Annamalai vs Vasanthi and Others: 2025 INSC 1267--------------------------------------------------------Ratio Decidendi When the vendor wrongfully repudiates the contract or waives the right to terminate by conduct, the buyer can directly sue for specific performance.Separate declaratory relief is unnecessary in such cases. Hon‘ble Supreme Court analyzed the discretionary power of the court under Section 20 of the Specific Relief Act, 1963. Hon‘ble Court held that in a suit for specific performance, the ultimate relief includes the right to possession, so a bona fide but unproven claim of existing possession is not a sufficient reason to deny the relief, especially when the plaintiff had paid over 90% of the total consideration and the conduct of the defendants was found to be fraudulent.

Novenco Building And Industry A/S Versus Xero Energy Engineering Solutions Private Ltd. & Anr:2025 INSC 1256--------------------------------------------------------------Whether a commercial suit seeking injunction for patent infringement can bypass mandatory pre-institution mediation under Section 12-A by merely claiming “urgent interim relief.”?-HELD the Supreme Court of India ruled that ongoing intellectual property (IP) infringement inherently creates "urgent interim relief," allowing plaintiffs to bypass mandatory pre-institution mediation under Section 12A of the Commercial Courts Act, 2015. Core Legal Principle The Court established that in cases of continuing IP infringement, urgency is "inherent in the nature of the wrong". • Standpoint of the Plaintiff: Urgency must be assessed holistically from the plaintiff’s perspective based on the plaint and annexed documents. • Delay is Not Fatal: Mere delay between the discovery of infringement and the filing of the suit does not negate urgency if the violation is persistent. • Public Interest: IP disputes involve a public interest dimension (preventing consumer deception and market confusion), which reinforces the need for immediate judicial intervention. Case Background & Procedural History • Parties: The appellant, Novenco, a Danish manufacturer of industrial fans, alleged that its former distributor, Xero Energy, was infringing its patents and registered designs by selling identical products. • High Court Ruling: The Himachal Pradesh High Court (Single Judge and Division Bench) had rejected Novenco's plaint, holding that a six-month delay after an expert inspection showed a lack of urgency, making pre-institution mediation mandatory. • Supreme Court Intervention: Earlier in the proceedings (February 2025), the Supreme Court directed the parties to attempt mediation while the legal question remained pending; that mediation ultimately failed on June 23, 2025. Key Findings & Outcome 1. Overruling High Court: The Supreme Court set aside the High Court judgments, noting they erred by evaluating the merits of the interim relief rather than merely checking if the plea for urgency was plausible. 2. Restoration of Suit: Commercial Suit No. 13 of 2024 was restored to the High Court of Himachal Pradesh to be decided on its merits. 3. Section 12A Exception: Rigidly insisting on mediation during ongoing infringement would allow infringers to profit from procedural formalities, rendering the plaintiff remediless—an outcome the Act did not intend

Karam Singh vs Amarjit Singh & Ors.:2025 INSC 1238- --------------------------------------------------the Supreme Court of India clarified critical procedural standards regarding the rejection of a plaint under Order VII Rule 11 of the CPC. Key Rulings & Principles ------------------Sole Reliance on Plaint Averments: The Court reaffirmed that while deciding an application for rejection of a plaint, a court must look only at the averments in the plaint. The defendant’s defense or any documents they produce cannot be considered at this threshold stage. Limitation as a Mixed Question: The Bench, comprising Justice J.B. Pardiwala and Justice Manoj Misra, held that the question of whether a suit is barred by limitation is often a mixed question of law and fact. A plaint can only be rejected if it is ex facie (on its face) barred by law based on its own statements. ------------------Multiple Reliefs: The Court noted that if even one of the reliefs sought in the plaint is within the limitation period, the entire plaint cannot be rejected. Adverse Possession: Claims regarding whether defendants perfected their title through adverse possession require evidence and cannot be decided at the Order VII Rule 11 stage. ----------------- Case Context The dispute involved a century-long property battle originating from 1924. The appellants filed a suit in 2019 seeking declaration of ownership and possession after mutation proceedings concluded in 2017. The High Court of Punjab and Haryana had previously rejected the plaint as time-barred, but the Supreme Court set aside that order and restored the suit for trial.

Komal Prasad Shakya v. Rajendra Singh: 2025 INSC1230 --------------------------------- The Supreme Court held that criminal proceedings could not be quashed at the threshold when the complaint disclosed specific, prima facie allegations of cheating, forgery, and conspiracy under Sections 420, 467, 468, 471, and 120B IPC. The Court criticized the High Court’s ―mini-trial‖ approach and restored the criminal case, clarifying that the trial must proceed uninfluenced by prior judicial findings, and the outcome should be based on evidence to be adduced.

Shivkumar @ Baleshwar Yadav v.The State Of Chhattisgarh: 2025 INSC 1231 --------------------------------The Supreme Court upheld the concurrent findings of both the lower courts, affirming the life sentence. The Court emphasized that the victim’s consistent and credible testimony, corroborated by medical evidence, sufficed for conviction. It clarified that mere knowledge of the victim's SC/ST status is enough for Section 3(2)(v) liability. The Court also criticized the practice of casually declaring witnesses hostile due to minor inconsistencies, instructing that cross-examination of one's own witness should be permitted only in cases of material deviation, not for insignificant omissions.

Rahul Agarwal v. State of West Bengal: 2025 INSC 1223----------------------------------the Supreme Court of India delivered a significant ruling on the constitutional validity of compelled voice samples. The Court held that a Judicial Magistrate has the authority to direct any person—whether an accused or a witness—to provide a voice sample during a criminal investigation. Key Highlights of the Judgment • Magistrate's Authority: The Court reaffirmed the principle from Ritesh Sinha v. State of Uttar Pradesh (2019), stating that even without explicit provisions in the old Code of Criminal Procedure (CrPC), Magistrates have the power to order voice samples. • Article 20(3) Compliance: The Bench ruled that a voice sample is material/physical evidence (similar to fingerprints or DNA) rather than "testimonial evidence". Therefore, compelling a person to provide it does not violate the fundamental right against self-incrimination. • Legislative Recognition: The Court noted that this power is now explicitly codified under Section 349 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023. • High Court Reversal: The Supreme Court criticized the Calcutta High Court for setting aside the Magistrate's order based on a pending larger bench reference, noting that binding precedents must be followed until formally overturned.

G. Prasad Raghavan v. Union Territory of Puducherry:2025 INSC 1221: -----------------------------------The Supreme Court held that a person who was a minor at the time of the alleged offence could not be held criminally liable for acts committed during minority, especially when there was no material indicating his participation or mens rea in the purported offence. It was observed that the concerned trial court as well as the High Court have committed an error while dismissing the discharge application filed by the present appellant. The Court noted that the essential ingredients of cheating, inducement, and conspiracy under the IPC were not satisfied as far as petitioner was concerned. Consequently, the charges against him were quashed, with an explicit direction that continuation of proceedings would be an abuse of the process of law, as there was no prima facie case against the appellant.

Sankar Padam Thapa v. Vijaykumar Dineshchandra Agarwal: 2025 INSC1210 ----------------------------------The Supreme Court held that a trust is not a legal person or juridical entity like a company, and legal proceedings for dishonor of a cheque may be validly maintained against individual trustees responsible for the issuance, without impleading the trust as a separate party. The judgment clarified that trustees who sign a cheque on behalf of a trust are personally liable under sections 138/141 of the NI Act. No specific averment is needed regarding their conduct of the trust’s day-to-day affairs—the act of signing suffices for liability. This landmark decision resolved prior legal ambiguities and affirmed that complainants are not barred by technical non-joinder of the trust, thereby strengthening accountability for trust transactions involving negotiable instruments.

M/S Anvita Auto Tech Work Pvt. Ltd. Vs. M/S Aroush Motors &Anr.:2025 INSC 1202- -------------------------SC delivered a landmark judgment on October 08, 2025, emphasizing that procedural rigidity should not sacrifice substantial justice. Key Rulings Right to Cross-Examination: The Court held that a defendant's right to cross-examine the plaintiff's witnesses is not forfeited even if they fail to file a Written Statement (WS). Denying this right was termed "absolutely perverse". COVID-19 Limitation Extension: The Bench ruled that the 120-day mandatory period for filing a WS in commercial suits must exclude the period from March 15, 2020, to February 28, 2022, as per the Court’s Suo Motu COVID-19 orders. Procedural Law Philosophy: Reaffirming Justice V.R. Krishna Iyer’s principle, the Court stated that procedural law is the "handmaid of justice and not its mistress". Case Summary & Outcome Dispute: The case arose from a commercial suit for recovery of monies (approx. ₹1.78 Crore) after the ban on BS-IV vehicles stalled a motorcycle dealership business. Trial Court Error: The lower court had rejected the defendant's WS for being late and subsequently marked their cross-examination as "Nil" solely because no WS was on record. Final Directions: The Supreme Court set aside the High Court's order and the Trial Court’s decree. It remanded the matter to the Trial Court with directions to: 1. Take the defendant's Written Statement on record, subject to a cost of ₹1,00,000. 2. Allow the defendant to cross-examine the plaintiff's witnesses. 3. Dispose of the suit expeditiously, preferably within six months

Lifestyle Equities C.V. & Anr. Versus Amazon Technologies Inc.: 2025 INSC 1190--------------- The Supreme Court of India established significant guidelines regarding the stay of money decrees under the Code of Civil Procedure (CPC). The Court clarified that appellate courts possess the discretionary power to grant an unconditional stay on money decrees in "exceptional cases," affirming that the requirement to deposit the decretal amount is directory, not mandatory.

K. S. Shivappa vs Smt. K. Neelamma: 2025 INSC 1195-------------------- Ratio Decidendi: A transfer made by a natural guardian in violation of Section 8(2) of Hindu Minority and Guardianship Act, 1956is voidable at the option of the minor (under Section 8(3)), not void ab initio. The minor, on attaining majority, need not necessarily file a suit to repudiate that voidable transaction; unequivocal conduct may suffice to show repudiation, provided it is done within the prescribed time (limitation). The limitation period for such a suit or for repudiation begins from the date of majority (i.e. when the minor becomes an adult) under Article 60 of the Limitation Act.

Dharmrao Sharanappa Shabadi & Others vs. Syeda Arifa Parveen: 2025 INSC 1187- -------------------- Case Summary---------- The dispute centered on 24 acres and 28 guntas of agricultural land in Gulbarga. The plaintiff (Syeda Arifa Parveen) claimed absolute ownership through an oral gift (Hiba) allegedly made by her mother in 1988 and through inheritance as the sole legal heir. The defendants, who were third-party purchasers, argued they were bona fide purchasers who had acquired the land via registered sale deeds in 1995. ---------------Key Findings of the Supreme Court Invalid Oral Gift (Hiba): The Court ruled that the alleged oral gift was not proved in law. It emphasized that under Muslim law, a valid Hiba requires clear evidence of delivery of possession, which was entirely missing in this case. ----------------Barred by Limitation: The plaintiff filed her suit in 2013 to challenge sale deeds from 1995. The Court held the suit was clearly barred by limitation, as it was initiated nearly 18 years after the registered transactions. ----------------Lack of Evidence on Relationship: The Court found that the plaintiff failed to provide objective proof of her familial relationship (status as the sole daughter) to the original owner. Revenue Records: The Court noted the absence of mutation in the plaintiff’s name. For over 25 years, the Record of Rights (ROR) consistently reflected the names of the defendants or their predecessors, contradicting the plaintiff’s claims. ------------------Legal Principles Reaffirmed Section 50 of the Evidence Act: The Court clarified that general reputation alone is not enough to prove a relationship; it must be backed by specific conduct that witnesses personally observed. Judicial Sympathy vs. Legal Proof: The judgment underscored that "judicial sympathy cannot substitute legal proof" and that the law aids the vigilant, not those who "slumber on their rights"

Nazim & Others. v. The State of Uttarakhand: Criminal Appeal No. 715 of 2018----------------------------The Supreme Court acquitted three appellants who had been convicted for the 2007 murder of a 10-year-old boy. Case Summary The case against Nazim, Aftab, and Arman Ali was based entirely on circumstantial evidence. While the Trial Court and the Uttarakhand High Court had upheld their life sentences, the Supreme Court set aside these judgments after identifying significant gaps in the prosecution's chain of evidence. Key Findings for Acquittal • Omissions in FIR: The appellants, Nazim and Aftab, were not named in the initial FIR, even though they were known to the complainant. This omission cast serious doubt on their later implication. • Unreliable Witness Testimony: o Conspiracy: A witness (PW-2) claimed to have overheard the murder plot at a wedding feast. The Court found this testimony improbable, noting that conspiracies are rarely discussed openly and that the witness had stayed silent for days after the incident. o Last-Seen Evidence: The time gap between the alleged sightings and the recovery of the body was too wide to exclude other possibilities. • Lack of Identification: Key witnesses identified the accused for the first time in court. The Court ruled this dock identification unreliable as no Test Identification Parade (TIP) had been conducted. • Neutral Forensic Evidence: Scientific reports on DNA and fingerprints were inconclusive and failed to link the appellants to the crime scene or the weapon. • Motive: The alleged motive of revenge for an insult to a relative was deemed speculative and unproven. Legal Principles Reaffirmed The judgment, authored by Justice Satish Chandra Sharma, reinforced the "Panchsheel" principles of circumstantial evidence established in Sharad Birdhichand Sarda v. State of Maharashtra, emphasizing that suspicion, however strong, cannot take the place of proof

Ram Sagar v. Central Bureau of Investigation--------------- Case Summary & Key Legal Issues The case involves Ram Sagar, the former Director of the Aryabhatta Research Institute of Observational Sciences (ARIES), who was charged by the CBI with criminal conspiracy, cheating, and corruption related to illegal appointments and contract escalations. Sanction under Section 197 CrPC: The primary legal dispute was whether the CBI required prior government sanction to prosecute him for Indian Penal Code (IPC) offences (like Sections 420 and 120B). Supreme Court Ruling (2025): A Division Bench of the Supreme Court (Justices J.B. Pardiwala and Sandeep Mehta) held that while the trial should proceed, the petitioner can raise the "want of sanction" plea before the trial court as the case progresses. The court noted that whether an act was done in "discharge of official duty" (requiring sanction) depends on the evidence presented during the trial. Trial Court Autonomy: The Supreme Court declined to interfere with the Uttarakhand High Court's earlier rejection of the revision petitions, instead directing the trial court to decide the sanction issue based on the evidence.

HLV Limited v. PBSAMP Projects Pvt. Ltd.: 2025 INSC 1148---------------------------------------------------The Supreme Court held that when an arbitral award expressly stipulates a composite rate of interest, the awardholder cannot claim any further or compound interest. The power of the arbitral tribunal to grant pre-award interest under Section 31(7)(a) is subject to the parties’ agreement, while Section 31(7)(b) mandates interest at 18% per annum post-award only ―unless otherwise directed‖ by the tribunal. Since the arbitral award in this case specifically awarded simple interest at 21% per annum until payment, it must be treated as a complete and self-contained direction on interest. Grant of compound interest requires an express stipulation, which was absent here. The executing court’s acceptance of full payment, including interest, was therefore correct, and the High Court’s remand was set aside

Kailas v. State Of Maharashtra: 2025 INSC 1117------------ The appellant was convicted under the NDPS Act for possession of 39 kg ganja, mainly based on video evidence of the raid. The High Court set aside the conviction but ordered a re-trial, which the Supreme Court found unjustified. The Supreme Court ruled that a re-trial merely to cure procedural lapses, especially regarding electronic evidence, is impermissible. Instead, it restored the appeal for a merit-based decision by the High Court. This judgment clarified that trials should not be repeated unless substantive injustice has occurred.

Chakardhari Sureka v. Prem Lata Sureka: 2025 LiveLaw (SC) 919----------------------------------------------The Supreme Court held that the pendency of a Section 37 appeal does not, by itself, operate as a stay against the execution of an arbitral award. The Court emphasized that execution can only be halted if a competent court has passed an explicit interim order staying enforcement of the award. In the absence of such an order, the award-holder retains the statutory right to proceed with execution. The execution court, however, may consider any specific objections raised to the executability of the award but cannot defer consideration merely because an appeal is pending. Thus, the award remains enforceable unless an express stay is granted, reaffirming the legislative intent to ensure finality and expedition in arbitration.

Shanti Devi (Since Deceased) Through LRs. Goran v. Jagan Devi & Ors. [2025 INSC 1105] Factual Summary The Dispute: The case involved agricultural land in Gurgaon, Haryana. The plaintiff (Rasali) claimed her one-third share was transferred via a fraudulent 1973 sale deed that she never signed and for which she received no payment. Suit Timeline: The suit was filed in 1984, approximately 11 years after the disputed deed. Court Findings: Evidence showed the plaintiff's thumb impression was forged and no sale consideration was paid, rendering the deed void. Supreme Court Decision: Justice J.B. Pardiwala and Justice R. Mahadevan held that since the deed was void, the plaintiff could recover possession within the 12-year period prescribed by Article 65 of the Limitation Act. Significance This ruling strengthens the rights of original property owners by ensuring they are not barred by a short three-year window when their title is attacked by a completely fraudulent or void transaction. It confirms that an owner can reclaim their property as long as they act within 12 years of the possession becoming adverse

Shivamma (Dead) By Lrs. Vs Karnataka Housing Board (Khb): 2025 INSC 1104------- Ratio Decidendi: Hon‘ble Supreme Court‘s held as under: Interpretation of Section 5 Limitation Act: The Court held that for condoning delay under Section 5, the applicant must explain the entire period from when the limitation period begins to the date of actual filing of the appeal. It is not enough to explain only the period after expiry of limitation; delays before that must also be accounted for. ―Sufficient Cause‖ standard: The cause for delay must be bona fide and must cover the full period. Mere administrative laxity, bureaucratic inefficiency or negligence doesn‘t by itself suffice. The State or government instrumentality is not to be given a special or liberal dispensation just because it is a State body.

Mamman Khan v. State of Haryana: 2025 INSC 1113---------- Key Ruling & Principles No Preferential Segregation: The Court held that an MLA's status alone does not justify a deviation from the rule of joint trials under Section 223 of the CrPC. Equality Before Law: Preferential segregation based solely on political status violates the principle of equality enshrined in Article 14 of the Constitution. Fairness vs. Speed: While the Court acknowledged the need for the expeditious disposal of cases involving MPs/MLAs, it clarified that this "right to speedy trial" cannot be secured at the cost of the fairness and procedural safeguards guaranteed under the law. Same Transaction Rule: Under Section 223 CrPC, when offences arise out of the "same transaction" and are based on common evidence, they should generally be tried together. Case Context Parties: Mamman Khan (a sitting MLA from Haryana) versus the State of Haryana. Origin: The case arose from FIRs related to the 2023 Nuh communal violence. Procedural History: The Trial Court had ordered a separate chargesheet and trial for Khan to avoid delays caused by other co-accused, a decision previously upheld by the Punjab and Haryana High Court. Final Order: A bench of Justices J.B. Pardiwala and R. Mahadevan set aside the segregation orders and remitted the case to the trial court for a joint trial with the co-accused.

Vandana v. State of Maharashtra2025 INSC 1098------------ Key Findings & Legal Principles The Supreme Court allowed the appeal based on four key issues: Chain of Custody: Lack of proof that document tampering occurred while under the appellant's exclusive control. Forensic Evidence: Conviction based on "apparent overwriting" without a handwriting expert's opinion was considered unsafe. Mens Rea: The prosecution did not establish the appellant's dishonest intention. Procedural Violation: The court noted issues with the "compound and omnibus questions" used in the appellant's Section 313 CrPC statement. Final Verdict The Supreme Court allowed the appeal and acquitted the appellant of all charges

Mohammad Afzal Mohammad Sharif v. State of Maharashtra: 2025 INSC 1100-------------- Key Rulings Mandatory FIR Registration: The Court reaffirmed that under Section 154 of the CrPC (now BNSS), police are legally obligated to register an FIR upon receiving information about a cognizable offence. Dereliction of Duty: The Bench, comprising Justices Sanjay Kumar and Satish Chandra Sharma, observed a "patent dereliction of duty" by the police for failing to act despite being aware of the victim's injuries. Overturning the High Court: The Supreme Court set aside the Bombay High Court (Nagpur Bench) order, which had dismissed the appellant's petition after questioning his "bona fides" and suggesting an "ulterior motive". Establishment of an SIT: The Court directed the Maharashtra Government to constitute a Special Investigation Team (SIT) comprising senior officers from both Hindu and Muslim communities to ensure an impartial investigation. Recent Developments In November 2025, the State of Maharashtra filed a Review Petition specifically challenging the Court's direction that the SIT must be composed of officers from both Hindu and Muslim communities, arguing it impinges upon "institutional secularism". The Supreme Court has issued notice on this limited aspect of the review

Vinod Kumar Pandey v. Seesh Ram Saini: 2025 INSC 1098 ----------- Key Highlights of the Judgment: Accountability of Investigators: The Court famously remarked that "sometimes those who investigate must also be investigated". It emphasized that public servants, including high-ranking CBI officials, are not immune from criminal investigation if allegations disclose a cognizable offence. Mandatory FIR Registration: Reaffirming the principles of Section 154 CrPC, the Court held that police must register an FIR if a complaint prima facie discloses a cognizable offence. Limits of Preliminary Inquiry: The judgment clarified that a preliminary inquiry cannot be used as a "shield" to avoid FIR registration. The veracity of allegations should be tested during a full investigation, not dismissed at the inquiry stage. Arrest Guidelines: The Court ruled that for offences punishable by up to seven years' imprisonment, arrest is an exception, not a routine step. Police must provide written reasons for the necessity of an arrest, especially under the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023.

Malleeswari v. K. Suguna HELD Facts: The dispute originates from a partition suit concerning ancestral property, designated in a registered partition deed dated 22.11.1991, executed between the deceased patriarch (the ―first defendant‖) and his brother. The suit was pursued without impleading Malleeswari (the appellant), who is the daughter of the deceased first defendant and another party, Muniammal. On 25 February 2003, the trial court passed an ex-parte preliminary decree, granting partition as prayed. Following this decree; the first defendant executed a registered sale deed on 27.12.2004, transferring items 4–7 of the suit property to K. Suguna (respondent).Simultaneously, a settlement deed was executed conveying items 1–3 and 8–10 to Malleeswari. Ratio Decidendi: The Hon‘ble Supreme Court‘s reasoning likely rested on established principles: •In partition suits involving ancestral Hindu Undivided Family (HUF) property, all coparceners and heirs must be joined as parties. Their exclusion invalidates any decree affecting their rights. •An ex-parte decree obtained without impleading a rightful heir is legally unsustainable. •Consequently, post-decree property transfers—be it by sale or settlement— would be void or liable to be vacated, as the decree itself lacked authority over an unjoined, entitled heir. Outcome: Hon‘ble Supreme Court allowed the appeal of Malleeswariquashing or modifying the ex-parte preliminary decree and declaring the post-decree transactions void or unenforceable insofar as they pertain to her share.The case remanded for rehearing with all necessary parties— including Malleeswari—properly impleaded to protect her legal rights.

Sreeja D.G v. Anitha R. Nair:------------ Key Highlights of the Case: Background: The respondent, Anitha R. Nair, was an accused in 31 crimes involving offences under Sections 406 and 420 of the IPC and the Banning of Unregulated Deposit Schemes Act, 2019. The Conflict: While a Special Leave Petition (SLP) challenging her anticipatory bail was pending in the Supreme Court, the Kerala High Court entertained a fresh application and modified its own bail order to allow her to travel abroad. Supreme Court Ruling: A bench of Justices J.K. Maheshwari and Vipul M. Pancholi held that once the Supreme Court is seized of a matter, a High Court should not pass orders that could circumvent or render the pending proceedings infructuous. Outcome: The Court stayed the High Court's modification orders, directed the accused to surrender her passport immediately, and issued a show-cause notice as to why her bail should not be cancelled for suppressing material facts.

C.P. Francis Versus C.P. Joseph And Others------- Ratio Decidendi: Hon‘ble Supreme Court held that in a second appeal under Section 100 CPC, a High Court cannot raise new substantial questions of law that were not part of the pleadings/issues or argued by parties / decided in lower courts. Doing so is a violation of fair procedure. The proviso to Section 100(5) CPC allows a High Court to entertain ―any other substantial question of law‖ only if certain conditions are met, including that there must be grounding in pleadings and evidence, foundation in issues, recorded reasons for framing it, and giving a fair opportunity to the parties to address it. A legal bar (like Section 67 ISA) which depends on foundational facts cannot be invoked without those facts being tested/established in the lower proceedings. If they are not, then introducing that bar at the second appeal stage amounts to creating a new case, which is impermissible.

Phireram v. State of Uttar Pradesh: 2025 INSC1074------- Key Highlights of the Judgment Criticism of the High Court: The bench (Justices J.B. Pardiwala and Sandeep Mehta) strongly deprecated the Allahabad High Court's practice of passing "cyclostyled" orders that mechanically dismissed bail cancellation applications by simply directing complainants to the Witness Protection Scheme. Judicial vs. State Function: The Court explained that bail cancellation is a judicial and preventive function intended to protect the integrity of the trial, whereas witness protection is a remedial and curative state obligation. Grounds for Cancellation: It reiterated that liberty granted via bail is not an absolute licence. If an accused misuses this liberty—especially by intimidating witnesses—it strikes at the root of the rule of law and warrants revocation of bail. Directives: The Supreme Court set aside the High Court's order and remanded the matter for a fresh hearing, directing the High Court to consider the merits of the cancellation application based on an Investigating Officer's report regarding new threats

Shree Nagani Silk Mills Pvt. Ltd. v. L.D. Industries Ltd.: 2025 INSC 1064-------- Facts and Ratio Decidendi The Supreme Court restored criminal proceedings under Section 138 NI Act against the accused company, despite its ‘sick’ status under SICA. The cheques for discharged liability were dishonoured, and the accused sought quashing based on a BIFR restraint order. The Court held SICA does not bar prosecution for cheque dishonor and questions about the purpose of cheque issuance must be decided at trial, not preliminarily.

Oil and Natural Gas Corporation v. G & T Beckfield Drilling Services Pvt. Ltd :2025 INSC 1066-----------------The Court held that an arbitral tribunal possesses the statutory power to grant pendente lite interest (interest during the pendency of arbitration) under Section 31(7)(a) of the Arbitration and Conciliation Act, 1996, unless the contract expressly or by necessary implication bars it. Core Principles Established • Insufficiency of Generic Clauses: A general clause stating that "no interest" is payable on delayed payments or disputed claims (like Clause 18.1 in this case) does not automatically strip a tribunal of its power to award interest during the arbitration proceedings. • Specific Language Required: To effectively bar pendente lite interest, parties must use comprehensive language that explicitly excludes interest "in any respect whatsoever" or "under any circumstances". • Statutory Nature of Post-Award Interest: The Court reaffirmed that post-award interest under Section 31(7)(b) is a statutory right that parties cannot waive by contract. • Tripartite Structure of Interest: The judgment clarifies that interest can be awarded for three distinct stages: • Pre-reference: From the cause of action to the start of arbitration. • Pendente lite: From the start of arbitration to the date of the award. • Post-award: From the date of the award until the payment is made.

Ramesh Chand (Deceased) through Legal Representatives vs. Suresh Chand & Anr.: 2025 INSC 1059: The Supreme Court set aside previous rulings by the Trial Court and the Delhi High Court, dismissing the suit filed by Suresh Chand. The key findings were: Invalidity of "GPA Sales": The Court reaffirmed that documents like an Agreement to Sell (ATS), General Power of Attorney (GPA), and Receipt do not confer valid legal title to immovable property. Under Section 54 of the Transfer of Property Act, 1882, ownership of property valued at ₹100 or more can only be transferred through a registered deed of conveyance. Stricter Proof for Wills: The Court held that even a registered Will does not automatically prove title. It must be strictly proved as per Section 63 of the Indian Succession Act and Section 68 of the Evidence Act, requiring at least one attesting witness to testify in court. In this case, the Will was found suspicious as it excluded other siblings without explanation and no attesting witnesses were examined. Doctrine of Part Performance (Section 53A): The Court ruled that Suresh Chand could not claim protection under Section 53A of the Transfer of Property Act because he was not in possession of the property at the time of the dispute (having filed a suit for possession against his brother)

Sushil Kumar Tiwari v. Hare Ram Sah (2025 INSC 1061)----- Facts and Ratio Decidendi: The Supreme Court restored life imprisonment for two accused who raped a minor girl, overturning the High Court‘s acquittal based on alleged defects in charges and joint trial procedure. The Court held that procedural lapses do not vitiate a trial unless they cause real prejudice, emphasizing the importance of victim testimony and medical evidence in sexual offence cases. Substantive justice cannot yield to hyper-technicalities.

Sushil Kumar Tiwari vs. Hare Ram Sah and Others : 2025 INSC 1061---------------- the Supreme Court of India overturned a Patna High Court acquittal, reinstating the conviction and life imprisonment sentences of two men for the aggravated rape of a 12-year-old girl. Key Rulings & Legal Principles Procedural vs. Substantive Justice: The Court held that procedural lapses, such as an improper joint trial under Section 223 CrPC or defective framing of charges, do not vitiate a trial unless they result in a conclusive "failure of justice" or actual prejudice to the accused. Age Determination under POCSO: The Bench clarified that as long as the victim's age conclusively appears to be under 18, special protections under the POCSO Act cannot be diluted by insisting on a rigid determination of the exact age. Standard of "Reasonable Doubt": The Court cautioned against “loose acquittals” based on minor inconsistencies, stating that the principle of “beyond reasonable doubt” should not be misapplied to allow culprits of heinous crimes to escape. Case Summary Incident: In 2016, a minor girl was repeatedly raped by the respondents (Hare Ram Sah and Manish Tiwari), resulting in pregnancy. Trial Court: Convicted both under Section 376(2) IPC and Sections 4 & 6 of POCSO, sentencing them to rigorous life imprisonment. High Court: Acquitted them, citing minor document discrepancies regarding the victim's age and procedural errors in the trial. Supreme Court Verdict: Restored the Trial Court's judgment in its entirety, ordering the respondents to surrender within two weeks

Ratio Decidendi: The Supreme Court held that the right to appeal under the proviso to Section 372 CrPC for a victim extends to legal heirs, recognizing that access to justice should not be thwarted merely due to the victim’s death. The Court affirmed that the definition of “victim” in Section 2(wa) is inclusive of legal heirs, allowing substitution upon death and continuation of the appeal. Further, the Court observed that the High Court, as the first appellate court, is required to independently reassess the evidence and deliver a reasoned judgment, especially when overturning convictions for grave offences like murder. Since the High Court did not discuss evidence or provide reasons for acquittal, the Supreme Court set aside the judgment and remanded the matter for fresh consideration. The judgment reinforces the rights of victims' families to seek justice and mandates courts to deliver reasoned judgments in criminal appeals involving acquittals

Whether there was a binding arbitration agreement between the parties under Contract No. 061-16-12115-S dated March 11, 2016, warranting reference to arbitration under Section 45 of the Arbitration and Conciliation Act, 1996 (Act of 1996). The Supreme Court’s decision in Glencore International AG v. Shree Ganesh Metals & Anr. 2025 INSC 1036 corrects a line of reasoning that had allowed procedural rigidity to override commercial reality in the interpretation of arbitration agreements. The dispute arose from a 2016 contract for the supply of zinc metal. Although Shree Ganesh Metals did not formally sign the agreement, it accepted delivery of 2,000 metric tons, furnished Standby Letters of Credit through HDFC Bank and repeatedly referred to the contract in its correspondence. The contract contained an arbitration clause referring disputes to the London Court of International Arbitration. Despite these facts, both the Single Judge and Division Bench of the Delhi High Court declined to refer the matter to arbitration, citing the absence of a signature as fatal to the existence of a binding arbitration agreement. The Hon’ble Supreme Court rejected this view. Relying on Section 7 of the Arbitration and Conciliation Act, 1996 and decisions such as Govind Rubber Ltd. v. Louis Dreyfus Commodities Asia Pvt. Ltd., (2015) 13 SCC 477 and Caravel Shipping Services Pvt. Ltd. v. Premier Sea Foods Exim Pvt. Ltd., (2019) 11 SCC 461, the Court held that an arbitration clause embedded in a contract remains enforceable if the parties’ conduct demonstrates acceptance of the underlying terms. The absence of a signature does not, in itself, negate the existence of an agreement. This judgment restores a measure of practicality to arbitration jurisprudence. In contemporary commercial transactions, agreements are frequently concluded through electronic correspondence and formal execution is not always the final step. Insisting on signatures alone disregards the substance of the parties’ engagement and undermines the efficiency that arbitration is designed to promote. By setting aside the Delhi High Court’s interpretation, the Supreme Court has reinforced the principle that arbitration law must respond to the realities of modern commerce. Where conduct shows clear acceptance, courts must not allow procedural formalities to defeat the intent to arbitrate. This decision is a necessary recalibration of how Indian courts approach arbitration in cross-border and commercial contexts.

Key Issue Whether an appellate court can entertain and allow an application for production of additional evidence under Order XLI Rule 27(1) CPC without first examining whether the proposed evidence is supported by or consistent with the case pleaded by the party in its pleadings (written statement, in this case). In other words: Is a preliminary scrutiny of pleadings mandatory before applying the three conditions/tests laid down in Order XLI Rule 27 CPC for admitting additional evidence at the appellate stage? Supreme Court's Decision and Reasoning The Supreme Court allowed the appeal, set aside the High Court's judgment and decree, and remanded the matter back to the High Court for fresh consideration in accordance with law. The Court laid down an important procedural principle (often referred to as the "pleadings-first doctrine" in commentaries): Before considering whether a party satisfies the strict conditions of Order XLI Rule 27(1) CPC (i.e., that despite due diligence the evidence could not be produced earlier, or for any other substantial cause), the appellate court must first examine the pleadings of that party. The court must ascertain whether the case sought to be established or supported through the additional evidence finds any foundation or basis in the pleadings already on record. If the proposed evidence is inconsistent with, or seeks to set up a case not pleaded at all, permission to adduce it should be refused outright — even before reaching the Rule 27 tests. Allowing additional evidence that contradicts or introduces a fundamentally new case without corresponding pleadings would amount to permitting a party to make out a new case at the appellate stage, which is impermissible.

Ratio Decidendi: The Supreme Court held that decision of the Constitution Bench in Iqbal Singh Marwah’s case does not in any way express its disagreement with the view in Raj Singh’s case and M. Narayandas’s case. On the contrary, a perusal of Iqbal Singh Marwah’s case shows that the Court has leaned in favour of giving an interpretation, which limits the scope of Section 195 of the Cr.P.C. There is no contradiction in invocation of Section 156(3) by the learned Magistrate, the registration of the F.I.R. and the conduct of the investigation by the police, with Section 195 read with Section 340 Cr.P.C. As noticed in M. Narayandas’s case once the investigation is completed, then the embargo under Section 195 would come into play and the Court would not be competent to take cognizance. However, the concerned Court could then file the complaint for the offence mentioned in Section 195(1)(b)(ii) on the basis of the F.I.R. and the material collected during investigation and by following the procedure laid down in Section 340 Cr.P.C. Further, the procedure contemplated under sub-section (1) of Section 340 of the Cr.P.C. is limited to such cases, as are provided in clause (b) of sub-section (1) of Section 195 of the Cr.P.C. only. Section 340 of the Cr.P.C. does not envisage a procedure with reference to an offence described in Section 195(1)(a) of the Cr.P.C. However, the observations made in Raj Singh’s case and M. Narayandas’s case), more specifically that Section 195 Cr.P.C does not have any application at the stage of investigation holds good as regards both Section 195(1)(a) and 195(1)(b) of the Cr.P.C. respectively. The overall bar contemplated under Section 195 could be said to kick in only at the stage of cognizance.

Ratio Decidendi: The Supreme Court held that Section 362 CrPC prohibits criminal courts from reviewing or altering their final orders and judgments except to correct clerical or arithmetical errors. The High Court’s power of review in criminal matters cannot be exercised via the Civil Procedure Code; thus, the recall petition under Order XLVII CPC was not maintainable. The Court found that the Khosla Group’s recall application did not fall within the narrow exceptions of Section 362 CrPC and constituted an impermissible attempt to revisit the concluded matter. Reinforcing the finality of criminal judgments, the Supreme Court set aside the High Court's recall order and restored the original judgment.

• Trademark law protects against likelihood of confusion, not just actual deception.
• The term PRIDE is not generic in the liquor industry; it forms a dominant part of appellants’ mark.
• London Pride and Blenders Pride share structural similarity that could mislead consumers into assuming association.
• Packaging of London Pride showed colourable imitation of Imperial Blue.
• Use of Seagram’s embossed bottles by respondent was a clear infringement.
• Lower courts erred in dissecting marks and ignoring overall similarity.
• Dishonest adoption and injurious association justify injunctive relief.
• Interim injunction principles satisfied: prima facie case established, balance of convenience in appellants’ favour, irreparable harm likely.

Ratio Decidendi : The Hon’ble Supreme Court emphasized that when an inordinate delay is sought to be condoned, courts must presume third party rights or additional interests may have emerged in the meantime. Restoration was granted without hearing the appellant-developer, who had a material stake. The Supreme Court held this violated principles of fairness and due process. Condoning such a massive delay (over 14 years) demands a proper, reasoned judicial order. The High Court’s brief order relying on an affidavit and a past judgment was insufficient. Outcome : Bombay High Court’s order dated 25.10.2023 was set aside. The matter was remitted back for a fresh hearing, with clear directions to hear the appellant developer.

Ratio Decidendi: The Supreme Court held that a loan transaction creates a debtor-creditor relationship, giving rise to civil liability. Section 405 IPC (criminal breach of trust) generally does not apply when the lender intends the borrower to use the loaned money, unless a different intention appears from the contract. For criminal liability under Section 405, all statutory ingredients must be satisfied, including dishonest misappropriation or conversion of property. On the facts, no evidence of misappropriation was found; the beneficent ownership of funds was transferred to M/s. Benlon India Ltd, and use of funds even if not strictly per contract did not amount to criminal breach of trust. Breach of trust not established in absence of dishonest intention and due to circumstances beyond the borrower's control and the Supreme Court set aside the High Court order, clarifying the boundary between civil and criminal liability in loan transactions.

It is held by Apex Court that: (i) The authorities of the Enforcement Directorate can bring on record further evidence during the trial; (ii) the further evidence can be brought on record with the prior permission of the Court; and (iii) the Enforcement Directorate can either file a fresh complaint or the Court can proceed against such other person under Section 319 Cr.P.C. (now substituted by a new provision under the Bharatiya Nagarik Suraksha Sanhita, 2023).There is no gainsaying if the Enforcement Directorate or the authority has acted contrary to the principles of law, which are explained by this Court in Vijay Madanlal Choudhary, the aggrieved person(s), including the petitioner, if so advised, shall always be at liberty to approach the High Court questioning such action of the authorities.

Key Issue Whether a plea of adverse possession can be raised or granted for the first time at the appellate stage (particularly in first appeal), when it was never specifically pleaded in the plaint, framed as an issue at trial, or supported by cogent evidence with the opposing party given a fair opportunity to rebut it. Supreme Court's Decision and Reasoning The Supreme Court dismissed the Special Leave Petition, thereby affirming the High Court's judgment and restoring the dismissal of the suit. The Court re-affirmed long-standing principles of pleadings and procedural fairness in civil litigation, particularly in property disputes involving adverse possession: A plea of adverse possession is not a mere technicality — it is a substantive claim requiring strict proof. The claimant must specifically plead: The date on which possession began, The nature of possession (hostile, open, continuous, and without permission), How it became adverse to the true owner, And other essential ingredients to show perfection of title after 12 years (under Article 65 of the Limitation Act, 1963). The plea must be put in issue at trial, evidence led on multiple aspects, and the defendant given a full opportunity to refute it. It cannot be introduced or accepted as a "surprise" for the first time in appeal, as this violates principles of natural justice and fair trial. Parties cannot be allowed to shift or fundamentally alter the basis of their case midway through litigation.

Ratio Decidendi: The Supreme Court reaffirmed that the solitary, credible, and consistent testimony of the rape victim (prosecutrix) was sufficient for conviction, even if medical corroboration was weak or absent. The Court held that in cases of sexual offences, the law does not require corroboration of the victim's account as a rule; such insistence adds insult to injury and undermines the sensitivity required in cases involving sexual violence. Minor discrepancies in witness statements that do not affect the core of the prosecution’s case should be ignored. The Bench cited prior decisions noting that absence of injuries or medical evidence is not conclusive against rape, particularly where the testimony of the prosecutrix inspires confidence. Consequently, the appeal was dismissed and the conviction and sentence affirmed, reinforcing the principle that a creditworthy victim’s evidence overrides medical insufficiencies in sexual assault prosecutions.

Ratio Decidendi: The Supreme Court acquitted Appellant, identifying critical legal errors in the High Court's ruling. Firstly, the Court held that the confession in the FIR lodged before the police is inadmissible as evidence under Section 25 of the Indian Evidence Act. Secondly, the medical evidence could not alone establish guilt; expert opinions are advisory and must be corroborated by credible facts. Thirdly, the Court found the High Court misapplied Exception 4 of Section 300 IPC as the deceased allegedly made an obscene remark, "get your girlfriend to my place and leave her with me for one night." Such a statement might have provoked the appellant, who then picked up a vegetable-cutting knife lying in one corner of the house and inflicted injuries upon the deceased. This aspect could have been considered in that context. Consequently, there was no legally admissible evidence to sustain conviction, mandating acquittal.

Satauram Mandavi vs. The State of Chhattisgarh & Anr.: 2025 INSC 892-------------------- the Supreme Court of India delivered a critical ruling on the constitutional limits of retrospective sentencing. Key Legal Findings Constitutional Protection: The Court reaffirmed that Article 20(1) of the Constitution provides an "absolute bar" against applying harsher penalties retrospectively. No person can be subjected to a penalty greater than what was prescribed by the law at the time of the offence. POCSO Amendment (2019): The central issue was whether the 2019 Amendment to the POCSO Act, which introduced more severe punishments (including "imprisonment for the remainder of natural life"), could apply to an offence committed before the amendment came into effect. Judgment on Sentencing: While the Court upheld the conviction of the appellant for the sexual assault of a five-year-old girl, it ruled that the lower courts erred by applying the 2019 enhanced penalty. Final Decision Modification of Sentence: The Court set aside the sentence of "imprisonment for the remainder of natural life". Revised Penalty: The sentence was modified to rigorous imprisonment for life (in its conventional sense) as per the law in force on the date of the offence (May 20, 2019). Fine: The fine of ₹10,000 imposed by the trial court was maintained. The case, decided on July 25, 2025, was heard by a bench comprising Justice Vikram Nath and Justice Sandeep Mehta.

The Supreme Court in Vishnu Vardhan @ Vishnu Pradhan v. State of Uttar Pradesh & Ors. (2025 INSC 884) reaffirmed that limitation and procedural safeguards cannot be bypassed in criminal and civil proceedings, emphasizing that courts must strictly adhere to statutory timelines and principles of natural justice. The judgment clarified the scope of delay condonation, the role of equitable considerations, and reinforced that rights cannot be extinguished casually without due process.

Ratio Decidendi: The Court held that involuntary narcoanalysis tests violate constitutional rights under Articles 20(3) and 21, and such tests cannot be conducted forcibly or used as evidence. While voluntary tests may be permissible with safeguards, their results alone cannot be the sole basis for conviction; any information obtained can only be admitted into evidence with the aid of Section 27 of the Indian Evidence Act. The order authorizing involuntary tests was set aside, and the appeal was allowed.

Ratio Decidendi: The court held that the application for closure must be complete, properly documented, and made to the competent authority—the ‘appropriate Government’ exercising its statutory powers. If the authority fails to communicate a decision within the statutory period, permission is deemed granted only if the application was complete and genuine reasons were provided. Administrative correspondence or internal notes that do not constitute a formal decision or reflect a proper application of mind are invalid as decisions. The law requires that decisions be taken by the appropriate authority, with reasons recorded, and that procedural safeguards be strictly followed. When these procedures are not adhered to, the deemed approval cannot be legally invoked, and the administrative actions are invalid, emphasizing the importance of procedural compliance for constitutional validity of restrictions on the right to carry on trade or business under Article 19(1)(g).

Ratio Decidendi: The court held that the police officer’s refusal to register the FIR and the use of objectionable language violated the complainant’s and his family’s human rights, specifically their right to dignity and fair treatment under Article 21 of the Constitution. The conduct was deemed to infringe upon the fundamental rights guaranteed by the Constitution, justifying the findings of human rights violation

Ratio Decidendi: The court held that while the conviction was justified based on the evidence, the statutory minimum sentences cannot be reduced below the prescribed minimum by invoking constitutional powers. However, considering exceptional circumstances, the court exercised its discretion to modify the sentence for one offence, reducing it to a lesser term, but upheld the conviction