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Supreme Court Decisions: Weekly Insights for Legal Professionals || Dec 15 - Dec 21, 2025
Supreme Court Decisions: Weekly Insights for Legal Professionals || Dec 15 - Dec 21, 2025
Stay ahead with our expert analysis of recent Supreme Court rulings. This edition covers critical developments spanning environmental law, corporate governance, arbitration, employment, and criminal jurisprudence, offering valuable insights for legal practitioners, business leaders, and policy-makers.
In a landmark decision, the Supreme Court has redefined the balance between protecting critically endangered species and advancing India's renewable energy goals. This ruling modifies a previous blanket ban on overhead power lines in GIB habitats, recognizing the complexities of large-scale infrastructure and climate commitments. Professionals in infrastructure, energy, and environmental consulting will find this a crucial development, shaping future project planning and regulatory compliance.
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M.K. Ranjitsinh & Others Vs Union of India & Others, decided on 19-12-2025]
The Supreme Court clarifies that mere state reorganisation does not automatically convert a state-registered cooperative society into a multi-State entity. The determining factor is whether the society's 'objects,' not just its area of operation or members' residence, extend to more than one State. This judgment is crucial for cooperative sector governance and regulatory compliance, particularly for entities spanning newly formed state boundaries.
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The State of Uttar Pradesh Through Principal Secretary & Ors. VS Milkiyat Singh & Ors. Etc., decided on 15-12-2025]
A critical ruling where the Supreme Court acquitted an appellant convicted in a child sexual assault case, highlighting severe investigative and procedural flaws. The Court emphasized stringent standards for circumstantial evidence, questioning the 'last seen' theory and noting unnatural witness conduct and failure to conduct crucial DNA profiling. This underscores the need for meticulous investigation and robust evidentiary standards in criminal justice.
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Manojbhai Jethabhai Parmar (Rohit) VS State of Gujarat, decided on 15-12-2025]
The Supreme Court has reinstated a conviction in a dowry death case, reversing the High Court's acquittal. This judgment reiterates the legislative intent behind dowry prohibition laws, emphasizing that demands made post-marriage also constitute dowry. It serves as a stark reminder of judicial commitment to eradicate dowry and highlights the serious consequences for perpetrators, with a focus on systemic reforms and awareness programs.
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STATE OF U.P. VS AJMAL BEG ETC., decided on 15-12-2025]
In a case concerning motor accident claims, the Supreme Court re-evaluated the deceased's monthly income, finding previous computations speculative due to lack of income tax returns. It reduced the compensation for loss of dependency while confirming other entitlements. This ruling provides clarity on the rigorous standards required for income proof in compensation claims, impacting insurance companies, legal professionals, and victims' families.
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M/s National Insurance Co. Ltd. VS Neeru Devi & Ors., decided on 15-12-2025]
The Supreme Court ruled that Section 44C of the Income Tax Act, 1961, applies to all 'head office expenditure' incurred by non-resident assessees, whether common administrative costs or exclusive expenses for Indian branches. This decision clarifies a long-standing dispute, directly impacting international banks and other non-resident entities operating in India, and necessitating a review of their tax deduction strategies.
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DIRECTOR OF INCOME TAX (IT) -I, MUMBAI VS M/S. AMERICAN EXPRESS BANK LTD. AND M/S. OMAN INTERNATIONAL BANK, decided on 15-12-2025]
Exercising its extraordinary powers, the Supreme Court dissolved a marriage that had been irretrievably broken down for 24 years. This ruling reaffirms the Court's stance that prolonged separation without reconciliation can amount to cruelty, justifying divorce even without fault-based grounds. It underscores the practical approach taken by the apex court in family matters.
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NAYAN BHOWMICK VS APARNA CHAKRABORTY, decided on 15-12-2025]
The Supreme Court has enhanced motor accident compensation for the parents of a deceased 14-year-old boy, adopting a higher notional income and multiplier for loss of dependency. This judgment provides updated guidance on calculating compensation for minor victims, offering solace to affected families and clear benchmarks for insurance claims adjusters and legal professionals.
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Devendra Kumar Tripathi & Ors. VS The Oriental Insurance Company Ltd. & Anr., decided on 15-12-2025]
In a significant ruling on property law, the Supreme Court declared a separate suit by *pendente lite* transferees (buyers during ongoing litigation) challenging an auction sale as non-maintainable. The Court emphasized that such transferees are representatives of the judgment-debtor, subject to the doctrine of *lis pendens*, and must utilize remedies within the execution proceedings. This clarifies the finality of execution sales and the limited recourse available to those acquiring property amidst legal disputes.
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DANESH SINGH & ORS. VS HAR PYARI (DEAD) THR. LRS. & ORS., decided on 15-12-2025]
The Supreme Court restored a trial court's order for the refund of an advance payment in a property sale agreement, finding that the seller fraudulently concealed an equitable mortgage. This judgment underscores the importance of full disclosure in real estate transactions and reinforces the buyer's right to rescission and refund in cases of material misrepresentation or concealment.
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MOIDEENKUTTY vs ABRAHAM GEORGE, decided on 15-12-2025]
The Supreme Court ruled that judicial orders of the Patna High Court, passed before the Bihar Reorganisation Act, 2000, are binding on the High Court of Jharkhand. This decision ensures pay scale parity for employees allocated to the new State and confirms that claims for anomaly removal constitute a continuing cause of action, overriding arguments of delay or laches. Crucial for understanding service law implications post-state bifurcations.
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SANJAY KUMAR UPADHYAY VS STATE OF JHARKHAND AND ORS., decided on 16-12-2025]
In a significant ruling, the Supreme Court affirmed that the SARFAESI Act cannot be invoked in Nagaland without specific legislative applicability and a direct security interest in favor of the creditor. This judgment highlights regional legal specificities and constitutional provisions (Article 371A), critical for financial institutions and businesses operating in special category states.
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NORTH EASTERN DEVELOPMENT FINANCE CORPORATION LTD. (NEDFI) VS M/S L. DOULO BUILDERS AND SUPPLIERS CO. PVT. LTD., decided on 16-12-2025]
The Supreme Court quashed an FIR against a former minister for alleged illegal land allotments, citing the absence of mandatory prior sanction and evidence of political malice. This ruling reiterates the Court's power to prevent abuse of process in politically motivated cases and emphasizes adherence to procedural safeguards, particularly concerning public servants.
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R. Ashoka & Anr. VS State of Karnataka & Ors., decided on 16-12-2025]
The Supreme Court acquitted a doctor convicted in a rape case, citing hostile witnesses, unreliable forensic evidence, and the victim's failure to identify the accused. This decision emphasizes the critical need for robust, corroborated evidence in criminal trials and highlights judicial scrutiny of investigations where key witnesses turn hostile.
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JAYANTIBHAI CHATURBHAI PATEL VS STATE OF GUJARAT, decided on 16-12-2025]
In a significant ruling for the insurance sector, the Supreme Court clarified that the cause of a fire is generally immaterial for coverage under a 'Standard Fire and Special Perils Policy,' unless explicitly excluded or due to willful act of the insured. It reinstated a claim for fire loss following attempted theft, emphasizing strict interpretation of exclusion clauses in favor of the insured. This impacts risk assessment and claims processing for insurers.
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CEMENT CORPORATION OF INDIA VS ICICI LOMBARD GENERAL INSURANCE COMPANY LIMITED, decided on 16-12-2025]
The Supreme Court, applying the 'dominant nature test,' reinstated a cashier who was terminated, holding him to be a 'workman' under the Industrial Disputes Act despite his designation as 'Manager.' This judgment emphasizes that an employee's actual duties, rather than their formal title, determine their status. A critical reminder for HR professionals and employers on correctly classifying employees and understanding labor law protections.
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SRINIBAS GORADIA VS ARVIND KUMAR SAHU & ORS., decided on 17-12-2025]
The Supreme Court reaffirmed that a referral court's role under Section 11(6) of the Arbitration Act is limited to a *prima facie* determination of the existence of an arbitration agreement, leaving deeper inquiries into complex issues like individual consortium member's capacity or arbitrability to the Arbitral Tribunal itself. This reinforces the *kompetenz-kompetenz* principle and streamlines pre-arbitral judicial intervention.
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M/S ANDHRA PRADESH POWER GENERATION CORPORATION LIMITED (APGENCO) & M/S VA TECH WABAG LTD. VS M/S TECPRO SYSTEMS LIMITED & ORS., decided on 17-12-2025]
The Supreme Court modified a life sentence to 25 years without remission in a rape and murder case, while quashing the conviction under the SC/ST Act due to lack of evidence regarding the accused's knowledge of the victim's caste. This judgment provides crucial clarifications on sentencing powers, the admissibility of evidence, and the specific requirements for proving offenses under the SC/ST Act, impacting criminal litigation and social justice.
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Shaik Shabuddin VS State of Telangana, decided on 17-12-2025]
The Supreme Court allowed an appeal, dismissing a suit for permanent injunction where the respondents failed to establish valid title or properly identify the disputed land. The Court scrutinized an invalid original acquisition, non-compliance with construction conditions, and a suspicious rectification deed. This reinforces fundamental principles of property law regarding the necessity of clear title and identifiable property for seeking injunctive relief.
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Obalappa and Ors. VS Pawan Kumar Bhihani and Ors., decided on 17-12-2025]
The Supreme Court upheld a registered will, even when it excluded a legal heir, emphasizing that minor discrepancies in a witness's testimony many years later should not invalidate the will if core execution and attestation requirements are met. This ruling clarifies principles of proof for wills, particularly concerning attestation and judicial scrutiny of disinheritance clauses, offering guidance for estate planners and beneficiaries.
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K. S. Dinachandran VS Shyla Joseph & Ors., decided on 17-12-2025]
The Supreme Court acquitted appellants in a murder case, finding that the prosecution failed to prove guilt beyond reasonable doubt due to material contradictions in eyewitness testimony and uncorroborated medical evidence. This decision reiterates the high bar for conviction in criminal cases, particularly when relying on interested witnesses or inconsistent evidence.
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PUNIMATI & ANR. AND DAYALU & ORS. VS. THE STATE OF CHHATTISGARH & ORS., decided on 18-12-2025]
The Supreme Court clarified that Section 45A of the ESI Act, for summary best-judgment assessments, can only be invoked in cases of actual non-production of records or obstruction of inspection, not merely for perceived inadequacy. If an employer cooperates and produces records, disputes should proceed under Section 75, subject to the prescribed limitation period. This is a vital ruling for employers, ESI authorities, and legal advisors managing social security contributions.
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M/S. Carborandum Universal Ltd. VS ESI Corporation, decided on 18-12-2025]
The Supreme Court overturned the disqualification of a bidder, affirming that experience gained as a partner in a joint venture should be considered for tender eligibility. This judgment reiterates the need for fairness and non-arbitrariness in public procurement, preventing tender conditions from being interpreted to exclude capable bidders. Essential for companies participating in government tenders and those forming joint ventures for large projects.
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M/S. SURGUJA BRICKS INDUSTRIES COMPANY VS STATE OF CHHATTISGARH & ORS., decided on 18-12-2025]
The Supreme Court ruled that a 'continuously' valid driving licence for recruitment purposes means uninterrupted legal capacity to drive. Any period where the licence has expired, even if subsequently renewed, constitutes a break in continuity. This interpretation, post-Motor Vehicles (Amendment) Act, 2019, clarifies eligibility criteria for public service jobs requiring continuous licence possession, impacting recruitment boards and applicants.
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TELANGANA STATE LEVEL POLICE RECRUITMENT BOARD & RAMAVATH SURESH AND ORS. ETC. VS PENJARLA VIJAY KUMAR & ORS. ETC. & THE STATE OF TELANGANA, decided on 18-12-2025]
In a major verdict, the Supreme Court declared unauthorized percentile relaxation for BDS admissions in Rajasthan illegal. While regularizing admissions of students who have completed their degrees (under Article 142), it imposed a hefty fine of Rs. 10 crores on each errant college and Rs. 10 lacs on the State. This sends a strong message against undermining educational standards and unlawful regulatory actions.
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Siddhant Mahajan and Ors. VS The State of Rajasthan and Ors., decided on 18-12-2025]
The Supreme Court clarified that Sessions Courts lack the extraordinary power to impose life imprisonment 'till the end of natural life' or deny statutory set-off benefits under Section 428 Cr.PC. These powers are reserved for Constitutional Courts. This ruling reinforces the hierarchy of judicial powers and the mandatory nature of certain criminal procedure benefits, impacting criminal justice administration.
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Kiran VS The State of Karnataka, decided on 18-12-2025]
The Supreme Court allowed the State's appeal, holding that agricultural leases on forest land without Central Government approval are illegal under the Forest (Conservation) Act, 1980. This decision reinforces the imperative of forest protection and directs the reforestation of 134 acres of previously leased forest land, setting a precedent for environmental compliance and land use policies.
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STATE OF KARNATAKA & ORS. VS GANDHI JEEVAN COLLECTIVE FARMING CO-OPERATIVE SOCIETY LIMITED, decided on 18-12-2025]
Exercising Article 142 powers, the Supreme Court dissolved a marriage due to irretrievable breakdown after nearly two decades of separation, setting aside lower court denials. The Court ordered a one-time settlement of ₹20,00,000 as permanent alimony. This emphasizes the Court's pragmatic approach in matrimonial disputes where reconciliation is impossible.
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JATINDER KUMAR VS JEEWAN LATA, decided on 18-12-2025]
The Supreme Court dissolved a marriage by mutual consent under Article 142, setting aside a prior divorce decree based on desertion. The Court ordered a ₹25 lakh lump-sum payment as full and final settlement, underscoring its broad powers to achieve complete justice in matrimonial disputes, particularly when parties agree to separation.
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BHAGYASHREE BISI VS ANIMESH PADHEE, decided on 18-12-2025]
The Supreme Court ruled that a Forest Settlement Officer cannot adjudicate complex questions of land title in summary proceedings, especially when prior judgments affirm government ownership. It quashed the exclusion of 'Arazi-Makta' land from a reserved forest, emphasizing strict proof for title claims against the State. This decision is crucial for land disputes involving forest areas and government property claims.
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THE STATE OF TELANGANA REPRESENTED BY FOREST DIVISIONAL OFFICER VS MIR JAFFAR ALI KHAN (DEAD) THR. LRS. & ORS., decided on 18-12-2025]
The Supreme Court acquitted an appellant in a murder case, reiterating that conviction based solely on the 'last seen together' theory is weak without a complete and unbroken chain of incriminating circumstances. This judgment reinforces the high evidentiary standards for circumstantial evidence, particularly when there is a time gap between sighting and discovery of death, impacting criminal defense strategies.
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MANOJ @ MUNNA VS THE STATE OF CHHATTISGARH, decided on 18-12-2025]
The Supreme Court restored an arbitral award, clarifying that judicial intervention to set aside an award on grounds of 'patent illegality' is narrow. Courts cannot re-appreciate evidence or substitute their interpretation for the arbitrator's, especially if the findings are not perverse. This is a crucial affirmation for arbitration practitioners, reinforcing the finality of arbitral awards and limited appellate scope.
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RAMESH KUMAR JAIN VS BHARAT ALUMINIUM COMPANY LIMITED (BALCO), decided on 18-12-2025]
The Supreme Court referred to a Larger Bench the question of whether an interim deposit under Section 148 of the NI Act can be imposed on a director when the company is undergoing winding-up. This referral addresses a conflict in interpretation regarding 'drawer' and vicarious liability, promising crucial clarity for corporate governance, insolvency professionals, and directors facing cheque dishonor cases.
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BHARAT MITTAL VS STATE OF RAJASTHAN AND ORS., decided on 18-12-2025]
The Supreme Court upheld the administrative designation of Kolhapur as an additional sitting place for the Bombay High Court, affirming the Chief Justice's independent and continuing power under Section 51(3) of the States Reorganisation Act, 1956. This decision clarifies judicial administration and reinforces measures to enhance access to justice, setting a precedent for other high courts considering decentralization.
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RANJEET BABURAO NIMBALKAR VS STATE OF MAHARASHTRA & AN R., decided on 18-12-2025]
The Supreme Court clarified that while a rank list is valid for a statutory period, appointments from it must adhere to the communal rotation roster. A vacancy arising from a reserved candidate's resignation is deemed a 'fresh vacancy' and must follow the communal rotation. This decision impacts HR policies, recruitment in educational institutions, and understanding of reservation principles.
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RADHIKA T. VS COCHIN UNIVERSITY OF SCIENCE AND TECHNOLOGY & ORS., decided on 18-12-2025]
The Supreme Court reversed a High Court order that suspended a life sentence and granted bail to a murder convict, emphasizing that such relief is only for 'exceptional cases' or 'very gross errors.' The Court found the High Court's reasoning flawed, reiterating that appellate courts should be very slow in granting bail to those convicted of serious offenses. This is a critical reminder for criminal defense and prosecution on bail jurisprudence.
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RAJESH UPADHAYAY VS THE STATE OF BIHAR & ANR., decided on 18-12-2025]
The Supreme Court restored a mutation in revenue records based on a registered will, setting aside a High Court order that had intervened in summary mutation proceedings. The Court clarified that Tehsildars can base mutations on wills, and that minor disputes or objections lacking specific performance decrees do not automatically prevent such entries. This provides clarity for property owners and legal practitioners dealing with inheritance and land records.
TARACHANDRA VS BHAWARLAL & ANR., decided on 19-12-2025]
The Supreme Court clarified that criminal revision proceedings, especially when initiated by an informant or complainant, do not abate on their death. The Court emphasized that victims or their legal heirs have locus standi to assist the revisional court. This is a crucial ruling for victims' rights and the continuity of criminal justice processes, ensuring that serious legal questions are not foreclosed due to a party's demise.
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Syed Shahnawaz Ali VS The State of Madhya Pradesh & Ors., decided on 19-12-2025]
The Supreme Court restored a specific performance decree, holding that a 27-day delay in filing the execution application and depositing balance consideration was not fatal, given the appellant's established readiness and willingness. The ruling reiterates that courts should avoid a 'hyper-technical approach' and apply the doctrine of merger. This provides important clarity for contract law and execution proceedings.
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DR. AMIT ARYA VS KAMLESH KUMARI, decided on 19-12-2025]
The Supreme Court upheld the West Bengal Clinical Establishments Regulatory Commission's jurisdiction to find deficiency in service and award compensation, including examining the qualifications of medical personnel. This ruling clarifies the regulatory scope of such commissions, emphasizing accountability for patient care and the employment of qualified staff, crucial for healthcare providers and regulators.
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KOUSIK PAL VS B.M. BIRLA HEART RESEARCH CENTRE & ORS., decided on 19-12-2025]
The Supreme Court affirmed conviction in a child trafficking and commercial sexual exploitation case, emphasizing the credibility of a minor victim's testimony without requiring corroboration. The ruling highlights judicial sensitivity towards vulnerable victims and reinforces the importance of school certificates for age determination over medical opinions, crucial for child protection and criminal justice.
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K.P. Kirankumar @ Kiran VS State by Peenya Police, decided on 19-12-2025]
The Supreme Court set aside a High Court order that quashed NI Act proceedings, emphasizing that a High Court cannot conduct a roving inquiry into disputed facts like the existence of debt or liability at the pre-trial stage. The statutory presumption under Section 139 NI Act must be rebutted during trial, not at the quashing stage. This provides critical guidance for handling cheque dishonor cases.
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M/S SRI OM SALES VS ABHAY KUMAR @ ABHAY PATEL & ANR., decided on 19-12-2025]
The Supreme Court found hostile discrimination in the non-regularization of High Court employees, setting aside High Court judgments and directing their reinstatement and regularization. This ruling highlights the constitutional imperative for judicial bodies to act as model employers, upholding principles of equality and non-arbitrariness in their administrative functioning.
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Ratnank Mishra & Others, Sanjeev Kumar Sharma, Ajay Kumar Mishra & Others, Dharmendra Singh Rathore VS High Court of Judicature at Allahabad Through Registrar General & Ors., decided on 19-12-2025]
The Supreme Court affirmed the High Court's decision to reverse an acquittal and convict five individuals for murder. The ruling underscores that minor contradictions in witness testimony are not fatal if the core narrative is credible, and emphasizes the duty of courts to 'sift the grain from the chaff' in evidence. Crucial for criminal appellate practice.
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PATCHAIPERUMAL @ PATCHIKUTTI & ANR.; KULASEKARAPANDIAN; BILEDY GANESAN @ SELVAGANESAN; MURUGESAN @ SHANMUGASUNDARAM VS. STATE REP. BY INSPECTOR OF POLICE & ANR.; P. THILAGAVATHY & ANR., decided on 19-12-2025]
The Supreme Court curtailed the Allahabad High Court's directions for time-bound investigation and blanket interim protection from arrest, emphasizing that such interventions in criminal matters should be exceptional, not routine. This ruling reinforces that High Courts must adhere to established precedents and Section 438 CrPC conditions for anticipatory bail, impacting criminal procedure and writ practice.
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STATE OF U.P. & ANR. VS MOHD ARSHAD KHAN & ANR. (WITH SANJAY @SANJAY KAPOOR AND MUHAMMAD ZAID KHAN), decided on 19-12-2025]
The Supreme Court restored the dismissal of a CISF Constable for bigamy, reiterating that High Courts should not overstep their judicial review powers by substituting their judgment for disciplinary authorities on penalty proportionality, unless it 'shocks the conscience.' This judgment reinforces discipline in uniformed forces and clarifies the limited scope of judicial interference in service matters.
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UNION OF INDIA & ORS. VS PRANAB KUMAR NATH, decided on 19-12-2025]
The Supreme Court ruled that non-compete fees, aimed at protecting or enhancing business profitability, constitute allowable revenue expenditure under Section 37(1) of the Income Tax Act. It also affirmed that interest on borrowed funds for investments in subsidiaries or interest-free advances to sister concerns is deductible if commercially expedient. This judgment offers vital clarity for corporate tax planning and M&A transactions.
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SHARP BUSINESS SYSTEM THR. FINANCE DIRECTOR MR. YOSHIHISA MIZUNO VS COMMISSIONER OF INCOME TAX -III N.D. and connected matters, decided on 19-12-2025]
The Supreme Court quashed a State Government notification creating new Revenue Villages named after individuals, finding it in contravention of a binding state policy. This judgment reinforces that executive actions must adhere to established government policies and cannot be arbitrary, impacting administrative law and regional governance.
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BHIKA RAM & ANR. VS STATE OF RAJASTHAN & ORS., decided on 19-12-2025]
The Supreme Court quashed criminal proceedings against a husband under Section 498A IPC and the Dowry Prohibition Act, finding the allegations vague, omnibus, and lacking specific details of cruelty or dowry demand. This judgment highlights concerns about the misuse of these laws for personal vendettas, providing relief against unsubstantiated matrimonial disputes.
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BELIDE SWAGATH KUMAR VS STATE OF TELANGANA & ANOTHER, decided on 19-12-2025]
The Supreme Court overturned a High Court order granting bail to accused and directing a joint trial in an SC/ST Act and murder case. The Court annulled bail due to perversity and non-application of mind by the High Court, which ignored prior bail cancellation after the accused allegedly murdered a key witness. This ruling emphasizes strict scrutiny in bail matters, especially in serious and caste-based violence cases.
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LAKSHMANAN VS STATE THROUGH THE DEPUTY SUPERINTENDENT OF POLICE & ORS. ETC., decided on 19-12-2025]
The Supreme Court disallowed the examination of a minor child witness seven years after an incident, finding no evidence of her presence and apprehension of memory distortion or tutoring. This ruling clarifies that Section 311 CrPC powers should be used sparingly, especially when belated examination of tender-aged witnesses could prejudice the accused.
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MAYANKKUMAR NATWARLAL KANKANA PATEL & ANR. VS STATE OF GUJARAT AND ANR., decided on 19-12-2025]
The Supreme Court ruled that individuals facing criminal proceedings can renew their regular passports, even with court-imposed conditions restricting foreign travel. The Court clarified that denial of a renewed passport is disproportionate when courts control foreign travel. This affirms the right to personal liberty and travel, offering crucial guidance for legal and administrative processes involving passports and criminal cases.
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Mahesh Kumar Agarwal VS Union of India & Anr., decided on 19-12-2025]
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