MONTHLY JUDGEMENTS MAGAZINE MARCH

✅ Manoj Rameshlal Chhabriya Vs. Mahesh Prakash Ahuja & Anr., 2025

• The Supreme Court upheld the acquittal of the accused, emphasizing that acquittals should not be overturned without compelling evidence of guilt.
  
  
• The prosecution failed to prove the guilt beyond a reasonable doubt, and the evidence presented was insufficient to establish the accused's involvement in the crime.
  
  
• The testimony of hostile witnesses significantly weakened the prosecution’s case, indicating the importance of reliable and consistent witness testimony in criminal cases.
  
  
• The chain of circumstantial evidence was found to be incomplete, making it difficult to conclusively link the accused to the crime.
  
  
• The Supreme Court dismissed the appeal, affirming the acquittal and underlining the principle that the court should not interfere with an acquittal unless the evidence is overwhelming and irrefutable.
  

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✅ Mortuza Hussain Choudhary Vs. State of Nagaland, 2025

• The Supreme Court quashed the detention orders, stating that the detaining authority must frame independent grounds for preventive detention.
  
  
• The mere statement that the detaining authority was “satisfied on examination of the proposals and supporting documents” was found to be insufficient and did not meet the constitutional or statutory requirements.
  
  
• The Supreme Court held that the detaining authority must apply its mind to the material and articulate independent grounds of detention, which was not done in this case.
  

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✅ Naresh Meena alias Narsaram Meena Vs. State of Uttar Pradesh, 2025

• The Allahabad High Court granted bail to the accused, Naresh Meena, with the condition that he marry the victim within three months of his release.
  
  
• The Court emphasized that bail is generally granted unless there are compelling reasons to deny it, such as concerns of the accused fleeing or obstructing the course of justice.
  
  
• The accused was deemed to have no prior criminal record, and the State failed to present any exceptional circumstances that would justify the denial of bail.
  

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✅ Saranga Anilkumar Aggarwal Vs. Bhavesh Dhirajlal Sheth & Ors., 2025

• The Supreme Court ruled that an interim moratorium under Section 96 of the IBC does not apply to penalty proceedings under Section 27 of the CP Act.
  
  
• The Court emphasized that penalties imposed under the CP Act are regulatory and punitive, aimed at enforcing compliance with consumer protection laws, and are not considered as "debt" under the IBC.
  
  
• The Court rejected the appellant’s argument, stating that the penalties were part of statutory obligations and not financial liabilities owed to a creditor.
  
  
• The judgment clarifies that the moratorium under the IBC does not extend to regulatory penalties designed to uphold consumer rights.
  
  
• The appeal was dismissed, and the appellant was directed to comply with the penalties within eight weeks of the judgment.
  

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✅ In Re Recruitment of Visually Impaired in Judicial Services v. The Registrar General, The High Court of Madhya Pradesh, 2025

• The Court directed the Rajasthan Judicial Service Examination authorities to declare separate cut-off marks and publish separate merit lists for PwD candidates at every stage of the recruitment process.
  
  
• The Court emphasized that separate cut-off lists are mandatory to ensure that PwD candidates are adequately represented in judicial services.
  
  
• The non-declaration of cut-off marks was found to create ambiguity and unfair competition for PwD candidates.
  
  
• The Court highlighted that both the RPwD Act and Rajasthan Judicial Service Rules mandate separate treatment for PwD candidates to ensure equal opportunity.
  

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✅ Fab Tech Works & Constructions Pvt. Ltd. vs Savvology Games Pvt. Ltd. & Ors., 2025

• Section 9 provides interim relief, such as safeguarding the subject matter of the dispute, whereas Section 11 only deals with the appointment of an arbitrator when there is a dispute regarding the arbitration agreement.
  
  
• The High Court emphasized that these provisions are meant to function independently, and their invocation does not constitute parallel proceedings.
  
  
• The Court's clarification on Section 11(6A) reinforces the limited role of the court at the stage of appointing an arbitrator, leaving questions about the scope and validity of disputes to the arbitral tribunal under Section 16.
  
  
• This decision clarifies the procedural relationship between Sections 9 and 11, underlining that interim measures can coexist with proceedings to appoint an arbitrator.
  
  
• The Court’s ruling supports the autonomy of the arbitral process and emphasizes that substantive disputes should be adjudicated by the arbitrator, not the court.
  

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✅ X Vs. Y, 2025

• The Patna High Court reaffirmed that a Muslim woman, even after being divorced, is entitled to claim maintenance under Section 125 Cr.PC if her former husband has not made adequate provision for her during the Iddat period or thereafter.
  
  
• The Court referred to the Muslim Women (Protection of Rights on Divorce) Act, 1986, but held that it does not negate the remedies available under Section 125 Cr.PC, as per the Supreme Court’s judgments (Danial Latifi case and Md. Abdul Samad).
  
  
• The Court noted that the husband had not proven that sufficient provision had been made for the wife during the Iddat period and that she was unable to maintain herself.
  
  
• The Court dismissed the husband's allegations of adultery due to lack of substantive evidence, stating that the wife was living separately with her daughter and was unable to maintain herself.
  
  
• The Court awarded maintenance of ₹2,000 per month each to the wife and the minor daughter, considering the husband’s financial liabilities, including aged parents and a second wife.

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✅ Imran Pratapgarhi v. Gujarat Police, 2025

• The Supreme Court quashed the FIR registered by the Gujarat Police against Imran Pratapgarhi.

• The Court compared Section 154 of CrPC with Section 173 of BNSS, highlighting that the BNSS introduces a significant departure by allowing a preliminary inquiry before FIR registration under certain conditions.

• Section 173(3) BNSS mandates a preliminary inquiry before FIR registration for offences punishable with imprisonment between 3 to 7 years, but only with prior approval from a senior police officer.

• The Court observed that while Section 173(1) of BNSS is substantially similar to Section 154 CrPC (mandating FIR registration if a cognizable offence is disclosed), Section 173(3) of BNSS provides an exception for certain offences.

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✅ The State of Jharkhand & Ors. vs. Rukma Kesh Mishra, 2025

• The Supreme Court ruled in favor of the State of Jharkhand, overturning the High Court’s decision. The Court stated that separate approval from the Chief Minister for the charge sheet was not required under the Jharkhand Civil Service Rules.
  
  
• The Court explained that Article 311(1) does not necessitate that disciplinary proceedings or charge sheet issuance must be carried out by the appointing authority. Instead, it simply requires that dismissal or removal must be approved by the appointing authority and not by a subordinate authority.
  
  
• The Court held that the Chief Minister’s approval of the draft charge sheet (part of the proposal to initiate disciplinary action) was adequate. Separate approval of the charge sheet was not required.
  
  
• The Court emphasized that disciplinary proceedings can be initiated by any superior authority, and not necessarily by the appointing authority, provided the rules do not specifically require it. This is in line with Jharkhand’s service rules, which allow for such flexibility.
  
  
• The Court found that the High Court’s reasoning, which relied on Central law precedents, was incorrect because Central service rules differ from state-specific rules. The High Court had wrongly relied on judgments that were based on Union Government laws, which are different from the Jharkhand Civil Service Rules.

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✅ STATE Vs. G. EASWARAN, 2025

• The Supreme Court overturned the High Court's decision to quash the FIR.
  
  
• The Court criticized the High Court for prematurely deciding factual issues like the validity of the sanction and the conviction prospects before the trial began.
  
  
• The Court observed that the sanction’s validity and other factual issues should be examined during the trial, not at the pre-trial stage.
  
  
• The Court emphasized that Section 482 CrPC cannot be used to quash proceedings based on a premature appraisal of the evidence.
  

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✅ REKHA SHARAD USHIR Vs. SAPTASHRUNGI MAHILA NAGARI SAHKARI PATSANSTA LTD., 2025

• The Supreme Court quashed the complaint filed for cheque dishonour under Section 138 of the NI Act.
  
  
• The Court emphasized that criminal law cannot be set in motion by suppressing material facts. It observed that the complainant had suppressed important documents that would have allowed the appellant to contest the debt’s validity.
  
  
• The Court ruled that setting criminal law in motion by withholding key documents and facts is an abuse of the judicial process.
  

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✅ KULANDAISAMY & ANR. Vs. STATE REPRESENTED BY ITS INSPECTOR OF POLICE & ANR., 2025

• The Supreme Court disagreed with the Madras High Court's approach, which dismissed the petition based on the premature stage of the investigation. The Supreme Court emphasized that there is no absolute rule preventing interference by the Court under Section 482 CrPC at the early stages of an investigation.
  
  
• The Court found that the High Court had failed to address the merits of the petitioners’ plea for quashing the FIR.
  
  
• The Supreme Court set aside the High Court's order and remitted the matter for a fresh hearing on its merits.

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✅ Jothiragawan v. State, 2025

• The Supreme Court quashed the rape charges against the accused, emphasizing that a breach of promise to marry does not automatically equate to rape unless there is evidence of fraudulent intent at the time of consent.
  
  
• The Court noted that the victim had willingly accompanied the accused to the hotel on multiple occasions, which contradicted her allegations of coercion and force.
  
  
• The Court further stated that the promise to marry, if made after the first sexual incident, could not be deemed to have been fraudulent or coercive as no evidence was found that the promise was made to deceive the victim from the outset.
  
  
• The Supreme Court relied on the Prithvirajan v. State case, reiterating that for rape under false promise of marriage, the intent to deceive must be established from the very beginning.

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✅ Rahul v. State (NCT of Delhi), 2025

• The Delhi High Court granted bail to Rahul, stating that the prosecution had failed to produce sufficient evidence connecting him to the crime.
  
  
• The Court emphasized that under Section 25 of the NDPS Act, an accused must have knowledge of the illegal use of their premises or vehicle.
  
  
• Since there was no corroborative material to establish that Rahul knew about the use of his car for drug transport, the court concluded that his defense could not be disregarded.

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✅ Amit Kumar & Ors. v. Union of India & Ors., 2025

• National Task Force formed to investigate and address student suicides in HEIs.
  
  
• Task Force will:
  • Identify causes of student suicides, including ragging, caste-based and gender-based discrimination, sexual harassment, academic pressure, and financial stress.
  • Review existing policies on student welfare and mental health.
  • Recommend legal reforms to strengthen protections under the SC/ST (Prevention of Atrocities) Act, 1989, and other relevant laws.
  • Conduct surprise inspections in universities to assess student support mechanisms.
  • Develop a national action plan for mandatory inclusion of mental health services in HEIs.
  • Task Force to submit an interim report within four months and a final report within eight months.
    
    
• Court directed Chief Secretaries of all States/Union Territories to nominate a high-ranking officer to act as nodal officer and assist the Task Force.

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✅ National Highway Authority of India v. Sugandha Sawhney and Ors., 2025

• The Supreme Court stayed the High Court's 80% reduction in toll charges at the Lakhanpur and Bann Toll Plazas on NH–44 until further proceedings. The toll will be collected at 75% of the notified fee, as per existing rules.
  
  
• The High Court exceeded its jurisdiction by mandating toll reductions in violation of the National Highways Fee Rules, particularly Rule 4(9), which allows a 25% reduction during road upgradation work. The NHAI’s 75% toll collection was in line with the law.
  
  
• The Supreme Court did not agree with the High Court’s direction to suspend toll collection, particularly considering the existing regulatory provisions that already reduced tolls during the construction phase. Therefore, NHAI is permitted to continue toll collection at reduced rates.
  
  
• The Supreme Court directed that the case proceed to trial, where the Commercial Court will address issues related to toll rates and toll collection fairness. The High Court’s initial dismissal of the case was deemed premature, requiring a deeper evaluation of toll policies and road conditions.
  
  
• The Supreme Court issued notice returnable by May 19, 2025 for further arguments on the matter, keeping the toll collection at 75% until the next hearing.
  
  
• The Supreme Court sided with NHAI's argument that toll reductions and adjustments should adhere strictly to statutory provisions and existing guidelines for infrastructure projects, ensuring both public interest and legal consistency.

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✅ M/S A.P. Electrical Equipment Corporation Vs. The Tahsildar & Ors., 2025

• The Supreme Court reinforced the High Court’s authority under Article 226, ensuring justice prevails over procedural technicalities.
  
  
• Strengthens writ jurisdiction in land acquisition cases.
• Increases scrutiny of State claims regarding possession of land.
  
  
• The State may find it harder to claim possession without solid evidence in future cases.
  
  
• This ruling could lead to more judicial intervention in similar land disputes.
  
  
• Actual physical possession is crucial in land disputes.
  
  
• High Courts can intervene under Article 226, even in cases involving disputed facts.
  
  
• The judgment limits administrative overreach, ensuring State actions are backed by substantial evidence.

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✅ Ramesh A. Naika Vs. The Registrar General, High Court of Karnataka, etc., 2025

• The Court reiterated that the death penalty is reserved for the "rarest of rare" cases, and that mitigating factors such as the appellant’s prior good conduct, absence of a criminal history, and the possibility of reformation were not properly considered by the lower courts.
  
  
• The Court relied on precedents such as Swamy Shraddananda (2) v. State of Karnataka (2008) and Deen Dayal Tiwari v. State of U.P. to argue that life imprisonment without remission was a just alternative.
  
  
• The Court referred to earlier decisions that laid out the guiding principles for imposing the death penalty, emphasizing that it should not be a default sentence and should only apply in cases where there are no mitigating factors.

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✅ Rajnish Singh @ Soni Vs. State of U.P. and Another, 2025

• The Court held that a long-term consensual relationship cannot be transformed into rape solely based on a false promise of marriage unless there is evidence of deceit from the outset of the relationship.
  
  
• The 16-year delay in filing the FIR raised doubts about the veracity of the allegations, especially since the complainant had referred to herself as the appellant’s wife on several occasions.
  
  
• The Court concluded that this case was more indicative of a love affair or live-in relationship gone sour rather than a rape case.
  
  
• The Supreme Court allowed the appeal, quashing the criminal proceedings against the appellant and dropping all charges.
  
  
• The Court stated that it would be unjust to continue with the criminal proceedings, finding the allegations full of contradictions and inconsistencies that made them unbelievable.

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✅ C.S. Umesh Vs. T.V. Gangaraju & Ors., 2025

• The Court reasoned that allowing modifications to judicial orders through oral mentions compromises the integrity and finality of judicial decisions.
  
  
• Such practices can lead to uncertainty and may be misused, thereby undermining public confidence in the judiciary.
  
  
• The Court underscored that any request for modification should follow the established legal procedures, ensuring that all parties have an opportunity to be heard, thus adhering to the principles of natural justice.

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✅ Rahul Verma & Others Vs. Rampat Lal Verma & Others, 2025

• The Supreme Court ruled that legal heirs of deceased partners are bound by the arbitration agreement if they inherit the deceased partner’s business interests.
  
  
• The Court held that the arbitration agreement extends to legal heirs as they inherit the deceased’s rights and obligations in the partnership.
  
  
• The Court interpreted Section 40 of the Arbitration Act and found that arbitration agreements do not lapse upon the death of a party unless explicitly stated otherwise.
  
  
• The Court ruled that the lower court erred in refusing arbitration, and it directed the dispute to be resolved through arbitration.

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✅ Sudershan Singh Wazir v. State (NCT of Delhi) and Ors., 2025

• The Supreme Court held that High Courts should not ordinarily stay discharge orders passed by trial courts in criminal cases, stating that such a stay should only be granted in exceptional circumstances.
  
  
• The Court emphasized that an order of discharge signifies that the accused is freed from trial, and staying such an order would contradict its legal effect.
  
  
• Regarding the invocation of Section 390 of CrPC, the Court observed that even when an appellate court orders the arrest of an accused while considering an appeal against acquittal or discharge, bail should be the norm, reinforcing the principle that bail is the rule, and jail is the exception.
  
  
• The Supreme Court quashed the High Court's stay order and the directive for Sudershan Singh Wazir to surrender, thereby allowing the discharge order to remain in effect.

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✅ Periyammal (Dead Through LRs.) and Ors. vs. V. Rajamani and Anr., 2025

• The Supreme Court expressed concern over the significant delays in execution proceedings across the country, which were frustrating the intent of decrees in favor of decree-holders.
  
  
• The Court directed all High Courts to gather data on pending execution petitions in district courts and issue administrative circulars ensuring that such petitions are disposed of within six months.
  
  
• It further stated that if executing courts fail to decide execution petitions within the specified period, the concerned presiding officers will be answerable to the High Court on the administrative side.
  
  
• The Court also ordered the executing court in this particular case to ensure that possession of the suit property is handed over to the decree-holder, using police assistance if necessary, within two months.

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✅ Aruvela Shravan Kumar Rao v. The State of Telangana

• The Court’s decision to grant interim protection is based on the understanding that this would encourage Aruvela Shravan Kumar to return to India for investigation without fearing arrest.
  
  
• The interim protection ensures that Kumar complies with the investigation process, addressing concerns about absconding and non-cooperation.
  
  
• The Court has strategically used its powers to balance the interests of the State of Telangana and the rights of the accused.
  
  
• The extradition suggestion reflects a proactive approach by the Court, taking into consideration Kumar’s international whereabouts, ensuring that he faces legal consequences.
  
  
• The Court's focus on national security and privacy infringement showcases the gravity of the charges and the importance of a comprehensive investigation.

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✅ Patel Babubhai Manohardas & Ors. vs. State of Gujarat, 2025

• The Supreme Court set aside the conviction of the appellant, stating that the prosecution failed to prove the essential elements of abetment to suicide beyond reasonable doubt.
  
  
• The Court held that the evidence, including the suicide note, was not sufficient to establish mens rea (intention) required for abetment under Section 306 IPC. The Court emphasized that for a conviction under this section, instigation or intentional aid must be proved beyond doubt.
  
  
• The Court ruled that the suicide note, though naming the appellant, was not sufficient to prove abetment unless corroborated by other evidence.
  
  
• The Court found that the handwriting expert's testimony was inadmissible because the expert was not examined in court. The Court referenced Keshav Dutt v. State of Haryana to support this view.
  
  
• The Court observed that the proximate act of blackmail or harassment by the appellants did not directly cause the suicide. The Court reiterated that there must be a clear, positive act by the accused that leads the victim to commit suicide, which was missing in this case

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✅ M/S Shri Sendhuragro and Oil Industries Pranab Prakash v. Kotak Mahindra Bank Ltd., 2025

• The Supreme Court rejected the appellant’s request to transfer the case from Chandigarh to Coimbatore, holding that the trial court in Chandigarh had jurisdiction over the matter. The court emphasized that the jurisdiction for a cheque dishonor complaint under Section 138 of the NI Act lies where the cheque is presented for collection, not where the transaction or issuance of the cheque took place.
  
  
• The Court referred to the 2015 amendment to Section 142(2)(a) of the NI Act, stating that the jurisdiction for a Section 138 complaint is where the payee maintains the bank account and where the cheque is presented for collection. This effectively overturned the previous stance held in the Dasrath Rupsingh Rathod v State of Maharashtra (2014) case, which had created confusion about the jurisdiction.
  
  
• The Court clarified that mere inconvenience, such as the need for the accused to travel from Coimbatore to Chandigarh, is not a sufficient ground to transfer the trial under Section 406 CrPC. The Court stated that the power of the Supreme Court to transfer cases should not be exercised routinely and must be reserved for exceptional situations.

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✅ C. Kamalakkannan Vs. State of Tamil Nadu Rep. by Inspector of Police C.B.C.I.D., Chennai, 2025

• The court held that expert testimony, particularly handwriting expert evidence, cannot be relied upon if the original document (in this case, the postal cover) is not presented and proven in evidence.
  
  
• The court emphasized that corroboration of expert testimony is not always mandatory, but in this case, due to the imperfect nature of handwriting identification science, the evidence must be scrutinized cautiously, especially when the original document is not available.
  
  
• The court ruled that since the existence of the postal cover was not proven, the handwriting expert's report lacked evidentiary value, making it insufficient to support the conviction.
  
  
• As a result, the conviction was quashed, and the Appellant was acquitted.

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✅ K. S. Mehta Versus M/S Morgan Securities and Credits Pvt. Ltd., 2025

• The Supreme Court held that non-executive and independent directors cannot be held vicariously liable for the company’s obligations under Section 138 and Section 141 of the NI Act unless it is demonstrated that they had direct involvement in the company’s financial transactions or day-to-day operations at the relevant time.
  
  
• The Court reiterated that non-executive directors cannot be held liable merely due to their position in the company. Liability under Section 141 can only arise when specific allegations demonstrate that the director had control or responsibility for the company’s operations, particularly in terms of financial management and the issuance of cheques.
  
  
• The Court observed that the appellants did not issue or sign the dishonored cheques, nor did they have any direct role in their execution. Their involvement was purely non-executive, limited to governance oversight and did not extend to financial decision-making or operational management. This was sufficient grounds for quashing the criminal proceedings against them.
  
  
• The Court rejected the argument that the appellants, by attending annual board meetings, could be held liable under Section 141. Merely attending meetings or being part of corporate governance does not automatically translate to responsibility for the company’s financial operations. Board meeting attendance does not equate to control over financial decisions.
  
  
• The Court emphasized that specific allegations of the director's involvement in the company's financial decisions must be made to hold them liable under Section 141 of the NI Act.

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✅ JAMIN & ANR. Vs. STATE OF UTTAR PRADESH & ANR., 2025

• The Court affirmed the High Court's use of revisional jurisdiction and emphasized the importance of Section 319 Cr.P.C. in ensuring that no guilty person escapes trial.
  
  
• It was held that a High Court order under revisional jurisdiction to reconsider a Section 319 application relates back to the original order of the Trial Court. This means that the reconsideration can occur even after the trial has concluded, without the need for a stay.
  
  
• The Court clarified that the revisional order "relates back" to the original rejection order, and the Trial Court can still decide on the application after the trial's completion, provided the High Court has intervened.

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✅ SMT LAVANYA C & ANR VERSUS VITTAL GURUDAS PAI SINCE DESEASED BY LRS. & ORS., 2025

• A party cannot escape liability for violating an injunction order simply because the injunction is later set aside or the suit is dismissed.
  
  
• The Court upheld the High Court’s finding that the appellants had willfully disobeyed the court's order and remained liable for that violation.
  
  
• The Court emphasized the principle that compliance with court orders during the pendency of litigation is essential, and a violation of an interim order (such as an injunction) is treated as a distinct offense that must be addressed separately.
  
  
• The Court partly allowed the appeal, deleting the imprisonment but increasing the compensation payable for the disobedience.

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✅ Joyi Kitty Joseph Vs. Union of India & Ors., 2025

• Judgment Interpretation: Court reinforced that COFEPOSA should not override due process and that bail conditions must be considered before detention.
  
  
• This ruling will strengthen protection against wrongful preventive detention and ensure that bail conditions are carefully examined before issuing detention orders.
  
  
• Future cases may further clarify what constitutes a "live link" between past offenses and preventive detention.
  
  
• Preventive detention should be exercised cautiously and not as an alternative to regular prosecution.
  
  
• Authorities must establish a strong factual basis before invoking COFEPOSA.
  
  
• Bail conditions must be explicitly considered, or detention orders risk being quashed.

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✅ Gyanendra Singh @ Raja Singh vs. State of Uttar Pradesh, 2025

• The Supreme Court upheld the conviction of the appellant under Sections 376(2)(f) and 376(2)(i) of the IPC and Sections 3/4 of the POCSO Act.
  
  
• The Court clarified that Section 42 of the POCSO Act mandates applying the higher punishment when an act constitutes an offense under both IPC and POCSO.
  
  
• The Court modified the sentence, directing that the appellant undergo life imprisonment instead of imprisonment for the remainder of his natural life.

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✅ State of Rajasthan vs. Indraj Singh, 2025

• The Supreme Court allowed the appeal filed by the State of Rajasthan, thereby setting aside the bail granted to the respondents by the High Court.
  
  
• The Court emphasized the gravity of the offense, noting that such acts undermine public trust in the recruitment process, especially given the high demand for government jobs.
  
  
• The respondents were directed to surrender before the concerned Court within two weeks.
  
  
• The Court permitted the respondents to apply afresh for bail after the examination of material witnesses, to be decided on its own merits.

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✅ State of Himachal Pradesh vs. Rajesh Kumar, 2025

• The Supreme Court held that the prosecutrix's refusal to undergo a medical examination deprived the court of crucial evidence, thereby weakening the prosecution's case.
  
  
• The Court observed that medical examinations are critical in rape cases to provide objective evidence supporting the victim's testimony.
  
  
• The Court referred to its earlier judgment in Dola v. State of Odisha (2018), reiterating that non-cooperation in medical examinations can weaken the prosecution's case.

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✅ M/s Manoj Petroleum and Another Vs. Union of India and Others, 2025

• The court held that M/s Manoj Petroleum is not a "State" under Article 12 of the Constitution.
  
  
• The court ruled that merely complying with government regulations does not make a private entity a part of the State machinery.
  
  
• The writ petition was dismissed as not maintainable since it was filed against a private company that does not qualify as a "State."
  
  
• The court reaffirmed that writ jurisdiction under Article 226 applies primarily to entities performing public functions or those having deep governmental control.

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✅ M/S Smartschool Education Private Limited Vs M/S Bada Business Pvt. Ltd And Ors, 2025

• The court reinforced the distinction between preventive detention and regular judicial proceedings. It reaffirmed that preventive detention should not be used in cases where regular legal mechanisms, such as bail cancellation, are available.
• This judgment sets a precedent that authorities must follow proper legal channels instead of resorting to preventive detention arbitrarily.
  
  
• Future cases may further clarify the circumstances under which preventive detention can be applied without violating fundamental rights.
  
  
• The case highlights the importance of judicial scrutiny in matters of personal liberty and serves as a warning against the misuse of preventive detention laws.

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✅ YUVRAJ LAXMILAL KANTHER & ANR. Vs. STATE OF MAHARASHTRA, 2025

• The Supreme Court clarified that the essential ingredients for an offence under Section 304 Part II IPC—knowledge or intention to cause death—were absent in this case. The accident, as described, was not a result of any criminal intent or recklessness on the part of the appellants.
  
  
• This judgment reiterates that, for a charge of culpable homicide or death by negligence, there must be clear evidence of intent or knowledge, and a mere accident does not automatically give rise to such charges. Employers should be mindful of their obligations to provide safety equipment, but criminal liability requires more than just a failure to act—it requires culpable intent or gross negligence.
  
  
• This ruling may be challenged in future cases where employers fail to provide safety equipment, but the Court’s insistence on a prima facie case ensures that not all instances of negligence result in serious criminal charges.
  
  
• This case reinforces the principle that criminal liability for culpable homicide or death by negligence requires more than just a failure in duty; it requires a clear nexus between the employer’s actions and the death, such as intentional conduct or reckless disregard for safety. Employers must still ensure safety standards are maintained, but liability under Section 304 Part II IPC requires serious evidence of culpability.

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✅ ARUN RAMESHCHAND ARYA Vs. PARUL SINGH, 2025

• The Supreme Court held that Section 17(2)(vi) of the Registration Act, 1908 provides an exemption from stamp duty for property transferred as part of a compromise in matrimonial disputes.
  
  
• The Court relied on the recent case of Mukesh v. The State of Madhya Pradesh & Anr. (2024) to support the contention that the flat in question was part of the settlement and thus forms part of the proceedings before the Court.
  
  
• The Court concluded that, under these circumstances, the registration of the flat in the exclusive name of the wife would be exempt from the payment of stamp duty.
  
  
• The Court directed the Sub-Registrar concerned to register the flat in the exclusive name of the respondent-wife as its owner.

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✅ PRADEEP NIRANKARNATH SHARMA Vs. DIRECTORATE OF ENFORCEMENT & ANR, 2025

• The Court ruled that the offence of money laundering is a continuing offence and does not depend on the date when the predicate offence was committed or notified.
  
  
• The relevant date for the offence of money laundering is when the person continues to indulge directly or indirectly in the process of handling or dealing with the proceeds of crime, regardless of when the predicate offence occurred.
  
  
• The Court emphasized that money laundering has a cascading effect, leading to revenue loss for the state and depriving legitimate sectors of investment.
  
  
• The Court further observed that judicial intervention at a preliminary stage should be exercised with caution, especially in cases involving serious economic offences like money laundering, as procedural loopholes should not be exploited to evade justice.
  
  
• The appeal was dismissed, reinforcing the stringent approach in prosecuting money laundering cases under the PMLA.

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✅ Gopal Pradhan vs. State of Chhattisgarh & Ors., 2025

• The Supreme Court agreed with the petitioner that a Magistrate does not have the authority to direct the police to include a person’s name in the charge sheet.
  
  
• The Court observed that if the police do not name a person in the charge sheet, the Magistrate can still take cognizance of the offense and issue summons to the person, even if they are not named in the charge sheet.
  
  
• The Court also emphasized that while the Magistrate cannot direct the inclusion of a name in the charge sheet, the ultimate result, i.e., summoning the person as an accused, is legally valid. Thus, the court dismissed the petition based on this reasoning.
  
  
• No interference with the High Court's order: Despite agreeing with the petitioner on the procedural error, the Court noted that the outcome (summons issuance) was correct, and therefore, the High Court’s decision was not interfered with.

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✅ ACID SURVIVORS SAAHAS FOUNDATION (NGO) Versus UNION OF INDIA AND ORS., 2025

• Liberty to Approach SLSA: The Court granted acid attack victims the liberty to approach the State Legal Services Authority (SLSA) in case of any default or delay in receiving their compensatory amount.
  
  
• Additional Time for Responses: The Court granted an additional 4 weeks to the Union of India and several States to file their responses to the PIL. The States of U.P., Karnataka, Madhya Pradesh, and Maharashtra were noted for not yet filing their responses.
  
  
• SLSA’s Responsibility: The Court directed the State Legal Services Authorities (SLSA) to compile a chart containing details of all the compensation applications filed by victims, including the names and dates when applications were submitted.
  
  
• Treatment in Private Hospitals: The Court further directed the SLSA to ensure that acid attack victims are admitted to private hospitals for treatment if required, and that any complaints regarding treatment should be promptly reported to the private hospitals and, if necessary, to the Court.

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✅ Ranjit Singh Bath & Anr. v. Union Territory Chandigarh & Anr., 2025

• The Supreme Court reiterated that before seeking a Magistrate’s direction under Section 156(3) of the CrPC to register an FIR and investigate a cognizable offence, the complainant must exhaust remedies under Section 154(1) and 154(3) of the CrPC.
  
  
• The Court quashed the Magistrate’s order, emphasizing that both Sub-Sections (1) and (3) of Section 154 are the remedies available to set the criminal law in motion.
  
  
• It also referred to the binding precedent in Priyanka Srivastava and expressed concerns about the misuse of Section 156(3), stressing that applications under this section must be accompanied by an affidavit to ensure accountability.

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✅ M/S CITICORP FINANCE (INDIA) LIMITED Vs. SNEHASIS NANDA, 2025

• The Supreme Court overturned the NCDRC's ruling, stating that the complainant (respondent) did not have privity of contract with Citicorp Finance, and thus could not be termed a "consumer" under the Consumer Protection Act.
  
  
• The Court noted that the sale transaction was between the complainant and the borrower, not involving Citicorp Finance directly.
  
  
• The loan sanctioned to the borrower was Rs. 23,40,000/-, and there was no contractual obligation on Citicorp Finance to pay the full sale consideration of Rs. 31,00,000/- to the complainant.

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✅ State (CBI) Vs Mohd. Salim Zargar @ Fayaz & Ors, 2025

• The Supreme Court dismissed the CBI’s appeals, affirming the acquittal of the accused persons.
  
  
• The Court held that the confessional statements were unreliable as they did not meet the procedural safeguards under TADA.
  
  
• The Court noted that the confession was recorded in an environment that was not conducive to a free atmosphere, such as a heavily guarded BSF camp.
  
  
• The Court observed that the time of recording and place of production of the accused were not mentioned, further undermining the reliability of the confessions.
  
  
• The failure to recover the murder weapon (AK-47) weakened the prosecution's case, with forensic evidence failing to link the accused to the crime.
  
  
• Witnesses could not identify the accused, as their descriptions were too vague to establish any connection.

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✅ State of Rajasthan v. Chatra, 2025

 

• The Supreme Court reinstated the conviction of the accused, criticizing the Rajasthan High Court for failing to properly assess the evidence.
  
  
• The Court emphasized that the silence of the child victim should not have been construed as a lack of testimony, as it was more indicative of the trauma the child experienced.
  
  
• The Court observed that the victim’s tears during cross-examination could not be dismissed as irrelevant.
  
  
• The eyewitness testimony and medical report corroborated the charge of sexual assault, and the absence of direct testimony from the victim did not diminish the case.
  
  
• The High Court's approach was criticized for disbelieving key evidence, including the eyewitness account and medical findings, which were essential in securing the conviction.
  
  
• The Supreme Court also expressed concern over the High Court’s reference to the victim's name, which violated privacy protections for victims in sexual assault cases.

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✅ Leelawati (Dead) Thr. LRs. v. State of U.P. & Ors., 2025

 

• The Supreme Court upheld the Allahabad High Court's dismissal and justified the imposition of costs on the appellant for filing a vexatious petition.
  
  
• The Court highlighted that once the writ petition was dismissed, any interim orders passed in it would merge with the final order and lose their efficacy. Therefore, the appellant could not rely on the 2006 interim order to file a new petition.
  
  
• The Court found that the filing of the third writ petition was an attempt to mislead the Court and pursue frivolous litigation.
  
  
• The Court emphasized the need for sanctions against vexatious litigation to preserve the integrity of judicial processes. It observed that such conduct amounted to an abuse of judicial process.
  
  
• The Supreme Court increased the cost imposed by the Allahabad High Court from ₹20,000 to ₹50,000, as the appellant persisted in pursuing a vexatious claim even before the Supreme Court.
  
  
• The Court ruled that the cost would be deposited with the Uttar Pradesh State Legal Services Authority, Allahabad.

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✅ Manoj Rameshlal Chhabriya Vs. Mahesh Prakash Ahuja & Anr., 2025

 

• The Supreme Court emphasized the role of strong and direct evidence in criminal cases.
  
  
• Acquittal should not be disturbed unless there is substantial proof of miscarriage of justice.
  
  
• This case reinforces the principle that mere circumstantial evidence is insufficient unless conclusively linked to the crime.
  
  
• Prosecutors must ensure that witnesses do not turn hostile, as it significantly weakens the case.
  
  
• If new evidence emerges, the case could be reopened under exceptional circumstances.
  
  
• The ruling sets a precedent that High Courts should be cautious before granting leave to appeal acquittals.
  
  
• A weak circumstantial case cannot overturn an acquittal.
  
  
• High Courts have discretion to deny leave to appeal in cases lacking strong legal grounds.
  
  
• The prosecution must build a solid case with direct and corroborative evidence.

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✅ X Vs. X, 2025

 

• The Madras High Court held that watching pornography or self-pleasure by itself did not amount to cruelty under Section 13(1)(ia) of the Hindu Marriage Act, unless it was shown that these actions affected the matrimonial relationship.
  
  
• The Court observed that the privacy of the spouse, particularly a woman’s sexual autonomy, was protected as a fundamental right under Article 21 of the Constitution of India. The Court emphasized that self-pleasure was not a forbidden act and that the woman's individuality and sexual autonomy remained intact after marriage.
  
  
• The Court reasoned that if the wife’s actions affected the psychological health of the husband or led to adverse effects on the relationship, then it could constitute cruelty. However, without such evidence, the husband’s claim of cruelty was dismissed.
  
  
• Regarding the venereal disease claim, the Court found that the husband failed to provide strict proof to substantiate the allegation. The Court also pointed out that the husband had not provided medical evidence linking the condition to sexual relations with the wife. The husband's claim was dismissed as false.
  
  
• The Court held that self-pleasure or watching pornography, if done in private, should not be stigmatized or used as a basis for dissolving the marriage, especially in the absence of direct evidence of adverse impact on the conjugal relationship.

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✅ RAJU NAIDU VERSUS CHENMOUGA SUNDRA & ORS., 2025

 

• The Supreme Court upheld the High Court's decision and dismissed the appellant's appeal.
  
  
• The Court ruled that Section 53A of the Transfer of Property Act is not applicable in this case.
  
  
• The Court stated that a transferee cannot use Section 53A to resist or obstruct the rights of decree holders who have acquired legal rights over the property.
  
  
• It emphasized that the appellant, aware of the pending litigation, cannot invoke Section 53A to override the respondents' rights.

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✅ Ashish Mishra Alias Monu v. State of U.P., 2025

 

• The Court’s interim order balancing Ashish Mishra’s rights to celebrate a religious festival with his family and the need to ensure justice for the victims shows a nuanced approach, ensuring that Mishra’s bail conditions are upheld while addressing public concerns.
  
  
• The decision to allow Balwinder Singh to file a complaint reflects the Court’s commitment to ensuring justice and preventing any witness intimidation in the sensitive case.
  
  
• The Court’s criticism of the lengthy witness list and the suggestion to prioritize vulnerable witnesses underlines the need for efficiency in the judicial process, especially in high-profile cases like this.
  
  
• By granting permission to file complaints and ensuring a fair investigation, the Court safeguards the rights of witnesses and ensures that justice is not compromised by external pressures or influences.