MONTHLY MAGAZINE JULY

Lexpedia · 1 July 2025 · 31 min read

✅ G. Nagarathna & Ors. v. G. Manjunatha & Anr.

The Supreme Court dismissed the appeal and upheld the findings of the Karnataka High Court and the MACT. It held that:

The deceased was negligently driving and caused his own death.
Since he was the tortfeasor, his legal heirs were not entitled to compensation under Section 166 of the MV Act.
The deceased, having borrowed the vehicle, assumed the role of the owner, and thus the insurance company was not liable to indemnify the claim.
The Court emphasized that allowing such a claim would be contrary to the principle that no one should benefit from their own wrong.

✅ P Kishore v. The Secretary to Government and Others, 2025

The court provided a firm reaffirmation of constitutional limits on state surveillance in the post-Puttaswamy era.
The court invoked the “Lakshman Rekha” metaphor, emphasizing judicial restraint and legislative supremacy.
Highlighted how statutory safeguards, such as review by a Review Committee, are not optional but mandatory to protect fundamental rights.
Strongly rejected the Centre’s argument that “public safety” can be broadly interpreted to include non-visible threats like corruption.
Clarified that allowing such an expansion would make the law vulnerable to abuse by the executive.
Reinforced the idea that privacy is a constitutional right, and state intrusions must be strictly justified, narrowly tailored, and subjected to judicial/administrative checks.

✅ UMRI POOPH PRATAPPUR (UPP) Tollways Pvt. Ltd. v. M.P. Road Development Corporation and Another, 2025

The Supreme Court upheld the High Court's decision that allowed the writ petition filed by MPRDC.
It affirmed that a writ petition is maintainable against a private party performing a public function, like building public roads under a government contract.
The Court cautioned against indiscriminate outsourcing of core State responsibilities to private players.
It reiterated that roads are a public good and fall under the protection of Article 21.
The Court further clarified that while a writ may lie in matters involving public law elements, pure contractual disputes must be referred to the designated tribunal as per the statutory framework.

✅ Satinder Kumar Antil v. Central Bureau of Investigation, 2025

The Supreme Court rejected the State of Haryana’s application seeking permission for electronic service of Section 35 notices.
The Court emphasized that electronic communication is not a valid mode of service unless specifically provided in the statute.
"A summons issued by a Court is a judicial act, whereas a notice issued by the Investigating Agency is an executive act. Hence, the procedure prescribed for a judicial act cannot be read into the procedure prescribed for an executive act," the Court said.
The next contention of the State was that since summons under Section 93 and 193 can be served electronically, S.35 summons should also be allowed to be served so. Section 93 is the summons to produce a document. Section 193 allows the service of the particularts of the final report to the magistrate electronically.
"None of these procedures have any bearing on the liberty of an individual," the Court observed, rejecting the comparison.
Hence, when viewed from any lens, we are unable to convince ourselves that electronic communication is a valid mode of service of notice under Section 35 of the BNSS, 2023, since its conscious omission is a clear manifestation of the legislative intent. Introducing a procedure into Section 35 of the BNSS, 2023, that has not been specifically provided for by the Legislature, would be violative of its intent," the Court stated in conclusion.
"..service of a notice under Section 35 of the BNSS, 2023 needs to be carried out in a manner that protects this substantive right, as non-compliance with the notice can have a drastic effect on the liberty of an individual.
Section 35 BNSS does not permit electronic service, and introducing it judicially would amount to overriding legislative intent.
The Court observed that non-compliance with a Section 35 notice can lead to arrest, and hence personal liberty under Article 21 is directly implicated.
It was noted that summons under Sections 63, 71, 93, and 193 BNSS either do not affect liberty or are part of judicial processes, unlike Section 35, which is part of an executive investigation.
"The contention of the applicant that a notice under Section 35 of the BNSS, 2023 falls within the same category as a summons under Section 71 of the BNSS, 2023, and therefore, since the latter allows electronic mode of service, the former must also be permitted to be transmitted electronically, cannot be accepted, for the simple reason that a summons under Section 71 of the BNSS, 2023, has no immediate bearing on the liberty of an individual in case of its non-compliance. However, a notice under Section 35 of the BNSS, 2023 could have an immediate bearing on the liberty of the individual in case of its non-compliance, as laid down under Section 35(6) of the BNSS, 2023," the Court observed.
The Court further stated that a summons issued by a Court under Sections 63 or 71 of the BNSS, 2023, and a notice issued by the Investigating Agency under Section 35 of the BNSS, 2023 cannot be equated with each other.

✅ Federation of Leprosy Organizations (FOLO) & Another v. Union of India & Others, 2025

This is a landmark PIL reflecting the evolving intersection of health, dignity, and law.
The Court's directions reinforce that legal frameworks must align with medical advancements and social understanding.
The slow pace of compliance by States reflects systemic inertia toward marginalized communities.
The judgment also stresses the use of executive and legislative powers to correct legal injustices without procedural delays.
The inclusion of NHRC as a monitoring authority provides an institutional safeguard against future backsliding.
The Court’s proactive stance sets a precedent in ensuring that laws reflect constitutional morality rather than outdated prejudices.

✅ Jagtar Singh v. State of Punjab, 2025

The Supreme Court expressed strong displeasure at the Punjab & Haryana High Court for failing to hear a bail application for almost two years.
The Court stated that such repeated adjournments in liberty-related matters were a “severe blow to the personal liberty of an individual.”
The Court criticized the High Court’s insensitivity and observed that “Courts should not delay such matters nor grant frivolous adjournments.”
A notice was issued to the Respondents, and it was directed that a copy of the Supreme Court’s order be sent to the Registrar General of the Punjab & Haryana High Court, to be placed before the Hon’ble Chief Justice.
Though the order’s complete contents are not available in the summary, it is implied that the Supreme Court granted bail or expedited the proceedings, in line with its earlier consistent approach in liberty cases.

✅ Chirag Sen and Another etc. v. State of Karnataka and Another, 2025

The bench comprising Justices Sudhanshu Dhulia and Aravind Kumar held that the allegations were false, baseless, and an abuse of the criminal process.
The Court found that the complaint relied solely on an unauthenticated document (1996 GPF nomination form), lacking any proof of fraudulent intent or act by the appellants.
The Sports Authority of India had previously closed the investigation after medical tests (bone ossification and dental tests at AIIMS Delhi) confirmed the ages of Lakshya and Chirag.
There was no evidence that the appellants knowingly used forged documents or induced any authority to confer benefits dishonestly.
The Court emphasized that criminal proceedings are serious and should not be initiated lightly, referencing the precedent Pepsi Foods Ltd. v. Special Judicial Magistrate (1998) 5 SCC 749.

✅ S. Mohammed Hakkim v. National Insurance Co. Ltd. & Ors., 2025

The Supreme Court enhanced the compensation to ₹91,39,253/-, partially modifying the Madras High Court’s ruling.
Negligence Apportionment: Car driver: 50% (increased from 40%), Bus driver: 30% (unchanged), Appellant: 20% (reduced from 30%).
Sudden braking on a highway, without giving adequate warning, is negligent driving.
Despite not having a licence and not maintaining adequate distance, the primary cause of the accident was the car driver's unexpected brake.
The bus driver also contributed by not keeping proper distance.
The Court restored the Rs. 18 lakh attendant charges, citing the lifelong disability due to leg amputation.

✅ Just Rights for Children Alliance v. Sahjan Ali and Anr., 2025

The Supreme Court issued fresh notice to the accused, reopening the matter for consideration.
The bench of Justices Dipankar Datta and AG Masih took note of the controversy over interpreting ‘samband’.
The Court observed that the Delhi High Court’s acquittal, which hinged on the ambiguity of ‘samband’ and held that mere age below 18 does not automatically prove penetrative sexual assault, needed reconsideration.
The case was listed for further hearing with a returnable period of four weeks.

✅ Satauram Mandavi v. The State of Chhattisgarh & Anr. (Arising out of SLP (Crl) No. 13834 of 2024), 2025

The retrospective application of the amended harsher punishment was violative of Article 20(1) of the Constitution, which prohibits retrospective imposition of a heavier penalty.
The sentence of life imprisonment till remainder of natural life did not exist at the time of the offence (May 20, 2019), so only the unamended provision applied.
The sentence under the unamended Section 6 allows imprisonment for life in its conventional sense, not for the remainder of natural life.
The trial court’s order was found contrary to constitutional safeguards under Article 20(1) and Article 21.

✅ Bansal Milk Chilling Centre v. Rana Milk Food Pvt. Ltd. & Anr., 2025

The Supreme Court held that amendments are permissible even at the post-cognizance stage, provided they do not alter the fundamental nature of the complaint or cause prejudice to the accused.
The Court emphasized that the amendment was made before cross-examination started, so the accused would have a full opportunity to contest the evidence and facts at trial.
It was observed that the correction from “Desi Ghee” to “milk” was a curable procedural irregularity and did not affect the existence of the debt or liability.
The Court restored the Trial Court’s order allowing the amendment and set aside the High Court’s decision disallowing it.

✅ Anurag Bhatnagar & Anr. v. State (NCT of Delhi) & Anr., 2025

The Ordinary Rule is that Complainants should first approach police authorities under Section 154(3) before going to the Magistrate.
However If the complaint discloses a cognizable offence, and The Magistrate applies his judicial mind, Then the Magistrate is empowered under Section 156(3) to order an investigation.
The failure to exhaust remedies under Section 154(3) is a procedural irregularity, not a jurisdictional error.
There should be no prejudice was caused to the accused by the order.
The Magistrate had not taken cognizance under Section 190, but merely directed investigation which is permissible in law.
The order thus cannot be quashed simply because of skipped procedure.

✅ Sadashiv Parbati Rupnawar vs State of Maharashtra, 2025

Justice Modak further said that the trial Court was fully aware of the Explanation (a) to Section 498-A, which reads that 'the wilful conduct must be of a high degree.'
"However, when the evidence of the three witnesses are considered by the trial Court, there is no finding that the harassment is of high degree. There cannot be such a finding simply for the reason that even if the reasons for harassment are admitted, no case will fall under Section 498-A of the Indian Penal Code. The findings need to be set aside," the judge opined.
The bench further held that the trial court rightly rejected the defence of the accused that the deceased fell accidentally into the well, as there was no presence of any material at the spot to suggest that she accidentally fell down.
"There is other reason to believe that it was suicide, but the prosecution could not prove the connection between the harassment and the act of suicide. There was harassment, but it was not of that kind of harassment due to which criminal law can be set in motion. The judgment of the trial Court cannot be sustained in the eyes of law. The trial Judge has forgotten the basic principles and ingredients of the Sections," Justice Modak said while quashing and setting aside the July 31, 1998 judgment of a sessions court in Satara district.

✅ Kishundeo Rout & Ors. v. Govind Rao & Ors., 2025

The plea of adverse possession must be specifically pleaded, relevant issues framed, and evidence led at the trial stage.
“It is a settled position of law that the foundation for the plea of adverse possession must be laid in the pleadings and then an issue must be framed and tried. A plea not properly raised in the pleadings or in issues at the stage of trial would not be permitted to be raised for the first time at the stage of First Appeal under Section 96 of the Code of Civil Procedure (CPC).”, the court observed.
A party cannot succeed on a case that has not been alleged or proved (principle of secundum allegata et probata).
The First Appellate Court erred in accepting an unpleaded claim of adverse possession.
An appellate court cannot frame new issues or entertain new claims not raised in the original pleadings or trial.
The Supreme Court upheld the High Court decision and dismissed the petition.

✅ N vs R, 2025

The Supreme Court allowed the review petition, set aside the High Court's October 2023 judgment, and restored the Family Court's 2022 order.
The Permanent custody was restored to the mother.
The father was granted virtual and physical visitation rights.
The mother cannot relocate the child abroad except for Onam, Christmas, and 50% of summer vacation, with prior intimation.
Both parents were directed to undergo psychological counselling and obtain a fresh psychological assessment by October 31, 2025.

✅ State of Chhattisgarh v. Rupendra Das Manikpuri, 2025

The Court upheld the acquittal, observing that:
- The sole expression “I love you”, though directed at a minor girl, was not made with sexual intent.
- It was a “solitary act”, and not accompanied by physical contact or any sexually suggestive behavior.
- The testimonies of the victim and her friends corroborated that there was no act involving sexual desire or physical advances.
The Court emphasized that “sexual intent” is the crucial element, not physical contact. Relying on Attorney General for India v. Satish, the Court clarified that expression without intent does not constitute sexual assault.
Section 354-D IPC will Not attracted as no repeated or continued following or contact was established. The girl had not expressed disinterest in a way that would invoke criminality.
The Court found no filthy or obscene language or attempt to insult her modesty.
The prosecution failed to show that the accused had knowledge that the girl belonged to a Scheduled Caste or Scheduled Tribe.

✅ SKD v. MG & Others, 2025

The Delhi High Court upheld the Family Court’s order awarding ₹25,000/month total maintenance to the wife and child.
It clarified that “capability to earn” is not the same as “actual earnings.”
The Court accepted that the wife may have left her job after separation to take care of their young child, and may not have been able to return to the workforce due to lack of experience or changing circumstances.
The husband failed to produce evidence before the Family Court or High Court that the wife was currently employed.
The Court also criticized the husband for contesting ₹25,000/month, while voluntarily paying ₹35,000/month as maintenance to his mother.
It reiterated that personal loans, home loans, or society investments cannot be grounds for reducing maintenance, as they are voluntary financial commitments taken by the husband.

✅ Vishnu Vardhan @ Vishnu Pradhan vs. The State of Uttar Pradesh & Others, 2025

The Supreme Court allowed Vishnu’s appeal, holding that when a judgment is obtained by fraud, it is a nullity in law.
The Court observed that the doctrine of merger does not apply when the earlier decision either of the High Court or Supreme Court was tainted by fraud.
The 2022 Supreme Court order, affirming the High Court decision, does not create a true merger because the initial High Court judgment itself was not on merits, but rather based on suppressed facts.
The Court noted that fraud unravels everything, including otherwise final judicial orders.X v. Y, 2025
The Court quashed the chargesheet filed against the mother-in-law and father-in-law under Section 498A IPC.
It held that the mere fact that the husband had custody of the child after the matrimonial discord does not amount to cruelty or harassment under Section 498A.
The Court found no evidence of dowry demands or any acts that would fall within the definition of cruelty under the IPC.
The Court described the FIR as a "counterblast" to the divorce case and stated it was aimed at pressuring the husband and his family.
However, the Court refused to quash the complaint filed under the Domestic Violence Act, stating that these proceedings are civil in nature and the Magistrate is required to adjudicate them based on the merits of the case.KSIQ vs IAQ, 2025
The High Court reversed the Family Court’s decision and granted custody to the mother, citing the child’s well-being, emotional attachment to the mother, and the absence of female members in the father's household.
"In the present case, the mother has flouted interim orders passed by this Court. But that will not disentitle her to retain custody of the child. On the legalistic basis though merits of the matter tilt in the favour of the father, considering minor's ordinary contentment, health and favourable surroundings, this Court is inclined to decide in favour of the mother. When the personal law is pitted with comfort and welfare of the child, latter would have upper hand," the bench held, while referring to various rulings of the Supreme Court.
Single-judge Justice Shailesh Brahme noted that the Muslim Personal Law allows the custody of a minor above the age of 7-years to the father and the child in the instant case was 9-years-old.
However, after personally interacting with the child, the judge noted that he has a greater bonding with his mother and thus granted custody in her favour.
The judge noted that despite the mother flouting earlier interim orders, the overarching concern should be the minor’s comfort, health, and emotional security.

✅ Ms. X v. State (NCT of Delhi), 2025

The Court held that DNA testing is an almost perfect science to determine the truthfulness of rape allegations and that Police have a duty under Section 53A Cr.P.C. to collect blood samples for analysis.
It emphasized that if the police fail to collect such samples, it could attract court’s strict action.
The Court noted that reasonable force may be used if the accused refuses to cooperate, as per Section 53A Cr.P.C.
However, the Court also highlighted the need to balance the rights of the accused and victim, examining facts on a case-by-case basis.
It recognized that absolute evidence of non-access to the victim can be a valid consideration for refusing blood sampling.
The Court rejected the accused’s reliance on Section 112 Evidence Act presumption because the prosecutrix had separated from her husband before the alleged incident.
The Court observed, “There can be no better evidence than the DNA Test to prove or disprove the commission of the offence.”
The petition was allowed, and the accused was directed to present himself for blood sample collection.

✅ Pandurangan v. T. Jayarama Chettiar and Another, 2025

The Supreme Court allowed the appeal and set aside the order of the Madras High Court.
It held that res judicata is a mixed question of law and fact, which cannot be summarily decided at the stage of Order VII Rule 11 application.
The Court emphasized that the trial court must examine pleadings, evidence, and prior judgments to determine if res judicata applies.
Prakash Ramachandran v. The District Collector and Others, 2025
The Madras High Court ruled that Nama Sankeerthanam or any religious gathering involving public participation cannot be conducted in residential premises without prior approval from the District Collector.
The Court restrained the respondent from using the premises as a prayer hall until such permission is granted.
The Court directed the Inspector of Police to ensure that no public nuisance is caused due to any such gatherings.
It clarified that any personal prayer must be restricted to within the home, without public gatherings or disturbance to others.

✅ Kum. Shubha @ Shubhashankar v. State of Karnataka & Anr., 2025

The Supreme Court upheld the conviction of Shubha and the co-accused under Section 302 read with Section 120-B of the IPC, confirming their involvement in the murder conspiracy.
Shubha was additionally convicted under Section 201 IPC for causing disappearance of evidence and attempting to mislead the investigation.
The Court found the eyewitnesses’ conduct during the incident to be unnatural and therefore rejected their testimony as unreliable.
In the absence of credible eyewitnesses, the Court relied on circumstantial evidence to establish guilt beyond reasonable doubt.
The Court applied the five foundational principles from Sharad Birdhichand Sarda v. State of Maharashtra, which guide the evaluation of circumstantial evidence in criminal cases.
Shubha’s motive was established through a statement given by her friend Pramod Dixit, to whom she had confessed her unwillingness to marry the deceased.
Call Detail Records (CDRs) of the accused were admitted into evidence under Section 65-B(4) of the Indian Evidence Act, supported by valid certificates from Airtel and Reliance.
The CDRs revealed unusually high volumes of communication among the accused during the engagement, the night of the murder, and immediately after, raising strong suspicion.
The recovery of the scooter and the iron rod used in the murder was accepted by the Court as valid evidence; although two accused were present during recovery, their independent voluntary disclosures rendered it admissible under Section 27 of the Indian Evidence Act.
The Court relied on Kishore Bhadke v. State of Maharashtra to hold that simultaneous but separate disclosures by co-accused do not invalidate recovery under Section 27.
The delay in sending the steel rod for forensic (FSL) analysis was considered a procedural lapse but not serious enough to discard the credibility of the prosecution’s case.
Citing State of Madhya Pradesh v. Chhaakki Lal, the Court reiterated that lapses in investigation, unless substantial, do not by themselves vitiate an otherwise strong prosecution case.
The absence of relevant messages on the phones, and the failure of the accused especially Shubha and Arun to provide an adequate explanation for extensive communication before and after the crime, supported the finding under Section 201 IPC.
Arun’s plea of alibi that he was at the hospital visiting his father-in-law on the night of the incident was rejected as the hospital discharge summary did not mention his presence, and no visitor records were maintained.
The Supreme Court dismissed the appeals, affirming the convictions and life sentences imposed by the High Court for murder and conspiracy.
The Court emphasized that although the legal process confirmed guilt, the motive rooted in emotional distress Shubha being forced into an unwanted marriage could not be ignored entirely.
Acknowledging the 22-year gap since the incident and the personal circumstances of the convict, the Court showed sympathy without condoning the crime.
The Court allowed the convicts to file mercy petitions under Article 161 of the Constitution, which empowers the Governor to grant pardon or commute sentences.
The Court suspended the execution of the sentence for eight weeks to allow the appellants time to submit their petitions for pardon to the Governor of Karnataka.

✅ Ram Charan & Ors. v. Sukhram & Ors., 2025

The Supreme Court allowed the appeal, setting aside the lower courts’ judgments, and granted the appellants equal share in the ancestral property.
It held that in the absence of any established or proven custom prohibiting female succession, the right to equality under Article 14 must prevail.
The Court also emphasized that the burden should not lie on women to prove that they are entitled to inherit, but rather on those who seek to exclude them to prove a valid, prevailing custom.
The judgment authored by Justice Sanjay Karol called the gender-based exclusion unreasonable and discriminatory, stating: “Customs too, like the law, cannot remain stuck in time and others cannot be allowed to take refuge in customs or hide behind them to deprive others of their right.”

✅ Kailash Ramchandani v. State of Maharashtra, 2025

The Supreme Court issued a stern warning to the Union of India and the State of Maharashtra.
It held that: “If authorities fail to establish special courts with requisite infrastructure... the Courts would invariably be left with no option but to release undertrials on bail.”
The Court rejected the argument that mere designation of existing courts is adequate: “We outrightly reject such a plea... Designating an existing court... comes at the cost of other pending cases involving senior citizens, marginalized sections, etc.”
It directed that unless exclusive, fully-equipped special courts are established, the petitioner’s bail plea will be considered on merits at the next hearing, marking this as the final opportunity to the governments.

✅ Ability Dodzi @ Chinazom Ability v. State NCT of Delhi, 2025

The Delhi High Court dismissed the petition, holding it was not maintainable.
The Court emphasized that: “What is prohibited by law cannot be done by invoking inherent powers, as that would be allowing backdoor entry to the relief claimed.”
- The impugned order was held to be interlocutory in nature, and not appealable or revisable under Section 438(2) BNSS.
- The petition was found to be an abuse of process, and the High Court imposed a cost of Rs. 20,000 on the petitioner.

✅ PAB vs ARB, 2025

The Family Court’s decree of divorce in favor of the husband was upheld.
The wife’s appeal was dismissed. The court recognized multiple instances of mental cruelty inflicted by the wife.
"The husband is a part of his family's business. The unrebutted evidence pertaining to the wife's behaviour with his employees is sure to cause agony to him. Similarly, humiliating him in front of his friends is also 'cruelty' to him. Moreover, apathetic and indifferent behaviour with his specially abled sister is also sure to cause pain to him and his family members. Refusal to have a physical relationship and making allegations of extra-marital relations is also cruelty by the wife," the judges held.
Mediation attempts failed over the years, and the court observed that the marriage had irretrievably broken down.
"The marriage has broken without any possibility of being mended is quite clear even from the fact of the parties filing a mutual consent divorce petition as early as in 2015. It is also an admitted fact that the husband made an attempt to work on their relationship by moving out of his family home to a rented flat. He invited the wife to live there and gave her the key to the said flat. Despite this, she did not show up at the new flat. This evidence of the husband is also unchallenged, further refuting the assertion of the wife regarding him deserting her," the judges said.
The husband's efforts to save the marriage were accepted as genuine and unrebutted.

✅ L. Muruganantham v. State of Tamil Nadu & Others, 2025

The Supreme Court held that while the State has constitutional and moral duties to accommodate prisoners with disabilities, the right to reasonable accommodation does not extend to personalized or costly food demands.
Institutional shortcomings, such as inability to provide preferred diets, stem from systemic issues and do not per se constitute human rights violations unless demonstrable harm occurs.
The Prisons are correctional institutions, not extensions of civil society comforts; denial of non-essential or indulgent items isn’t a rights violation if health and dignity are preserved.
The court upheld the compensation order but dismissed claims of violation against jail authorities based on lack of deliberate neglect or malice.
The Emphasized the urgent need for prison reforms, especially infrastructure and policies sensitive to disabilities.

✅ Baljinder Kumar @ Kala v. State of Punjab, 2025

The Supreme Court examined the evidence and found major contradictions in the testimonies of key prosecution witnesses.
"It is settled law that in order to record conviction based on ocular evidence, their testimonies have to be completely credible and trustworthy. However, in the present matter, where there are major contradictions in the testimonies of key prosecution witnesses accompanied by glaring investigative defects, it cannot be said that the prosecution has established the charge beyond reasonable doubt.
At the cost of repetition, we must state that the standard of proof is an absolutely strict one and cannot be faltered with. When at stake are human lives and the cost is blood, the matter needs to be dealt with utmost sincerity.
Therefore, given the facts and circumstances of the case and in light of the above discussion, we cannot bring ourselves to hold the accused-appellant guilty of the charged offence as his guilt has not been proved beyond a reasonable doubt."
The court has remarked that since the matter garnered some sensation, it put pressure on the investigation agencies to find the culprit, ultimately leading to a shoddy investigation. It equally blamed the trial court and the high court for their hasty decisions in delivering justice, because of which a man, against whom there is no sufficient evidence, ended up on death row.
"The breakdown of the legal system becomes apparent when such haste to lay a finger of blame on somebody leads to a shoddy investigation and a poorly conducted trial.
The result is a loosely tied prosecution case with glaring loopholes all across and yet the Courts' enthusiasm to deliver justice in such a heinous crime ensures that the accused person ends up on the death row, albeit without sufficient evidence. This is precisely the misery which the instant case entails."
The Court found that the prosecution's case relies on the testimonies of the brother (complainant) of the Appellant's wife, the mother-in-law of the Appellant, and the Appellant's minor son, since the incident had happened in the complainant's house where her sister was residing after having left Appellant's house.
The complainant had alleged that he was present at the spot along with his mother, who was the eyewitness. However, these testimonies have major contradictions in terms of the presence of the complainant.
Further, as for the complainant's mother, the court finds contradictions in the testimony of the complainant who says her mother was in the Gurudwara, whereas, in her statement, she says she was hiding due to the fear of the Appellant.
Additionally, the court found that while initially the complainant alleged that the Appellant was carrying 'datar,' later he changed it to 'gandasi'.
Lastly, none of the recoveries made by the prosecution, such as the weapon or the blood-stained clothes, were corroborated by independent witnesses.
Investigative lapses and procedural defects were identified, including lack of independent corroboration for the weapon and blood-stained clothes.
The prosecution failed to prove the guilt of the appellant beyond reasonable doubt, a standard especially critical in death penalty cases.
The Court criticized the investigation and lower courts for their haste and undue pressure, which led to a miscarriage of justice.
The trial court and High Court judgments were set aside due to these failings.
The appellant’s conviction and death sentence were overturned.
The appellant was acquitted of all charges based on the totality of circumstances and evidentiary gaps.

✅ Kathyayini v. Sidharth P.S. Reddy & Ors., 2025

The Supreme Court allowed the appeal and set aside the Karnataka High Court's order quashing the criminal proceedings.
Held that where prima facie allegations of fraud, misappropriation, and cheating exist, civil proceedings do not preclude the continuation of criminal prosecution.
The court emphasized that parallel civil remedies do not negate the existence of criminal liability, especially where criminal intent is alleged.
The matter was remitted for full-fledged trial.

✅ Madhukar & Ors. v. The State of Maharashtra & Anr., 2025

The Supreme Court quashed the criminal proceedings against the Appellants.
The bench held that in exceptional and peculiar circumstances, proceedings for serious offences like rape may be quashed, especially if the prosecutrix unequivocally withdraws support and the continuance would lead to injustice.
It relied on the categorical affidavit filed by the complainant and the fact that the FIR was a reactionary measure, with no productive outcome likely from a prolonged trial.
Indian Oil Corporation Limited & Ors. v. M/s Shree Niwas Ramgopal & Ors., 2025
The Supreme Court dismissed IOCL’s appeal, upholding the Calcutta High Court’s ruling.
It ruled that the firm did not dissolve on the death of a partner because the partnership deed clearly allowed for continuity.
IOCL was directed to resume the kerosene supply to the surviving partnership firm until it is properly reconstituted, subject to any further legal directions.

Monthly Magazine

MONTHLY MAGAZINE JULY

✅ G. Nagarathna & Ors. v. G. Manjunatha & Anr.

✅ P Kishore v. The Secretary to Government and Others, 2025

✅ Vishnu Vardhan @ Vishnu Pradhan vs. The State of Uttar Pradesh & Others, 2025

✅ Ms. X v. State (NCT of Delhi), 2025

✅ Pandurangan v. T. Jayarama Chettiar and Another, 2025

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