100 Supreme Court Judgments of 2025 You Must Know: Legal Bites Year Update 2025

Legal Bites presents a curated compilation of 100 essential Supreme Court judgments of 2025, focusing on the core ruling and legal impact of each case. Throughout the year, the Court decided important matters across criminal justice and bail, property rights, service law, arbitration, gender justice, and procedural rules, bringing clarity to unsettled areas and refining established legal principles. This collection serves as a useful reference for lawyers, judges, academics, students, and readers seeking to understand how Indian law evolved during the year.

100 Supreme Court Judgments of 2025 You Must Know

1. Workplace Injury Compensation

In the matter of Kamal Dev Prasad v. Mahesh Forge (2025), the Supreme Court of India adjudicated a crucial issue regarding the quantification of compensation for a workplace injury under the Employees’ Compensation Act, 1923 (formerly Workmen's Compensation Act). The Court reconsidered the statutory disability percentage prescribed in the Schedule to the Act and evaluated the appropriateness of its rigid application when multiple injuries cumulatively affect an employee's functionality.

2. Chain Collision Liability

The Supreme Court decision in Royal Sundaram Alliance Insurance Co. Ltd. v. Honnamma & Ors. (2025), has clarified critical issues related to fault and insurance liability in such accidents. The court held that if an insured vehicle hits another vehicle, which in turn hits a third vehicle, then for the entire chain of accidents, the liability would pass on to the vehicle which was the root cause of the accident.

3. 3 Years' Bar Practice Mandatory for Civil Judge Exam

The Court in All India Judges Association and Others v. Union of India and Others (2025), addressed long-standing concerns over promotions, quota allocation, and eligibility norms for judicial officers. This judgment marks a significant evolution in judicial policy, especially regarding the Limited Departmental Competitive Examination (LDCE), minimum practice requirement for judicial entrants, and structured incentives for meritorious service.

4. One Rank One Pension for judges 

The Court in In Re: Refixation of Pension Considering Service Period in District Judiciary and High Court (2025), affirmed that once a person assumes the constitutional office of a High Court Judge, “birthmarks” from previous service should disappear. Whether the judge rose through the Bar, civil service, or the judiciary, their pension must reflect the stature of the office, not the route taken.

5. Greater Gender Representation in the Judiciary 

The Supreme Court of India, in Pinky Meena v. The High Court of Judicature for Rajasthan at Jodhpur & Anr. (2025), not only reinstated a young tribal woman judge who was discharged from service during probation, but also made a powerful case for greater gender representation in the judiciary. This judgment becomes a significant touchstone for institutional introspection on inclusivity and the retention of women judges in India’s legal system.

6. Public Trust Doctrine in Land Allotment Case 

The Supreme Court of India, in Kamla Nehru Memorial Trust & Anr. v. U.P. State Industrial Development Corporation Ltd. & Ors. (2025), upheld the cancellation of an industrial land allotment originally granted to the Kamla Nehru Memorial Trust (KNMT) by the Uttar Pradesh State Industrial Development Corporation (UPSIDC). The judgment is a strong reaffirmation of contractual obligations, procedural propriety, and the Public Trust Doctrine in matters of public resource allocation.

7. Supreme Court Cautions Against Overreliance on Circumstantial Evidence 

In Vaibhav v. State of Maharashtra (2025), the Supreme Court overturned the appellant’s conviction for murder under Section 302 IPC (Section 103 of BNS), citing insufficient and inconclusive circumstantial evidence. The case involved the death of Vaibhav’s friend Mangesh, allegedly caused by a gunshot from the appellant’s father’s service pistol. The Court noted inconsistencies in the bullet trajectory and the lack of forensic proof linking Vaibhav directly to the firing.

8. Compensatory Environmental Damages 

In Delhi Pollution Control Committee v. Lodhi Property Co. Ltd. & Others (2025), the Supreme Court examined whether State Pollution Control Boards (SPCBs), such as the Delhi Pollution Control Committee (DPCC), have the power to impose compensatory environmental damages under Section 33A of the Water (Prevention and Control of Pollution) Act, 1974, and Section 31A of the Air (Prevention and Control of Pollution) Act, 1981. The Court upheld these powers, provided they are exercised fairly, transparently, and through proper procedures.

9. Supreme Court Rejects False Juvenility Claim

In Suresh v. State of Uttar Pradesh & Anr. (2025), the Supreme Court delivered a significant pronouncement on the determination of juvenility under the Juvenile Justice (Care and Protection of Children) Act, 2000, particularly when conflicting evidence arises. The Court set aside the finding of juvenility recorded by both the trial court and the High Court and directed the respondent-accused to face trial as an adult in a murder case. This judgment reiterates the importance of corroborative documentary evidence, medical reports, and judicial discretion in determining the age of an accused in heinous crimes.

10. Directions to High Courts on Reserved Judgments

In Ravindra Pratap Shahi v. State of U.P.(2025), the Supreme Court delivered a landmark ruling addressing a chronic issue in the Indian judiciary—delayed pronouncement of judgments after conclusion of hearings. By reaffirming the principles laid down in Anil Rai v. State of Bihar and supplementing them with a structured reporting and escalation mechanism, the Court underscored the importance of timely justice as an inseparable facet of Article 21. This intervention not only safeguards the fundamental rights of litigants but also reinforces public confidence in the justice delivery system.

11. Application of Section 67 of Indian Succession Act 

In C.P. Francis v. C.P. Joseph & Ors. (2025), the Supreme Court of India examined crucial questions concerning Section 67 of the Indian Succession Act, 1925, the proof and validity of a joint will, and the scope of High Court jurisdiction under Section 100 of the Civil Procedure Code (CPC). At its core, the dispute involved inheritance rights within a family, the sanctity of testamentary succession, and whether the attestation of a will by a close relative of the beneficiary undermines its validity. The ruling is significant for reaffirming the boundaries of second appellate jurisdiction, protecting testamentary intent, and illustrating the constitutional restraint the Supreme Court observes under Article 136.

12. Regulatory Supremacy in Electricity Tariff Fixation

In M/s. KKK Hydro Power Limited v. Himachal Pradesh State Electricity Board Limited & Ors. (2025), the Supreme Court of India examined fundamental questions on electricity tariff fixation, the binding authority of State Electricity Regulatory Commissions (SERCs), and the impermissibility of private negotiations in the power sector under the Electricity Act, 2003. At its core, the ruling clarified whether a private generating company and a state distribution licensee can execute supplementary agreements altering tariff terms without prior approval from the SERC.

13. Repudiation of Guardian’s Voidable Sale by Clear Conduct After Majority

In K.S. Shivappa v. Smt. K. Neelamma (2025), the Supreme Court held that a guardian’s sale of a minor’s immovable property without court permission is voidable, not void, and that upon attaining majority, the minor may repudiate that sale by clear, unequivocal conduct (such as selling the same property) rather than being bound to file a separate suit. The Court applied this to the facts where, after majority, the former minors re-sold the property within the limitation period, thereby repudiating their guardian’s unauthorised sale, and in doing so, deprived the subsequent claimant (Neelamma) of any valid title.

14. Marriage Existing Only on Paper Cannot Be Forced to Continue

In Nayan Bhowmick v. Aparna Chakraborty (2025), the Supreme Court held that a marriage which has effectively existed only on paper after decades of separation and prolonged litigation cannot be compelled to continue. The Court observed that the absence of cohabitation, complete emotional breakdown, and no realistic possibility of reconciliation amount to mental cruelty and reflect an irretrievable breakdown of marriage.

Exercising its powers under Article 142 of the Constitution, the Court dissolved the marriage, emphasising that law should ensure dignity and closure rather than mechanically preserving a hollow marital bond.

15. Resignation Forfeits Pension Rights Under CCS Rules

In Ashok Kumar Dabas (Dead Through Legal Heirs) v. Delhi Transport Corporation (2025), the Supreme Court held that when a government employee resigns from service, their past service stands forfeited under Rule 26 of the Central Civil Services (Pension) Rules, 1972, and they lose entitlement to pension and family pension, even if they had qualifying years of service.

The Court distinguished resignation from voluntary retirement and rejected the argument that resignation could be treated as retirement for pensionary benefit purposes. However, it clarified that statutory benefits like gratuity (under the Payment of Gratuity Act, 1972) and leave encashment remain payable where conditions are met. 

16. Statutory Benefits Cannot Be Claimed After Settlement

In Government of Tamil Nadu v. P.R. Jaganathan & Ors. (2025), the Supreme Court ruled that once parties voluntarily enter into a negotiated compensation settlement under Section 7(2) of the Tamil Nadu Acquisition of Land for Industrial Purposes Act, 1997, they cannot later claim additional statutory benefits, such as interest under Section 12, beyond what was agreed.

The Court held that a concluded settlement is a binding contract that excludes the operation of statutory provisions intended for cases where compensation is determined through a statutory process, and that parties are estopped from seeking further statutory relief after accepting the benefits of a negotiated settlement.

17. Commercial Software Buyers Not Entitled to Consumer Remedies

In M/s Poly Medicure Ltd. v. M/s Brillio Technologies Pvt. Ltd. (2025), the Supreme Court held that a company purchasing specialised commercial software for its business cannot be treated as a “consumer” under Section 2(1)(d) of the Consumer Protection Act, 1986, because the purchase was made for commercial purposes linked to profit-generation, efficiency and cost reduction.

As a result, such business-to-business software buyers cannot seek relief in consumer forums even if the software is defective; instead, disputes must be resolved through contractual mechanisms or civil remedies.

18. ‘Pay and Recover’ Principle in Motor Accident Cases

In Akula Narayana v. The Oriental Insurance Company Ltd. & Anr. (2025), the Supreme Court reaffirmed the “pay and recover” principle in motor accident compensation cases, holding that an insurer must first satisfy the award in favour of the victim or dependents, even where there is a breach of policy conditions by the vehicle owner.

The Court emphasised that the primary object of compulsory insurance under the Motor Vehicles Act is to protect innocent victims, and insurers cannot avoid immediate liability on technical grounds, though they retain the right to recover the amount later from the vehicle owner.

19. DNA Test Cannot Be Ordered Without a Clear Nexus to the Crime

In R. Rajendran v. Kamar Nisha & Ors. (2025), the Supreme Court held that a DNA test cannot be ordered in the absence of a clear and direct nexus with the offence under investigation. The Court emphasised that compulsory DNA testing seriously intrudes upon privacy, bodily autonomy, and dignity, and therefore cannot be directed as a routine or speculative measure. Such orders must satisfy the tests of necessity, relevance, and proportionality, and courts must ensure that scientific evidence is sought only when it is indispensable to determining the issues in the case.

20. Burden of Proof in Execution Proceedings Lies on the Judgment-Debtor

In Kapadam Sangalappa & Ors. v. Kamatam Sangalappa & Ors., the Supreme Court held that in execution proceedings, once a valid decree is produced, the onus shifts to the judgment-debtor to prove objections such as payment, discharge, or denial of liability. The Court clarified that execution is a continuation of the original proceedings and is summary in nature, and the decree-holder is not required to re-establish the original claim unless the objections raise substantive issues affecting rights.

21. Contempt Power Is Not a Shield Against Judicial Criticism

In Vineeta Srinandan v. High Court of Judicature at Bombay (2025), the Supreme Court clarified that contempt jurisdiction exists to protect the authority of the judicial process and not the personal sensitivities of individual judges. Emphasising that courts must remain conscious that this power is not a personal armour for judges, nor a sword to silence criticism, the Court held that fair criticism of judicial functioning does not amount to contempt unless it has a real tendency to obstruct justice, reaffirming that openness to scrutiny is integral to public confidence in the judiciary.

22. Genuine Cultivators Cannot Be Deprived of Plantation Land

In M. Jameela v. State of Kerala & Anr. (2025), the Supreme Court held that bona fide cultivators should not be penalised by treating their plantation lands as vested forest under the Kerala Private Forests (Vesting and Assignment) Act, 1971, and declared a 37.5-acre coffee and cardamom plantation in Wayanad exempt from vesting with the State. 

23. Insurer Not Absolved by Driver’s Fake Licence Unless Owner Knew of It

In Hind Samachar Ltd. (Delhi Unit) v. National Insurance Company Ltd. & Ors. (2025), the Supreme Court held that an insurer cannot avoid liability or exercise “pay and recover” against a vehicle owner simply because a driver’s licence is later found to be fake; the insurer must prove that the owner knowingly breached the insurance policy or colluded in hiring the unlicensed driver. The Court observed that the High Court had erred in inferring collusion between the employer and the employee solely on the ground that the employer produced the driving licence and the driver did not contest the claim.

24. Absence of Mutation Weakens Claim of Valid Hiba Under Muslim Law

In Dharmrao Sharanappa Shabadi & Ors. v. Syeda Arifa Parveen (2025), the Supreme Court held that an oral gift (hiba) under Muslim law must strictly satisfy its essential requirements, namely a clear declaration by the donor, acceptance by the donee, and delivery of possession. The Court ruled that a hiba cannot be asserted belatedly without reliable supporting evidence, and observed that the absence of mutation in revenue records, prolonged inaction, and lack of continuous acts of ownership seriously weaken the claim of a valid gift. It was emphasised that mere oral assertions, without proof of possession or control over the property, are insufficient to establish a lawful hiba.

25. Cheque Bounce and NI Act Principles

In Sanjabij Tari v. Kishore S. Borcar & Anr. (2025), the Supreme Court allowed the appeal against the High Court’s ex-parte acquittal under Section 138 of the Negotiable Instruments Act, 1881, affirming that when a dishonoured cheque is admitted to have been signed in discharge of a legally enforceable debt, statutory presumptions under Sections 118 and 139 arise unless effectively rebutted by credible evidence, and that merely filing a reply notice without independent proof of financial incapacity is inadequate to dispel those presumptions.

26. Honour Killing

In K.P. Tamilmaran v. State by Deputy Superintendent of Police (2025), the Supreme Court upheld convictions in a brutal honour killing of an inter-caste couple and delivered strong findings on caste-based violence, police complicity, and evidentiary standards. The Court condemned honour killings as a grave violation of constitutional values of dignity, equality, and liberty, criticised procedural lapses that delayed justice for years, and clarified that hostile or related witnesses are not unreliable per se and can be relied upon if their testimony is credible and corroborated.

27. Format Compliance is Crucial for Caste-Based Reservation

In Mohit Kumar v. State of Uttar Pradesh (2025), the Supreme Court reaffirmed that strict compliance with the State-prescribed format for caste certificates is essential when seeking reservation benefits. The Court held that submitting a caste certificate that does not conform to the prescribed format can result in disqualification from availing of a reservation, even where the applicant genuinely belongs to a backward category, underscoring that procedural compliance is integral to the effective implementation of affirmative action policies.

28. Sharia Court Directives Have No Binding Legal Force

In Shahjahan v. State of Uttar Pradesh & Anr. (2025), the Supreme Court clarified that directives, decisions, or fatwas issued by so-called Sharia Courts, Courts of Kazi, or Darul Kajiyat have no legal recognition or binding force under Indian law. The Court held that only courts constituted under the Constitution or statute can adjudicate disputes, and religious bodies cannot override statutory rights or judicial remedies.

29. Preventive Detention is not a Substitute for Criminal Prosecution

In Dhanya M v. State of Kerala & Ors. (2025), the Supreme Court reaffirmed that preventive detention is an exceptional and precautionary measure and cannot be used as a substitute for criminal prosecution. The Court held that where ordinary criminal law remedies such as investigation, trial, or cancellation of bail are available, the State cannot bypass them by resorting to preventive detention.

30. Driving Licence Renewal Delay Applies Only Prospectively

In Telangana State Level Police Recruitment Board v. Penjarla Vijay Kumar & Ors. (2025), the Supreme Court clarified that renewal of a driving licence after its expiry operates only prospectively from the date of renewal and not retrospectively from the date of expiry. Interpreting Sections 14 and 15 of the Motor Vehicles Act as amended in 2019, the Court held that once a licence expires, its validity stands broken and the intervening period cannot be treated as legally valid, even if renewal is sought within the permissible time.

31. Supreme Court Directs Reforms to Address Dowry and Marital Inequality

In State of Uttar Pradesh v. Ajmal Beg & Anr. (2025), the Supreme Court restored a conviction in a dowry death case and issued reform-oriented directions to combat dowry and marital inequality. The Court recognised dowry as a deep-rooted social evil undermining women’s dignity and constitutional equality, and stressed that criminal punishment alone is insufficient. It called for stronger enforcement of dowry laws, sensitisation of police and judges, activation of Dowry Prohibition Officers, educational reforms promoting marital equality, and faster disposal of dowry-related cases, emphasising a holistic and preventive approach to justice. 

32. Public Photographs of Women Alone Don’t Amount to Voyeurism

In Tuhin Kumar Biswas @ Bumba v. State of West Bengal (2025), the Supreme Court held that merely taking or possessing photographs of women in public places does not constitute voyeurism in the absence of sexual intent, secrecy, or intrusion into a private space. The Court clarified that the offence of voyeurism requires deliberate and surreptitious conduct aimed at violating a woman’s sexual privacy, and openly taken public photographs, by themselves, do not attract criminal liability.

33. Parity Alone is No Ground for Bail

In Sagar v. State of Uttar Pradesh (2025), the Supreme Court held that bail cannot be granted solely on the ground of parity with a co-accused, reiterating that parity applies only when the role, conduct, and circumstances of the accused are nearly identical. Setting aside the Allahabad High Court’s order granting bail to Rajveer, the Court found that the High Court failed to examine his specific role in the offence, relied mechanically on parity with a co-accused whose bail itself had been quashed earlier, and ignored the gravity of the murder charge and settled bail parameters.

34. Dowry Turning Marriage Into Commerce

In Yogendra Pal Singh v. Raghvendra Singh @ Prince & Anr. (2025), the Supreme Court cancelled the bail granted to a husband accused of causing his wife’s dowry-related death just four months after marriage, condemning dowry as a “social evil” that has reduced marriage to a commercial transaction and stressing that such heinous crimes demand strict judicial scrutiny.

The Court held that the High Court erred in granting bail without properly considering the gravity of the offence, corroborated evidence, and the mandatory statutory presumption under Section 113B of the Evidence Act (Section 118 of the Bharatiya Sakshya Adhiniyam), and directed the accused to surrender immediately, underscoring that leniency in dowry-death cases undermines justice and emboldens offenders.

35. Territorial Jurisdiction Under the NI Act Post-2015

In Jai Balaji Industries Ltd. & Ors. v. M/s HEG Ltd. (2025), the Supreme Court settled the long-standing confusion over territorial jurisdiction in cheque-dishonour cases under Section 138 of the Negotiable Instruments Act by holding that only the court within whose local limits the payee’s “home branch” (where the payee maintains a bank account) is situated has jurisdiction to try a complaint for an account-payee cheque deposited through an account, regardless of where the cheque was physically presented or dishonoured.

36. No Review of Court’s Order Appointing Arbitrator

In Hindustan Construction Company Ltd. v. Bihar Rajya Pul Nirman Nigam Ltd (2025), the Supreme Court clarified that the law does not permit a review of a court’s order appointing an arbitrator under Section 11 of the Arbitration and Conciliation Act, 1996, as the statute provides no mechanism for review or recall of such an order.

Emphasising the principle of minimal judicial interference, the Court held that once an arbitrator is appointed, parties must raise objections relating to jurisdiction, validity of the arbitration agreement, or impartiality before the arbitral tribunal under Section 16, or invoke the Supreme Court’s jurisdiction under Article 136, but cannot seek a review from the same court, as doing so would defeat the speed and efficiency of the arbitral process.

37. Letter of Intent Alone Does Not Create Contractual Rights

In State of Himachal Pradesh & Anr. v. OASYS Cybernetics Pvt. Ltd. (2025), the Supreme Court held that parties cannot claim enforceable contractual rights solely based on a Letter of Intent (LoI) unless all stipulated pre-conditions are fulfilled and a final agreement or letter of acceptance is executed. The Court clarified that an LoI merely reflects a preliminary intention to enter into a contract and creates only a commercial expectation, not a legal entitlement.

38. TIP Loses Evidentiary Value If Witness Had Prior Exposure to Accused

In Raj Kumar @ Bheema v. State of NCT of Delhi (2025), the Supreme Court held that test identification proceedings (TIP) and subsequent dock identification lose evidentiary value when the witness had prior exposure to the accused or when identification is made after an inordinate delay.

The Court set aside the murder conviction, noting that the sole eyewitness identified the accused in court nearly eight-and-a-half years after the incident under doubtful conditions, without a reliable TIP and with material contradictions in testimony. It reiterated that TIP is only corroborative and not substantive evidence.

39. Jurisdictional Defects and Decree Nullity Clarified

In Vikram Bhalchandra Ghongade v. State of Maharashtra & Ors. (2025), the Supreme Court held that a decree passed in proceedings vitiated by jurisdictional defects, such as an appeal decided after the death of parties without substitution of legal heirs, is a nullity in law. The Court clarified that such a void decree has no legal effect, cannot prevent execution of a valid trial court decree, and its invalidity may be raised at any stage, including in execution proceedings, as jurisdictional competence is fundamental and cannot be cured by limitation or procedural lapses.

40. Mere Use of “Arbitration” Doesn’t Create an Arbitration Agreement

In M/s Alchemist Hospitals Ltd. v. M/s ICT Health Technology Services India Pvt. Ltd. (2025), the Supreme Court held that mere use of the word “arbitration” in a dispute-resolution clause does not make it a valid arbitration agreement under Section 7 of the Arbitration and Conciliation Act, 1996. The Court ruled that the clause in question only provided a multi-tier mechanism of negotiation and mediation, lacked binding adjudicatory intent, finality, and neutrality, and even permitted recourse to civil courts, thereby negating true arbitration.

41. Property Registration Cannot Depend on Mutation Records

In Samiullah v. State of Bihar & Ors. (2025), the Supreme Court held that registration authorities cannot refuse to register sale or gift deeds merely because the seller has not produced proof of mutation or jamabandi, as such a requirement is ultra vires the Registration Act, 1908 and violates the constitutional right to property under Article 300A.

42. Power of a Magistrate to Direct the Police to Register a First Information Report

In Sadiq B. Hanchinmani v. State of Karnataka & Ors. (2025), the Supreme Court of India reaffirmed that when a private complaint prima facie discloses a cognizable offence, a Magistrate can direct the police to register an FIR and investigate at the preliminary stage. The Court held that such directions, if passed after proper application of mind and adherence to prescribed safeguards, should not be lightly interfered with by High Courts. 

43. Refusal to Marry Cannot Be Construed as Instigation to Commit Suicide

In Yadwinder Singh @ Sunny v. State of Punjab & Anr. (2025), the Supreme Court clarified that a mere refusal to marry, even if it causes emotional distress, does not amount to abetment of suicide under Section 306 IPC (Section 108 BNS). The Court held that criminal liability requires clear mens rea and a positive act of instigation, provocation, or intentional aid as defined under Section 107 IPC (Section 45 BNS); emotional fallout from a failed relationship or parental opposition to marriage, without direct incitement, cannot attract penal consequences.

44. Mere Recovery of Bribe Money Not Enough Without Proof of Demand and Acceptance

In P. Somaraju v. State of Andhra Pradesh (2025), the Supreme Court reaffirmed that mere recovery of tainted money is insufficient to convict a public servant under the Prevention of Corruption Act, 1988, unless the prosecution proves the essential ingredients of demand and voluntary acceptance of illegal gratification beyond a reasonable doubt.

Setting aside the Andhra Pradesh High Court’s reversal of the acquittal, the Court held that the trial court’s view was reasonable and not perverse, especially in light of serious inconsistencies in the complainant’s version, lack of independent corroboration, a negative phenolphthalein test, and a plausible defence that the money was planted.

45. Armed Forces Tribunal Gains Judicial Backing to Alter Court-Martial Findings

In S.K. Jain v. Union of India (2025), the Supreme Court upheld the Armed Forces Tribunal’s power under Section 15(6) of the Armed Forces Tribunal Act, 2007, to substitute a court-martial conviction with a cognate offence where evidence so warrants. While setting aside the appellant-officer’s conviction for corruption and unlawful possession of ammunition under Section 69 of the Army Act, the Tribunal validly convicted him under Section 63 for conduct prejudicial to good order and military discipline, based on proven recovery of ammunition and procedural neglect.

46. Ink & Chemicals Used in Printing Lottery Tickets are Taxable

In M/s. Aristo Printers Pvt. Ltd. v. Commissioner of Trade Tax (2025), the Supreme Court held that ink, chemicals, and processing materials used in printing lottery tickets are taxable under Section 3F(1)(b) of the Uttar Pradesh Trade Tax Act, 1948, as they constitute “goods transferred in some other form” during the execution of a works contract. The Court clarified that even though such materials are chemically altered or merged with the paper, their property is transferred to the contractee since the ink and chemicals remain traceable and visible on the printed tickets.

47. Suspicion Cannot Replace Proof Beyond a Reasonable Doubt

In Rajendra Singh & Ors. v. State of Uttaranchal (2025), the Supreme Court set aside the Uttarakhand High Court’s reversal of the acquittal and acquitted the accused of murder, holding that the prosecution failed to establish their identity beyond a reasonable doubt.

The Supreme Court acquitted the accused, holding that their identity as assailants was not proved beyond a reasonable doubt, eyewitnesses were unreliable, no test identification parade was conducted, and weapon recoveries lacked forensic corroboration.

48. Age Bar Under Surrogacy Law Cannot Apply to Couples Who Froze Embryos Before 2022

In Vijaya Kumari S. & Another v. Union of India (2025), the Supreme Court held that the age restrictions under the Surrogacy (Regulation) Act, 2021 cannot be applied retrospectively to couples who had already commenced the surrogacy process by freezing embryos before the Act came into force on 25 January 2022.

The Court ruled that embryo freezing amounts to commencement of the surrogacy procedure, creating vested reproductive rights protected under Article 21, and that in the absence of clear legislative intent, statutory age limits cannot invalidate bona fide steps taken under the earlier legal regime.

49. Non-Disclosure of Encumbrances Vitiates Bank Auction

In Delhi Development Authority v. Corporation Bank & Ors. (2025), the Supreme Court of India held that a bank-conducted auction is invalid if the sale notice fails to disclose material encumbrances, statutory dues, or lease restrictions. The Court ruled that the mortgage was illegal for lack of mandatory prior consent under the lease deed and that non-disclosure of DDA’s rights violated Rule 53 of the Second Schedule to the Income Tax Act.

50. Fabricated Documents Not Protected Under Insolvency Law

In Singamasetty Bhagavath Guptha v. Allam Karibasappa (2025), the Supreme Court held that Section 37 of the Provincial Insolvency Act, 1920 does not protect transactions based on fabricated or fraudulent documents. The Court clarified that only bona fide and lawfully made acts of a receiver are protected after annulment of insolvency, and insolvency proceedings cannot be used to legitimise fraud.

51. Fixation of Interest by Arbitrator Till Repayment Ends Further Claims

In HLV Limited (formerly Hotel Leelaventure Pvt. Ltd.) v. PBSAMP Projects Pvt. Ltd. (2025), the Supreme Court clarified that where an arbitral tribunal has already fixed the rate and period of interest payable “till repayment” under Section 31(7) of the Arbitration and Conciliation Act, 1996, the award creditor cannot later claim additional or compound interest at the execution stage. Emphasising party autonomy, finality of arbitral awards, and the limited powers of executing courts, the Court held that permitting such claims would amount to impermissibly modifying the award.

52. States Cannot Impose Discriminatory Taxes on Goods from Other States

In a recent Supreme Court ruling in M/s U.P. Asbestos Ltd. v. State of Rajasthan & Ors. (2025), the Court reaffirmed that under Article 304(a) of the Constitution, a State cannot impose or design tax exemptions that discriminate against goods brought in from other States by favouring locally manufactured goods, as this undermines the freedom of trade and commerce across State borders. 

53. SC Bars Second SLP After Unconditional Withdrawal of the First Petition

In Satheesh V.K. v. The Federal Bank Ltd. (2025), the Supreme Court held that a second Special Leave Petition (SLP) against the same order is not maintainable if the first SLP was withdrawn unconditionally without obtaining liberty to file afresh. The case arose out of SARFAESI Act recovery proceedings, where the Kerala High Court had directed a borrower to pay dues in instalments. The appellant first filed an SLP against the High Court’s order, withdrew it without seeking liberty, then sought High Court review (which was dismissed), and thereafter filed fresh SLPs in the Supreme Court.

54. One-Day Delay Cannot Deny Justice to a Tribal Woman

In Shreya Kumari Tirkey v. State of Jharkhand & Ors. (2025), the Supreme Court reaffirmed its role as a sentinel of social justice by granting relief to a tribal woman who was denied employment due to a one-day delay in appearing for a mandatory medical examination. The Court held that even if some negligence could be attributed to the appellant, such procedural lapses must be viewed leniently when dealing with candidates from marginalised communities.

55. Value-Added Processing of Imports Attracts Excise Duty

In M/s Quippo Energy Ltd. v. Commissioner of Central Excise, Ahmedabad-II (2025), the Supreme Court held that containerising imported gas-generating sets and fitting them with essential components results in a new, distinct, and marketable product known as a “Power Pack.” The Court ruled that such value-added processes amount to “manufacture” under excise law since the final product acquires a separate commercial identity and marketability from the imported Gensets, thereby attracting excise duty.

56. False Representation Must Relate to Material Fact to Constitute Cheating

In Jupally Lakshmikantha Reddy v. State of Andhra Pradesh & Anr. (2025), the Supreme Court reiterated that not every false statement amounts to cheating under criminal law; the misrepresentation must relate to a material fact and must induce the victim to act to their detriment. The Court held that where the alleged false representation has no bearing on the decision-making process of the authority or causes no wrongful gain or loss, the essential ingredients of cheating are not satisfied.

57. Neighbourhood Quarrels Alone Insufficient to Constitute Abetment of Suicide

In Geeta v. State of Karnataka (2025), the Supreme Court held that ordinary neighbourhood quarrels, verbal altercations, or casual insults, even if unpleasant or frequent, do not by themselves amount to abetment of suicide under Section 306 IPC (Section 108 of the BNS). The Court clarified that abetment requires clear proof of mens rea and a direct act of instigation, intentional aid, or conduct creating circumstances that leave the victim with no option but to commit suicide.

58. Power of Review: To Correct Mistakes, Not to Replace Views

In Malleeswari v. K. Suguna & Anr. (2025), the Supreme Court reiterated that the power of review under Section 114 and Order XLVII Rule 1 of the Code of Civil Procedure, 1908 is limited and purely corrective, and cannot be exercised as a substitute for an appeal. The Court held that review jurisdiction is confined to correcting an error apparent on the face of the record or considering material that could not be produced earlier despite due diligence, but it does not permit reappreciation of evidence or substitution of one judicial view with another.

59. Selective Regularisation among Daily wagers is Both Arbitrary and UnConstitutional

In Dharam Singh & Ors. v. State of Uttar Pradesh & Anr. (2025), the Supreme Court held that selective regularisation of daily wage workers is arbitrary and unconstitutional, observing that the State cannot exploit employees by keeping them in temporary service for years while regularising others who are similarly placed. The Court ruled that vague claims of financial constraints cannot justify the denial of sanctioned posts where the work is perennial in nature, and such unequal treatment violates Articles 14, 16, and 21 of the Constitution, directing regularisation with consequential benefits.

60. Witness Protection Cannot Replace Bail Cancellation

The Supreme Court in Phireram v. State of Uttar Pradesh & Anr. (2025), held that bail cancellation and witness protection serve distinct and complementary purposes: while witness protection is a curative measure aimed at safeguarding witnesses from threats, bail cancellation is a preventive judicial power exercised when an accused misuses the liberty granted by violating bail conditions, such as intimidating witnesses.

61. NCLT’s Role in Protecting Shareholder Rights

In Mrs. Shailja Krishna v. Satori Global Limited & Ors. (2025), the Supreme Court of India restored the NCLT’s order holding that the appellant was illegally ousted as a director and majority shareholder through a fraudulent gift deed and manipulated share transfers, amounting to oppression and mismanagement. The Court ruled that the NCLT has wide jurisdiction to adjudicate allegations of fraud when they are integral to claims under Sections 397–398 of the Companies Act, and that fraudulent divestment cannot defeat a shareholder’s right to maintain proceedings by invoking technical shareholding thresholds.

62. Government Cannot Cancel Statutorily Conducted Recruitment Midway

In Partha Das & Ors. v. State of Tripura & Ors. (2025), the Supreme Court held that the Tripura government acted arbitrarily in cancelling an almost-completed recruitment process for Enrolled Followers in the Tripura State Rifles after introducing a new recruitment policy. The Court ruled that executive instructions cannot override statutory rules framed under the Tripura State Rifles Act and Rules, and that applying a new policy to an ongoing selection amounts to impermissibly changing the “rules of the game” mid-way, violating Articles 14 and 16 of the Constitution.

63. Mere Delay Without Wilful Disobedience Does Not Amount to Contempt

In A.K. Jayaprakash (Dead) through LRs v. S.S. Mallikarjuna Rao & Anr. (2025), the Supreme Court of India clarified that mere delay in complying with a court’s directions does not amount to civil contempt unless it is marked by wilful and deliberate disobedience. Interpreting Section 2(b) of the Contempt of Courts Act, 1971, the Court held that contempt jurisdiction is attracted only where non-compliance is intentional and contumacious, and not where it results from administrative hurdles, bona fide difficulties, or procedural lapses.

64. Supreme Court Expands Scope of ‘Interim Order’ Under Consumer Law

In Palm Groves Cooperative Housing Society Ltd. v. Magar Girme and Gaikwad Associates & Ors. (2025), the Supreme Court clarified that the expression “interim order” in Section 25(1) of the Consumer Protection Act, 1986 must be read broadly to mean “any order,” including final orders. The Court held that a literal interpretation restricting enforcement only to interim orders would defeat the beneficial object of consumer law and render consumer fora ineffective.

65. Acceptance of Benefits Triggers Estoppel Against Later Challenge

In Sanjit Singh Salwan & Ors. v. Sardar Inderjit Singh Salwan & Ors. (2025), the Supreme Court reaffirmed that a party cannot approbate and reprobate by accepting the benefits of an arrangement and later disputing its validity once the other side has acted upon it. The Court held that since the respondents had consented to arbitration, accepted the resulting award, and secured disposal of their appeal on that basis, they were estopped by conduct and election from later contending that the compromise decree was a nullity.

66. Humiliation or Pressure Alone is Not Abetment to Suicide

The Supreme Court, in Abhinav Mohan Delkar v. State of Maharashtra & Ors. (2025), clarified that humiliation, harassment, or pressure by itself does not amount to abetment of suicide. Upholding the quashing of an FIR, the Court held that a conviction for abetment requires clear mens rea and a proximate act of instigation or intentional aid that directly drives the victim to take their life. Mere allegations in a suicide note, without prior complaints or a “live link” between the accused’s conduct and the suicide, are insufficient.

67. Child Welfare Prevails Over Procedural Lapses in Adoption

In Dasari Anil Kumar & Anr. v. The Child Welfare Project Director & Ors. (2025), the Supreme Court held that the welfare and best interests of the child must prevail over procedural lapses in adoption when emotional bonding and stability are already established. Exercising its powers under Article 142, the Court ordered the return of children to their adoptive parents while directing periodic monitoring to safeguard their welfare, clarifying that the decision was confined to the facts of the case and not a general relaxation of adoption laws.

68. Non-Compliance with Order 39 Rule 3 CPC Defeats Ex-Parte Injunctions

The Supreme Court in Time City Infrastructure and Housing Ltd. v. State of U.P. & Ors. (2025), held that an ex parte injunction must be vacated if the plaintiff fails to comply with the mandatory requirements of Order 39 Rule 3 CPC. The Court clarified that when injunctions are granted without notice, the applicant must immediately serve all relevant pleadings and documents on the opposite party and file an affidavit confirming such service. Non-compliance disentitles the plaintiff to the protection of the ex parte order, which can be set aside without examining the merits, reaffirming that these safeguards are integral to fairness and natural justice.

69. Custom Cannot Operate to Deny Inheritance to Tribal Women

In Ram Charan & Ors. v. Sukhram & Ors. (2025), the Supreme Court held that tribal women cannot be denied inheritance rights solely on the basis of customary practices unless such a custom is clearly proved, specific, and non-discriminatory. The Court ruled that in the absence of an established custom, courts must apply the principles of justice, equity, and good conscience, and that exclusion of women from succession purely on gender grounds violates Article 14 of the Constitution. It emphasised that customs cannot be used as a shield to perpetuate inequality and must yield to constitutional guarantees of equality and social justice.

70. Post-Delivery Penalties for Misdeclared Railway Goods Are Lawful

In Union of India v. M/s Kamakhya Transport Pvt. Ltd. (2025), the Supreme Court clarified that Indian Railways can impose penalties for misdeclaration of goods even after delivery of the consignment. Interpreting Section 66 of the Railways Act, 1989, the Court held that, unlike provisions dealing with overloading, the law does not restrict the levy of misdeclaration charges to the pre-delivery stage. Since misdeclaration undermines railway revenue and logistics planning, post-delivery scrutiny and recovery were found to be consistent with legislative intent.

71. State Cannot Object to Marriage Approved by Both Families

In Aman Siddiqui alias Aman Chaudhary v. State of Uttarakhand (2025), the Supreme Court reaffirmed that the State cannot interfere with or criminalise a consensual inter-faith marriage solemnised with the informed consent of both partners and their families, merely by invoking anti-conversion laws. Granting bail, the Court held that in the absence of any prima facie evidence of coercion, fraud, inducement, or forced religious conversion, the provisions of the Uttarakhand Freedom of Religion Act, 2018 could not be attracted.

72. Res Judicata Applies Across Different Stages of the Same Suit

In Sulthan Said Ibrahim v. Prakasan & Ors. (2025), the Supreme Court reaffirmed that the doctrine of res judicata is not confined to barring re-litigation between separate suits but also applies at different stages of the same proceeding. The Court held that once an issue has been conclusively decided at an earlier stage, a party cannot reopen or challenge it later by filing fresh applications, especially after having participated without objection.

73. Maternity Leave as a Constitutional Right Under Article 21

In K. Umadevi v. Government of Tamil Nadu & Ors. (2025), the Supreme Court firmly held that maternity leave is not merely a statutory or service-related benefit but an integral facet of the right to life and personal liberty under Article 21 of the Constitution. The Court ruled that denying maternity leave to a woman government employee for a child born from her second marriage, by mechanically applying a two-child norm, violates her dignity, health, and reproductive autonomy.

74. Unfulfilled Marriage Promise Does Not Make Consensual Sex Rape

In Amol Bhagwan Nehul v. State of Maharashtra & Anr. (2025), the Supreme Court quashed rape and allied charges arising from a long-term consensual relationship, holding that a failed or unfulfilled promise of marriage does not, by itself, vitiate consent. The Court noted that the complainant was a mature, married woman at the inception of the relationship, making any alleged promise of marriage legally unenforceable, and found no material to show deceit or coercion from the outset.

75. Entire Plaint Cannot Be Rejected Due to One Defective Relief

The Supreme Court of India, in Vinod Infra Developers Ltd. v. Mahaveer Lunia & Ors. (2025), clarified that a plaint cannot be rejected in its entirety under Order VII Rule 11 CPC merely because one of the prayers or reliefs sought is legally untenable, if other prayers disclose a valid and triable cause of action. The Court held that rejection at the threshold is permissible only when the whole plaint is ex facie barred by law or discloses no cause of action at all, and courts must avoid dissecting pleadings for piecemeal rejection.

76. Delay Cannot Be Condoned as an Act of Generosity

In Thirunagalingam v. Lingeswaran & Anr. (2025), the Supreme Court reaffirmed that condonation of delay under the Limitation Act is not a matter of charity and can be granted only upon showing a bonafide and genuine cause. The Court held that repeated reliance on the same grounds already rejected in earlier proceedings amounts to abuse of process and cannot justify condonation, especially when parties were duly served and later remained negligent.

78. Washing & Dry Cleaning Qualify as ‘Manufacturing Process’ Under Factories Act

In State of Goa & Anr. v. Namita Tripathi (2025), the Supreme Court held that commercial washing and dry cleaning of clothes constitute a “manufacturing process” under Section 2(k) of the Factories Act, 1948, since the statute expressly includes “washing” and “cleaning.” Reversing the High Court, the Court clarified that importing the excise-law test of transformation into a new marketable commodity is erroneous for a welfare legislation like the Factories Act, which must be interpreted liberally to protect workers.

79. NCLAT Cannot Condon Delay Beyond Statutory Limit Under IBC

The Supreme Court, in Tata Steel Ltd. v. Raj Kumar Banerjee & Ors. (2025), reaffirmed that the National Company Law Appellate Tribunal (NCLAT) has no jurisdiction to condone delays beyond the outer limit expressly prescribed under Section 61(2) of the Insolvency and Bankruptcy Code, 2016. The Court held that an appeal must be filed within 30 days from the date of the NCLT order, with a maximum condonable delay of only 15 additional days, making 45 days the absolute cut-off.

80. Limits of Narco-Analysis in Criminal Investigation

The Supreme Court in Amlesh Kumar v. State of Bihar (2025), held that a High Court, while considering a bail application, cannot accept or endorse a proposal for conducting narco-analysis tests on the accused, as doing so amounts to overstepping judicial limits and violating constitutional protections. Reiterating the principles laid down in Selvi v. State of Karnataka, the Court clarified that involuntary narco-analysis infringes the right against self-incrimination and personal liberty, while even voluntary narco-analysis has limited evidentiary value and cannot form the sole basis for conviction without independent corroboration.

81. Employment Bond Not Unfair Enrichment if Reasonable and Agreed

In Vijaya Bank & Anr. v. Prashant B. Narnaware (2025), the Supreme Court held that an employment bond requiring payment of a fixed sum on premature resignation does not amount to unfair enrichment or restraint of trade if it is reasonable, proportionate, and operates during the period of employment. Upholding a clause mandating payment of ₹2 lakhs for leaving before completing three years of service, the Court ruled that such stipulations are legitimate pre-estimates of loss incurred due to recruitment costs and administrative disruption, especially in public sector institutions, and do not violate public policy when voluntarily accepted by the employee.

82. High Court Cannot Decide Entire Suit While Hearing Appeal Against Interim Order

In Mahendra Magruram Gupta & Anr. v. Rajdai Shaw & Ors. (2025), the Supreme Court clarified that when a High Court hears an appeal against an interlocutory order, such as a refusal of a temporary injunction, it must confine itself strictly to examining the correctness of that interim decision and cannot adjudicate or dispose of the substantive claims of the suit. The Court held that deciding declaratory or final reliefs at the interim appellate stage amounts to exceeding jurisdiction, undermines the trial process, and violates settled principles of civil procedure, as issues relating to evidence, admissibility of documents, and final rights must be determined only after a full trial.

83. Additional Evidence Can Be Produced After Chargesheet If Omission Was Inadvertent

In Sameer Sandhir v. Central Bureau of Investigation (2025), the Supreme Court held that there is no absolute bar on the prosecution producing additional documents or evidence after filing the chargesheet, even if such material existed earlier, provided the omission was inadvertent, and no prejudice is caused to the accused. Reaffirming that the requirement under Section 173(5) CrPC [Section 193(6) BNSS] is directory and not mandatory, the Court relied on the R.S. Pai doctrine to permit later production of omitted evidence with court permission, while safeguarding the accused’s right to receive copies, recall witnesses, and challenge the authenticity and admissibility of such material during trial.

84. High Court Cannot Enhance Sentence in Accused’s Appeal Alone

In Nagarajan v. State of Tamil Nadu (2025), the Supreme Court held that when an appeal is filed only by the accused, the High Court cannot enhance the sentence or convict the accused on an additional charge in the absence of any appeal or revision by the State, victim, or complainant. The Court clarified that appellate powers must be exercised strictly within statutory limits and that the doctrine of no reformatio in peius protects an appellant from being placed in a worse position merely for exercising the right to appeal.

85. Long-Term Live-In Relationship Negates Allegation of Rape

The Supreme Court in Ravish Singh Rana v. State of Uttarakhand (2025), held that a long-term consensual live-in relationship between two adults cannot be retrospectively criminalised as rape merely because the man later refuses to marry. The Court drew a clear distinction between a false promise of marriage made with no intention to marry from the outset and a mere breach of promise due to subsequent developments, holding that only the former can vitiate consent.

86. Registered Sale Deed Is Mandatory to Transfer Property Ownership

The Supreme Court in Mahnoor Fatima Imran & Ors. v. M/s Visweswara Infrastructure Pvt. Ltd. & Ors. (2025), reaffirmed that ownership of immovable property cannot be transferred based on an unregistered agreement of sale, even if possession is claimed or the agreement is later “revalidated.” The Court held that under the Transfer of Property Act, 1882, and the Registration Act, 1908, only a duly registered sale deed can convey a valid title, and subsequent registration cannot cure defects arising from an unregistered or fraudulent foundational agreement.

87. Courts Cannot Act as Appellate Authorities in Departmental Inquiries

In State Bank of India & Others v. Ramadhar Sao (2025), the Supreme Court reaffirmed that constitutional courts cannot re-appreciate evidence or substitute their own views in disciplinary proceedings unless there is a clear violation of natural justice, procedural illegality, or perversity in findings. Setting aside the High Court’s interference, the Court restored the penalty of removal from service with superannuation benefits imposed on a Class IV SBI employee found guilty of acting as a conduit in loan irregularities and accepting illegal gratification.

88. Obstruction of Public Servant Not Limited to Physical Force

In Devendra Kumar v. State (NCT of Delhi) & Anr. (2025), the Supreme Court held that the offence of obstructing a public servant under Section 186 IPC (now Section 221 of the Bharatiya Nyaya Sanhita, 2023) is not limited to physical force or violence. The Court clarified that any voluntary conduct—such as threats, intimidation, humiliation, unlawful detention, or other non-physical acts—that hinders or prevents a public servant from lawfully discharging official duties amounts to obstruction.

89. CBI Officers Can Be Investigated for Abuse of Power Despite Internal Inquiry

The Supreme Court in Vinod Kumar Pandey & Anr. v. Sheesh Ram Saini & Ors. (2025), upheld the Delhi High Court’s direction to register an FIR against CBI officers accused of intimidation, abuse of authority, and fabrication of records, holding that an internal CBI preliminary inquiry finding no offence cannot override a constitutional court’s duty to ensure investigation when prima facie cognizable offences are disclosed.

90. Anticipatory Bail Bar Under SC/ST Act: Prima Facie Test Reaffirmed

In Kiran v. Rajkumar Jivraj Jain & Anr. (2025), the Supreme Court reiterated that Section 18 of the SC/ST (Prevention of Atrocities) Act imposes a near-absolute bar on anticipatory bail, with a narrow exception only where the FIR, on its face, discloses no prima facie offence under the Act. The Court held that High Courts cannot conduct a mini-trial or discard explicit caste-based allegations at the bail stage; if the complaint alleges intentional caste-based insult or intimidation in public view with a clear caste nexus, the statutory bar applies and anticipatory bail must be denied.

91. Adverse Possession Cannot Be Raised for the First Time in Appeal

In Kishundeo Rout & Ors. v. Govind Rao & Ors. (2025), the Supreme Court held that a plea of adverse possession cannot be introduced for the first time at the appellate stage in the absence of specific foundational pleadings at trial. Reiterating the principle of secundum allegata et probata, the Court clarified that adverse possession is a fact-intensive claim requiring precise pleadings and proof regarding the nature, continuity, publicity, and hostility of possession.

92. Bail Cannot Be Granted on the Basis of Undertakings Alone

The Supreme Court in Gajanan Dattatray Gore v. State of Maharashtra & Anr. (2025), held that bail cannot be granted merely on the basis of undertakings or monetary assurances offered by an accused. The Court deprecated the practice of securing liberty through financial promises that are later dishonoured and clarified that bail must be decided strictly on merits, including the nature of the offence, conduct of the accused, and statutory considerations, reaffirming that courts are not recovery agents and judicial discretion cannot be undermined by such tactics.

93. Refusal of Industrial Closure Must Be by Competent Authority and Within Statutory Time

In Harinagar Sugar Mills Ltd. (Biscuit Division) v. State of Maharashtra & Ors. (2025), the Supreme Court held that a refusal of permission to close an industrial undertaking under Section 25-O of the Industrial Disputes Act, 1947 must be issued by the duly notified “appropriate government” or a properly delegated authority, be reasoned, follow due enquiry and hearing, and be communicated within the mandatory 60-day period; otherwise, permission for closure is deemed granted under Section 25-O(3).

94. Court’s Sole Discretion to Recall Witnesses Under Order 18 Rule 17 CPC

In Shubhkaran Singh v. Abhayraj Singh & Ors. (2025), the Supreme Court reaffirmed that the power to recall a witness under Order 18 Rule 17 of the CPC lies exclusively with the court and not at the behest of the parties. The provision is intended for a limited purpose, to enable the court to clarify any ambiguity or doubt arising from the evidence already recorded. It cannot be invoked to fill evidentiary gaps, cure defects in a party’s case, or grant a second opportunity to lead evidence, thereby preserving procedural discipline and fairness in civil trials.

95. Unsigned Arbitration Agreements Enforceable If Parties Act on Them

The Supreme Court, in Glencore International AG v. M/s Shree Ganesh Metals & Anr. (2025), held that an arbitration agreement does not become unenforceable merely because it is unsigned, so long as the parties’ conduct clearly demonstrates acceptance of its terms. Interpreting Section 7 of the Arbitration and Conciliation Act, 1996, the Court clarified that what is mandatory is a written record of consensus, which can be established through emails, correspondence, invoices, bank guarantees, and performance of contractual obligations. 

96. Interest Payable on Future Prospects in Motor Accident Compensation

In The Oriental Insurance Co. Ltd. v. Niru @ Niharika & Ors. (2025), the Supreme Court held that interest can validly be awarded on the entire compensation amount in motor accident claims, including the component of future prospects. Rejecting the insurer’s argument that future prospects are speculative and should not carry interest, the Court reasoned that prolonged litigation converts the “future” loss into a present deprivation for claimants. Interest, the Court clarified, is not a windfall but a minimal compensation for delayed payment, especially where claimants are kept out of funds for years due to contest by insurers.

97. No Retrospective Effect Without Express Legislative Intent

In M. Rajendran & Ors. v. M/s KPK Oils and Proteins India Pvt. Ltd. & Ors. (2025), the Supreme Court clarified that statutes affecting substantive or vested rights are presumed to operate prospectively unless Parliament expressly or by necessary implication provides otherwise. Examining the 2016 amendment to Section 13(8) of the SARFAESI Act, which curtailed the borrower’s right of redemption, the Court held that the amendment was substantive in nature and therefore could not apply retrospectively.

98. Doctrine of Merger has Limits When Fraud is Alleged

The Supreme Court in Vishnu Vardhan v. State of Uttar Pradesh & Ors. (2025), clarified that the doctrine of merger cannot be applied mechanically to shut out judicial scrutiny where fraud, suppression of material facts, or violation of natural justice is alleged. While the doctrine ordinarily ensures finality by merging a lower court’s decision into that of a superior court, the Court held that it does not operate where the earlier adjudication was limited in scope or where judgments were obtained by deceit. Reaffirming that “fraud unravels everything,” the Court ruled that orders procured without impleading necessary parties or by misleading the court cannot be protected by merger, as justice and fairness must prevail over rigid finality.

99. Informant’s Death Does Not Abate Criminal Revision; Other Victims May Assist the Court

In Syed Shahnawaz Ali v. State of Madhya Pradesh & Ors. (2025), the Supreme Court of India authoritatively held that a criminal revision petition does not automatically abate simply because the original informant dies during its pendency; unlike appeals, there is no statutory provision for abatement of revision proceedings and the strict rules of locus standi that apply to appeals do not apply to revisions. The Court explained that revisional jurisdiction is supervisory and discretionary in nature, aimed at correcting legal errors, and that where a revision is filed by an informant or victim (and not by an accused), the death of the informant does not terminate the court’s power to examine the impugned order.

100. Lis Pendens Extends Beyond Property Suits

The Supreme Court in Danesh Singh & Ors. v. Har Pyari (Dead) through LRs & Ors. (2025), clarified that the doctrine of lis pendens under Section 52 of the Transfer of Property Act, 1882 applies even to money recovery suits where repayment is secured by a mortgage. The Court held that when a suit seeks recovery of a loan backed by mortgaged immovable property, rights in that property are “directly and substantially in issue,” making any pendente lite transfer subordinate to the outcome of the litigation.

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