposed on the Appellant, it ought to have set things right by interfering with the findings and granting full relief to the Appellant.
Cause Title- Bhupinderpal Singh Gill v. State Of Punjab & Ors. (Neutral Citation: 2025 INSC 83)
Date of Judgment- January 20, 2025
Coram- Justice Dipankar Datta and Justice Manmohan
2) Value of goods for computation of excise duty will be transaction value only if all 3 conditions u/s 4(1)(a) Central Excise Act are fulfilled
The Court held that the value of the goods for the purpose of computation of excise duty will be the transaction value only if all three conditions under Section 4(1)(a) of the Central Excise Act, 1944 are fulfilled.
The Court held thus in a batch of Civil Appeals in which one of the Appeals was filed by Bharat Petroleum Corporation Ltd. (BPCL), a public sector undertaking.
Cause Title- Bharat Petroleum Corporation Ltd. v. Commissioner of Central Excise Nashik Commissionerate (Neutral Citation: 2025 INSC 84)
Date of Judgment- January 20, 2025
Coram- Justice Abhay S. Oka and Justice Pankaj Mithal
3) Asking deceased not to be alive if she cannot live without marrying her lover will not gain the status of abetment of suicide
The Court held that a remark such as asking the deceased to not be alive if she cannot live without marrying her lover will not gain the status of abetment of suicide.
The Court quashed the charges under Section 306 of the IPC against the Appellant accused of abetment of suicide. The Court partly set aside the Orders of the Calcutta High Court which had quashed the chargesheet only against two of the accused while rejecting the application preferred by the Appellant (Accused no. 4).
Cause Title- Laxmi Das v. State Of West Bengal & Ors. (Neutral Citation: 2025 INSC 86)
Date of Judgment- January 21, 2025
Coram- Justice BV Nagarathna and Justice Satish Chandra Sharma
4) State Government can levy royalty on production & disposal of brick earth as it is a minor mineral
The Court observed that the State Government gets the right to levy royalty on the production and disposal of brick earth as the same has been declared as a minor mineral under the Mineral Rules.
The Appellants approached the Apex Court challenging the judgment whereby the suit seeking permanent injunction restraining the appellants from recovering royalty was decreed in the favour of the Respondents.
Cause Title- State of Punjab & Ors. v. M/s Om Prakash Brick Kiln Owner, Etc. (Neutral Citation: 2025 INSC 88)
Date of Judgment- January 21, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
5) Exercise of powers by disciplinary authority is always subject to principles of proportionality & fair play
The Court reiterated that the exercise of powers by the disciplinary authority is always subject to principles of proportionality and fair play.
The Court was deciding a Civil Appeal filed by the General Manager Personnel, Syndicate Bank against an employee who was dismissed from his service.
Cause Title- The General Manager Personnel Syndicate Bank & Ors. v. B S N Prasad (Neutral Citation: 2025 INSC 89)
Date of Judgment- January 21, 2025
Coram- Justice Abhay S. Oka and Justice Augustine George Masih
6) A litigant coming to court can’t claim negative discrimination seeking direction to department to act in violation of law or rules
The Court observed that a litigant coming to the Court cannot claim negative discrimination seeking direction from the Court to the department to act in violation of the law or statutory Rules.
The Court observed thus in a Special Leave Petition (SLP) seeking to examine the validity of an Order where the parties failed to produce proper documents or annexed incorrectly typed documents.
Cause Title- Jyostnamayee Mishra v. The State of Odisha and Ors. (Neutral Citation: 2025 INSC 87)
Date of Judgment- January 20, 2025
Coram- Justice J.K. Maheshwari and Justice Rajesh Bindal
7) Maintainability of Writ Petition against Orders passed by Micro & Small Enterprises Facilitation Council u/s 18 MSMED Act: Supreme Court refers issue to larger Bench
The Court referred the issue regarding the maintainability of Writ Petitions under Article 226 of the Constitution against orders passed by the Micro and Small Enterprises Facilitation Council under Section 18 of the MSME Act to a larger bench.
The Court pointed out that Pre-deposit was a condition for hearing a decision on the objections to the award. Therefore, another issue which needed consideration was whether there would be an absolute and complete bar to invoke the Writ Jurisdiction under Article 226 of the Constitution even in exceptional and rare cases where fairness, equity and justice were warranted.
Cause Title- M/s Tamil Nadu Cements Corporation Limited v. Micro and Small Enterprises Facilitation Council & Anr. (Neutral Citation: 2025 INSC 91)
Date of Judgment- January 22, 2025
Coram- CJI Sanjiv Khanna, Justice Sanjay Kumar and Justice Manmohan
8) No case is made out: SC rejects State’s plea challenging quashing of FIR against MPs Nishikant Dubey & Manoj Tiwari
The Court dismissed an Appeal filed by the State challenging the Jharkhand High Court's decision to quash an FIR against Members of Parliament (MP) Nishikant Dubey and Manoj Tiwari.
The Court upheld the Jharkhand High Court’s decision of quashing the FIR against the Respondents who were accused of barging into the Air Traffic Control (ATC) room at Deoghar Airport and creating pressure on the officials to grant take-off clearance for a chartered flight. The FIR was registered under Sections 336, 447, and 448 of the IPC and Sections 10 and 11A of the Aircraft Act, 1934 (the Act).
Cause Title- State of Jharkhand v. Nishkant Dubey & Ors. (Neutral Citation: 2025 INSC 94)
Date of Judgment- January 21, 2025
Coram- Justice Abhay S Oka and Justice Manmohan
9) Mere conjectures or hypothetical inconsistencies can’t form basis for acquittal when evidence points to the guilt of accused
The Court held that mere conjectures or hypothetical inconsistencies cannot form the basis for acquittal when the evidence points to the guilt of the accused.
The Court held thus in a Criminal Appeal filed under Section 2(a) of the Supreme Court (Enlargement of Criminal Appellate Jurisdiction) Act, 1970, read with Section 379 of the Code of Criminal Procedure, 1973 (CrPC) against the Judgment of conviction.
Cause Title- Baban Shankar Daphal & Ors. v. The State of Maharashtra (Neutral Citation: 2025 INSC 97)
Date of Judgment- January 22, 2025
Coram- Justice Vikram Nath and Justice Prasanna B. Varale
10) "We understand concerns of a mother of a teenage daughter": SC orders Court appointed female commissioner to be present during father’s visitation meetings
In a child custody matter, the Court ordered a female Commissioner to be present during the father-daughter visitation meetings in light of the allegations made by the mother regarding the father’s alleged history of abusive behaviour, criminal charges and past incidents of conflict during visitation.
The Petition before the Court arose from an Order of the Chhattisgarh High Court granting specified visitation rights to the Respondent – father in his appeal against the dismissal of his petition seeking custody of the child before the Family Court.
Cause Title- A v. B (Neutral Citation: 2025 INSC 99)
Date of Judgment- January 22, 2025
Coram- Justice Vikram Nath and Justice Prasanna B. Varale
11) Granting interim bail to accused for election campaigning might open pandora's box: Supreme Court in Tahir Hussain’s case
The Court while dealing with former AAP (Aam Aadmi Party) Councillor and Delhi Riots accused Mohd. Tahir Hussain’s Special Leave Petition (SLP), expressed its concern over granting of interim bail to the convicts for election campaigns.
The Court delivered a Split Verdict but agreed on the fact that pandora’s box cannot be opened by letting convicts or under-trial prisoners seek release for election campaigns.
Cause Title- Mohd. Tahir Hussain v. State of NCT of Delhi (Neutral Citation: 2025 INSC 100)
Date of Judgment- January 22, 2025
Coram- Justice Pankaj Mithal and Justice Ahsanuddin Amanullah
12) HC not to comment on merits when scope of Appeal is limited to examining correctness of Order declining condonation of delay
The Court restored two appeals filed by the appellants-allottees to the Maharashtra Real Estate Appellate Tribunal and observed that the Bombay High Court ought not to have commented upon the merits of the orders when the scope of the appeal was limited to examining the correctness of the order declining condonation of delay.
The Court was considering two appeals assailing a common judgment of the Bombay High Court passed in the Second Appeal.
Cause Title- Surendra G. Shankar & Anr. v. Esque Finamark Pvt. Ltd & Ors. (Neutral Citation: 2025 INSC 102)
Date of Judgment- January 22, 2025
Coram- Justice Pamidighantam Sri Narasimha and Justice Manoj Misra
13) Mere assertion of ‘filthy language’ alleged in complaint is not sufficient to establish an offence u/s. 509 IPC
The Court held that the mere assertion of "filthy language" alleged in a complaint is not sufficient to establish the commission of an offence under Section 509 of the IPC.
The Court set aside the impugned Order of the Karnataka High Court which dismissed the Criminal Petition filed under Section 482 of the CrPC by the management officials (Appellants) of the company seeking quashing of the criminal proceedings under Sections 323, 504, 506, 509 and 511 of the IPC initiated by a former employee.
Cause Title- Madhushree Datta v. The State Of Karnataka & Anr. (Neutral Citation: 2025 INSC 105)
Date of Judgment- January 24, 2025
Coram- Justice Dipankar Datta and Justice Prashant Kumar Mishra
14) Revenue authority lacks statutory mandate to review its own final Orders; Jurisdiction cannot be created by consent or waiver
The Court clarified that the Chief Controlling Revenue Authority does not have the statutory mandate to review its own final Orders explaining that such jurisdiction cannot be created by consent of waiver.
The Court allowed an Appeal assailing the decision of the Bombay High Court concerning the rejection of the Appellants’ claim for refund of stamp duty under the Maharashtra Stamp Act, 1958 (the Act) by the Chief Controlling Revenue Authority, Maharashtra State (CCRA/Revenue Authority). The Bombay High Court had upheld the rejection of the refund claim as time-barred.
Cause Title- Harshit Harish Jain & Anr. v. The State of Maharashtra & Ors. (Neutral Citation: 2025 INSC 104)
Date of Judgment- January 24, 2025
Coram- Justice Vikram Nath, Justice Sanjay Karol and Justice Sandeep Mehta
15) SC directs husband to pay Rs. 3 lakhs in compensation to wife for subjecting her to harassment by making unlawful dowry demand
The Court directed a husband to pay Rs. 3 Lakhs in compensation to the wife for subjecting her to harassment by making unlawful demands for gold sovereigns in dowry.
The Court partly allowed the Appeal by the husband (Appellant) by confirming his conviction under Section 498A of the IPC and Section 4 of the Dowry Prohibition Act, 1961 (DP Act), but modified the sentence of imprisonment to the period already undergone. The Madras High Court too had confirmed the conviction but modified the sentence from three years of imprisonment to two years.
Cause Title- M. Venkateswaran v. The State (Neutral Citation: 2025 INSC 106)
Date of Judgment- January 24, 2025
Coram- Justice KV Viswanathan and Justice SVN Bhatti
16) Employability of a person with serious head injuries is a circumstance to be considered for determining loss of income
The Court held that the employability of a person with serious head injuries is a circumstance which has to be kept in perspective for determining the loss of income of the victim of a motor accident.
The Court partly allowed the Appeal filed by the legal representatives of the deceased motor accident victim against the Oriental Insurance Company Limited (Insurer) for enhanced compensation.
Cause Title- T. Rajamoni v. The Manager, Oriental Insurance Company Limited & Anr. (Neutral Citation: 2025 INSC 107)
Date of Judgment- January 24, 2025
Coram- Justice KV Viswanathan and Justice SVN Bhatti
17) Case of sheer negligence & dereliction of duty on part of Investigating Agency & Public Prosecutor for not conducting Test Identification Parade: SC Orders acquittal in murder case
The Court ordered the acquittal of accused persons in a 24-yr-old murder case and observed that the present matter was a case of sheer negligence and dereliction of duty on the part of the Investigating Agency and the Public Prosecutor for not conducting Test Identification Parade(TIP).
The Court was considering an appeal challenging the judgment of the Karnataka High Court whereby the order confirming the conviction of the accused-appellants was upheld. One out of the three accused persons passed away during the pendency of the matter and his appeal was dismissed as abated.
Cause Title- Thammaraya and Another v. The State of Karnataka (Neutral Citation:2025 INSC 108)
Date of Judgment- January 22, 2025
Coram- Justice Vikram Nath, Justice Sanjay Karol and Justice Sandeep Mehta
