Case Digest January 2025: Supreme Court Judgments | Lawcutor

  • Name of the case: Krishna Devi @ Sabitri Devi ( Rani ) M/S S. R. Engineering Construction  Vs Union of India & Ors.
  • Citation: 2025 INSC 24
  • Bench: Justice Pamidighantam Sri Narsimha and Justice Sandeep Mehta
  • Issues Involved: The question for consideration is whether the time for filing a Section 17 application commences when the party seeking to challenge the award receives a formal notice of the making of the award, or from the date such party is aware of the existence of the award?
  • Ratio Decidendi:
    • It was held that the date of receiving a copy of the award is not the requirement of Section 14(2), but merely awareness that it is available to the parties.
    • This holding signifies that the parties have to take steps to scrutinise the award themselves as soon as it becomes accessible and they are aware of its accessibility.
  • Judgments Referred:
    • Nilkantha Sidramappa Ningashetti Vs Kashinath Somanna Ningashetti
    • Ch Ramalinga Reddy vs Superintending Engineer 1999 9 SCC 610
    • Indian Rayon Corporation Ltd Vs Raunaq & Co (P) Ltd 1988 4 SCC 31
    • Bharat Coking Coal Ltd Vs C.K. Ahuja 1995 SUPP (1) SCC 744
    • Food Corporation of India Vs E Kuttappa 1993 3 SCC 445
  • Provisions
    • Section 14 and 17 of the Arbitration Act 1940
    • Article 119 to the schedule of Limitation Act 1963

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  • Date: 02 January 2025
  • Name of the case: Urmila Dixit vs Sunil Sharan Dixit
  • Citation: 2025 INSC 20
  • Bench: Justice C.T. Ravikumar and Justice Sanjay Karol
  • Issues Involved: Whether the High Court was correct in setting aside the order of the Tribunal, granting benefit of Section 23 of the Maintenance and Welfare of the Parents and Senior Citizens Act, 2007, to the Appellant?
  • Ratio Decidendi:
    • Placing reliance on the beneficial interpretation of the legislation the Court held that the relief available to senior citizens under Section 23 is intrinsically linked with the statement of objects and reasons of the Act, that elderly citizens of our country, in some cases, are not being looked after.
    • It is directly in furtherance of the objectives of the Act and empowers senior citizens to secure their rights promptly when they transfer a property subject to the condition of being maintained by the transferee.
  • Judgments Referred:
    • X2 Vs State of NCT Delhi 9 SCC 433
    • S Vanitha Vs Deputy Commissioner, Bengaluru Urban District and Ors 2021 15 SCC 730
    • Vijaya Manohar Arbat Dr Vs Kashirao Rajaram Sawai and Anr 1987 2 SCC 278
    • Badshah Vs Urmila Badshah Godse and Anr 2014 1 SCC 188
    • Sudesh Chhikara Vs Ramti Devi and Anr 2022 SCC Online SC 1684
  • Provisions:
    • Section 23 of the Maintenance and Welfare of the Parents and Senior Citizens Act 2007 

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  • Date: 03 January 2025
  • Name of the Case: Serosoft solutions Pvt Ltd vs Dexter Capital Advisors Pvt Ltd
  • Citation: 2025 INSC 26
  • Bench: Justice Pamidighantam Sri Narsimha and Justice Manoj Misra
  • Issue Involved: Whether the High Court
    has correctly exercised its supervisory jurisdiction under Article 227 in granting the respondent /claimant one more opportunity to cross examine appellant/ respondent’s witness, despite the Arbitral Tribunal rejecting such a prayer?
  • Ration Decidendi: The SC held that due to lack of any proper justification given by HC in exercise of its powers under Article 227 by interfering with the directions of Arbitral Tribunal in restraining any further cross examination after providing sufficient opportunity, the impugned order of HC shall be set aside.
  • Cases Referred: Kevlin Air Conditioning and ventilation  system Pvt Ltd Vs Triumph Reality Pvt Ltd 2024 SCC Online Del 7137
  • Provisions:
    • Article 227 of the constitution of India
    • Section 18 of the Arbitration and Conciliation Act 1996 

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  • Name of the case: Omi @ Omkar Rathore & Anr Vs The State of Madhya Pradesh and Anr
  • Citation: 2025 INSC 27
  • Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
  • Issues Involved: Whether a person exonerated in a police closure report or not named in chargesheet be summoned later by trial court to face trial?
  • Ratio Decidendi: The SC for the case in hand upheld the order of HC and ruled that a person not named in chargesheet or exonerated in a police closure report could be summoned later by trial court to face trial only when strong and cogent evidence occurs against a him. Meanwhile, the apex court has also cautioned the trial courts that power under Section 319 CrPC should not be exercised in a casual and cavalier manner.
  • Cases Referred:
    • Ramesh Chandra Srivastava Vs State of UP & Anr 2021 12 SCC 608
    • Hardeep Singh  vs State of Punjab 2014 3 SCC 92 : 2014 2 SCC (Cri) 86
    • S Mohammed Ispahani Vs Yogendra Chandak 2017 16 SCC 226
       
  • Provisions: Section 319 CrPC

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  • Name of the case: M/S Naresh Potteries Vs M/s Aarti Industries & Anr
  • Citation: 2025 INSC 1
  • Bench: Justice B.R. Gavai and Justice K.V. Viswanathan
  • Issues Involved: Whether the appellant herein filed complaint under section 138 NI Act is in accordance with the requirement under section 142 of the NI Act?
  • Ratio Decidendi:
    • HC has passed an impugned judgement and order on a completely perfunctory and erroneous reasoning which depicts absence of careful consideration.
    • Thus HC having inherent powers under section 482 CrPC should use it with great caution and therefore avoid any interference with the jurisdiction of the lower courts or to scuttle a fair investigation or prosecution.
  • Cases Referred:
    • A.C. Narayanan v. State of Maharashtra, (2014) 11 SCC 790 : (2014) 4 SCC (Civ) 343
    • Krosaki Refractories Limited v. SMS Asia Private Limited and Another 2022 SCC 7 612: 2022 INSC 214
  • Provisions:
    • Section 138 , 142 NI ACT 
    • Section 200 , 482 of CrPC

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  • Name of the case: Bharat Aambale vs The State of Chhatisgarh
  • Citation: 2025 INSC 78
  • Bench: Justice J.B. Pardiwala and R. Mahadevan
  • Issues Involved: Whether the conviction could be said to have stood vitiated because of the non-compliance of section 52A of the NDPS Act?
  • Ratio Decidendi: The Supreme Court thus held that what  is actually required is only a substantial compliance of the procedure laid down under Section 52A of the NDPS Act and the Standing Order(s) / Rules
    framed thereunder, and any discrepancy or deviation in the same may lead the court to draw an adverse inference against the police as per the facts of each and every case.
  • Cases Referred:
    • Mangilal v. State of Madhya Pradesh 2023 SCC Online SC 862
      Union of India v. Mohan Lal & Anr.  (2016) 3 SCC 379
    • Simarnjit Singh v. State of Punjab 2023 SCC Online SC 906
    • Khet Singh v. Union of India (2002) 4 SCC 380
  • Provisions: Section 52A of NDPS Act

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  • Name of the case: M/S Vidyavati Construction Company Vs Union of India
  • Citation: 2025 INSC 101
  • Bench: Justice Abhay S. Oka and Justice Ujjal Bhuyan
  • Issues Involved: Whether appointment of arbitrator made in contravention of agreement be challenged at a stage later after filing of statement of defence, where the party knows the defect and still participates in the proceedings of the tribunal?
  • Ratio Decidendi: The SC underlining the principle of section 16 of the Arbitration and Conciliation Act 1996 held that a party is said to waive off his right to challenge the appointment of the arbitrator when he has knowledge of such a defect and still continues to participate in proceedings of the tribunal.
  • Provisions:
    • Section 16, 34, 37 of The Arbitration of Conciliation Act 1966

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  • Name of the case: Om Prakash @ Israel @ Raju @ Raju Das Vs Union of India
  • Citation: 2025 INSC 43
  • Bench: Justice M.M. Sundresh and Justice Aravind Kumar
  • Issues Involved: Age determination of Criminal undertrials and whether overlooking juvenility would amount to violation of constitutional provisions of Article 14 and 21?
  • Ratio Decidendi: The Supreme court after discovering the juvenility of the accused overturned a life sentence and thereby held that procedural lapses involving non determination of juvenility of the accused violates article 14 and 21 of the constitution and also stressed that plea of juvenility could be raised at any stage of the proceedings under section 9 of the Juvenile Justice Act 2015
  • Provisions:
    • Section 9 JJ Act 2015
    • Article 14 and 21 of the constitution of India

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  • Name of the case: State of Uttar Pradesh Vs RK Pandey
  • Citation: 2025 INSC 48
  • Bench: Chief Justice of India Sanjeev Khanna, Justice Sanjay Kumar and Justice R. Mahadevan
  • Issues Involved:
    • Whether an ex parte award based out of invalid arbitration agreement be executed?
    • Whether Unilateral appointment of Arbitrator Valid for conduct of arbitral proceedings?
  • Ratio Decidendi: The SC set aside both of the ex parte arbitral award as they were pronounced by unilaterally appointed arbitrator based upon non-existence of a valid arbitration agreement between parties which is in contrary to provisions of the Arbitration and Conciliation Act 1996. 
  • Cases Referred:
    • Bilkis Yakub Rasool v. Union of India and Others (2024) 5 SCC 481
    • Central Organisation of Railway Electrification v. ECI PIC SMO MCPL (JV), a Joint Venture Company 2024 INSC 857
  • Provisions:
    • Section 11, Section 34 of the Arbitration and Conciliation Act 1996

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  • Name of the case: My Preferred Transformation & Hospitality Pvt Ltd & Anr.  Vs M/S Faridabad Implements Pvt Ltd
  • Citation: 2025 INSC 56
  • Bench: Justice Pankaj Mithal
  • Issues Involved:
    • Do the provisions of the Limitation Act apply to Section 34 proceedings, and to what extent?
    • Does Section 4 of the Limitation Act apply to Section 34(3) as per an analysis of the statutory scheme as well as Precedents of this Court on the issue? If Section 4 applies, does it apply only to the 3-month limitation period or also the 30-day condonable period
    • In light of the answer in (ii), will Section 10 of the GCA
      apply to Section 34(3), and if so, in what manner?
  • Ratio Decidendi:
    • The SC held that the purpose of reading the Limitation Act alongside the ACA is not to restrict the special remedy under the ACA, but to enable exercise of such remedy in circumstances as contemplated under the Limitation Act. In this context, Section 29(2) of the Limitation Act becomes relevant as it incorporates Sections 4 to 24 of the Limitation Act in special statutes, including the ACA, to the extent that its provisions are not expressly excluded.
    • It will be wrong to confine the period of limitation to just 3 months by interpreting it as the “prescribed period” and excluding the balance 30 days under the proviso to Section 34(3) as not being the prescribed period through a process of interpretation.
    • Since Section 4 of the Limitation Act applies to proceedings under Section 34 of the ACA, the applicability of Section 10 of the GCA stands excluded in view of the express wording of its proviso that excludes the applicability of the provision when the Limitation Act applies.
  • Cases Referred:
    • State of Goa v. Western Builders, (2006) 6 SCC 239
    • Consolidated Engineering Enterprises v. Principal Secretary, Irrigation Department, (2008) 7 SCC 169
    • Kirpal Singh v. Government of India, 2024 SCC OnLine SC 3814
    • Bhimashankar Sahakari Sakkare Karkhane Niyamita v Walchandnagar Industries Limited 2024 8 SCC 453
    • State of West Bengal v. Rajpath Contractors and Engineers Ltd 2024 7 SCC 257
  • Provisions:
    • Section 4, 5, 12, 14, 17, 29 of the Limitation Act
    • Section 34 and 37, 43 of the ACA
    • Section 10 GCA

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  • Name of the case: Frank Vitus Vs Narcotics Contol Bureau and Ors
  • Citation: 2025 INSC 30
  • Bench: Justice Abhay S Oka and Justice Ujjal Bhuyan
  • Issues Involved:
    • Whether it is necessary to implead a Foreign Registration Officer appointed under Rule 3 of the Registration of Foreigners Rules, 1992 (for short ‘the Rules’) in the bail application filed by a foreigner within the meaning of the Foreigners Act, 1946
    • Whether the imposition of condition of dropping a pin on google map for bail upon the accused relevant under section 437(3) CrPC in light of “interests for Justice” or it violates the fundamental rights of the accused as provided under Article 21 of the Constitution of India?
    • Whether to grant bail under NDPS Act to an accused who is a foreign national a condition to obtain a ‘certificate of assurance’ from the Embassy/ High Commission necessarily be imposed upon such an accused?
  • Ratio Decidendi:
    • The SC issued direction that while granting bail to a foreigner within the meaning of the Act, the concerned court shall issue direction to the State or prosecuting agency, as the case may be, to immediately communicate the order granting bail to the concerned Registration Officer appointed under Rule 3 of the Rules who, in turn, shall communicate the order to all concerned authorities including the Civil Authorities
    • With regards to the condition of dropping a pin on google map for bail upon accused, the apex court held that no conditions which track constant movement of the accused could be imposed under section 437(3) of the CrPC as it necessarily violates the fundamental rights of accused enshrined under Article 21 of the Constitution of India.
    • The SC held that it is not necessary that in every case where bail is granted to an accused in an NDPS case who is a foreign national on the ground of long incarceration of more than 50% of minimum sentence, the condition of obtaining a ‘certificate of assurance’ from the Embassy/High Commission should be incorporated.
  • Cases Referred:
    • Kunal Kumar Tiwari v. State of Bihar (2018) 16 SCC 74
    • Munish Bhasin v State (NCT of Delhi) (2009) 4 SCC 45
    • State of A.P. v Challa Ramkrishna Reddy (2000) 5 SCC 712
  • Provisions:
    • Rule 3 of the Registration of Foreigners Rules, 1992
    • Section 2(a) Foreigners Act, 1946
    • Section 67, NDPS Act 1985
    • Section 437, 439 CrPC 1973
    • Article 21 of the Constitution

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  • Name of the case: Sunkari Tirumala Rao & ors vs Penki Aruna Kumari
  • Citation: 2025 INSC 92
  • Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
  • Issues Involved: Whether a partner of an unregistered partnership firm could not have filed the Suit for recovery of money, being hit by Section 69 of the Indian Partnership Act, 1932
  • Ratio Decidendi: The SC for the case in hand upheld the view of the High Court that a suit of such nature could not be said to be maintainable in the absence of the registration of the partnership firm as expressly mentioned under section 69 of the Indian Partnership Act 1932
  • Cases Referred:
    • Seth Loonkaran Sethiya and Others v. Mr. Ivan E. John and Others (1977) 1 SCC 379
    • Mukund Balkrishna Kulkarni v. Kulkarni Powder Metallurgical Industries and Another  (2004) 13 SCC 750
  • Provisions: Section 69 of Partnership Act, 1932

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  • Name of the case: The State Of Punjab Vs Hari Kesh
  • Citation: 2025 INSC 50
  • Bench: Justice Bela M Trivedi and Justice Prasanna B Varale
  • Issues Involved: Whether the High Court could have set aside the
    impugned Sanction Order and the proceedings arising therefrom, more particularly, when the trial had already commenced and the prosecution had examined seven witnesses ?
  • Ratio Decidendi: Whether the High Court could have set aside the
    impugned Sanction Order and the proceedings arising therefrom, more particularly, when the trial had already commenced and the prosecution had examined seven witnesses ?
  • Cases Referred: State of Karnataka, Lokayukta Police Vs
    S. Subbegowda (2023 SCC Online SC 911),
  • Provisions: Section 7, 13, and 19 of The Prevention of Corruption Act 1988

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  • Name of the case: NBCC (India) Ltd Vs The state of West Bengal and Ors
  • Citation: 2025 INSC 54
  • Bench: Justice Pamidighantam and Justice Pankaj Mithal
  • Issues Involved: Whether an MSME cannot make a reference to the
    Facilitation Council for dispute resolution under Section 18 of the MSMED Act if it is not registered under Section 8 of the Act before the execution of the contract with the buyer?
  • Ratio Decidendi: Whether an MSME cannot make a reference to the
    Facilitation Council for dispute resolution under Section 18 of the MSMED Act if it is not registered under Section 8 of the Act before the execution of the contract with the buyer?
  • Cases Referred:
    • Silpi Industries v. Kerala State Road Transport Corporation
    • Gujarat State Civil Supplies Corporation Ltd. v. Mahakali Foods Pvt. Ltd (2023) 6 SCC 401
  • Provisions: Section 8, 15, 16, 17 and 18 of MSMED Act 2006

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  • Name of the case: Rajeeb Kalita vs. Union of India
  • Citation: 2025 INSC 75
  • Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
  • Issues Involved: Public Interest litigation for seeking directions to all States and UT for ensuring availability of basic toilet facilities in court premises  to men, women, transgender, Person with disabilities as well as to advocates and court staff etc.
  • Ratio Decidendi:
    • The SC relying on several legislations and international view, in larger public interest issued directions to all HC, States and UTs to ensure construction of public conveniences in court premises which should be clearly identifiable to judges, advocates, litigants, court staff etc.
      Also they are required to allocate funds accordingly for the said purpose and hereby are required to form committee in all states which would prepare comprehensive plan and ensure implementation.
  • Cases Referred:
    • Vincent Panikurlangara v. Union of India (1987) 2 SCC 165
    • Amarnath Shrine v. Union of India (2013) 3 SCC 247
    • Common Cause (A Registered Society) v. Union of India 1999 6 SCC 667
    • Consumer Education and Research Centre v. Union of India AIR 1995 SC 922
    • State of M.P. v. Kedia Leather & Liquor Ltd 2003 7 SCC 389
    • National Legal Services Authority v. Union of India 2014 5 SCC 438
    • Dignity, Respect & Honour of Girls and Women Milun Suryajani v. Pune Municipal Commissioner 2015 SCC OnLine Bom 6256
    • P. Saravanan v. Union of India Order dated 17.08.2021 made in W.P(MD)No.4959 of 2019
    • Smita Kumari Rajgarhia v. Govt. of NCT of Delhi Order dt. 16.10.2024 in W.P.(C) No.14517 of 2024
  • Provisions:
    • Article 21, 47, 48A of The Constitution of India
    • Sec 3, Transgender person (Protection of Rights) Act, 2019
    • Rule 10, Transgender Person (Protection of Rights) Rules, 2020

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  • Name of the case: Biswajeet vs. Central Bureau of Investigation
  • Citation: 2025 INSC 85
  • Bench: Justice Dipankar Datta and Justice Manmohan
  • Issues Involved:
    • Whether the scope of appeal under Article 142 of the Constiution of India could be enlarged if a limited notice has been issued by the court?
  • Ratio Decidendi:
    • The SC held that In such a case, the jurisdiction to decide all legal and valid points, as raised, does always exist and would not get diminished or curtailed by a limited notice issuing order
    • However, whether or not to exercise the power of enlarging
      the scope of the petition/appeal is essentially a matter in the realm of discretion of the Bench and the discretion is available to be exercised when a satisfaction is reached that the justice of the case so demands.
  • Cases Referred:
    • State of Gujarat v. Manshankar Prabhashankar Dwivedi (1972) 2 SCC 392
    • Kutchi Lal Raeshwar Ashram Trust Evam Anna Kshetra Trust v.
      Collector, Haridwar (2017) 16 SCC 418
    • Yomeshbhai Pranshankar Bhatt vs. State of Gujarat (2011) 6 SCC 312
  • Provisions: Article 142, Article 136 of the Constitution of India

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  • Name of the case: U. Sudheera vs C Yashoda
  • Citation: 2025 INSC 80
  • Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
  • Issues Involved:
    • Whether the High Court can pass any ad interim order for a limited period, before framing substantial question(s) of law, while dealing with a second appeal filed under Order XLI r/w Section 100 CPC?
  • Ratio Decidendi:
    • The SC held that the High Court has jurisdiction to pass an interim order ex parte, however, it does not empower to grant ad interim relief, without examining the parties and formulating the substantial question of law involved in the second appeal as it is contrary to section 100 CPC.
  • Cases Referred:
    • Ram Phal v. Banarasi (2003) 11 SCC 762
    • Raghavendra Swamy Mutt v. Uttaradi Mutt (2016) 11 SCC 235
    • Santosh Hazari v. Purushottam Tiwari (2001) 3 SCC 179
    • Roop Singh v. Ram Singh (2000) 3 SCC 708
    • State Bank of India v. S.N. Goyal (2008) 8 SCC 92
    • Municipal Committee, Hoshiarpur v. Punjab SEB (2010) 13 SCC 216
    • Umerkhan v. Bismillabi (2011) 9 SCC 684
    • Hemavathi & others v. V.Hombegowda and another 2023 INSC 848 : 2023 SCC OnLine SC 1206
  • Provisions: Section 100 r/w Order XLI CPC 1908

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  • Name of the case: Vijay @ Vijayakumar vs State represented by Inspector of Police
  • Citation: 2025 INSC 90
  • Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
  • Issues Involved:
    • What are the essential ingredients of Exception 1 of Section 300 upon whose fulfilment murder could be converted into culpable homicide.
  • Ratio Decidendi:
    • The SC laying its emphasis on the elements of Exception 1 to section 300 held that the case can only fall under the exception when the court is able to hold that provided the alleged provocation is given, every normal person would behave or
      act in the same way as the accused in the circumstances in which the accused was placed, acted
  • Cases Referred: Mancini v. Director of Public Prosecutions 1942 A.C. 1
  • Provisions:
    • Section 304 (1) , Section 300 IPC
    • Section 313 CrPC

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  • Name of the case: Vimal Babu Dhumadiya & Ors Vs The State of Maharashtra & Ors
  • Citation: 2025 INSC 77
  • Bench: Justice Vikram Nath, Justice Sanjay Karol and Justice Sandeep Mehta
  • Issues Involved:
    • Whether the party being a necessary party aggrieved by the judgement of Division Bench of High Court for not being heard move to Supreme Court under Article 32 for setting aside of impugned judgement?
  • Ratio Decidendi:
    • The SC Held that under Article 32 of the Constitution, the judgment of the Division Bench of the High Court of Judicature at Bombay cannot be declared as illegal.
    • If the petitioners have not been heard and are affected by the
      said judgment, the remedy available to them is to either file a petition/application for recall of the said order/judgment or
      to challenge the same by way of a petition under Article 136
      of the Constitution before this Court
  • Provisions: Justice Vikram Nath, Justice Sanjay Karol and Justice Sandeep Mehta
  • Article 32 and Article 136 of The Constitution of India

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  • Name of the case: Jyostnamayee Mishra vs The State of Odisha
  • Citation: 2025 INSC 87
  • Bench: Justice J.K. Maheshwari and Justice Rajesh Bindal
  • Issues Involved:
    • Whether an employee in an establishment is entitled to claim promotion on a post for which he does not fall in the feeder cadre and the post is required to be filled up 100% by way of direct recruitment
    • Whether a vacancy meant for direct recruitment can be filled up merely by issuing a circular in the establishment and not by
      issuing an advertisement calling application from the eligible candidates from public at large
    • Whether an order passed by the Court below where the parties failed to produce proper documents or annexed incorrectly typed documents is valid?
  • Ratio Decidendi:
    • The Supreme Court held that public recruitments must be done in light of pre-established rules and therefore has set aside the judgement of the HC noting that the position of Tracer has to be filled by way of direct recruitment and not by way of promotion.
    • Also mere issuing circular for recruitment in the establishment does not follow the procedure established for such recruitments.
  • Cases Referred:
    • Union Public Service Commission v. Girish Jayanti Lal Vaghela and Others 2006 INSC 58 : 2006 (2) SCC 482
    • Saumya Chaurasia v. Directorate of Enforcement 2023 INSC 1073 : (2024) 6 SCC 401
  • Provisions:
    • Article 14, Article 16 of the Constitution of India
    • Rule3, 4, 5(1)(e), 6, 7 of Sub-ordinate Architectural Service Rules, 1979

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  • Name of the case: Directorate of Enforcement Vs Subhash Sharma
  • Citation: 2025 INSC 141
  • Bench: Justice Abhay S Oka and Justice Ujjal Bhuyan
  • Issues Involved:
    • Whether the non -fulfilment of requirements of PMLA restrict grant of bail even if the fundamental rights of the accused are violated?
  • Ratio Decidendi:
    • The SC held that when arrest is illegal or is vitiated thereby violating fundamental rights of accused under Article 21 and 22, bail cannot be denied on the grounds of non-fulfillment of
      twin tests under clause (ii) of sub-section 1 of Section
      45 of PMLA.
  • Provisions:
    • Article 21 and Article 22 of The Constitution of India
    • Section 57 CrPC
    • Section 65 and 45 PMLA

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  • Name of the case: Thammaraya and Another vs The State of Karnataka
  • Citation: 2025 INSC 108
  • Bench: Justice Vikram Nath, Justice Sanjay Karol and Justice Sandeep Mehta
  • Issues Involved: Examining the chain of circumstantial evidence in leading to prove guilt of accused
  • Ratio Decidendi:
    • The SC in light of established principles for circumstantial evidence held that the chain of circumstantial evidences in the present case cannot be held to be so complete, so as to lead to the only hypothesis of the guilt of the accused which is totally inconsistent with their innocence
  • Cases Referred:
    • Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116
    • Babu Sahebagouda Rudragoudar and Other v. State of Karnataka (2024) 8 SCC 149.
    • Munna Kumar Upadhyay alias Munna Upadhyaya v. State of Andhra Pradesh through Public Prosecutor, Hyderabad, Andhra Pradesh (2012) 6 SCC 174
  • Provisions:
    • Circumstantial evidence under Indian Evidence Act, 1872

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  • Name of the case: Nimai Ghosh & Ors Vs The state of Bihar (Now Jharkhand)
  • Citation: 2025 INSC 816
  • Bench: Justice J.K Maheshwari and Justice Aravind Kumar
  • Issues Involved:
    • To determine the appellants’ guilt, it is imperative to consider as to how and in what manner a witness’s testimony may be deemed
      credible or otherwise in support of the prosecution’s case
  • Ratio Decidendi:
    • The SC held that as a general rule, to prove the case of the prosecution, the testimony of eyewitness primarily ought to be considered and be relied upon to prove the guilt of the accused. It is trite to say that the testimony of the eyewitness must be trustworthy, free from any kind of blemish and of sterling character to prove the incident, whereby the case of the prosecution may be proved beyond reasonable doubt. It is also settled that the quality of evidence brought to prove the guilt is a relevant factor and not the quality of the witnesses
    • To adjudge the credibility of the said testimony, relevant factor
      would be the conduct of the witness indicating the natural reaction comparable to a prudent man, making the conduct of witness realistic.
  • Cases Referred:
    • Alil Mollah and Anr. Vs. State of West Bengal (1996) 5 SCC 369
    • Gopal Singh Vs. State of Madhya Pradesh (2010) 6 SCC 407
    • Shivasharanappa and Others Vs. State of Karnataka (2013) 5 SCC 705
    • Lahu Kamlakar Patil and Another Vs. State of Maharashtra (2013) 6 SCC 417
  • Provisions: Credibility of witness testimony

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  • Name of the case: S Shobha vs Muthoot Finance Ltd
  • Citation: 2025 INSC 117
  • Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
  • Issues Involved:
    • Whether a Private non banking financial institution being regulated by norms of RBI be covered under definition of state under Article 12 of the Constitution and therefore be amenable to writ jurisdiction to HC under Article 226 of the Constitution of India ?
  • Ratio Decidendi:
    • The Supreme Court held the judgement of HC to be correct and stated that any private body which is merely bound by regulatory measures of Govt.  Institution or is carrying out banking operation as scheduled bank cannot said to be statutory body or performing public duty respectively and hence could not be covered under definition of state under Article 12 of the Constitution of India and  thereby restricts amenability through writ jurisdiction of High Court under Article 226 of the Constitution of India.
  • Cases Referred:
    • LIC of India v. Escorts Ltd. reported in AIR 1986 SC 1370
  • Provisions:
    • Article 226, Article 12 of the Constitution of India

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  • Name of the case: Madhushree Datta Vs The State of Karnataka & Anr
  • Citation: 2025 INSC 105
  • Bench: Justice Prashant Kumar Mishra and Justice Dipankar Datta
  • Issues Involved:
    • Whether Use of Filthy Language amounts to breach of Peace under section 504 and to outraging modesty under section 506 of IPC?
  • Ratio Decidendi:
    • The SC in the case in hand set aside the impugned judgement of High Court and held that use of filthy language in isolation and without context does not invoke section 504 and 506 of IPC.
  • Cases Referred:
    • Fiona Shrikhande v. State of Maharashtra & Anr AIR 2014 SC 2013
    • Ramkripal v. State of Madhya Pradesh (2007) 11 SCC 265
    • Rupan Deol Bajaj v. Kanwar Pal Singh Gill (1995) 6 SCC 194
    • Manik Taneja and Another v. State of Karnataka & Anr (2015) 7 SCC 423
  • Provisions:
    • Section 504 and 506 of IPC 1860

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  • Name of the case: Bhupinder Pal Singh Gill vs The State of Punjab & Ors
  • Citation: 2025 INSC 83
  • Bench: Justice Dipankar Datta and Justice Manmohan
  • Issues Involved:
    • Whether the impugned order of the High Court, in which the Disciplinary Authority’s order imposing penalty and the order of the Single Judge dismissing the writ petition of the appellant have merged, warrants any interference on any of the grounds available for judicial review?
  • Ratio Decidendi:
    • The SC on subject of interference through Judicial review held that should on consideration of the materials on record, the court be satisfied that there has been a violation of the principles of natural justice, or that the inquiry proceedings have been conducted contrary to statutory regulations prescribing the mode of such inquiry, or that the ultimate decision of the disciplinary authority is vitiated by considerations extraneous to the evidence and merits of the case, or that the conclusion of the disciplinary authority is ex facie arbitrary or capricious, so much so that no reasonable person could have arrived at such conclusion, or there is any other ground very similar to the above, the high court may in the exercise of its discretion interfere to set things right.
  • Cases Referred:
    • Union of India v. H.C. Goel (1964) 4 SCR 718
    • Madhayamam Broadcasting Ltd. v. Union of India (2023) 13 SCC 401 
  • Provisions:
    • Article 226 of the Constitution of India

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  • Name of the case: Somdatt Builders NEC-NCC Vs National Highways Authority of India
  • Citation: 2025 INSC 113
  • Bench: Justice Abhay S Okla and Justice Ujjal Bhuyan
  • Issues Involved:
    • Whether the High Court in exercise of its powers under Section 37 of the Arbitration and Conciliation Act 1996 having extremely limited jurisdiction set aside arbitral award made under section 34 of the act?
  • Ratio Decidendi:
    • The SC held that it is necessary to remind the courts that a great deal of restraint is required to be shown while examining the validity of an arbitral award when such an award has been upheld, wholly or substantially, under Section 34 of the 1996 Act.
    • Frequent Interference with arbitral awards would defeat the very purpose of the 1996 Act.
  • Cases Referred:
    • UHL Power Company Ltd. Vs. State of Himachal Pradesh (2022) 4 SCC 116
    • M/s. Hindustan Construction Company Ltd. Vs. M/s
      NHAI (2024) 2 SCC 613
    • Reliance Infrastructure Ltd. Vs. State of Goa (2024) 1 SCC 479
    • M/s Larsen Air Conditioning and Refrigeration Company Vs Union of India 2023 INSC 708
  • Provisions:
    • Section 34, Section 37 of the Arbitration and Conciliation Act 1996

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  • Name of the case: Ivan Rathinam vs Milan Joseph
  • Citation: 2025 INSC 115
  • Bench: Justice Surya Kant and Justice Ujjal Bhuyan
  • Issues Involved:
    • Whether the presumption of legitimacy, if not displaced, determines Paternity in law?
  • Ratio Decidendi:
    • The SC in light of eminent requirement for DNA test and the principle of right to privacy enshrined under Article 21 of the Constitution of India held that Legitimacy determines paternity under Section 112 of the Indian Evidence Act, 1872, until the presumption is successfully rebutted by proving ‘non-access’.
  • Cases Referred:
    • Goutam Kundu v. State of W.B. 1993 (3) SCC 418
    • Bhabani Prasad Jena v. Orissa State Commission for Women (2010) 8 SCC 633
    • K.S. Puttaswamy (Privacy-9J.) v. Union of India (2017) 10 SCC
  • Provisions:
    • Section 112 Evidence Act 1872
    • Article 21 of the Constitution of India and Article

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  • Name of the case: Dr Tanvi Behl vs Shreya Goyal
  • Citation: 2025 INSC 125
  • Bench: Justice Hrishikesh Roy, Justice Sudhanshu Dhulia and Justice S.V.N. Bhatti
  • Issues Involved:
    • Whether residence-based reservation in Post Graduate (PG) Medical Courses by a State is constitutionally valid?
    • The concept of Domicile in Indian Laws
  • Ratio Decidendi:
    • The SC held that the residence based reservation in Post Graduate (PG) Medical Courses by a state is unconstitutional
    • ‘Domicile’ is primarily a legal concept for the purposes of determining what is the ‘personal law’ applicable to an individual. Therefore, even if an individual has no permanent residence or permanent home, he is still invested with a ‘domicile’ albeit by law or implication of law.
  • Cases Referred:
    • Jagadish Saran v. Union of India, (1980) 2 SCC 768
    • Dr. Pradeep Jain v. Union of India, (1984) 3 SCC 654
    • Saurabh Chaudri v. Union of India, (2003) 11 SCC 146
    • Magan Mehrotra and Ors. v. Union of India (UOI) and Ors. (2003) 11 SCC 186
    • Nikhil Himthani vs. State of Uttarakhand and Others (2013) 10 SCC 237
    • Vishal Goyal and Others v. State of Karnataka and Others (2014) 11 SCC 456
    • Neil Aurelio Nunes (OBC Reservation) and Others v. Union of India and Others (2022) 4 SCC 1
  • Provisions:
    • Article 14 and 15 of the Constitution of India

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  • Name of the case: Jasminbhai Bharatbhai Kothari vs State of Gujarat
  • Citation: 2025 INSC
  • Bench:
  • Issues Involved:
    • When can a person seek exemption from surrender by way of interlocutory application in special leave petition?
  • Ratio Decidendi:
    • The SC relying upon Order 22 Rule 5 of the Supreme Court Rules 2013 held that an Interlocutory Application for exemption from surrendering is admissible only where the petitioner in the special leave petition has been ‘sentenced to a term of imprisonment’ and not in any other situation.
  • Cases Referred:
    • Mahavir Arya v. State Government NCT of Delhi and Anr [Diary No. 8160 of 2021]
    • Kapur Singh v. State of Haryana (2021) 18 SCC 579
    • Mayuram Subramanian Srinivasan v. CBI (2006) 5 SCC 752
  • Provisions:
    • Article 136 of the Constitution of India

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  • Name of the Case: Shripal Vs Nagar Nigam
  • Citation: 2025 INSC 144
  • Bench: Justice Vikram Nath and Justice Prasanna B. Varale
  • Issues Involved:
    • Whether termination during pendency of conciliation proceedings amount to violation of Section 6E of The UP Industrial Disputes Act 1947?
  • Ratio Decidendi:
    • The SC quashed the judgement of High Court and declared the act of Municipal Corporation as unfair labour Practice and therefore held that termination of employee during the pendency of conciliation proceeding would amount to violation of section 6E of the UP Industrial Disputes Act 1947
  • Cases Referred:
    • Jaggo v. Union of India 2024 SCC OnLine SC 3826
  • Provisions: Section 6E and 6N of the UP Industrial disputes Act 1947
     

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