Judgments

Landmark Judgments from January to June 2025

1️⃣ RINA KUMARI @ RINA DEVI @ REENA v. DINESH KUMAR MAHTO @ DINESH KUMAR MAHATO, 2025 SC

📌 Facts of the case

* In this case, the wife, Reena, had left her matrimonial home after suffering a miscarriage and being ill-treated by her husband and his family.

* The husband had obtained a decree of restitution of conjugal rights under Section 9 of the Hindu Marriage Act, 1955, which required the wife to return to live with him, but the wife did not return to the matrimonial home.

* The Family Court had granted maintenance to the wife under Section 125 of the CrPC, but the High Court later set aside that order, stating that since the wife had refused to live with her husband despite the decree, she was not entitled to maintenance.

📌 Supreme Court Held

* The Supreme Court held that even if a wife refuses to live with her husband despite a decree of restitution of conjugal rights, she is still entitled to claim maintenance under Section 125 of the CrPC if she has a valid reason for not returning.

* The Court observed that if a wife refuses to comply with the decree under Section 9 of the Hindu Marriage Act for a just cause, such as cruelty or ill-treatment, it will not disqualify her from claiming maintenance under Section 125 of the CrPC.

* Therefore, the Supreme Court allowed the wife's appeal and directed the husband to pay Rs. 10,000 per month as maintenance to the wife.

2️⃣ KIM WANSOO v. STATE OF UTTAR PRADESH, 2025 SC

📌 Facts of the case

* Hyundai Motor India awarded a construction project to HEC India LLP.

* HEC subcontracted the work to KOTEC, which further subcontracted it to YSSS India Construction Pvt. Ltd.

* After the work was completed, the complainant alleged that payments were not made, cheques bounced, and threats were issued.

* An FIR was filed alleging offences under Sections 406, 420, 323, 504, 506, and 120-B IPC.

* Kim Wansoo, a foreign national and project manager at HEC, was named in the FIR, even though he had no direct role in the transactions or payments. LAWVITA

📌 High Court's View

* Kim Wansoo had approached the High Court under Article 226 to cancel the FIR.

* The High Court rejected his request on technical grounds and did not properly check if there was real evidence.

📌 Supreme Court Held

* That this was an error, as the High Court failed to use its

powers properly under Article 226 and Section 482 CrPC.

* The Court observed that criminal law must not be misused to settle civil disputes or for personal vendetta.

* Referring to key precedents like State of Haryana v. Bhajan Lal, the Court quashed the FIR, noting it was an abuse of judicial process.

* So the conclusion was that the powers under Article 226 and Section 482 must be exercised to protect individuals from vexatious litigation.

3️⃣ VIHAAN KUMAR v. THE STATE OF HARYANA, 2025 SC

📌 Facts of the case

* Vihaan Kumar was arrested, and he claimed that the police did not inform him of the reasons for his arrest as required under Article 22(1) of the Constitution and Section 50 CrPC (Now Section 47 BNSS).

* The question before the Supreme Court was whether not informing the grounds of arrest would make the arrest and remand illegal.

📌 Supreme Court Held

* Informing the arrested person of the grounds of arrest is mandatory under Article 22(1).

* This information must be given clearly in a language the arrested person understands, ensuring they know the basic facts for the arrest.

* If the arrested person claims they were not informed, the police have to prove that they complied with Article 22(1).

* If this is not done, it violates the Fundamental Rights under Articles 21 and 22, making the arrest and remand illegal, but it does not invalidate the investigation, chargesheet, or trial. However, filing a chargesheet later will not cure this constitutional violation.

* When producing the arrested person for remand, the Magistrate must check whether Article 22(1) and other safeguards have been followed.

* If a violation of Article 22(1) is found, the court must immediately release the accused.

4️⃣ SUDHEERA v. C. YASHODA, 2025 SC

📌 Facts of the case

* A second appeal was filed under Section 100 CPC.

* Before deciding whether any substantial question of law arose, the High Court granted interim relief (stay).

* The question was whether the HC could grant such relief before framing the substantial question of law.

📌 Supreme Court Held

* It was held that the High Court cannot grant interim relief (like stay) before framing a substantial question of law.

* The HC gets jurisdiction to hear the case only after framing that question.

* If no substantial question of law arises, the appeal must be dismissed at admission stage.

5️⃣ RAJIV GHOSH v. SATYA NARAIN JAISWAL, 2025 SC

📌 Facts of the case

* The case involved Order 12 Rule 6 CPC, which deals with judgment based on admissions.

* The issue was how and when courts can use admissions to pass judgment and what constitutes a valid admission.

📌 Supreme Court Held

* Under Order 12 Rule 6 CPC, the court may pass a quick judgment based on clear, unconditional admissions made either in pleadings or outside (documents or statements), at any stage, on its own or on a party's request.

* The rule is discretionary, not mandatory, and must be applied fairly; a decree under it can be preliminary or final.

6️⃣ CENTRAL BANK OF INDIA v. SMT. PRABHA JAIN, 2025 SC

📌 Facts of the case

* Smt. Prabha Jain filed a civil case asking for 3 things about a mortgaged property.

* Two reliefs were about ownership and title.

* One relief was about getting possession back under SARFAESI Act.

* The Bank said this third relief could only be decided by DRT (Debt Recovery Tribunal) and asked the court to reject the entire case under Order VII Rule 11(d) of CPC.

📌 Supreme Court Held

* The Supreme Court rejected the Bank's request.

* It said if even one relief is legally valid, the whole plaint cannot be rejected.

* Courts must look at the plaint as a whole and not just one relief.

* Issues like ownership and title can still be heard by civil courts.

* Including a relief under SARFAESI does not make the entire suit invalid.

7️⃣ PRADEEP NIRANKARNATH SHARMA v. STATE OF GUJARAT, 2025 SC

📌 Facts of the case

* Pradeep Nirankarnath Sharma, a former IAS officer from Gujarat, approached the High Court stating that multiple FIRs had been filed against him.

* He argued that according to the Lalita Kumari v. Government of Uttar Pradesh (2014) judgment, the police must first conduct a preliminary inquiry before registering an FIR.

📌 Supreme Court Held

* The Supreme Court clarified that the Lalita Kumari judgment does not create an absolute rule that a preliminary inquiry is required in every case before filing an FIR.

* If the information clearly discloses a cognizable offence, then registration of FIR is mandatory under Section 154 CrPC, and no preliminary inquiry is needed.

* Preliminary inquiry is only needed when the information does not prima facie disclose a cognizable offence.

* In this case, the allegations against the accused were related to abuse of official position and corruption, which are cognizable offences, so no preliminary inquiry was required.

8️⃣ THE STATE OF TELANGANA v. DR. PASUPULETI NIRMALA HANUMANTHA RAO CHARITABLE TRUST, 2025 SC

📌 Facts of the case

* The Telangana government gave land to a charitable trust for public use.

* The allotment included conditions, including one that allowed the government to take the land back if it was misused.

📌 Supreme Court Held

* The Supreme Court said that such government allotments are not private or commercial deals, but are done for the public good.

* So, Section 10 of the Transfer of Property Act (TPA)-which usually stops complete restrictions on selling property-doesn't apply here.

* The condition allowing the government to take back land is valid.

9️⃣ SACHIN JAISWAL v. M/S HOTEL ALKA RAJE, 2025 SC

📌 Facts of the case

* In this case, the issue was whether a partner's personal property can become part of the partnership firm's property without any formal agreement.

📌 Supreme Court Held

* The Court said that under Section 14 of the Indian Partnership Act, a partner can bring in personal property into the firm just by showing intention.

* No formal written agreement is needed.

* If the property is added at the time of forming the partnership, it automatically becomes firm property.

1️⃣0️⃣ AMLESH KUMAR v. STATE OF BIHAR, 2025 SC

📌 Facts of the case

* The Patna High Court allowed the police to do involuntary narco-analysis tests (forcing accused to undergo narco-tests during investigation).

* Amlesh Kumar challenged this, saying it violated constitutional rights.

📌 Supreme Court Held

* The Supreme Court said forced narco-tests cannot be used as evidence in court.

* These tests violate Article 20(3) (right against self-incrimination) and Article 21 (right to personal liberty).

* The Supreme Court cancelled the High Court's order, confirming that forced narco-tests are unconstitutional and cannot be used in evidence.

* Police cannot force accused persons to undergo narco-tests, and if they do, the results cannot be used in court, as it violates constitutional rights.