Smt. Dhanlaxmi @ Sunita Mathuria & Anr. v. State of Rajasthan & Ors. (2025 INSC 196)
Headnotes:
Habeas Corpus & Its Mootness: A habeas corpus petition was dismissed as infructuous once the missing person (petitioners’ mother) returned.
Misuse of Judicial Process: Repeated attempts to reopen closed proceedings were rejected.
Judicial Conduct & Dignity: The court declined to entertain claims of defamation and humiliation in court proceedings.
Dr. Amaragouda L. Patil v. Union of India & Ors. (2025 INSC 201)
Headnotes:
Administrative Law – Selection Process for Statutory Bodies: The court scrutinized the appointment of the Chairperson of the National Commission for Homeopathy.
Role of Search Committees: The judgment reaffirmed that statutory eligibility conditions must be strictly followed.
Judicial Review of Selection Processes: Courts can intervene if a selection is based on misinterpretation of statutory provisions.
Jay Kishan & Ors. v. State of Uttar Pradesh & Ors. (2025 INSC 198)
Headnotes:
Gangsters & Anti-Social Activities Prevention Act: Examined the legitimacy of applying anti-gang laws to property disputes.
Criminal Law & Civil Disputes: The case questioned the use of criminal statutes to settle what appeared to be civil property disputes.
Quashing of FIRs: The Supreme Court emphasized that criminal charges must be based on solid evidence, not mere allegations.
State of Maharashtra v. Prism Cement Ltd. & Ors. (2025 INSC 199)
Headnotes:
Tax Law – Sales Tax Exemptions: The dispute revolved around tax exemptions granted under the Package Scheme of Incentives (PSI) 1993.
Retrospective Application of Tax Laws: The court ruled against the retrospective withdrawal of tax exemptions.
Legitimate Expectation & Business Incentives: The judgment protected businesses relying on government-promised tax benefits.
Sukhdev Singh v. Sukhbir Kaur (2025 INSC 197)
Headnotes:
Matrimonial Law – Maintenance in Void Marriages: The Supreme Court addressed conflicting judgments on whether alimony can be granted when a marriage is declared void.
Hindu Marriage Act, Sections 24 & 25: Reaffirmed that courts have discretion to grant maintenance in void marriages.
Gender Justice & Financial Dependence: The court favored a broad interpretation to prevent financial destitution of affected spouses.
. Suman Mishra & Ors. v. State of Uttar Pradesh & Anr. (2025 INSC 203)
Headnotes:
498A IPC & Dowry Prohibition: The case examined the misuse of dowry laws in matrimonial disputes.
False & Vexatious Litigation: The court addressed the issue of frivolous FIRs filed in retaliation to divorce proceedings.
Quashing of Criminal Proceedings: Reaffirmed that judicial intervention is warranted when allegations are prima facie baseless.
Future Gaming Solutions Pvt. Ltd. v. Union of India & Others (2025 INSC 181)
Constitutional Law – Taxation – Service Tax on Lotteries
The Supreme Court examined the legislative competence of the Union to impose service tax on lottery transactions. The Court reiterated that taxation on betting and gambling falls under Entry 62 of List II, making it an exclusive power of the States.
Service Tax – Finance Act, 1994 – Amendments from 2010 to 2016
The Court reviewed successive amendments to the Finance Act, 1994, which sought to bring lottery distributors within the ambit of service tax and declared these amendments unconstitutional.
Contract Law – Principal-Agent Relationship in Lotteries
The Court analyzed agreements between the State of Sikkim and lottery distributors, concluding that they were principal-to-principal transactions rather than agency relationships.
Naushey Ali & Ors. v. State of U.P. (2025 INSC 182)
Criminal Law – Quashing of Proceedings – Compromise Between Parties
The Supreme Court held that while Section 307 IPC (attempt to murder) is a serious offense, courts may quash proceedings if continuance of trial would be futile due to compromise between parties.
Difference Between Compounding and Quashing of Criminal Cases
The Court clarified that while Section 307 IPC is non-compoundable, the High Court retains inherent powers under Section 482 CrPC to quash proceedings in appropriate cases.
NUR AHAMAD ABDULSAB KANAVI v. Abdul Munaf & Ors. (2025 INSC 191)
Motor Vehicle Accident – Compensation – Assessment of Disability and Income
The Court enhanced compensation by revising the assessment of permanent disability and monthly income, aligning with recent precedents.
Multiplier Method – Future Prospects
The Court applied the appropriate multiplier and factored in future prospects as per judicial precedents.
Seema Rani & Ors. v. Oriental Insurance Co. Ltd. (2025 INSC 192)
Motor Accident Compensation – Dependency of Major Children
The Court held that major children of the deceased could be considered dependents if evidence supports financial reliance.
Future Prospects – Deduction Methodology
The High Court erred in excluding major children from dependency calculations, leading to an undervaluation of compensation.
Shyam Prashad Nagalla & Ors. v. Andhra Pradesh State Transport Corporation (2025 INSC 193):
Foreign Income in Compensation Claims – Exchange Rate at Filing Date
The Court held that the exchange rate at the time of filing the claim should be used to compute compensation.
Multiplier for Foreign Earners
The Court corrected the High Court’s reduction of the multiplier from 14 to 10, reaffirming that foreign currency earnings do not alter the standard method of calculation.
Amrit Yadav v. The State of Jharkhand & Ors. (2025 INSC 176)
Recruitment process must adhere strictly to advertisement terms.
Introduction of an interview stage without prior notification is unlawful.
Violation of Articles 14 and 16 leads to invalid appointments.
High Court can order fresh selection if original process is flawed.
AC Chokshi Share Broker Pvt. Ltd. v. Jatin Pratap Desai & Anr. (2025 INSC 174)
Arbitration agreements can be binding on non-signatories in certain cases.
Bye-law 248(a) of BSE covers disputes arising out of stock transactions.
Courts have limited scope for intervention under Sections 34 and 37 of the Arbitration and Conciliation Act.
Arbitral awards must not be set aside unless they suffer from perversity or patent illegality.
Hansraj v. State of Chhattisgarh (2025 INSC 178)
Circumstantial evidence must meet stringent legal standards for conviction.
Mere recovery of a weapon is insufficient without forensic correlation.
Guilt must be established beyond reasonable doubt in criminal cases.
Contradictions in witness testimonies can weaken the prosecution’s case.
Ravi v. State of Punjab (2025 INSC 170)
Conviction based on circumstantial evidence must rule out all other possibilities.
Post-mortem findings must conclusively support the prosecution’s theory.
Section 106 of the Evidence Act applies only when a prima facie case is established.
Courts must exercise caution before shifting the burden of proof onto the accused.