Weekly Overview| Supreme Court Judgments: January 27 – January 31, 2025
1) After split verdict Supreme Court orders burial of pastor in designated place away from village
The Court gave a split verdict on the issue of place of burial of a pastor, whose body is lying in a mortuary in Chhattisgarh since January 7, and directed that he be buried at a designated place for Christian burials.
Taking into account that the body of the pastor has been lying in the morgue since January 7 due to a dispute over the place of burial, the bench said it will not refer the matter to a larger bench and directed that the burial be held at a designated place, which is 20 km away from Chhindawada village of the State.
Cause Title- Ramesh Baghel v. State of Chhattisgarh & Others (Neutral Citation: 2025 INSC 109)
Date of Judgment- January 27, 2025
Coram- Justice B.V. Nagarathna and Justice Satish Chandra Sharma
2) Fundamental defect in enquiry was not employee’s fault: SC orders bank to grant retrospective promotion with monetary benefits to employee
The Court ordered the Bank of Baroda to grant a retrospective promotion to a former employee with all monetary benefits since the fundamental defect in the enquiry of his case was due to no fault of the employee.
The Court partly allowed the Appeal challenging the Judgment of the Telangana High Court which held that promotion up to Scale-V cannot be granted to the Appellant as there was no adjudication in the order of the Writ Court.
Cause Title- K Samba Moorthy v. Sanjiv Chadha & Ors. (Neutral Citation: 2025 INSC 110)
Date of Judgment- January 27, 2025
Coram- Justice BR Gavai and Justice KV Viswanathan
3) Consent required only when a jointly owned or leased out property is offered for distributorship by co-owners or co-lessee
The Court held that the consent of from all co-owners or co- lessees is required when a jointly owned or jointly leased out property is offered for distributorship by one of the co-owners or a co-lessee.
The Court dismissed the Appeal challenging the allotment of an LPG distributorship wherein the Punjab and Haryana High Court rejected the Appellant’s contention that the successful applicant’s (Respondent) distributorship application suffered from disqualification.
Cause Title- Jagwant Kaur v. Union of India & Ors. (Neutral Citation: 2025 INSC 112)
Date of Judgment- January 27, 2025
Coram- Justice Sudhanshu Dhulia and Justice K. Vinod Chandran
4) A great deal of restraint required while examining validity of arbitral award when it’s upheld wholly or substantially u/s 34 A&C Act
The Court reiterated that a great deal of restraint is required while examining the validity of an Arbitral Award when the same has been upheld wholly or substantially under Section 34 of the Arbitration and Conciliation Act, 1994 (A&C Act).
The Court reiterated thus in a Civil Appeal preferred against the Judgment of the Delhi High Court by which it allowed the Appeal of the National Highways Authority of India (NHAI) under Section 37 of the A&C Act.
Cause Title- Somdatt Builders –NCC – NEC(JV) v. National Highways Authority of India & Ors. (Neutral Citation: 2025 INSC 113)
Date of Judgment- January 27, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
5) Prosecution failed to show common intention: Supreme Court quashes HC’s conviction of 3 policemen in murder case
While holding that the prosecution failed to show that the policemen had common intention with the accused in a murder case, the Court quashed the order of their conviction by the High Court and affirmed the earlier acquittal by the Trial Court.
The Court allowed the Appeal by three policemen (Appellants) accused under Section 302 read with Section 34 of the IPC and Section 27(1) of the Arms Act, 1959 challenging the Order of conviction by the Uttarakhand High Court which set aside the order of acquittal qua the Appellants.
Cause Title- Constable 907 Surendra Singh & Anr. v. State Of Uttarakhand (Neutral Citation: 2025 INSC 114)
Date of Judgment- January 28, 2025
Coram- Justice B.R. Gavai and Justice Augustine George Masih
6) Legitimacy determines paternity u/s 112 Evidence Act until presumption is successfully rebutted by proving ‘non-access’
The Court held that the legitimacy determines paternity under Section 112 of the Indian Evidence Act, 1872 (IEA), until the presumption is successfully rebutted by proving ‘non-access’.
The Court was deciding a Criminal Appeal preferred against the Judgment of the Kerala High Court which upheld the Family Court’s Order, reviving a Maintenance Petition.
Cause Title- Ivan Rathinam v. Milan Joseph (Neutral Citation: 2025 INSC 115)
Date of Judgment- January 28, 2025
Coram- Justice Surya Kant and Justice Ujjal Bhuyan
7) Certificate u/s 65b(4) Evidence Act is a condition precedent to admissibility of evidence by way of electronic record
The Court held that a certificate under Section 65B(4) of the Indian Evidence Act is a condition precedent to the admissibility of evidence by way of electronic record.
The Court acquitted and set aside the death penalty awarded to a man (Appellant) for the rape and murder of a 23-year-old woman. The Bench allowed the Appeal filed by the Appellant challenging the Judgment of the Bombay High Court which upheld his conviction and the sentence of death imposed by the Trial Court under Sections 302, 364, 366, 376(2)(m), 376A, 392 read with Section 397 and 201 of the IPC.
Cause Title- Chandrabhan Sudam Sanap v. The State Of Maharashtra (Neutral Citation: 2025 INSC 116)
Date of Judgment- January 28, 2025
Coram- Justice BR Gavai, Justice Prashant Kumar Mishra and Justice KV Viswanathan
8) "Most vulnerable to exploitation": Supreme Court urges Centre to bring legal framework for protection of rights of domestic workers
Taking note of the fact that domestic workers lack legal protection in India, the Supreme Court directed the Central Government to consider the desirability of recommending a legal framework for the benefit, protection and regulation of the rights of domestic workers.
The Court passed such a direction while considering the appeals arising from a First Information Report containing allegations of wrongful confinement and trafficking of a female domestic worker-complainant.
Cause Title- Ajay Malik v. State of Uttarakhand and Anr. (Neutral Citation: 2025 INSC 118)
Date of Judgment- January 29, 2025
Coram- Justice Surya Kant and Justice Ujjal Bhuyan
9) Material omissions amount to contradiction: SC acquits murder accused who suffered incarceration for more than 12 years
The Court acquitted the appellant-convict, who suffered incarceration for more than 12 years in a murder case after noting that there were material omissions in the testimonies of two witnesses which would amount to contradiction.
The Court was considering a criminal Appeal challenging the Kerala High Court judgment affirming the conviction of the Appellant in a case registered under Section 302 of the Indian Penal Code, 1860.
Cause Title- Vinobhai v. State of Kerala (Neutral Citation: 2025 INSC 119)
Date of Judgment- January 29, 2025
Coram- Justice Abhay S Oka and Justice Ujjal Bhuyan
10) Even if Court or defence counsel overlooks accused's entitlement to any legitimate benefit during trial, Public Prosecutor should bring it to Court’s attention
The Court held that even if the Court or the defence counsel overlooks an accused entitlement to any legitimate benefit during trial, the Public Prosecutor has the added responsibility to bring it to the notice of the Court, if it comes to their knowledge.
The Court allowed the Appeal challenging the Order of the Punjab and Haryana High Court that set aside the acquittal granted by the Trial Court in a 1998 murder case and in turn convicted the Appellants for life for murder. The Court reiterated that sub-section (3) of Section 401 of the CrPC prohibits/bars the High Court from converting a finding of acquittal into one of conviction.
Cause Title- Mahabir & Ors. v. State Of Haryana (Neutral Citation: 2025 INSC 120)
Date of Judgment- January 29, 2025
Coram- Justice JB Pardiwala and Justice R Mahadevan
11) If transferee pendente lite does not come on record, he is bound by Judgment even though he remains unrepresented
The Court held that, if the transferee pendente lite does not come on record, the concept of him not being bound by the Judgment does not arise and consequently he would be bound by the result of the litigation, though he remains unrepresented.
The Court held thus a batch of Civil Appeals challenging the Order of the Karnataka High Court by which it allowed Applications and condoned the delay of 586 days in filing the Appeal.
Cause Title- H. Anjanappa & Ors. v. A. Prabhakar & Ors. (Neutral Citation: 2025 INSC 121)
Date of Judgment- January 29, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
12) SC sets aside HC’s reduction of MACT compensation; rejects claim that children did not suffer any pecuniary loss by gaining partnership in deceased parent’s firm
The Court set aside the High Court’s Order, which had drastically reduced the compensation awarded by the MACT, rejecting the claim that the children did not suffer any pecuniary loss as they stepped into their deceased parents’ shoes by becoming partners in their firm.
The Court restored the compensation awarded by the Motor Accidents Claims Tribunal (MACT). The Appeal was filed by the children (Appellants) of the Deceased parents challenging the decision of the Madras High Court which reduced the compensation awarded by the MACT.
Cause Title- S. Vishnu Ganga & Ors. v. M/S Oriental Insurance Company Limited & Ors. (Neutral Citation: 2025 INSC 123)
Date of Judgment- January 29, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
13) CCI’s approval of proposed combination must be obtained before approval of Resolution Plan by CoC u/s 31(4) IBC
The Court held that the approval of a proposed combination by the Competition Commission of India (CCI) must be obtained before the approval of Resolution Plan by the Committee of Creditors (CoC) under Section 31(4) of the Insolvency and Bankruptcy Code, 2016 (IBC).
The Court held thus in a batch of Civil Appeals preferred against the Judgment of the National Company Law Appellate Tribunal (NCLAT) pertaining to the Corporate Insolvency Resolution Process (CIRP) of the Hindustan National Glass and Industries Ltd. (HNGIL).
Cause Title- Independent Sugar Corporation Ltd. v. Girish Shriram Juneja & Ors. (Neutral Citation: 2025 INSC 124)
Date of Judgment- January 29, 2025
Coram- Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, and Justice S.V.N. Bhatti
14) Domicile-based reservation is constitutionally impermissible in PG medical courses
The Court held that domicile/residence-based reservation is constitutionally impermissible in PG Medical courses.
The Court held that reservation at the higher level on the basis of ‘residence’ would be violative of Article 14 of the Constitution. The admissions to PG Medical Courses at the Government Medical College and Hospital, Chandigarh (GMCH) were under challenge.
Cause Title- Dr. Tanvi Behl v. Shrey Goel & Ors. (Neutral Citation: 2025 INSC 125)
Date of Judgment- January 29, 2025
Coram- Justice Hrishikesh Roy, Justice Sudhanshu Dhulia and Justice S.V.N. Bhatti
15) Principle of audi alteram partem is cornerstone of justice; defect at the initial stage cannot generally be cured at the appellate stage
The Court held that a defect at the initial stage cannot generally be cured at the Appellate stage.
The Court held thus in a batch of Civil Appeals relating to a case posted before the larger Bench on account of the Split Verdict rendered in April 2024 by the two-Judge Bench.
Cause Title- Krishnadatt Awasthy v. State of M.P. & Ors. (Neutral Citation: 2025 INSC 126)
Date of Judgment- January 29, 2025
Coram- Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, and Justice S.V.N. Bhatti
16) Section 18(a)(vi) Drugs & Cosmetics Act| Altering or breaking up drugs for further sale or distribution allowed if parties hold a licence for manufacture
The Court held that Section 18(a)(vi) of the Drugs and Cosmetics Act does not prohibit the process of altering or breaking up a drug/medicine for further sale or distribution if parties hold a ‘licence for manufacture’.
The Court set aside the decision of the Andhra Pradesh High Court, which had dismissed the Petition filed by M/s. INOX Air Products Private Limited (Appellant) under Section 482 of the CrPC to quash the case.
Cause Title- INOX Air Products Limited Now Known As INOX Air Products Private Limited & Anr. v. State Of Andhra Pradesh (Neutral Citation: 2025 INSC 128)
Date of Judgment- January 30, 2025
Coram- Justice BR Gavai and Justice Augustine George Masih
17) Summoning Order is totally a non-speaking one: Supreme Court quashes criminal proceedings against JM Laboratories & its partners
The Court quashed the summoning order and criminal proceedings against M/S JM Laboratories and its partners (Appellants) while holding that the summoning order against them was “totally a non-speaking one.”
The Court allowed the Appeal by quashing the Judgment of the Andhra Pradesh High Court whereby the Petition filed by the Appellants under Section 482 of the CrPC to quash the proceedings before the Trial Court came to be dismissed. The Bench held that the Magistrate issued the process without assigning any reasons.
Cause Title- M/S. JM Laboratories & Ors. v. State Of Andhra Pradesh & Anr. (Neutral Citation: 2025 INSC 127)
Date of Judgment- January 30, 2025
Coram- Justice BR Gavai and Justice Augustine George Masih
18) Tanneries among most polluting industries; damaging water bodies: SC issues directions in Vellore river pollution case
The Court issued some directions in a case involving pollution due to tanneries damaging Palar River, Vellore District, Tamil Nadu.
The Court was hearing a batch of Civil Appeals preferred against the Common Order of the Madras High Court by which it dismissed the Writ Petition of Vellore District Environment Monitoring Committee and disposed of the latter Writ Petition filed by All India Skin and Hide Tanners and Merchants Association (AISHTMA).
Cause Title- Vellore District Environment Monitoring Committee v. The District Collector, Vellore District & Others (Neutral Citation: 2025 INSC 131)
Date of Judgment- January 30, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
19) SC-ST man abused by calling his caste name in a place not within public view: Supreme Court quashes chargesheet filed against accused
The Court made it clear that for constituting an offence under Section 3(1)(s) of the SC-ST Act, it will be necessary that the accused abuses any member of a Scheduled Caste or a Scheduled Tribe by caste name in any place within public view. If the alleged offence takes place within the four corners of the wall where members of the public are not present, then it cannot be said that it has taken place at a place within public view.
The Appeals before the Court challenged the judgment passed by the Single Judge of the High Court of Madras dismissing the petitions filed by the Appellant under Section 482 of the Code of Criminal Procedure to quash the proceedings pending before the Additional District and Sessions Judge (PCR).
Cause Title- Karuppudayar v. State Rep. By the Deputy Superintendent of Police, Lalgudi Trichy & Ors (Neutral Citation:2025 INSC 132)
Date of Judgment- January 31, 2025
Coram- Justice B.R. Gavai and Justice Augustine George Masih
20) Ingredients of offence of dowry death u/s. 304-b IPC repeatedly explained; but Trial Courts are committing same mistakes
The Court acquitted a man in a case of cruelty and dowry death and highlighted that it has explained the ingredients of the offence under Section 304-B IPC repeatedly but the Trial Courts are committing the same mistakes. It suggested that the State Judicial Academies should step in.
The Court was considering an appeal challenging the judgment confirming the conviction of the Appellant under Sections 304-B and 498-A of IPC. For the offence punishable under Section 304-B of IPC, the appellant was sentenced to undergo rigorous imprisonment for seven years and he was sentenced to undergo one year of rigorous imprisonment under Section 498-A.
Cause Title- Karan Singh v. State of Haryana (Neutral Citation: 2025 INSC 133)
Date of Judgment- January 31, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
21) Rules of game changed after the game has begun: SC sets aside Jharkhand HC Order allowing CTET & STET candidates in recruitment process for assistant teachers
The Court set aside the Order of the Jharkhand High Court that had permitted CTET and STET qualified candidates to participate in the recruitment process for Assistant Teachers in Primary and Upper Primary Schools in Jharkhand.
The Court allowed the Appeal filed by Jharkhand Teacher Eligibility Test (JTET) qualified candidates challenging the Jharkhand High Court's decision which allowed residents of Jharkhand who had cleared Central Teacher Eligibility Test (CTET) or the neighbouring states’ Teacher Eligibility Test (STET) to participate in the recruitment process under the Advertisement.
Cause Title- Parimal Kumar & Ors v. The State Of Jharkhand & Ors. (Neutral Citation: 2025 INSC 134)
Date of Judgment- January 30, 2025
Coram- Justice JK Maheshwari and Justice Rajesh Bindal
22) Clearly attempting to escape his liability to support her post-divorce: SC directs husband to pay ₹10l as permanent alimony to wife
The Court directed a man to pay Rs. 10 lakhs as a permanent alimony in favour of his wife.
The Court was dealing with a Civil Appeal filed by the wife against the Order of the Bombay High Court, Nagpur Bench by which it dismissed her Appeal challenging the Decree of Divorce granted by the Family Court.
Cause Title- ABC v. XYZ (Neutral Citation: 2025 INSC 135)
Date of Judgment- January 31, 2025
Coram- Justice Vikram Nath and Justice Prasanna B. Varale
23) Have been fighting this battle for regular pay-scale since 2016: Supreme Court allows Appeals of employees
The Court allowed the Appeals of employees preferred against the Judgment of the Madhya Pradesh High Court by which it denied regular pay-scale to them.
The Court took note of the fact that the said employees have been fighting this battle for regular pay-scale since the year 2016.
Cause Title- Rakesh Kumar Charmakar & Ors. v. The State of Madhya Pradesh & Ors. (Neutral Citation: 2025 INSC 136)
Date of Judgment- January 31, 2025
Coram- Justice Vikram Nath and Justice Prasanna B. Varale
24) Sexual intercourse by man with his wife can’t be termed as rape: Supreme Court quashes FIR
The Court quashed an FIR in a marital rape case after taking note of the appellant-husband’s argument that as per Exception 2 under Section 375 of IPC, sexual intercourse by a man with his own wife cannot be termed as rape.
The Court was considering an Appeal preferred against the order of the Punjab and Haryana High Court wherein the accused-appellant’s petition under Section 482 of the Criminal Procedure Code, 1973 seeking quashing of the FIR registered under Section 366, 376 and 506 of Indian Penal Code, 1860 was dismissed.
Cause Title- Kuldeep Singh v. The State of Punjab & Ors (Neutral Citation: 2025 INSC 137)
Date of Judgment- January 31, 2025
Coram- Justice Vikram Nath and Justice Prasanna B. Varale
25) S. 37 A&C Act grants narrower scope to Appellate Court to review findings in an award if it’s upheld u/s 34
The Court reiterated that Section 37 of the Arbitration and Conciliation Act, 1996 (A&C Act) grants narrower scope to the Appellate Court to review the findings in an Award, if it is upheld under Section 34.
The Court reiterated thus in a Civil Appeal challenging the Judgment of the Delhi High Court being passed in an Appeal under Section 37 A&C Act.
Cause Title- M/s. C & C Constructions Ltd. v. IRCON International Ltd. (Neutral Citation: 2025 INSC 138)
Date of Judgment- January 31, 2025
Coram- Justice Abhay S. Oka and Justice Ujjal Bhuyan
26) Possibility of incident occurring in spur of moment out of sudden provocation: SC alters man’s conviction in murder case
The Court granted the benefit of Exception 4 of Section 300 of the IPC to the appellant-accused after considering the possibility of the incident occurring in the spur of the moment. The Apex Court also couldn’t rule out the fact that the appellant assaulted the deceased on account of sudden provocation, due to a sudden fight between them.
The Appeal before the Court challenged the judgment passed by the Division Bench of the Allahabad High Court dismissing the appeal filed by the appellant against the order convicting the appellant for an offence under Section 302 of the Indian Penal Code and sentencing him to rigorous imprisonment for life along with a fine of Rs. 5,000/-.
Cause Title- Ajai Kumar Chauhan v. The State of Uttar Pradesh (Neutral Citation: 2025 INSC 140)
Date of Judgment- January 29, 2025
Coram- Justice B.R. Gavai, Justice Augustine George Masih and Justice K. Vinod Chandran
