Jai Balaji Industries Ltd. v. M/s HEG Ltd.: 2025 INSC ----------------------------------------------------------The Supreme Court held that after the 2015 amendment, the Explanation to Section 142(2)(a) of the Negotiable Instruments Act provides a deeming fiction: jurisdiction lies with the court within whose local limits the payee's home branch is situated, not the drawee bank's location. The Court rejected the "place of presentation" theory and upheld the "payee's account branch" theory, emphasizing legislative intent for a single, certain forum to prevent forum shopping and inconvenience to the accused. The Apex Court transferred the complaint from Bhopal, to Kolkata as the complaint had already advanced to evidence recording stage in Kolkata in a peculiar case.

Yogendra Pal Singh v. Raghvendra Singh Alias Prince : 2025 INSC 1367----------------------------------------Key Findings & Legal Principles • Mandatory Presumption: The Court emphasized that when an unnatural death occurs within seven years of marriage following dowry-related cruelty, the statutory presumption under Section 113B of the Evidence Act (now Section 118 of the Bharatiya Sakshya Adhiniyam) must be strictly applied. • Judicial Duty: It ruled that granting bail mechanically in such "heinous crimes" without considering the gravity and prima facie evidence (like dying declarations or forensic reports) undermines public confidence in justice. • "Commercial Transaction": The bench observed that marriage is a "sacred institution" and should not be reduced to a commercial bargain driven by greed. • Locus Standi: The judgment reaffirmed that the complainant-father is an "aggrieved person" competent to seek the cancellation of a legally flawed bail order.

Sagar v. State of UP:2025 INSC 1370--------------------------------------------------------------------------Core Principles Established • Assessment of Individual Role: Courts must evaluate the specific role, nature of involvement, and culpability of each accused individually, rather than applying a blanket rule for everyone named in the same FIR. • The "Position" Clincher: The Court defined "parity" as equality of position. It noted that "position" in a crime is not just being part of the same offence but refers to the actual acts performed (e.g., an instigator vs. a bystander). • Reasoned Orders are Mandatory: The Supreme Court set aside orders from the Allahabad High Court for being "non-speaking" (lacking reasoning). It emphasized that even if reasons are brief, they must reflect an application of mind regarding the gravity of the offence and the evidence. • Bail vs. Jail Balance: While reiterating that "bail is the rule and jail is the exception," the Court cautioned that this principle does not allow for the disregard of circumstances in serious crimes like murder.

G.R. Selvaraj (Dead), through LRs. versus K.J. Prakash Kumar and others: 2025 INSC 1353----------------------------Whether a judgment-debtor can challenge an auction sale, after it has been completed, on grounds, which could have been raised before the proclamation of sale under Order XXI?- HELD Core Ruling The Court held that under Order XXI Rule 90(3) of the Code of Civil Procedure (CPC), a judgment-debtor cannot challenge an auction sale after its completion on grounds they could have raised before the sale proclamation was drawn up. --

Samadhan v. State of Maharasthra: 2025 INSC 1351------------------------------------------------------------Ratio: The Supreme Court quashed the FIR, holding that a long-term consensual relationship cannot be retrospectively branded as rape merely because it failed to culminate in marriage. The relationship between the parties was cordial and also consensual in nature. A mere break up of a relationship between a consenting couple cannot result in initiation of criminal proceedings. For consent to be vitiated, promise of marriage must be illusory from inception with mala fide intent. Three-year relationship duration and complainant's own opposition to marriage proposals contradicted her claim. The relationship between the parties was cordial and also consensual in nature. A mere break up of a relationship between a consenting couple cannot result in initiation of criminal proceedings.

the Supreme Court addressed inconsistencies in organ transplantation laws, directing states/UTs to adopt the 2011 amendments and 2014 Rules to the 1994 Act for uniformity. It mandated establishment of SOTTO in states like Meghalaya and Nagaland, and emphasized linking brain-stem death certification with death certificates to boost donations. The Court held that NOTTO must develop national policies for swap transplantation, live donor welfare, and uniform allocation criteria.

Rajeswari & Ors. Versus Shanmugam & Anr.: 2025 INSC 1329 -----------------------------------------------Ratio Decidendi The Court reiterated that the registration of sale deed is mandated because it transfers the title and interest in the property, and no registration is required for assignment deed assigning the specific performance decree because it doesn't transfer the title but only grants a right to seek enforcement of the agreement to sell. Final Outcome The Supreme Court dismissed the appeal filed by the legal heirs of the judgmentdebtor. It upheld the judgment of the High Court, which had set aside the Executing Court's order. The Hon‘ble Court conclusively held that: 1. A decree for specific performance of a contract for the sale of immovable property does not, by itself, create any right, title, or interest in the immovable property. 2. Consequently, a deed assigning such a decree does not purport or operate to assign any right, title, or interest in immovable property. 3. Therefore, an assignment deed of a specific performance decree does not require compulsory registration under Section 17(1)(e) of the Registration Act, 1908.The assignment deed was valid and enforceable, and the assignee was entitled to execute the decree.

Mohammad Hanif Mohammad Ibrahim Patel & Ors. Versus Pallaviben Rajendra Kumar Patel & Ors: 2025 INSC 1347-----------------------------------------------------------------------Key Rulings Interim Relief Post-Dismissal: The Court held it is legally incorrect to assume that once a suit is dismissed, no interim relief can be granted during a pending appeal. Co-extensive Powers: An appeal is considered a continuation of the original suit. Therefore, the appellate court's powers are co-extensive with the trial court's, including the discretion to protect a party's rights. Misuse of Order XLI Rule 5: The Supreme Court noted that lower courts wrongly relied on Order XLI Rule 5 of the CPC. This rule applies only to staying the execution of a decree, which is not applicable when a suit has been dismissed (as there is no decree to execute). Discretionary Factors: Appellate courts must independently assess the request for interim protection based on a prima facie case, irreparable injury, and the balance of convenience.

Raj Kumar @ Bheema v. State of NCT of Delhi: 2025 INSC 1322-------------------------------------------------The Supreme Court of India acquitted the appellant of murder charges, reversing a conviction that had been upheld by the Delhi High Court. Key Facts & Prosecution Case • The Incident: In November 2008, a house robbery occurred in Sukhdev Vihar, Delhi. The intruders killed Madan Mohan Gulati and severely injured his wife, Smt. Indra Prabha Gulati (PW-18). • Conviction: The trial court acquitted all co-accused but convicted Raj Kumar @ Bheema under Section 302 of the IPC (now Section 103 of BNS), primarily based on the injured wife's identification and the recovery of a "chheni" (iron tool) and blood-stained pants. Supreme Court's Findings & Reasoning The bench of Justices Vikram Nath and Sandeep Mehta set aside the conviction for the following reasons: • • Unreliable Eyewitness Testimony: The sole eyewitness identification occurred eight and a half years after the incident via video conferencing. The Court noted she was elderly (approx. 73 years old), infirm, and had weak eyesight, making the delayed identification unsafe to rely upon. • Flawed Test Identification Parade (TIP): The Court observed that the accused’s photographs were shown to the witness before the TIP, compromising the procedure's sanctity. They further ruled that no adverse inference could be drawn from the accused's refusal to participate in a compromised parade. • Forensic & Recovery Gaps: While human blood was found on the recovered pants, the serology report was inconclusive as the blood group did not match the victims. Additionally, the "chheni" was recovered from an open area accessible to the public, weakening its evidentiary value. Procedural Directions for Video Conferencing The judgment established a significant procedural safeguard: for witnesses examined virtually, any prior statements must be electronically transmitted to them to ensure fair cross-examination and compliance with Sections 147–148 of the Bharatiya Sakshya Adhiniyam (corresponding to Sections 144–145 of the Evidence Act)

Sanjay Tiwari Vs. Yugal Kishore Prasad Sao & Ors: 2025 INSC 1310----------------------------------------------Whether a defendant, after being impleaded in a suit, can file a counter-claim not against the plaintiff, but against a codefendant?-HELD The Supreme Court of India clarified the procedural limits of filing counter-claims under the Code of Civil Procedure (CPC), 1908. Key Ruling The Court held that under Order VIII Rule 6A of the CPC, a counter-claim must be directed solely against the plaintiff and is not maintainable against a co-defendant. Case Summary • Background: The appellant (plaintiff) filed a suit for specific performance against the first defendant regarding an oral agreement to sell land. Two other individuals (Defendants 2 and 3) were later impleaded and attempted to file a counter-claim for specific performance and partition against their co-defendant (Defendant 1). • Lower Court Decisions: Both the Trial Court and High Court allowed the counter-claim to proceed, citing the need to avoid multiplicity of litigation. • Supreme Court Findings: The bench of Justices K. Vinod Chandran and N. V. Anjaria set aside these orders, ruling that: o A counter-claim is a statutory right that does not extend to disputes purely between co-defendants. o Procedural convenience (avoiding multiplicity) cannot override the clear statutory language of Order VIII Rule 6A. o The impleadment of Defendants 2 and 3 was upheld to prevent non-joinder issues, but their counter-claim was rejected. Legal Implication This judgment reinforces that while a defendant may include a claim against a plaintiff (with or without a co-defendant), they cannot use a counter-claim to litigate independent grievances against another defendant within the same suit.

Mitc Rolling Mills Private Limited And Anr. Versus M/S. Renuka Realtors And Ors.: 2025 INSC 1300 ------------------------------------------------------------Hon‘ble Supreme Court held that an order rejecting a plaint under Order VII, Rule 11 CPC decides the lis finally. Under Section 2(2) of the CPC, ―decree‖ includes ―the rejection of a plaint. Hon‘ble Supreme Court examined Section 13(1A)- the main provision allows appeals from a ―judgment or order‖ of a Commercial Court. The proviso to Section 13(1A) restricts appeals only in respect of those interlocutory orders that are specifically enumerated in Order XLIII CPC (and certain arbitration orders). The Court held that the proviso must be read harmoniously with the main provision. The main provision gives a broad right; the proviso is a narrower exception.

Nandkumar @ NanduManilalMudaliar v. State of Gujarat: 2025 INSC 1302 ---------------------------------------Key Details of the Case • Bench: Justice K. Vinod Chandran and Justice N.V. Anjaria. • The Incident: The case originated from a 1998 neighborhood dispute in Ahmedabad where the appellant stabbed the victim, Louis Williams, following a sudden quarrel. The victim died 13 days later due to septicemia (infection). • The Ruling: The Court set aside the murder conviction under Section 302 IPC and converted it to Section 304 Part I IPC (Culpable homicide not amounting to murder). Legal Principles Established 1. Intention vs. Knowledge: The Court held that while the appellant had the knowledge that his actions could cause death, there was no premeditated intention to kill. 2. Sudden Quarrel: The assault was found to be a result of impulse, anger, and self-provocation rather than a planned attempt on the victim's life. 3. Delayed Death: The fact that death was not instantaneous and was caused by subsequent medical complications (sepsis) served as an indicator that the specific objective was not necessarily to cause death. Outcome The appellant’s sentence was modified to the 14 years already served in jail, which the Court deemed sufficient for the reclassified offence

Sadiq B. Hanchinmani v. State of Karnataka: 2025 INSC 1282 ----------------------------------------------The Supreme Court of India delivered a reportable judgment on November 4, 2025, clarifying the powers of a Magistrate under Section 156(3) of the Code of Criminal Procedure (CrPC). Case Summary The Court set aside two orders from the Karnataka High Court that had quashed a Judicial Magistrate's direction to register an FIR and conduct a police investigation. The bench, consisting of Justice Ahsanuddin Amanullah and Justice Pankaj Mithal, ruled that when a private complaint prima facie discloses a cognizable offence, a Magistrate is justified in ordering an investigation. Key Highlights • Facts of the Dispute: The appellant alleged that the accused forged a Rent/Lease Agreement using a fake e-stamp paper to circumvent a High Court status quo order in a property dispute. • Substance Over Semantics: The High Court had quashed the FIR partly because the Magistrate used the phrase "further investigation" in the referral order. The Supreme Court rejected this "unduly semantic reading," holding that the Magistrate’s intent was clearly a pre-cognizance referral for a fresh investigation.

Jyoti Praveen Khandpasole v. Union of India, (SC) : (Writ Petition (Civil) No. 989/2025----------------------------A Bench of Hon'ble Mrs. Justice B.V. Nagarathna and Hon'ble Mr. Justice R. Mahadevan addressed systemic delays in victim compensation, noting that trial courts often fail to issue necessary compensation orders during judgments. • Mandatory Directions: The Court directed all Special and Sessions Courts to explicitly order victim compensation in appropriate cases, emphasizing it as a crucial restorative and rehabilitative measure. • Legal Framework: These directives are anchored in Section 357A of the Code of Criminal Procedure (CrPC) (or Section 396 of the Bharatiya Nagarik Suraksha Sanhita (BNSS)) and the POCSO Act and Rules. Case Background & Implementation • Case Catalyst: The petition arose from the tragic death of an intellectually disabled rape survivor who waited years for compensation. • Implementation Chain: The Court ordered the registry to circulate this ruling to all High Courts, Principal District Judges, and State Judicial Academies to ensure swift, proactive compensation by State Legal Services Authorities (SLSA)