Criminal revisions do not abate on the death of the revisionist when filed by an informant/complainant (unlike cases involving accused death, where trial abates). There is no provision for automatic abatement in revisions, and the court must exercise discretion to proceed on merits

K.P. Kirankumar @ Kiran v. State by Peenya Police: 2025 INSC 1473-------------------------------------------------------and High Court convicted the appellants, and the appeal was filed before the Supreme Court. Core Legal Principles The judgment established crucial, victim-centric guidelines for handling trafficking cases: • Victim Testimony: Minor victims of sex trafficking are recognized as "injured witnesses," allowing their testimony alone to support a conviction without needing independent corroboration. • Sensitive Evaluation: Courts are directed to evaluate evidence with sensitivity, recognizing the trauma of victims, rather than rejecting testimony over minor inconsistencies. • Age Proof: School records are reaffirmed as the primary, conclusive evidence of age, taking precedence over medical or ossification tests. • Procedural Fairness: Minor, non-prejudicial irregularities in procedures, such as those under ITPA section 15(2), do not automatically invalidate the case. Case Background Following a 2010 police raid in Bengaluru, a minor girl was rescued, leading to charges against the accused under the IPC and ITPA. After the trial court convicted the accused in 2013 and the Karnataka High Court upheld the decision in early 2025, the Supreme Court confirmed the conviction, concluding the legal process.

Bharat Mittal v. State of Rajasthan: 2025 INSC 1459---------------------------------------------------------Key Takeaways • The Issue: The central question was whether the term "drawer" in Section 148 is limited to the company itself or includes directors who are held vicariously liable under Section 141 for the dishonour of a cheque. • Court's Reasoning: The Court favoured a "purposive construction" of the statute. It noted that the 2018 Amendment aimed to prevent dilatory tactics by appellants and ensure restitution for complainants. Restricting the deposit requirement only to the company (which might be in liquidation) would create an "illogical gap" allowing convicted individuals to avoid accountability. • Ruling on Mandatory Deposit: The Court held that Section 148 is generally mandatory. Appellate courts can direct a convicted director to deposit at least 20% of the compensation even if the company is not before the court (e.g., due to liquidation). • Limited Discretion: While mandatory, appellate courts retain a narrow discretion to grant exemptions in "exceptional circumstances," but these reasons must be explicitly recorded. • Reference to Larger Bench: Due to conflicting interpretations in earlier jurisprudence (notably whether a director strictly fits the technical definition of "drawer"), the Supreme Court referred this specific legal question to a Larger Bench for a final, authoritative determination.

K. S. Dinachandran Versus Shyla Joseph & Ors. : 2025 INSC 1451-------------------------------------------------Key Rulings & Legal Principles • Curing Omissions in Testimony: The Court ruled that material omissions made during the examination-in-chief (initial questioning) can be cured during cross-examination. • Probative Value of Leading Questions: The Court held that answers elicited through leading questions in cross-examination do not lose their "probative value" just because of the nature of the question. If a witness affirms a positive suggestion during cross-examination, that evidence is valid for proving a document like a Will. • Testator’s Wish is Supreme: The Court emphasized that the "wish of the testator assumes pre-eminence". It stated that courts should not substitute their own views of "equity" for the clear intentions expressed by the person making the Will. • Standard of Proof: The Court noted that the standard of proof for a Will that merely excludes one legal heir (in this case, a daughter who married outside the community) is less stringent than for a Will that divests all legal heirs.

Shaik Shabuddin v. State of Telangana: 2025 INSC 1449----------------------------------------------------------Key Rulings • Section 27 Evidence Act (Recoveries): The Court held that items found on the body of an accused at the time of arrest or voluntarily handed over during a police check cannot be treated as valid "recoveries" under Section 27 of the Evidence Act. For this section to apply, the discovery must lead to hidden or concealed objects based on information provided by the accused. • SC/ST Act & Mens Rea: The Court set aside convictions under the SC/ST (Prevention of Atrocities) Act, ruling that mere proof of the victim’s caste is insufficient. The prosecution must establish that the accused had actual knowledge of the victim's caste and committed the offence based on that knowledge. • Modification of Sentence: While upholding the convictions for rape (Section 376D IPC) and murder (Section 302 IPC) based on circumstantial evidence like DNA and bloodstains, the Court modified the sentence from life imprisonment for the remainder of natural life to a fixed term of 25 years without remission. • Legal Aid Direction: Noticing that two other co-accused had not filed appeals, the Supreme Court directed the Telangana Legal Services Authority to provide them with legal assistance to approach the Court.

Moideenkutty Versus Abraham George: 2025 INSC 1428---------------------------------------------------------Hon’ble Supreme Court held and observed that non-disclosure of material encumbrances on a property by a seller amounts to fraudulent concealment, justifying the plaintiff’s right to rescind the contract or recover the advance. When a seller conceals a bank encumbrance that materially affects title/possession, the buyer is not at fault for not insisting upon original deeds in advance because the duty lies with the seller to disclose such encumbrances.

Danesh Singh & Ors. Versus Har Pyari (Dead) Thr. Lrs. & Ors.: 2025 INSC 1434--------------------------------------------------------Key Rulings • Expansion of Lis Pendens: The Court held that the doctrine under Section 52 of the Transfer of Property Act, 1882 applies not only to property title suits but also to money recovery suits where the debt is secured by a mortgage. • Ex Parte Proceedings: The bar on property transfer during litigation operates even if the proceedings are ex parte (in the absence of one party). • Bar on Separate Suits: A separate civil suit challenging a confirmed auction sale is barred under Order XXI Rule 92(3) of the CPC; the appropriate remedy for third parties or transferees lies under Section 47 of the CPC. • Rights of Pendente Lite Purchasers: Individuals who purchase mortgaged property during the pendency of a suit are considered "representatives" of the judgment debtor and are bound by the eventual decree and execution.

Jothi @ Nagajothi v. State: 2025 INSC1417--------------------------------------------------------------- Key Findings & Legal Principles • Procedural Lapses Not Always Fatal: The Court ruled that minor procedural irregularities, such as sampling at the site of seizure rather than before a Magistrate (as per Section 52-A), do not automatically invalidate a case if the chain of custody remains intact and the evidence is reliable. • Independent Witnesses: The absence of independent witnesses during the search and seizure is not a ground to discard prosecution evidence if the testimony of official witnesses is consistent and inspires confidence. • Mandatory Minimum Sentence: The Court clarified that it has no discretion to reduce a sentence below the statutory minimum (10 years for commercial quantities) based on humanitarian grounds like the appellant's age or family responsibilities. • Remission: While the Court cannot reduce the sentence, the appellant was granted liberty to seek executive remission through appropriate authorities.

The State of West Bengal v.Anil Kumar Dey: 2025 INSC 1413----------------------------------------------------- The Supreme Court held that Section 102 CrPC (investigative seizure) and Section 18A PC Act (judicial attachment) are distinct powers, neither mutually exclusive nor inconsistent. The Court reasoned that Section 102 CrPC allows police to freeze property as part of investigation, while Section 18A PC Act governs later judicial attachment and confiscation. The Court distinguished between passing observations and binding ratio in earlier judgments, holding that Ratan Babulal Lath did not lay down a binding principle against using Section 102 CrPC in PC Act cases. The Supreme Court allowed the State's appeal, upheld the freezing order, the Court clarified that investigative authorities (the police) are duly authorized to seize or freeze bank accounts when proceedings are initiated under the corruption act.

Suresh Sahu v. State of Bihar (Now Jharkhand): 2025 INSC 1382----------------------------------------------Key Rulings & Legal Principles The judgment, delivered by a Bench of Justice Vikram Nath and Justice Sandeep Mehta, emphasized three critical aspects of criminal trial fairness: • Defective Examination Under Section 313 CrPC: The Court ruled that the trial court failed to put specific incriminating circumstances to the accused. Such mechanical questioning violates a substantive right of the accused and can vitiate the entire trial. • Unreliable Oral Dying Declaration: The prosecution's claim of an oral dying declaration was rejected. Medical evidence showed the deceased had suffered grave cranial injuries, making it impossible for him to have spoken. • Evidentiary Value of Defence Witnesses: The Court reiterated that testimony from defence witnesses carries the same evidentiary weight as that of prosecution witnesses. In this case, defence witnesses (originally named by the prosecution but not examined by them) provided testimony that undermined the prosecution's version. • Suppression of First Information: The Court noted that the initial Fardbeyan (recorded immediately after the incident) did not name the accused, and a subsequent report with embellishments was used instead. The non-examination of the Investigating Officer who recorded these reports was deemed fatal to the prosecution's case.

Neeraj Kumar @ Neeraj Yadav v. State of U.P.: 2025 INSC 1386 ------------------------------------------------- Key Rulings & Principles • Imminence of Death Not Required: The Court ruled that for a statement to be a valid "dying declaration" under Section 32(1) of the Evidence Act, the maker does not need to be under the immediate expectation or "shadow of death" at the time of recording. • Section 161 Statements as Evidence: Statements recorded by the police under Section 161 CrPC can be treated as dying declarations once the declarant dies, provided they relate to the cause or circumstances of death. • No "Mini-Trial" at Summoning Stage: The Court emphasized that under Section 319 CrPC, judges should not conduct a "mini-trial" by meticulously weighing evidence or testing witness credibility. The standard is whether a prima facie case exists that is stronger than mere probability but lower than what is required for conviction. • Procedural Formalities: The absence of a Magistrate or a doctor’s fitness certification does not automatically render a dying declaration inadmissible; these factors only go to the weight of the evidence during the final trial.