MONTHLY MAGAZINE DECEMBER

✅Md. Hasib v. State of Bihar, 2025

• The Court held that non-examination of the first Investigating Officer did not weaken the prosecution case because the second IO’s testimony and the statements of multiple witnesses were sufficient to clearly establish the place of occurrence as the appellant’s house.

• It stated that technical lapses in investigation such as not examining one IO cannot override strong and consistent evidence, especially when the defence fails to show any actual prejudice caused by such omission.

• The Court confirmed that all ingredients of Section 304B IPC were fulfilled: the death was unnatural, it occurred within seven years of marriage, and the deceased had been subjected to dowry-related cruelty “soon before” her death, as proved by witness statements and the FIR.

• Once these foundational facts were established, the presumption under Section 113B Evidence Act automatically applied, shifting the burden to the accused to rebut it. The appellant failed to offer any credible rebuttal or explanation.

• The Court emphasized that whether the deceased’s death was homicidal or suicidal is immaterial for Section 304B IPC because suicide itself is considered an unnatural death, and thus the offence of dowry death still applies.

• The defence’s reliance on earlier cases like Kaila Yadav and Baijnath was rejected because those cases involved situations where the place of occurrence was doubtful, whereas in the present case it was clearly and consistently established by multiple pieces of evidence.

• The Court reinforced the principle that dowry death laws are meant to protect married women from cruelty, and convictions should not be overturned on minor procedural defects when strong substantive evidence is available.

• Ultimately, the Court concluded that the prosecution had successfully proven the essential elements of dowry death, and therefore the conviction and 10-year sentence were rightly upheld.

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✅Vishwa Bandhu vs. State of U.P. and 3 Others, 2025

• The Allahabad High Court interpreted the Pradnya judgment to mean that Section 528 BNSS petitions require the chargesheet and cognizance order to be placed on record.

• Since in Pradnya, the Supreme Court distinguished stages before and after cognizance, the Allahabad HC applied this strictly.

• The editorial note highlights that the Supreme Court never barred FIR-only quashing under Section 482/528.

• The SC merely stated that once cognizance is taken, the petitioner must challenge the cognizance order as well.

• Therefore, the Allahabad HC’s reliance on Pradnya is seen as over-extended, especially since no chargesheet existed in this case.

• In Imran Pratapgadhi and Abhishek Mishra, the SC held that:

  • 482/528 powers may be exercised even at the nascent investigation stage,

  • Filing of chargesheet is not a bar to exercise inherent powers.

• Thus, the Allahabad HC's strict reading appears in tension with these rulings.

• The State relied on the 1989 decision Ram Lal Yadav, which limits Section 482 (now 528) to post-cognizance situations.

• But that very decision was recently called obsolete by Justice Deshwal (Allahabad HC) and referred to a Nine-Judge Bench, indicating that the law is in flux.

• The case reflects an ongoing judicial debate about the scope of inherent powers under Section 528 BNSS.

• The Allahabad HC adopted a strict procedural approach, while the Supreme Court in recent cases has shown a liberal and flexible approach.

• The decision underscores the confusion created during the transition from CrPC to BNSS, especially regarding maintainability of pre-chargesheet applications.

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✅Poonam Wadhwa v. Ajay Wadhwa & Ors., 2025

• The Supreme Court clarified that employment structure (office vs. home) cannot determine a parent’s custodial suitability because both parents must earn a livelihood and cannot be constantly present.

• The Court reiterated that the welfare of the child is supreme, not the work arrangement of the parent, and that factors like emotional bonding, comfort, and stability hold far greater significance.

• The child's express desire to remain with the father during the in-chamber interaction weighed heavily, demonstrating the Court’s child-centric approach.

• The father having elder family members at home was seen as an important supportive factor, ensuring the child is not left alone even when the father is busy.

• The Court implicitly rejected the High Court’s oversimplified reasoning that a work-from-home parent is automatically superior in custody matters.

• The decision reinforces that custody cannot be reduced to superficial criteria; instead, the holistic welfare of the child must govern the outcome.

• The Court balanced correction of legal reasoning with practical welfare by disagreeing with the logic but maintaining the result in the child’s best interests.

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✅Tuhin Kumar Biswas @ Bumba v. State of West Bengal, 2025

• The Supreme Court adopted a strict, literal interpretation of Section 354C, emphasizing that the term voyeurism applies only when the woman is engaged in a “private act”, which carries a reasonable expectation of privacy.

• The Court stressed that “private act” has a very specific statutory meaning and cannot be expanded to cover all instances of photographing without consent.

• The complainant was in an open, non-private environment with workmen and a friend; the act therefore cannot intrude upon legally recognized privacy under Section 354C.

• The Court noted the absence of any allegation that the complainant was in a compromising, intimate, or privacy-expecting position.

• The judgment reinforces that not every unpleasant or unwanted act of photographing constitutes a criminal offence under the voyeurism provision.

• The Supreme Court supported the High Court’s decision to quash because the prosecution lacked the essential legal foundation and would not result in conviction.

• The Court reiterated an important principle: police and courts must screen out baseless prosecutions early to prevent misuse of criminal law and undue harassment.

• The ruling clarifies the scope and limits of Section 354C IPC to avoid criminalizing conduct that does not meet statutory requirements.

• The decision fine-tunes the jurisprudence on privacy-related offences by drawing a clear distinction between privacy in public spaces vs. privacy in intimate settings.

• The Court implicitly warns against overbroad interpretation of sexual or gender-protective offences, maintaining a balance between protection of women and preventing misuse.

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✅Ram Singar Singh v. State, 2025

• The Court emphasized that revenge is an instinctual emotional response, providing temporary satisfaction but often perpetuating negative emotions and distress.

• Motive is a critical factor in establishing intent; feelings of revenge helped establish the mental state of the offender.

• Circumstantial evidence, such as presence near the deceased with a rifle and sequence of events, was sufficient to infer guilt beyond reasonable doubt.

• Lack of forensic corroboration (fingerprints) does not automatically negate the strength of other compelling evidence.

• Reinforced the principle that Section 8 of the Evidence Act allows consideration of motive to connect the accused to the crime.

• The judgment serves as a cautionary note on human emotions, highlighting that indulgence in revenge is socially and legally destructive.

• Upholds the principle that direct and circumstantial evidence collectively can be decisive in criminal convictions.

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✅Sagar v. State of UP & Anr., 2025

• Parity is not automatic: Bail granted to one accused cannot mechanically extend to another unless roles are comparable.

• Individual role matters: Instigators, direct offenders, and accessory participants may have different legal treatment.

• Bail decisions require consideration of:

  • Nature of allegations

  • Severity of potential punishment

  • Threat to witnesses or tampering of evidence

  • Criminal antecedents

  • Prima facie case strength

• Supreme Court emphasized that bail on parity is a principle, not a right.

• The judgment underscores careful judicial scrutiny in multi-accused cases, preventing misuse of parity for release.

• The ruling clarifies that High Courts must independently assess each accused and provide reasoning in bail orders.

• Acts as a guideline for courts: role-specific assessment ensures that justice and public safety are not compromised.

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✅Rousanara Begum v. S.K. Salahuddin & Anr., 2025

• Section 3(1)(d) safeguards a divorced woman’s financial security by ensuring gifts given at marriage are her entitlement.

• The marriage register (qabilnama) trumps minor inconsistencies in witness statements.

• Ensures dignity, autonomy, and equality for women post-divorce.

• Courts must consider lived experiences and patriarchal discrimination, especially in rural/small-town contexts.

• Court allows direct payment to the woman’s bank account to prevent delay or misuse.

• Reinforces that divorced Muslim women have enforceable rights under the 1986 Act for properties gifted at marriage.

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✅Chandan Pasi & Ors. v. State of Bihar, 2025

• Trial court must ask specific, material questions relating to allegations; accused must have opportunity to answer each in their own words.

• Identical statements and generic questioning violate principles of fair trial.

• Prosecutors must assist the Court, not act solely as advocates for conviction.

• Right to fair trial under Article 21 cannot be compromised by procedural shortcuts.

• Reiterates Sovaran Singh Prajapati v. State of U.P. principle prosecution is an officer of the court, not a defense adversary.

• Convictions cannot stand when statutory safeguards are ignored; retrial ensures procedural justice.

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✅L.K. PRABHU @ L. KRISHNA PRABHU (DIED) THROUGH LRs v. K.T. MATHEW @ THAMPAN THOMAS & ORS., 2025

• The Supreme Court reinforced the protective nature of attachment before judgment, emphasizing it cannot be used to prejudice bona fide third-party purchasers.

• Clarified the distinct remedies under CPC and TPA:

  • CPC Order XXXVIII protects the plaintiff’s prospective decree during litigation.

  • Section 53 TPA addresses fraudulent transfers aimed at defrauding creditors.

• Strengthens property rights of bona fide purchasers, ensuring that legal remedies are not misused to target third-party ownership.

• Provides clarity on procedural prerequisites for invoking attachment before judgment, requiring actual ownership by the defendant.

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✅X vs. Y, 2025

• The judgment clarifies the threshold of proof required for disqualifying maintenance claims on grounds of adultery.

• Reinforces that circumstantial evidence can suffice in civil matters when direct evidence is practically impossible.

• Highlights that Section 125 CrPC balances wife’s right to maintenance with husband’s right to be protected from supporting a spouse engaged in adultery.

• Serves as guidance for Family Courts to properly evaluate cumulative circumstantial evidence rather than demand absolute proof.

• Emphasizes continuous behavior rather than isolated acts for disqualification, maintaining fairness in civil proceedings.

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✅Neeraj Kumar @ Neeraj Yadav v. State of Uttar Pradesh & Others, 2025

• Section 319 CrPC is recognized by the Supreme Court as an extraordinary judicial power, intended to be used sparingly but decisively whenever the material emerging during trial shows that persons not originally arraigned as accused appear to have participated in the crime.

• The Court emphasized that the threshold for invoking Section 319 CrPC is not excessively high, and courts should not insist on the same level of proof that is required for conviction or framing of charges.

• The Supreme Court clarified that courts should not demand “strong and cogent evidence” at this preliminary stage, because such a standard applies only after complete evaluation of evidence during the final trial.

• The Court further stated that the material on record need not be “evidence sufficient for conviction,” as this standard pertains to the conclusion of trial and not to the intermediate process of summoning additional accused.

• What Section 319 CrPC truly requires, as laid down by the Supreme Court, is evidence that reasonably indicates involvement, or material that suggests a prima facie connection of the proposed accused with the commission of the offence.

• Courts are required to avoid engaging in an assessment of witness credibility, because credibility can only be determined after cross-examination, scrutiny of conduct, and evaluation at the final stage of trial.

• Courts must not dwell on minor contradictions or inconsistencies in the statements of witnesses when deciding whether to summon additional accused, as these inconsistencies require deeper judicial analysis that is reserved for the final judgment.

• Courts must refrain from evaluating cross-examination details, since cross-examination is meant to test the reliability of a witness and is inappropriate to consider at an early procedural stage such as a Section 319 application.

• Courts are not allowed to assess overall consistency or harmony between different witness testimonies during Section 319 proceedings, because consistency analysis is part of the comprehensive final evaluation of evidence after all testimonies have been fully recorded.

• The Supreme Court clarified that the above assessments—credibility, contradictions, cross-examination, and consistency—are all trial-level inquiries and cannot be undertaken at a preliminary stage where the purpose is only to determine whether additional individuals should be made to face trial.

• Regarding dying declarations, the Court reiterated that Section 32(1) of the Evidence Act is grounded in necessity, permitting statements of deceased persons to be admitted because the maker of the statement is no longer available to testify in court.

• The Court firmly held that imminence of death is not a condition for treating a statement as a dying declaration; the declarant need not be under the expectation of death at the time of making the statement.

• The admissibility of such statements depends only on whether they relate to the cause of death or the circumstances that resulted in the death, making them relevant regardless of time lapse or absence of medical certification.

• The Supreme Court labeled the High Court’s insistence on imminence of death or medical certification as a “fundamental legal error,” reaffirming that such requirements are not mandated by Section 32(1).

• The Supreme Court criticized the High Court for engaging in a mini-trial, because the High Court carefully examined minor contradictions and the supposed tutoring of a child witness, which is an analysis appropriate only after the full trial concludes.

• The Court noted that the High Court failed to understand that prima facie involvement not conclusive proof is sufficient to summon additional accused under Section 319 CrPC.

• The judgment enhances procedural fairness by ensuring that potentially culpable individuals cannot evade trial simply because the courts prematurely scrutinize evidence with an overly strict standard.

• The ruling strengthens the flexible and corrective nature of Section 319 CrPC, affirming that courts must remain open to summoning new accused whenever fresh evidence emerges, ensuring that all responsible individuals face trial.

• The decision also broadens the jurisprudence surrounding dying declarations, making it clear that statements given significantly prior to death can still be relied upon when they relate to circumstances leading to death.

• The Supreme Court’s reasoning is expected to significantly influence cases involving delayed death scenarios, such as burn injuries, dowry harassment, medical negligence, and prolonged abuse, where victims often make statements long before the final fatal event.

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✅Swamy Shraddhananda @ Murali Manohar Mishra v. Union of India, 2025

• Supreme Court adhered to strict procedural compliance, refusing to interfere with past judicial orders on life imprisonment and review.

• Highlighted the principle that mere old age or duration of imprisonment does not automatically entitle a convict to parole or remission.

• Reinforced the finality of prior judicial proceedings:

  • Death sentence initially imposed and later commuted by a larger bench of the Supreme Court.

  • Review petitions and other writ petitions had been considered and dismissed over the years.

• Court stressed judicial discipline regarding repeated adjournments and unnecessary prolongation of cases.

• Emphasized that treatment of convicts in other cases (e.g., Rajiv Gandhi assassination case) cannot serve as a ground for special treatment.

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✅Sheikh Rafique Sk. Gulab v. State of Maharashtra, 2025

• The Court reaffirmed that POCSO Act protects children in all forms of sexual assault, including inducement or attempted acts.

• The victim’s testimony is paramount, especially in cases involving minors.

• Holding a minor’s hand, when coupled with sexual proposition and inducement, qualifies as sexual assault.

• Denial of probation underscores the balance between rehabilitation of the offender and societal protection, prioritizing child safety.

• Clarifies the scope of Sections 7 and 8 POCSO Act to include even minimal physical contact coupled with sexual intent.

• The judgment strengthens deterrence against attempted sexual assault and inducement of minors.

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✅XXX v. XXX, 2025

• The Court adopted a strict interpretation of Section 15 HMA, reiterating that the bar on remarriage becomes operative the moment an appeal is filed within limitation.

• Relying on Jasbir Kaur v. Kuljit Singh (2008) and the Supreme Court decision in N. Rajendran v. S. Valli (2025), the Court affirmed that service of appeal is irrelevant—the statutory bar triggers automatically upon filing.

• The Court emphasized that the husband deliberately avoided service, and his claim of ignorance was not believable, especially since he was served at the same address in previous proceedings.

• The judgment underscores that the administration of justice is harmed when parties act to frustrate appellate remedies, particularly in matrimonial matters where reconciliation opportunities exist.

• The Court viewed the conduct as a brazen breach of judicial authority, striking at the sanctity of rule of law.

• The refusal to accept the apology shows the Court’s commitment to deterring misuse of the legal process and ensuring that litigants do not render appellate proceedings meaningless through unilateral actions.

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✅Sheikh Rafique Sk. Gulab v. State of Maharashtra, 2025

• The Court applied the settled principle that sexual intent is inferred from conduct, noting that the combination of:

  • physical contact,

  • an offer of money, and

  • a sexually explicit invitation
    “unmistakably” showed intent.

• Justice Mehta emphasized that POCSO covers all forms of sexual misconduct, including attempts and inducement-based acts, not only overt physical assault.

• The argument that mere holding of hand is not an offence was rejected because context determines intent.

• The Court reaffirmed the high reliability of child testimony, especially when consistent and unembellished.

• Denial of probation reflected the Court’s prioritization of child protection, societal interests, and the deterrent purpose of sentencing.

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✅L v. R.D., 2025

• The Court reaffirmed the liberal evidentiary framework established under the Family Courts Act, prioritizing truth-finding over technical admissibility rules.

• The Court drew a clear distinction between general civil/ criminal proceedings (where Section 65B is mandatory) and matrimonial disputes, where the statutory scheme allows more flexibility.

• The judgment emphasizes the purpose of matrimonial adjudication:

  • substantial justice,

  • truth discovery,

  • avoiding technical barriers, especially where personal relationships are involved.

• The Court also scrutinized the conduct of the parties. The wife’s inability to explain the alleged fabrication and her admission about the photo transfer significantly undermined her defence.

• The husband’s conduct in breaking the wife’s phone was termed “natural,” reflecting his emotional reaction after discovering her messages and images.

• Overall, the judgment strengthens the principle that matrimonial courts may admit all material that assists in establishing the truth, even if such material does not strictly comply with the Indian Evidence Act.

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✅X v. Y, 2025

• The judgment reinforces that maintenance laws must be interpreted purposively to ensure financial protection of dependent family members.

• The Court focused on substance over technicality, recognizing that the daughter’s right to maintenance exists independently under HAMA.

• It emphasized avoiding “abuse of process” by preventing multiplicity of litigation when the rights and obligations of the parties are already clear.

• Justice Amit Mahajan stressed that the Family Court has broad jurisdiction and can grant relief under the correct statutory provision even if the petition cited another section.

• This decision strengthens the legal principle that unmarried major daughters remain entitled to parental support until marriage or gainful employment in Hindu law.

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✅Akola Municipal Corporation & Anr. v. Zishan Hussain Azhar Hussain & Anr., 2025

• The Supreme Court strongly reaffirmed the principle that courts should not interfere with economic and fiscal policy decisions unless the action is patently illegal.

• The judgment highlights the constitutional and practical necessity of municipal financial autonomy, emphasizing that municipalities:

  • are statutory bodies,

  • perform functions critical to citizens’ welfare, and

  • require stable revenue streams, including through property tax.

• The Court criticized the municipality for not revising taxes for 16 years but emphasized that such administrative delay cannot elevate a PIL challenge into a basis for invalidating a lawful revision.

• The ruling underscores the limited scope of writ jurisdiction, especially in policy matters, and promotes judicial restraint.

• The judgment reinforces that courts should not act as appellate bodies over policy decisions, particularly in taxation.

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✅Dadu @ Ankush & Anr. v. State of Madhya Pradesh & Anr., 2025

• The ruling reinforces the principle that hostile witness evidence must be examined in detail, not rejected in entirety.

• Cites State of U.P. v. Ramesh Prasad Misra to clarify legal position on hostile witnesses.

• Ensures that courts do not mechanically reject testimony, which may contain valuable facts supporting defense or prosecution.

• Highlights the importance of evaluating each portion of evidence independently to prevent miscarriage of justice.

• Promotes fair trial standards by balancing the treatment of uncooperative witnesses with the rights of the accused.

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✅X v. Y, 2025

• The Bench emphasized that the Supreme Court has consistently interpreted the right under Section 17 as non-proprietary—a protective right ensuring residence but not creating a title or permanent licence.

• Relying on Manju Arora v. Neelam Arora & Anr., the Court reiterated that the daughter-in-law’s residence rights cannot override the health, dignity, and peaceful enjoyment rights of senior citizens.

• The Court found uncontroverted evidence that the daughter-in-law’s continued presence was harming the in-laws’ health.

• The judgment underscores a balancing approach:

  • The woman’s rights should be protected through alternate accommodation and maintenance,

  • While preventing undue burden or distress to elderly parents-in-law.

• Importantly, the Court clarified that the wife was not being rendered homeless, which is a key consideration under the PWDV Act.

• The ruling reinforces that the law does not compel senior citizens to endure a corrosive domestic environment, particularly where dignified alternatives are arranged.

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✅SK v. RR, 2025

• The Court emphasized that mere assertions of dowry harassment, without specific details or corroboration, cannot rebut consistent evidence supporting non-consummation and marital discord.

• The Court adopted a holistic approach, assessing not just isolated statements but the entirety of the evidence: written pleadings, communications exchanged, and conduct of the parties.

• The recurring theme of refusal of physical intimacy, combined with immediate and prolonged separation, persuaded both the Family Court and the High Court that the behaviour amounted to mental cruelty.

• The Court noted that counselling and conciliation failed despite opportunities, showing irretrievable breakdown, though not a statutory ground, can reinforce findings of cruelty.

• The judgment reinforces that non-consummation and continuous separation may cumulatively establish cruelty under Section 13(1)(ia).

• The Court’s approach reflects the principle that matrimonial ties cannot be forced where living together has become impossible or emotionally damaging.

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✅Govind Mandavi v. State of Chhattisgarh, 2025

• The Court’s reasoning underscores the principle that FIR omissions, particularly relating to the identity of the accused, can significantly undermine the reliability of the prosecution’s case when the informant had the opportunity to disclose such facts.

• The Supreme Court applied a natural conduct test: if PW-2 described minute details (time, weapons, physical descriptions), it was unnatural that she would omit naming the accused if she truly recognised him.

• The Court rejected the prosecution's justification of PW-2’s illness, holding that it could not explain such a serious omission.

• The judgment reaffirms that delay in identification, without plausible explanation, is a weak piece of evidence.

• Use of Section 11 of the Evidence Act highlighted how omissions can become relevant facts by affecting the probability of the prosecution's story.

• The ruling strengthens jurisprudence requiring strict scrutiny of eyewitness testimonies, especially where conviction rests solely on their statements.

• The decision further reflects the constitutional principle that suspicion, however strong, cannot replace proof.

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✅THE STATE OF WEST BENGAL VERSUS ANIL KUMAR DEY, 2025

• The judgment clarifies the independence of procedural powers between general criminal law (CrPC) and special anti-corruption legislation (PC Act).

• It strengthens the investigatory powers of police and other investigating agencies, allowing swift action to prevent dissipation of assets.

• By rejecting the reliance on Ratan Babulal Lath, the Court emphasizes that observations without detailed reasoning are not binding.

• The ruling ensures that public servants cannot exploit procedural gaps to shield illicitly acquired assets.

• It provides a practical framework for enforcement agencies, confirming that prompt freezing under CrPC is legally valid even in PC Act cases.

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✅Aznan Khan vs. State of U.P. and Another, 2025

• Balances victim protection with procedural fairness for accused.

• Emphasizes that long delays in filing FIRs and questionable conduct of complainants can impact bail decisions.

• Sends a cautionary note that SC/ST Act provisions meant to protect victims should not be exploited to obstruct justice.

• Highlights judicial discretion in granting bail, even in serious allegations, when procedural anomalies exist.

• Reinforces that courts can critically examine conduct of parties when it impacts administration of justice, without commenting on merits of the criminal case.

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✅State of Jharkhand v. Sukhlal @ Prabir Murmu and Others, 2025

• It reinforces principle that death penalty is exceptional and requires unanimity among judges.

• It confirms that split opinions in appellate review are a valid ground for commuting death sentences.

• It balances state authority and rule of law against procedural fairness for appellants.

• It highlights the role of eyewitness testimony in establishing criminal liability, even in cases involving organized ambushes and multiple murders.

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✅Sheikh Irshad @ Monu v. State of Maharashtra, 2025

• The judgment clarifies that bail conditions must be reasonable and context-specific, and cannot be enforced rigidly once the trial has begun.

• The Court balances the State’s interest in investigation and prosecution with the accused’s right to fair treatment under the law.

• It establishes that once trial commences, police reporting conditions are largely procedural and cannot justify cancellation of bail, provided the accused attends court as required.

• The ruling reinforces the principle that bail is a right, not a privilege, and procedural non-compliance must be considered in context.

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✅Suvej Singh v. Ram Naresh and Ors., 2025

• The judgment reinforces the principle that once a dispute is finally adjudicated, it should not be reopened lightly, even if procedural irregularities are alleged.

• Courts must balance the rights of parties with the need to avoid protracted litigation.

• The decision signals that higher courts should aim to resolve disputes definitively, rather than sending them back for further proceedings that merely extend the conflict.

• It also clarifies the scope of Section 30 of the UP Revenue Code, restricting its use to true corrections and not as a tool for advantage-seeking.

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✅Chandrashekhar Bhimsen Naik v. State of Maharashtra & Ors., 2025

• Reinforces the principle that arrest cannot be routine or mechanical; it must be individualized.

• Upholds the rule of law and rights of the accused, ensuring that statutory safeguards are not bypassed even in high-profile cybercrime investigations.

• Clarifies the responsibility of magistrates to verify arrest reasons and prevent arbitrary detention.

• Signals that courts will closely examine group arrests to ensure each accused’s role and circumstances are considered.

• Reiterates the Supreme Court’s observation in Jogindar Kumar v. State of UP: the quality of law enforcement reflects the nation’s commitment to justice.

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✅Mamta Gurjar v. Pooja Kushwah, 2025

• It reinforces the principle that public servant immunity is limited and not a blanket protection.

• It clarifies that Section 197 CrPC and Section 218 BNSS protection requires a reasonable nexus with official duty.

• It strengthens accountability for police misconduct, custodial abuse, and false case registration.

• It highlights the judiciary’s role in preventing misuse of statutory immunity to shield misconduct.

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✅Himinder Lal & others v/s Madan Lal and others, 2025

• The Court emphasized the broad scope of Section 92(1)(h), which allows courts to provide relief as required for trust administration.

• The judgment clarifies that beneficiaries of a trust can seek judicial intervention when there is alleged mismanagement, even if defendants dispute the existence of a trust.

• It underlines that preliminary dismissal is not appropriate where fraud goes to the root of the matter; factual examination through evidence is necessary.

• Sets a precedent on trust property litigation and the application of Section 92 CPC in cases of alleged alienation.

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✅Baboo Khan v. The State of Rajasthan, 2025

• The Court clarified the scope of Section 304B IPC: dowry refers only to property or valuable security demanded in connection with the marriage.

• Post-marriage customary payments (e.g., for childbirth ceremonies) do not fall under dowry.

• Reinforces that dowry laws cannot be extended beyond marriage-related demands.

• Sets a precedent for distinguishing dowry demands from other customary payments in criminal cases.

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✅Jothi @ Nagajothi v. State, 2025

• The Court adopted a pragmatic and substance-over-form approach in NDPS prosecutions. Relying on Bharat Aambale v. State of Chhattisgarh, 2025 LiveLaw (SC) 84, the Court clarified that Section 52-A is directory, not mandatory, in the sense that every procedural deviation does not vitiate the trial.
  
  
• The judgment reinforces that Credibility of evidence, not mechanical compliance, is the decisive factor.

• Courts must examine whether alleged procedural defects strike at the root of the prosecution case.

• Where the chain of custody remains intact, seals are untampered, and forensic evidence confirms the nature of the substance, minor deviations in sampling procedure will not benefit the accused.

• This ruling strengthens prosecution cases under the NDPS Act by preventing acquittals based solely on technical or hyper-technical objections, while still safeguarding the accused against genuine prejudice or evidence tampering.

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✅V.P. Abdurahiman v. C. Safiya, 2025

• Justice Kauser Edappagath carefully balanced personal law principles with procedural fairness under Section 125 CrPC.

• The Court reaffirmed the settled principle that:

  • Long cohabitation can give rise to a presumption of marriage only in the absence of legal impediments.

• The existence of a subsisting second marriage constitutes an insurmountable obstacle under Muslim law.

• The judgment underscores that Nikah Halala is not a mere formality but requires strict proof of:

  • Intervening marriage,

  • Consummation, and

  • Dissolution.

• At the same time, the Court adopted a beneficial and equitable approach by remanding the matter rather than outright dismissing the maintenance claim.

• The ruling prevents misuse of presumptions under Section 125 CrPC while ensuring that genuine claims are not defeated on technical grounds.

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✅The New India Assurance Co. Ltd. v. Sabita Das & Ors., 2025

• Justice Biswaroop Chowdhury emphasized that statutory requirements under Section 185 must be strictly complied with before attributing drunken driving.

• The Court protected the beneficial nature of the Motor Vehicles Act, ensuring that legal heirs are not deprived of compensation based on speculative or inconclusive evidence.

• The ruling clarifies that:

  • A post-mortem note of alcoholic smell alone is insufficient to deny compensation.

  • Defences unrelated to the contractual liability of the offending vehicle’s insurer cannot be raised.

• The Court also made an important policy observation, urging insurance companies to inform transport authorities when vehicles ply without renewal of insurance, highlighting concerns of public safety.

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✅State v. Babulal Malviya, 2025

• The court emphasized the importance of reasoned judgments in appellate matters.

• Referring to Bani Singh v State of UP [(1996) 4 SCC 720)], it stated that appellate courts must analyze evidence and not merely follow trial court reasoning.

• Citing State of Rajasthan v Sohan Lal [(2004) 5 SCC 573)], it reiterated that giving reasons is essential for judicial accountability.

• The judgment highlighted that failure to provide reasons undermines legal transparency and accountability.

• By remitting the matter, the High Court ensured the appellate process fulfills its duty of independent scrutiny.

• Sets a precedent emphasizing the requirement of speaking orders in appellate courts for fair administration of justice.

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✅STATE OF U.P. v. AJMAL BEG, 2025

• Supreme Court reinforced that dowry is a deep-rooted social evil requiring societal and legal interventions.

• Emphasized that non-speaking judgments and ignoring evidence (as in High Court) are legally impermissible.

• Reiterated Section 304B and 113B IPC presumptions in dowry death cases.

• Balanced punitive action with practical considerations (e.g., age of mother-in-law).

• Issued proactive directions to improve awareness, police/judicial training, and case monitoring.

• Recognized the dual challenge of ineffectiveness of law vs. misuse (Section 498A and DPA) and stressed systemic reforms.

---

✅Danesh Singh & Ors. v. Har Pyari (Dead) through LRs & Ors. 2025

• The judgment reinforces the principle that procedural law cannot be circumvented by clever drafting or mislabeling of applications.

• The Supreme Court adopted a substance-over-form approach, emphasizing that courts must look at the real nature of the pleadings rather than their nomenclature.

• By restricting the scope of Section 47 CPC, the Court ensured finality of execution proceedings, which is a crucial objective of civil procedure.

• The judgment clarifies the limited scope of nullity, making it clear that only jurisdictional defects can render an execution sale void, while procedural irregularities must be challenged within limitation.

• The ruling prevents abuse of process by litigants who attempt to reopen settled execution sales after confirmation, thereby protecting bona fide auction purchasers.

• The decision harmonizes Section 47 CPC, Order XXI CPC, and the Limitation Act, ensuring that each provision operates within its intended statutory boundary.

---

✅N v. A, 2025

• The judgment reinforces the evolving jurisprudence that marriage should not be mechanically preserved when it has completely broken down.

• The Supreme Court shifted focus away from the fault theory, recognizing that prolonged separation itself causes mental cruelty to both parties.

• By invoking Article 142, the Court emphasized that substantive justice prevails over rigid statutory limitations in exceptional matrimonial cases.

• The ruling acknowledges individual autonomy by holding that forced continuation of a dead marriage violates personal dignity.

• The decision aligns with earlier precedents such as:

  • Rakesh Raman v. Kavita (2023), holding that long separation constitutes cruelty.

  • Shilpa Sailesh v. Varun Sreenivasan (2023), recognizing the Court’s power to dissolve marriages notwithstanding statutory fault.

  • Kumari Rekha v. Shambhu Saran Paswan (2025), affirming that irretrievable breakdown justifies dissolution under Article 142.

• The judgment contributes to a human-centric and pragmatic approach in matrimonial law, discouraging endless litigation with no prospect of reconciliation.

---

✅MAK v. AKK, 2025

• The judgment reiterates that maintenance is need-based, not income-proportionate, aligning with the principle that it must satisfy reasonable requirements of dependents.

• The Court balanced the financial capacity of the husband with the needs of the children and wife, preventing arbitrary or inflated claims.

• The decision underscores the importance of documented evidence when claiming maintenance, ensuring that awards are grounded in reality.

• By clarifying the Family Court’s order, the Court resolved ambiguity regarding payment to children, ensuring clarity in enforcement.

• The ruling contributes to jurisprudence on Section 125 CrPC, promoting a fair and practical approach to maintenance without imposing undue burden on the paying spouse.

---

✅X v. Y, 2025

• The judgment reinforces that maintenance is need-based, not asset-based, and cannot be denied on the ground of natal family wealth.

• The ruling emphasizes the principle that maintenance should preserve the reasonable standard of living enjoyed during marriage, rather than arbitrarily reducing it due to theoretical financial independence.

• The Court clarified that all sources of husband’s income, whether from employment, business, or other ventures, are relevant when determining maintenance.

• This decision safeguards women against attempts to undermine maintenance claims by relying on stridhan or gifts and promotes a practical and equitable approach under Section 125 CrPC.

---

✅Mukhtar Ahmad v. State of U.P. through Additional Chief Secretary, 2025

• The judgment highlights the importance of witness credibility in bail applications for serious offences.

• The Court recognized the possibility of misuse of legal provisions, noting the rise in fake dowry claims, and factored this into its discretion.

• By granting bail, the Court balanced individual liberty of the accused with the need for justice, showing that bail decisions are dynamic and context-specific.

• The decision underscores that even in serious offences, bail cannot be denied automatically and must respond to trial realities rather than only the nature of the allegations.

---

✅T. Prabhakar Rao v. State of Telangana, 2025

• The Court struck a balance between the State’s duty to investigate and the petitioner’s rights, ensuring the interrogation is lawful and safe.

• It reaffirmed that anticipatory bail proceedings remain unaffected by lawful surrender.

• The judgment demonstrates the Court’s commitment to procedural fairness, particularly in sensitive cases involving senior officers.

• The order also clarifies the limits of coercive action and emphasizes compliance with legal safeguards during custodial procedures.

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✅Manojbhai Jethabhai Parmar (Rohit) v. State of Gujarat, 2025

• The Court reinforced the importance of procedural rigor in criminal trials, especially those involving minors and sensitive evidence.

• Highlighted that circumstantial and forensic evidence must be meticulously documented, and lapses can lead to acquittal even when allegations are serious.

• By recommending charts and tabulated formats, the Court aimed to reduce trial delays, simplify complex evidence, and prevent errors in record-keeping.

• The judgment serves as a guideline for trial courts across India, emphasizing that justice is as much about process as it is about facts.

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✅Kangra Central Cooperative Bank Limited v. The Kangra Central Cooperative Bank Pensioners Welfare Association (Regd.) & Ors., 2025

• The judgment strengthens procedural discipline in appellate litigation before the Supreme Court.

• Balances the right of a party to seek review against the need for finality in judicial decisions.

• Provides a clear precedent that successive SLPs are maintainable only with express liberty.

• Reinforces the principle that non-speaking orders dismissing petitions do not confer implicit rights to re-litigate before the Supreme Court.

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✅K. S. Dinachandran v. Shyla Joseph & Ors., 2025

• The Court clarified that gaps in examination-in-chief do not automatically render a Will invalid if they are addressed in cross-examination.

• It reinforced that the Court cannot substitute its judgment or notions of fairness for the testator’s decision.

• The judgment establishes that testamentary freedom is paramount, and minor omissions in witness testimony can be legally remedied during cross-examination.

• The decision strengthens legal principles regarding proof of Wills, the role of attesting witnesses, and testamentary capacity, and provides clarity on procedural evidence rules.

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✅Shaik Shabuddin v. State of Telangana, 2025

• The Court clarified that Section 27 protects only recoveries of objects previously concealed, discovered due to a disclosure by the accused.

• Recoveries of objects already in possession of the accused cannot be legitimised as Section 27 discoveries.

• The judgment emphasizes proper investigative practices and prevents misuse of confessions to justify otherwise inadmissible evidence.

• It reaffirms limits on the application of Section 27, ensuring that courts do not treat routine recoveries as legally significant disclosures.

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✅Harish Rana v. Union of India, 2025

• The case applies the Common Cause 2018 guidelines for passive euthanasia, including Primary and Secondary Medical Board evaluations.

• The Court stressed the importance of personal consultation with family members before exercising the sensitive decision to allow passive euthanasia.

• It highlights the balance between preserving life under Article 21 and upholding dignity in end-of-life care.

• The case reflects the Supreme Court’s approach to prolonged vegetative states and the role of medical evidence in ethical and legal decisions.

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✅Tasaul Sk v. The State of West Bengal & Another, 2025

• It reinforces that consensual relationships cannot automatically attract criminal liability unless all elements of the offence are proven.

• It highlights the misuse of criminal law in failed personal relationships.

• It confirms that procedural compliance and corroboration of evidence are essential before framing serious charges.

• It emphasizes the precedent of Shreya Singhal to strike down obsolete or unconstitutional IT provisions.

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✅X v. Y, 2025

• It affirms judicial flexibility in divorce by mutual consent to prevent parties from being trapped in unworkable marriages.

• It distinguishes between the first motion (13B(1)) and second motion (13B(2)) periods.

• It recognizes the primacy of autonomy and dignity of spouses over rigid adherence to timelines.

• It clarifies that misrepresentation or concealment may affect granting of waiver.

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✅Baddam Prashanth Reddy vs. State of Andhra Pradesh, 2025

• The case reinforces the safeguard under Section 118 to prevent wrongful convictions based on untested child testimony.

• The judgment highlights the need for preliminary judicial inquiry into the child’s ability to testify, ensuring justice and fairness.

• It serves as a binding precedent for cases where the entire conviction is based on a minor’s statement without corroboration.

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✅Modh. Asif v. State of U.P. and Another, 2025

• Reaffirmed that in Muslim marriages, maintenance of the first wife is independent of obligations to other spouses.
• Emphasized that courts must consider dependency and need of the wife.
  
  
• Clarified that polygamous obligations cannot override the first wife’s entitlement.
  
  
• Reinforced precedent from Shamima Farooqui v. Shahid Khan, stressing husband’s financial capacity but protecting first wife’s rights.

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✅Dr. Amit Arya v. Kamlesh Kumari, 2025

• The Court reiterated that time is generally not the essence of contracts involving immovable property.

• Reliance was placed on Ram Lal v. Jarnail Singh (2025 LiveLaw (SC) 283), which held that non-payment within the stipulated time does not amount to abandonment of contract.

• The Court clarified that the real test is whether the plaintiff’s conduct shows a positive refusal to perform the contract.

• The buyer’s actions filing execution proceedings and depositing the consideration proved continuous readiness and willingness.

• On the doctrine of merger, the Court held that once the High Court restored the decree without prescribing a new timeline, the Trial Court decree merged with the appellate decree.

• Therefore, the decree could not be rendered inexecutable merely because the buyer complied beyond the original timeline.

• The Court relied on Balbir Singh & Anr. v. Baldev Singh to reinforce the principle of merger.

• The judgment strengthens the equitable nature of specific performance and prevents injustice caused by rigid procedural interpretations.

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✅Belide Swagath Kumar v. State of Telangana & Another, 2025

• The Court reiterated that Section 498A IPC requires specific, proximate, and grave acts amounting to cruelty.

• It clarified that the term “cruelty” cannot be interpreted so broadly as to include ordinary matrimonial disagreements.

• The judgment stressed that FIRs invoking criminal machinery must disclose clear particulars, including dates, conduct, and roles of accused persons.

• The Court cautioned against the misuse of matrimonial criminal provisions to harass spouses and their families.

• It held that vague and omnibus allegations weaken the prosecution’s case and undermine the credibility of the complainant.

• The ruling reinforces judicial scrutiny at the threshold stage to prevent abuse of criminal process.

• The decision contributes to balancing protection of genuine victims while preventing misuse of Section 498A IPC.

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✅M/s Sri Om Sales v. Abhay Kumar @ Abhay Patel & Another, 2025

• The Court reaffirmed the settled principle that at the stage of quashing, courts must only see whether a prima facie case is made out.

• It clarified that appreciation of evidence and determination of disputed facts is the exclusive domain of trial courts.

• The judgment emphasised the importance of Section 139 N.I. Act, which creates a rebuttable presumption in favour of the cheque holder.

• The Court held that such presumption can be rebutted only through evidence led during trial.

• By conducting a detailed factual enquiry, the High Court effectively short-circuited the trial process, which was impermissible.

• The ruling strengthens the object of the Negotiable Instruments Act by preventing premature termination of legitimate cheque dishonour prosecutions.

• It reinforces judicial discipline in the exercise of inherent powers under Section 482 CrPC.

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✅X v. Union of India, 2025

• The case raises serious constitutional concerns relating to custodial safeguards and professional freedom of advocates.

• Alleged violations of Section 46(4) CrPC highlight systemic issues in compliance with protections afforded to women.

• Reference to DK Basu and Sheela Barse underscores the continuing relevance of custodial jurisprudence.

• Alleged non-functioning of CCTV cameras directly implicates compliance with Paramvir Singh Saini.

• The plea seeks structural and preventive guidelines, not merely individual relief.

• The matter has potential implications for nationwide safety standards for women advocates.

• Final legal impact will depend on findings after notice and responses from authorities.

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✅Kiran v. State of Karnataka, 2025

• The Court clarified the legal meaning of life imprisonment, which ordinarily lasts for the convict’s entire life but remains subject to remission and commutation.

• It reaffirmed that the “special category” sentencing evolved in Swamy Shraddananda (2) can only be exercised by Constitutional Courts, not trial courts.

• The judgment relied on the Constitution Bench ruling in V. Sriharan, which upheld the power of higher courts to restrict remission in appropriate cases.

• The Court emphasized that Sessions Courts are creations of the CrPC and cannot override or restrict the very statutory framework that establishes them.

• The ruling draws a clear jurisdictional boundary between trial courts and constitutional courts in sentencing matters.

• It ensures uniformity and legality in sentencing by preventing overreach by trial courts.

• The decision protects the statutory and constitutional balance between punishment, executive discretion, and judicial review.

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✅Sahiba Sodhi v. The State (NCT of Delhi) & Another, 2025

• The Court drew a clear distinction between maintenance and right to residence under the Domestic Violence Act.

• It reaffirmed that the PWDV Act provides multiple, independent reliefs, and denial of one does not negate entitlement to others.

• The judgment recognizes the practical realities faced by women who may temporarily reside with relatives due to marital disputes.

• By granting rental expenses, the Court ensured the wife’s right to dignified and secure accommodation.

• The ruling balances accountability for concealment of income with the protective object of the DV Act.

• The direction to expedite trial reflects judicial concern over prolonged matrimonial litigation.

• The decision strengthens jurisprudence that residence orders are not contingent solely on financial dependency.

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✅Sanjay Kumar & Anr v. State of J&K, 2025

• Reinforces principle that legal doctrines do not cure evidentiary deficiencies.

• Delay in FIR, contradictions in statements, and non-corresponding medical evidence are critical in assessing credibility.

• Minor status of victim cannot be used as a fallback if the crime’s occurrence is doubtful.

• Highlights importance of procedural diligence, including examination of investigating officers and preservation of primary records.

• Balances protecting minor victims with ensuring fair trial and prevention of wrongful conviction.

• Serves as a cautionary precedent against automatic reliance on statutory presumptions in sexual offence cases.

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✅Lakshmanan v. State through the Deputy Superintendent of Police & Others, 2025

• The Supreme Court reaffirmed that personal liberty must be balanced with societal interest and fair trial.

• The Court emphasized that prior misuse of bail is a decisive factor against re-grant of bail.

• The Court criticised the High Court for ignoring the death of a key eyewitness, which threatened the fairness of the trial.

• The Court observed that merely recording criminal antecedents without analysing their relevance amounts to an empty formality.

• The judgment reinforces that bail orders must demonstrate application of mind, especially in cases involving serious offences and SC/ST victims.

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✅Syed Shahnawaz Ali v. The State of Madhya Pradesh, 2025

• The Supreme Court drew a clear distinction between appeals and revisions, emphasizing the supervisory nature of revisional jurisdiction.

• The Court reaffirmed that strict rules of locus standi do not apply to criminal revision proceedings.

• The judgment prevents mechanical dismissal of revisions on technical grounds such as death of the revisionist.

• The Court cautioned that revisional jurisdiction should not be abused by strangers with no legitimate interest.

• The definition of victim under Section 2(wa) CrPC was endorsed as a guiding factor for permitting assistance to the court.

• The ruling strengthens victim participation in criminal proceedings and ensures continuity of judicial scrutiny.

• The decision promotes substantive justice over procedural rigidity.

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✅Mayankkumar Natwarlal Kankana Patel & Anr. v. State of Gujarat and Anr., 2025

• The Supreme Court reaffirmed that Section 311 CrPC is meant to discover the truth but cannot be invoked for delaying proceedings or adding speculative evidence.

• The judgment underscores that trial courts must evaluate the indispensability and reliability of witnesses, especially child witnesses.

• The Court highlighted the importance of preventing prejudice to the accused and avoiding protracted trials.

• The ruling reinforces that late-stage applications under Section 311 CrPC require strong justification, particularly when the witness was not previously involved.

• The judgment emphasizes the need for judicial caution in invoking child witnesses due to the passage of time, tender age, and potential tutoring.

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✅State of U.P. & Anr. v. Mohd Arshad Khan & Anr., 2025

• The judgment underscores the principle that quashing petitions and anticipatory bail are distinct remedies and cannot be conflated.

• The Court reinforced the precedent of Neeharika Infrastructure, emphasizing that High Courts cannot interfere in ongoing investigation by granting blanket protections.

• The judgment clarifies that judicial timelines for investigation must be evidence-based and reactive, preventing courts from overstepping executive functions.

• The ruling ensures that investigation and prosecution retain their statutory independence and prevents misuse of judicial powers under the guise of quashing FIRs.

• The Court’s reasoning provides guidance to High Courts to exercise caution while entertaining quashing petitions and issuing directions affecting coercive steps.

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✅X & Anr. v. Y, 2025 

• The judgment reinforces that sub-clause (iii) of Section 5 of the Hindu Marriage Act is not a ground for void marriage under Section 11.

• Only spouses have legal standing to question the validity of marriage, not third parties such as parents or in-laws.

• The ruling discourages raising belated claims of underage marriage after a marriage has been recognized by a competent court.

• The Court clarified the distinction between void and voidable marriages, and the scope of sections 11 and 12 in the Hindu Marriage Act.

• The case underscores the principle of finality in judicial proceedings and protection of rights of the spouse recognized by law.

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✅Teekam v. State of Uttar Pradesh, 2025

• The judgment clarifies an important procedural aspect of bail jurisprudence, ensuring that technical practice does not override statutory powers.

• The Court reaffirmed that Section 439 CrPC does not impose any hierarchy or mandatory sequence between the Sessions Court and the High Court.

• The reliance on Kamal @ Kamal Choudhary v. State of M.P. (2025) strengthens the principle that fresh material during trial constitutes a change in circumstances.

• The ruling balances judicial discipline with practical justice, ensuring that an accused is not denied bail merely due to procedural rigidity.

• The judgment reinforces that hostile testimony or weakening of prosecution evidence during trial can justify reconsideration of bail.

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✅Farha Naz v. State of Uttar Pradesh and Another, 2025

• The judgment reinforces the principle laid down in Rajnesh v. Neha, that courts must insist upon income affidavits and documentary proof before deciding maintenance.

• The High Court clarified that earning potential and actual income are distinct concepts, and maintenance cannot be denied merely because a wife is educated or engaged in some activity.

• The ruling protects women from speculative and presumptive findings relating to income, especially in the digital era where content creation does not automatically translate into financial independence.

• The decision strengthens procedural fairness by requiring Family Courts to conduct a proper financial inquiry before deciding maintenance applications

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✅Chhote Lal Kushwaha and 3 Others v. State of Uttar Pradesh and Another, 2025

• The judgment reinforces the settled principle that the Public Prosecutor is an officer of the Court, not a mouthpiece of the Government.

• The High Court emphasised that judicial scrutiny under Section 321 CrPC is mandatory, especially in cases involving vulnerable sections of society.

• The decision safeguards the rights of victims belonging to Scheduled Castes by ensuring that prosecutions are not withdrawn arbitrarily or politically.

• The ruling underscores that public interest, fairness of trial and seriousness of allegations must prevail over executive discretion.

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✅Mehraj Ahmad Ganai and Another v. Mst. Sara Begum and Others, 2025

• The judgment clearly distinguishes between withdrawal of proceedings and compromise of proceedings, preventing misuse of procedural law.

• The High Court reaffirmed that procedural safeguards under Order XXIII Rule 3 CPC are mandatory, and non-compliance renders any compromise legally ineffective.

• The ruling protects litigants from being forced into litigation against their expressed will after lawful withdrawal.

• By rejecting the invocation of Section 151 CPC, the Court reinforced the principle that inherent powers cannot override express statutory rights.

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✅Manoj @ Munna v. State of Chhattisgarh, 2025

• The Court reiterated that in cases based purely on circumstantial evidence, the chain of circumstances must be complete and unbroken.

• The last-seen theory was described as a weak form of evidence requiring independent corroboration.

• The lower courts erred by relying excessively on the silence of the accused.

• Section 106 Evidence Act cannot be used to fill gaps in the prosecution’s case.

• The Court emphasized that suspicion cannot substitute proof.

• The judgment reinforced the presumption of innocence and safeguarded against wrongful convictions.

• The ruling strengthens criminal jurisprudence standards in cases relying solely on circumstantial evidence.

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✅Rajesh Upadhayay v. State of Bihar & Anr., 2025

• The Supreme Court reiterated that suspension of sentence post-conviction is an exception, not the rule.

• The Court emphasized that the mere pendency of an appeal is not a sufficient ground to suspend sentence.

• It was clarified that courts must consider:

  • The nature of accusation,

  • The manner of commission of the crime, and

  • The seriousness and gravity of the offence.

• The Court relied on Vijay Kumar v. Narender, reaffirming that judicial discretion under Section 389 CrPC must be exercised judiciously.

• The judgment reinforces that where the accused has played a direct and active role in a heinous offence, suspension of sentence is generally unwarranted.

• The ruling strengthens the principle that public confidence in the criminal justice system must not be undermined by casual grant of post-conviction relief.

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✅Ramesh Kumar Jain v. Bharat Aluminium Company Limited (BALCO), 2025

• The Supreme Court clarified that patent illegality arises only when an arbitral finding is irreconcilable with any permissible view of the evidence.

• The Court emphasized that arbitrators cannot conjure facts, but they are free to rely on some evidence, even if minimal.

• It was reiterated that arbitration is not governed by strict rules of evidence, as per Section 19 of the A&C Act.

• The arbitrator’s interpretation of a silent contractual clause was held to be within jurisdiction.

• The Court recognised that where extra work is directed and accepted, denial of compensation would lead to unjust enrichment.

• The High Court was found to have re-appreciated evidence and substituted its own interpretation, which is impermissible under Sections 34 and 37.

• The judgment strengthens the principle of minimal judicial interference in arbitral awards.

• It reinforces that brevity of reasoning is not a ground for setting aside an award if the reasoning path is discernible.

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✅State of U.P. and Another v. Mohan Lal, 2025

• Reinforces that “sufficient cause” must be shown honestly and cannot be invoked for mere administrative or bureaucratic delay.

• The decision underscores the principle of parity between private litigants and the State in legal proceedings.

• Reliance on multiple Supreme Court precedents highlights that courts do not accept lenient interpretation of “sufficient cause” where delay is excessive.

• Emphasizes accountability of government agencies to act diligently in pursuing legal remedies.

• Prevents state machinery from exploiting procedural delays for undue advantage.

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✅Mehraj Ahmad Ganai and Anr. v. Mst. Sara Begum & Ors., 2025

• Clarifies the distinction between Order XXIII Rule 1 CPC (withdrawal) and Order XXIII Rule 3 CPC (compromise decree).

• Reinforces the absolute right of plaintiffs/appellants to withdraw without being forced to continue litigation.

• Confirms that inherent powers under Section 151 CPC cannot override an express statutory right.

• Protects against misinterpretation of withdrawal orders as compromise decrees by courts or authorities.

• Prevents jurisdictional overreach by lower courts.

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✅X v. Y, 2025

• The judgment emphasizes that concealment of fertility-related facts can amount to mental cruelty under Hindu Marriage Act.

• The Court reinforced that lack of supporting evidence weakens claims against a divorce petition.

• While upholding the divorce, the High Court balanced equity by granting permanent alimony, in line with precedent and socio-economic considerations.

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✅Devendra Srivastava and Others v. M/S Eifel Recreation Club (P) Ltd., 2025

• The judgment reinforces the principle that, at the stage of Order VII Rule 11 CPC, courts must confine themselves strictly to the plaint averments.

• By emphasizing the two distinct parts of Article 54, the Court clarified that limitation in suits for specific performance is not always triggered by the original contractual date.

• The decision protects plaintiffs from premature dismissal where pleadings disclose facts suggesting an extended timeline or delayed refusal.

• The Court correctly treated the existence and effect of the supplementary agreement as triable issues requiring evidence.

• The ruling prevents misuse of Order VII Rule 11 CPC as a shortcut to avoid a full trial in complex contractual disputes.

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✅State of U.P. and Another v. Mohan Lal, 2025

• Reinforces the principle that law treats State and private parties equally regarding limitation and delay.

• Highlights that condonation of delay is an exceptional remedy, and negligence or casual procedural delay by government cannot justify it.

• Emphasizes the duty of government agencies to act with diligence and commitment in legal proceedings.

• Signals that bureaucratic delays and internal procedural steps cannot shield the State from consequences of gross delay.

• Serves as a cautionary precedent against expecting leniency for delayed filings by government departments.

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✅Sajan Bhatt v. The State of Madhya Pradesh and Others, 2025

• Reinforces the strict protective intent of the POCSO Act regarding offences against minors.

• Clarifies that post-offence developments, such as marriage or child birth, cannot dilute legal accountability.

• Confirms that minor’s consent has no bearing on criminal liability in sexual offences.

• Distinguishes the powers of High Court versus Supreme Court under Article 142.

• Strengthens judicial message against attempts to seek indulgence based on personal circumstances post-commission of the offence.

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✅Vinod Kumar v. State of U.P. & Another, 2025

• Reinforces the fundamental right to liberty under Article 21, even for convicts.

• Highlights the administrative and legal obligations of authorities to release convicts immediately after serving sentences.

• Clarifies that detention in default of fine cannot continue once a court has stayed the fine.

• Serves as a precedent for oversight in compliance with court orders and protection of convicts’ rights.

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✅Rajan Sareen v. State NCT of Delhi & Ors, 2025

• Clarifies the legal threshold for defamation, emphasizing intent and knowledge.

• Distinguishes between malafide complaints and actionable criminal offences.

• Upholds the principle that legal recourse for false complaints is not automatic, preventing abuse of law for retaliation.

• Reinforces that courts must examine substance over form in allegations of defamation or related criminal offences.

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✅Surender Kumar v. State of Himachal Pradesh, 2025

• Clarifies that self-defense requires actual threat or attack, and heat of passion/sudden fight requires mutual physical confrontation.

• Emphasizes that pre-meditation or cruelty is key in distinguishing murder from culpable homicide.

• Provides a precedent for evaluating exceptions under Section 300 IPC, especially in cases of knife/blunt weapon attacks on unarmed victims.

• Reinforces the principle that mere verbal quarrel is insufficient to invoke Exception 4.

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✅Adil Noshir Mithaiwala v. The State of Uttar Pradesh & Ors., 2025

• Establishes that duplicate proceedings on the same issue across jurisdictions cannot be sustained.

• Reaffirms the principle of abuse of process of law and double jeopardy.

• Clarifies limits on Power of Attorney holders in filing criminal complaints when facts are exclusive to the principal.

• Acts as a deterrent against forum shopping, where parties try to relitigate resolved disputes in another country.

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✅Shakeel Ur Reham Vs SHO Women’s PS Anantnag, 2025

• The Court recognized the interconnectedness of matrimonial remedies, highlighting that civil, domestic violence, and criminal proceedings may overlap.

• Material inconsistencies and delayed allegations weakened the prosecution’s case, showing the Court’s reliance on evidence scrutiny.

• Applied principles to prevent misuse of Section 498-A IPC, reiterating Supreme Court guidance on retaliatory complaints.

• Judgment underscores balance between protecting genuine victims and curbing abuse of criminal law in matrimonial disputes.

• Sets a precedent in J&K and Ladakh for careful evaluation of FIRs lodged during pending civil or domestic proceedings.

• Highlights importance of temporal consistency and specificity in claims of domestic cruelty and dowry harassment.

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✅X vs Y, 2025

• The Court clarified the jurisdictional interface between High Courts and subordinate courts under Section 36 of the Act 1996.

• Ensured that Part I of Act 1996 and Section 36 are interpreted harmoniously with Section 2(1)(e) and subsequent amendments under Act 2015.

• Prevents misinterpretation that enforcement of international commercial arbitration awards could be done by District Commercial Courts.

• Confirms the High Court as the competent forum, reinforcing judicial uniformity in enforcement of international arbitration awards.

• Aligns with Supreme Court precedents on enforcement under Part I and Part II distinction of the Act.

• Promotes legal certainty and predictability for parties seeking enforcement of international commercial arbitration awards in India.

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✅Dalip Singh (D) through LRs v. Sawan Singh (D) through LRs, 2025

• The Court reinforced the protective principle for mortgagors in usufructuary mortgages.

• Clarified interaction between Limitation Act (Section 61(a)) and Transfer of Property Act (Section 52).

• Ensured mortgagees cannot exploit mere lapse of limitation to acquire ownership.

• Strengthened the doctrine that usufructuary mortgages maintain mortgagor’s rights until full payment, preserving equity in property law.

• Provides legal clarity for courts on calculating limitation in usufructuary mortgages.

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