Weekly Overview| Supreme Court Judgments: November 10 – November 14, 2025
1) ‘Transaction Value’ u/s 4 Central Excise Act serves as basis for computing quantum of excise duty payable, not excisability
The Court held that the ‘transaction value’ under Section 4 of the Central Excise Act, 1944 (CEA) serves as the basis for computing the quantum of excise duty payable, but cannot determine excisability.
The Court held thus in Civil Appeals challenging the Order passed by the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), West Zonal Bench, Mumbai.
Cause Title- Lipi Boilers Ltd. v. The Commissioner of Central Excise, Aurangabad (Neutral Citation: 2025 INSC 1297)
Date of Judgment- November 10, 2025
Coram- Justice J.B. Pardiwala and Justice Sandeep Mehta
2) Is unilateral termination of agreement to sell by one party permissible?: Supreme Court explains
The Court explained certain principles with respect to the unilateral termination of an agreement to sell.
The Court was hearing Civil Appeals filed against the Judgment of the Karnataka High Court, which allowed Appeals of the vendees and set aside the Trial Court’s Judgment and Decree.
Cause Title- K.S. Manjunath and Others v. Moorasavirappa @ Muttanna Chennappa Batil, since deceased by his LRs and Others (Neutral Citation: 2025 INSC 1298)
Date of Judgment- November 10, 2025
Coram- Justice J.B. Pardiwala and Justice R. Mahadevan
3) Appeal against rejection of plaint maintainable u/s.13(1A) Commercial Courts Act
The Court held that an Appeal against the Order rejecting a plaint is maintainable under Section 13(1A) Commercial Courts Act 2015.
The Appeal before the Court was filed against the final Judgment of the Bombay High Court in a Commercial First Appeal arising out of the Commercial Suit whereby the High Court dismissed the Appeal preferred by MITC Rolling Mills Pvt. Ltd. holding the same to be non-maintainable under Section 13(1A) of the Commercial Courts Act, 2015.
Cause Title- MITC Rolling Mills Private Limited v. M/s. Renuka Realtors (Neutral Citation: 2025 INSC 1300)
Date of Judgment- November 10, 2025
Coram- Justice Vikram Nath and Justice Sandeep Mehta
4) Transactions undertaken not within purview of “real estate agent” under Finance Act: Supreme Court dismisses appeals by service tax commissioner
The Court dismissed the Appeals filed by the Commissioner of Service Tax, New Delhi against a real estate partnership firm.
The said Appeals challenged the common Judgment of the Customs, Excise and Service Tax Appellate Tribunal, (CESTAT) passed in a Service Tax Appeal.
Cause Title- Commissioner of Service Tax v. M/s Elegant Developers (Neutral Citation: 2025 INSC 1299)
Date of Judgment- November 10, 2025
Coram- Justice J.B. Pardiwala and Justice Sandeep Mehta
5) Assault was with knowledge but without intention to cause death: Supreme Court converts murder conviction to culpable homicide
Holding that the assault was carried out with knowledge of its likely consequences, but without any deliberate intention to cause death, the Court set aside a conviction under Section 302 IPC. It held that the case fell within Section 304 Part I, as the facts did not disclose the mental element required to sustain a murder conviction.
The Court was hearing an Appeal against the judgment of the Gujarat High Court affirming a conviction under Section 302 IPC. The case involved a physical assault arising out of a sudden quarrel in which the injured later succumbed due to septicemia.
Cause Title- Nandkumar @ Nandu Manilal Mudaliar v. The State of Gujarat (Neutral Citation: 2025 INSC 1302)
Date of Judgment- November 10, 2025
Coram- Justice K. Vinod Chandran and Justice N.V. Anjaria
6) Forcefully subjecting individual to DNA testing is grave intrusion of privacy
While setting aside an Order upholding the decision to carry out DNA testing of a man, the Court held that forcefully subjecting an individual to DNA testing constitutes a grave intrusion upon privacy and personal liberty. It also said that a direction for such testing must have a direct and demonstrable nexus with the offences under investigation.
The Appeal before the Court challenged the Judgment of the Madras High Court whereby the High Court directed the Appellant to appear before the Dean, Government Rajaji Hospital, Madurai, for the collection of blood samples for DNA profiling as ordered by the Single Judge.
Cause Title- AB v. PA (Neutral Citation: 2025 INSC 1304)
Date of Judgment- November 10, 2025
Coram- Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi
7) GNCTD not acted with swiftness: Supreme Court directs constitution of DRMB as single-window authority for protection of Delhi ridge
The Court directed the constitution of Delhi Ridge Management Board (DRMB) as a single-window authority for the protection of Delhi Ridge, which is widely known as the “Green Lungs” of the city.
The Court was called upon to adjudicate on the issue concerning the various bodies/authorities monitoring, regulating, and permitting construction activities in the Delhi Ridge which is an area of vital ecological and geographical significance in the National Capital Territory (NCT).
Cause Title- T. N. Godavarman Thirumulpad v. Union of India & Others (Neutral Citation: 2025 INSC 1306)
Date of Judgment- November 11, 2025
Coram- Chief Justice of India (CJI) B.R. Gavai and Justice K. Vinod Chandran
8) In execution petition, primary onus lies on decree-holder to show that judgment debtor willfully disobeyed conditions of decree
While considering a civil dispute revolving around a compromise decree entered into between two religious sections of Kuruba community of Andhra Pradesh, the Court reiterated that in an Execution Petition, the primary onus lies on the decree-holder to show that the Judgment Debtor has willfully disobeyed the conditions of the decree.
The Appeals before the Court arose from a dispute between two sections of Kuruba community in Anantapur District of Andhra Pradesh i.e., the Kapadam families of Gungulakunta village and the Kamatam families of Yerrayapalli village. The controversy revolved around the performance of religious rituals and the custody of idols and paraphernalia associated with the deity Lord Sangalappa Swamy, who is the common deity worshipped by both sects.
Cause Title- Kapadam Sangalappa v. Kamatam Sangalappa (Neutral Citation: 2025 INSC 1307)
Date of Judgment- November 11, 2025
Coram- Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi
9) S. 27 Evidence Act doesn't operate once disclosure is not contemporaneously proved & prior knowledge is established
The Court held that Section 27 of the Indian Evidence Act, 1872 (IEA) ceases to operate once the disclosure is not contemporaneously proved and prior knowledge is established.
The Court held thus while allowing a Curative Petition filed by Surendra Koli challenging his conviction and death sentence in one of the Nithari murder cases.
Cause Title- Surendra Koli v. The State of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 1308)
Date of Judgment- November 11, 2025
Coram- Chief Justice of India (CJI) B.R. Gavai, Justice Surya Kant, and Justice Vikram Nath
10) Tenant taking shelter of pending appeal against order fixing fair rent without seeking stay can’t be absolved from tendering payment
While upholding an Order of eviction passed against the tenants on the ground of wilful default in a case pertaining to the Tamil Nadu Buildings (Lease and Rent Control) Act, 1960, the Court affirmed the view that the lessee/tenants taking shelter of the pending Appeal against the Order fixing fair rent without seeking a stay, cannot remain absolved from tendering payment to the landlord.
The Court was considering an Appeal filed by the heirs of a lessee seeking reversal of a revisional Judgment of the Madras High Court. The impugned Order affirmed an appellate order of eviction, which, in turn, had reversed the original order of dismissal of the Eviction Petition.
Cause Title- K. Subramaniam (Died) Through Lrs K.S. Balakrishnan v. M/s Krishna Mills Pvt.ltd (Neutral Citation: 2025 INSC 1309)
Date of Judgment- November 11, 2025
Coram- Justice Dipankar Datta and Justice Manmohan
11) Counter-claim against co-defendant can’t survive
While dealing with a property dispute matter relating to the recovery of possession, the Court reaffirmed that a counter-claim against the co-defendant cannot survive, and the same has to be directed against the plaintiff. The Appellant Plaintiff approached the Court challenging the Order of the High Court affirming the Order of the Trial Court admitting a counterclaim by the second and third defendants, who were subsequently impleaded, on their application.
The counterclaim was against the first defendant, against whom the plaintiff had sought a specific performance of the very same land which was the subject matter of the suit.
Cause Title- Sanjay Tiwari v. Yugal Kishore Prasad Sao (Neutral Citation: 2025 INSC 1310)
Date of Judgment- November 12, 2025
Coram- Justice K. Vinod Chandran and Justice N. V. Anjaria
12) Rights of tribals & forest dwellers are protected even after declaration of area as wildlife sanctuary
The Court held that the rights of the tribals and forest dwellers are protected under the Wildlife (Protection) Act, 1972 (WPA) and the Forest Rights Act, 2006 (FRA) even after declaration of an area as a Wildlife Sanctuary.
The Court held thus while banning mining activities within an area of one kilometre (km) from National Parks and Wildlife Sanctuaries, noting that such activities will be hazardous to the wildlife.
Cause Title- In Re: Saranda Wildlife Sanctuary (Neutral Citation: 2025 INSC 1311)
Date of Judgment- November 13, 2025
Coram- Chief Justice of India (CJI) B.R. Gavai and Justice K. Vinod Chandran
13) Software bought for profit-linked business automation is a "commercial purpose": Supreme Court upholds dismissal of consumer complaint
The Court held that the purchase of software by a company for automating its business processes, where the dominant purpose is connected to profit generation, constitutes a commercial transaction under the Consumer Protection Act, 1986.
The Court was hearing a Civil Appeal challenging the concurrent findings of the State Consumer Disputes Redressal Commission, Delhi, and the National Consumer Disputes Redressal Commission, both of which dismissed the complaint as not maintainable.
Cause Title- M/s Poly Medicure Limited v. M/s Brillio Technologies Private Limited (Neutral Citation: 2025 INSC 1314)
Date of Judgment- November 13, 2025
Coram- Justice J.B. Pardiwala and Justice Manoj Misra
14) Subsequent discovery of damage or corrosion can’t be used to repudiate claim as it defeats main purpose of insurance contract
The Court held that a subsequent discovery of damage or corrosion cannot be used to repudiate the claim as it would defeat the main purpose of the insurance contract.
The Court was deciding Civil Appeals preferred by a company, arising from a Consumer Complaint against the Insurance Company before the Maharashtra State Consumer Dispute Redressal Commission, Mumbai, Circuit Bench at Aurangabad.
Cause Title- Kopargaon Sahakari Sakhar Karkhana Ltd v. National Insurance Co. Ltd. & Anr. (Neutral Citation: 2025 INSC 1315)
Date of Judgment- November 13, 2025
Coram- Justice J.B. Pardiwala and Justice Manoj Misra
15) Mere deposit of embezzled amount won’t absolve employee of misconduct: Supreme Court upholds post master’s dismissal from service
While upholding the removal of a Branch Post Master from service and setting aside his reinstatement, the Court observed that mere deposit of the embezzled amount will not absolve an employee of the misconduct.
The Court also held that ignorance of rules of procedure cannot be accepted. The Appeal before the Court was filed against the Order of the Rajasthan High Court whereby the penalty of removal imposed upon the Respondent employee was set aside.
Cause Title- Union of India v. Indraj (Neutral Citation: 2025 INSC 1313)
Date of Judgment- November 13, 2025
Coram- Justice Rajesh Bindal and Justice Manmohan
16) Offences involving commercial quantity of drugs stand on distinct statutory footing; S.37 NDPS Act enacts specific embargo on grant of bail
While remitting a matter to the Bombay High Court involving bail of a company’s director in a case pertaining to commercial quantity of drugs, the Court held that offences involving such quantity of narcotic drugs stand on a distinct statutory footing. It explained that Section 37 enacts a specific embargo on the grant of bail and obligates the Court to record satisfaction on the twin requirements, in addition to the ordinary tests under the Code of Criminal Procedure.
The Appeals before the Court were directed against the Orders of the Bombay High Court granting bail to the accused on prosecutions instituted by the Directorate of Revenue Intelligence under the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act).
Cause Title- Union of India v. Vigin K. Varghese (Neutral Citation: 2025 INSC 1316)
Date of Judgment- November 13, 2025
Coram- Justice Aravind Kumar and Justice N.V. Anjaria
17) Victim’s fear identifying accused in court a pointer in itself: Supreme Court upholds conviction in POCSO case
The Court upheld the conviction of an accused in a POCSO case, observing that the behaviour of the minor victim in Court, marked by visible fear upon seeing the accused, was a pointer supporting the findings of the Trial Court and the High Court.
The Court was hearing an Appeal challenging the Judgment of the High Court of Chhattisgarh, which had affirmed the conviction and seven-year sentence imposed by the Special Judge (POCSO).
Cause Title- Dinesh Kumar Jaldhari v. State of Chhattisgarh (Neutral Citation: 2025 INSC 1317)
Date of Judgment- November 13, 2025
Coram- Justice Aravind Kumar and Justice N.V. Anjaria
18) Only that much information as is clearly connected with fact discovered can be treated as relevant u/s 27 Evidence Act
The Court clarified that under Section 27 of the Indian Evidence Act, 1872 (IEA), only that much information as is clearly connected with the fact discovered can be treated as relevant under the phrase ‘facts discovered’.
The Court was hearing a Criminal Appeal filed against the Punjab and Haryana High Court’s Judgment of conviction under Section 302 of the Indian Penal Code, 1860 (IPC) and Section 25 of the Arms Act, 1959.
Cause Title- Govind v. State of Haryana (Neutral Citation: 2025 INSC 1318)
Date of Judgment- November 14, 2025
Coram- Justice J.K. Maheshwari and Justice Vijay Bishnoi
19) Rights accruing to auction purchaser after confirmation of sale cannot be disturbed except for proven fraud or substantial irregularity
The Court reiterated that once a revenue auction sale is confirmed by the competent authority, rights accrue in favour of the auction purchaser, and such rights cannot be set aside except upon proof of fraud or substantial irregularity in the conduct of the sale.
The Court was hearing an Appeal challenging the dismissal of writ proceedings and a Review Petition by the Madras High Court concerning the auction of immovable property under the Tamil Nadu Revenue Recovery Act, 1864.
Cause Title- Kolanjiammal (D) through LRs v. Revenue Divisional Officer, Perambalur District & Others (Neutral Citation: 2025 INSC 1319)
Date of Judgment- November 14, 2025
Coram- Justice Satish Chandra Sharma and Justice Vipul M. Pancholi
20) Be careful while signing in pleadings making scandalous allegations against judges: Supreme Court cautions lawyers
While highlighting the growing trend of lawyers making scurrilous and scandalous allegations against the Judges when they do not get favourable orders, the Court held that lawyers should be careful while subscribing their signatures on the pleadings which are in the nature of making scandalous allegations against the Judges.
The Court was considering a matter where scurrilous and scandalous allegations were made against a sitting Judge of the Telangana High Court.
Cause Title- In Re: N. Peddi Raju and Others (Neutral Citation: 2025 INSC 1321)
Date of Judgment- November 14, 2025
Coram- Chief Justice Of India B.R. Gavai and Justice K. Vinod Chandran
