Weekly Overview| Supreme Court Judgments: June 2 – June 6, 2025
1) No party can take advantage of his own wrong: Supreme Court upholds dismissal of suit
The Court held that it would not be proper for a Court of law to assist or aid a person who states that the wrong he committed be set aside and a relief be granted de hors the wrong committed, after condoning the same.
The Court dismissed an Appeal, thereby upholding the Order of the Bombay High Court, which had dismissed the Appellants' Letters Patent Appeal.
Cause Title- Machhindranath Deceased Through Lrs v. Ramchandra Gangadhar Dhamne & Ors. (Neutral Citation: 2025 INSC 795)
Date of Judgment- June 2, 2025
Coram- Justice Sudhanshu Dhulia and Justice Ahsanuddin Amanullah
2) Complete absence of motive is a circumstance which weighs in favour of an accused in a case based on circumstantial evidence
The Court held that the complete absence of motive is certainly a circumstance which weighs in favour of an accused in a case based on circumstantial evidence. It partially set aside the conviction of the Appellant, by acquitting him for the offence punishable under Section 302 of the IPC and Section 5 read with 25(1)(a) of the Arms Act. However, his conviction under Section 201 of the IPC was sustained.
The Court explained the “significant difference” in the evidentiary burden to be discharged by the prosecution and the accused. Whereas the former is expected to discharge its burden beyond reasonable doubt, the latter is only required to prove a defence on the anvil of preponderance of probabilities.
Cause Title- Vaibhav v. The State Of Maharashtra (Neutral Citation: 2025 INSC 800)
Date of Judgment- June 4, 2025
Coram- Justice BV Nagarathna and Justice Satish Chandra Sharma
3) Article 19(1)(g) includes right to shut down a business but it is subject to reasonable restrictions
The Court observed that Article 19(1)(g) of the Constitution includes the right to shut down a business but the same is subject to reasonable restrictions.
The Court observed thus in Appeals preferred by Harinagar Sugar Mills Limited (Biscuit Division) and others, challenging the Judgment of the Bombay High Court.
Cause Title- Harinagar Sugar Mills Ltd. (Biscuit Division) & Anr. v. State of Maharashtra & Ors. (Neutral Citation: 2025 INSC 801)
Date of Judgment- June 4, 2025
Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra
4) High Court can’t exercise suo motu revision in appeal filed by accused to enhance sentence or to convict him on any other charge
While setting aside the conviction of an accused under Section 306 of the IPC and confirming the judgment of the Sessions Court, the Court held that in an Appeal filed only by the accused/convict, the High Court cannot suo motu exercise its revisional jurisdiction and enhance the sentence against the accused while maintaining the conviction.
The Appeal before the Court was filed against the Order passed by the Madras High Court dismissing the Criminal Appeal preferred by the Appellant and convicting him under Sections 306 and 448 of the Indian Penal Code, 1860.
Cause Title- Nagarajan v. State of Tamil Nadu (Neutral Citation: 2025 INSC 802)
Date of Judgment- June 4, 2025
Coram- Justice B.V. Nagarathna and Justice Satish Chandra Sharma
5) Unfortunate that complainant being officer of state initiated criminal machinery where aged parents-in-law were arrayed as accused: Supreme Court quashes S.498A IPC Case
The Court quashed a cruelty case registered under Section 498A of the IPC by a woman Police Officer against her husband, his parents and five sisters and observed that it was unfortunate that the Complainant, being an officer of the State, had initiated criminal machinery in such a manner, where the aged parents-in-law, five sisters & a tailor were arrayed as accused.
The Appeal before the Court challenged the impugned Judgment passed by the Delhi High Court whereby the Order passed by the Sessions Court discharging the Appellant for the offence under section 498A of the Indian Penal Code, 1860 was set aside.
Cause Title- ABC v. State (Govt. Of Nct of Delhi) & Anr. (Neutral Citation: 2025 INSC 803)
Date of Judgment- June 4, 2025
Coram- Justice B.V. Nagarathna and Justice Satish Chandra Sharma
6) Section 66(4) of Railways Act permits railway authority to charge for misdeclaration of goods either before or after delivery
While allowing the Appeal of the Railway Authorities, the Court explained that as per sub-section (4) of Section 66 of the Railways Act, 1989, if the statement is found to be materially false, the Railway authority is empowered to charge the goods at the required rate. Such a charge can be made either before or after delivery.
The Appeals before the Court arose from the final Judgment of the Gauhati High Court affirming the Order of the Railway Claims Tribunal.
Cause Title- Union of India v. M/s Kamakhya Transport Pvt. Ltd. Etc.etc (Neutral Citation: 2025 INSC 805)
Date of Judgment- June 5, 2025
Coram- Justice Sanjay Karol and Justice Prashant Kumar Mishra
7) Agreed compensation rate for delayed possession can be exceeded only for exceptional reasons by Consumer Forums
Once parties agree to a particular consequence for delay in handing over possession, the Court reiterated that a consumer forum needs exceptional and strong reasons to award compensation at more than the agreed rate.
The Court allowed the Appeal filed by the Greater Mohali Area Development Authority (GMADA), challenging the decision of the National Consumer Disputes Redressal Commission (NCDRC). NCDRC had affirmed the Ordr of the State Commission, which directed GMADA to refund the entire amount deposited by both parties in respect of securing flats in the residential scheme launched by it along with 8% interest thereon as also paying additional costs for mental harassment, litigation and the interest paid by the Respondents to the State Bank of India, for the loans that they had secured to arrange for the funds required to be invested in the project.
Cause Title- Greater Mohali Area Development Authority (GMADA) v. Anupam Garg Etc. (Neutral Citation: 2025 INSC 808)
Date of Judgment- June 4, 2025
Coram- Justice Sanjay Karol and Justice Prasanna B Varale
8) High Court in a petition u/s 482 CrPC can’t examine whether the charges may hold up in Court
The Court held that a High Court, in a Petition under Section 482 of the CrPC, cannot examine whether the charges may hold up in the Court.
The Court set aside the Order of the Patna High Court, which quashed the FIR registered under Sections 420, 406, and 34 of the IPC.
Cause Title- Abhishek Singh v. Ajay Kumar & Ors. (Neutral Citation: 2025 INSC 807)
Date of Judgment- June 5, 2025
Coram- Justice Sanjay Karol and Justice Manoj Misra
9) Putting a person in fear is an offence u/s 387 IPC; it need not satisfy all ingredients of extortion u/s 383 IPC
The Court clarified that putting a person in fear would make an accused guilty of an offence under Section 387 of the IPC; it need not satisfy all the ingredients of extortion as provided under Section 383 of the IPC.
The Court set aside the Order of the Allahabad High Court, which held that since no offence of extortion under Section 383 of the IPC was made out, consequently, no offence under Section 387 of the IPC would be made out, thus finding it a fit case to be quashed. It said that Section 387 of the IPC, being a penal provision, has to be strictly interpreted, and no condition/essential ingredient can be read into it that the Statute/Section does not prescribe.
Cause Title- M/S Balaji Traders v. The State Of U.P. & Anr. (Neutral Citation: 2025 INSC 806)
Date of Judgment- June 5, 2025
Coram- Justice Sanjay Karol and Justice Manoj Misra
10) Facts & circumstances did not fall under category of public order situation: Supreme Court quashes detention order under KAAPA
The Court quashed a detention order passed under the Kerala Anti-Social Activities (Prevention) Act, 2007, after noting that the facts & circumstances did not fall under the category of a public order situation. It reiterated that the provision for preventive detention is an extraordinary power in the hands of the State that must be used sparingly.
The Appeal before the Court was filed against the Judgment of the Kerala High Court whereby the Order of the District Magistrate directing the husband of the Appellant, Rajesh, to be kept under preventive detention in prison in terms of Section 3 of the Kerala Anti-Social Activities (Prevention) Act, 2007, was affirmed.
Cause Title- Dhanya M v. State of Kerala & Ors. (Neutral Citation: 2025 INSC 809)
Date of Judgment- June 6, 2025
Coram- Justice Sanjay Karol and Justice Manmohan
