As we step into March , it’s essential to reflect on the most impactful judicial pronouncements of February 2025 of Supreme court This month witnessed a series of significant rulings that have shaped legal discourse across various domains.
NEW DELHI: As we step into March, it’s important to reflect on the most impactful judicial pronouncements of February 2025. This month saw a series of significant rulings that have influenced legal discourse across various fields, including constitutional law, criminal justice, corporate regulations, and human rights. From Supreme Court verdicts establishing new precedents to High Court rulings with wide-ranging implications, these decisions continue to shape and evolve the legal landscape.
In this recap, we examine the most important judgments of February 2025, highlighting their key takeaways, legal reasoning, and potential ramifications.
Supreme Court Clarifies Maximum Sentence for Attempt to Murder Under Section 307 IPC
The Supreme Court ruled that the maximum sentence for an attempt to murder under Section 307 of the IPC, if life imprisonment is not imposed, cannot exceed 10 years. Accordingly, the Court set aside an Appellate Court’s order that had sentenced the accused to 12 years of rigorous imprisonment. The case involved an appeal by a man accused of subjecting his wife and children to continuous harassment.
- Case Title: Ganesan v. State of Tamil Nadu Rep. by Inspector of Police
- Neutral Citation: 2025 INSC 158
- Date of Judgment: February 7, 2025
- Coram: Justice B.R. Gavai and Justice K. Vinod Chandran
READ JUDGMENT HERE:
Father’s Remarriage Not a Ground to Deny Child Custody; Grandparents Have No Superior Claim
The Supreme Court ruled that a father’s remarriage cannot be a ground to deny him custody of his child, emphasizing that grandparents do not have a superior claim over the natural guardian. The case involved an appeal by a father challenging a Writ Court order in a Habeas Corpus petition, which had denied him custody of his child, who was living with the grandparents after the mother’s passing.
- Case Title: Vivek Kumar Chaturvedi & Anr. v. State of U.P. & Ors.
- Neutral Citation: 2025 INSC 159
- Date of Judgment: February 7, 2025
- Coram: Justice B.R. Gavai and Justice K. Vinod Chandran
READ JUDGEMENT HERE:
Implicating Relatives in Domestic Violence Cases Without Specific Allegations is an Abuse of Law
The Court held that implicating relatives in domestic violence cases without clear allegations and proceeding against them without prima facie evidence amounts to an abuse of the legal process. The ruling came in criminal appeals challenging a Telangana High Court judgment that had refused to quash criminal proceedings against the accused.
- Case Title: Geddam Jhansi & Anr. v. The State of Telangana & Ors.
- Neutral Citation: 2025 INSC 160
- Date of Judgment: February 7, 2025
- Coram: Justice B.V. Nagarathna and Justice N. Kotiswar Singh
READ JUDGEMENT HERE:
SC Quashes Suicide Abetment Case; Orders SIT Reinvestigation
While hearing an appeal under Section 482 of the CrPC, the Supreme Court quashed criminal proceedings under Section 306 IPC, questioning whether there was a more sinister aspect to the case of an alleged suicide by a girl. The Court directed the Director General of Police, Uttar Pradesh, to form a Special Investigation Team (SIT) to reinvestigate the unnatural death.
- Case Title: Ayyub & Ors. v. State Of Uttar Pradesh & Anr.
- Neutral Citation: 2025 INSC 168
- Date of Judgment: February 7, 2025
- Coram: CJI Sanjiv Khanna, Justice Sanjay Kumar, and Justice K.V. Viswanathan
READ JUDGEMENT HERE:
Informing an Arrested Person of Grounds of Arrest is a Mandatory Constitutional Requirement
The Supreme Court ruled that informing an arrested person of the grounds for their arrest is not a mere formality but a mandatory requirement under Article 22(1) of the Constitution. The Court clarified that simply informing a person of their arrest is not equivalent to providing them with the reasons for their arrest, emphasizing the distinction between the two.
Case Title: Vihaan Kumar v. State of Haryana & Anr.
Neutral Citation: 2025 INSC 162
Date of Judgment: February 7, 2025
Coram: Justice Abhay S. Oka and Justice Nongmeikapam Kotiswar Singh
READ JUDGEMENT HERE:
SC Acquits Man in Wife’s Murder Case After 10 Years in Jail
The Supreme Court acquitted a man convicted of murdering his wife, ruling that the prosecution failed to produce sufficient evidence to disprove his claim that she died naturally due to illness. The lower courts had convicted him for strangulating his first wife, leading to an appeal before the Apex Court.
Case Title: Ravi v. The State of Punjab
Neutral Citation: 2025 INSC 170
Date of Judgment: February 10, 2025
Coram: Justice Pankaj Mithal and Justice Ahsanuddin Amanullah
READ JUDGEMENT HERE:
SC Clarifies Approach to Settlements in Section 307 IPC Cases
The Court addressed whether the mere mention of Section 307 IPC (attempt to murder) in criminal proceedings mandates a “hands-off approach” by the judiciary when parties reach a settlement. The Court also outlined the tests to determine in which cases settlements should be accepted. It allowed the appeal, setting aside the Allahabad High Court’s ruling under Section 482 CrPC.
- Case Title: Naushey Ali & Ors. v. State of U.P. & Anr.
- Neutral Citation: 2025 INSC 182
- Date of Judgment: February 11, 2025
- Coram: Justice K.V. Viswanathan and Justice S.V.N. Bhatti
READ JUDGMENT HERE:
Total Time-Frame for Substitution and Setting Aside Abatement Under Order XXII CPC is 150 Days
The Court held that the total period for filing an application for substitution and for setting aside abatement under Order XXII of the CPC is 150 days (90 + 60). It set aside the Allahabad High Court’s decision, which had abated a second appeal in a long-standing property dispute. The Bench also clarified that a prayer for setting aside abatement can be considered as a prayer for substitution.
Case Title: Om Prakash Gupta Alias Lalloowa (Now Deceased) & Ors. v. Satish Chandra (Now Deceased)
Neutral Citation: 2025 INSC 183
Date of Judgment: February 11, 2025
Coram: Justice Dipankar Datta and Justice Prashant Kumar Mishra
READ JUDGEMENT HERE:
Compassionate Appointments Should Be Considered Only in “Hand-to-Mouth” Cases
The Supreme Court emphasized that claims for compassionate appointments should only be considered in cases where the family is in financial distress and other eligibility conditions are met. The ruling came in a civil appeal by Canara Bank against a Kerala High Court Division Bench judgment that had dismissed an intra-court appeal.
- Case Title: Canara Bank v. Ajithkumar G.K.
- Neutral Citation: 2025 INSC 184
- Date of Judgment: February 11, 2025
- Coram: Justice Dipankar Datta and Justice Prashant Kumar Mishra
READ JUDGEMENT HERE:
Workplace Admonition by Senior Not an “Intentional Insult” Under Section 504 IPC
The Court ruled that a senior’s admonition at the workplace, if related to discipline and discharge of duties, does not constitute an “intentional insult with intent to provoke” under Section 504 IPC. The ruling was made in a criminal appeal against a Telangana High Court judgment.
- Case Title: B.V. Ram Kumar v. State of Telangana & Anr.
- Neutral Citation: 2025 INSC 194
- Date of Judgment: February 10, 2025
- Coram: Justice Sanjay Karol and Justice Sandeep Mehta
READ JUDGEMENT HERE:
Permanent Alimony & Maintenance Under Section 25 HMA Can Be Granted Even If Marriage is Declared Void
The Supreme Court held that a spouse can seek permanent alimony or maintenance under Section 25 of the Hindu Marriage Act (HMA) even if the marriage is declared void under Section 11 HMA. Additionally, a court can grant maintenance pendente lite under Section 24 HMA if the necessary conditions are met, even in cases where the marriage is voidable.
- Case Title: X v. Y
- Neutral Citation: 2025 INSC 197
- Date of Judgment: February 12, 2025
- Coram: Justice Abhay S. Oka, Justice Ahsanuddin Amanullah, and Justice Augustine George Masih
READ JUDGEMENT HERE :
Doctrine of Proportionality Applies in Contractual Commercial Disputes
The Court reiterated that while judicial review in contractual commercial matters must be exercised with restraint, the doctrine of proportionality applies when an error is apparent and relief is warranted. It set aside the forfeiture of a bank guarantee in a tender dispute involving M/s ABCI Infrastructures Pvt. Ltd. and the Border Roads Organisation (BRO), highlighting the need for pragmatic decision-making in such cases.
- Case Title: M/S ABCI Infrastructures Pvt. Ltd. v. Union of India & Ors.
- Neutral Citation: 2025 INSC 215
- Date of Judgment: February 14, 2025
- Coram: CJI Sanjiv Khanna, Justice Sanjay Kumar, and Justice K.V. Viswanathan
READ JUDGEMENT HERE:
ALSO READ:When Faith Overshadows the Law: Moral Beliefs vs. Legal Boundaries
Principle of Res Judicata Applies to Writ Petitions Under Article 226
The Supreme Court reaffirmed that the principle of res judicata applies even in writ jurisdiction under Article 226 of the Constitution. The ruling came in civil appeals by companies challenging a Bombay High Court (Goa Bench) decision denying a 25% rebate on electricity tariffs.
- Case Title: Puja Ferro Alloys P Ltd. v. State of Goa & Ors.
- Neutral Citation: 2025 INSC 217
- Date of Judgment: February 14, 2025
- Coram: Justice Dipankar Datta and Justice Sandeep Mehta
READ JUDGEMENT HERE:
Accused Must Share Both “Criminal Act” and “Common Intention” Under Section 34 IPC
The Supreme Court upheld the conviction of a mother-in-law who set her daughter-in-law on fire, but acquitted the husband, ruling that mere presence in the house was insufficient to prove shared criminal intent. The decision came in a criminal appeal against a Karnataka High Court judgment that had reversed an acquittal.
- Case Title: Vasant @ Girish Akbarasab Sanavale & Anr. v. The State of Karnataka
- Neutral Citation: 2025 INSC 221
- Date of Judgment: February 11, 2025
- Coram: Justice J.B. Pardiwala and Justice R. Mahadevan
READ JUDGEMENT HERE:
Gratuity Forfeiture Not Contingent on Criminal Conviction if Misconduct Involves Moral Turpitude
The Supreme Court ruled that a criminal conviction is not a prerequisite for the forfeiture of gratuity if the employee’s misconduct, as alleged and proven, amounts to an offence involving moral turpitude. Upholding the forfeiture of an employee’s gratuity, the Court emphasized that an individual whose employment was illegal cannot claim employment benefits such as gratuity.
- Case: Western Coal Fields Ltd. v. Manohar Govinda Fulzele
- Neutral Citation: 2025 INSC 233
- Judgment Date: February 17, 2025
- Bench: Justice Sudhanshu Dhulia and Justice K Vinod Chandran
READ JUDGEMENT HERE:
Conditions in Remission Orders Must Curb Criminal Tendencies
The Court underscored that conditions imposed in orders granting permanent remission should be structured to prevent any potential recurrence of criminal behavior. It directed States and Union Territories without a remission policy under Section 432 CrPC or Section 473 BNSS to draft one within two months. The ruling delved into the nature of conditions that should accompany remission grants.
- Case: In Re: Policy Strategy For Grant Of Bail
- Neutral Citation: 2025 INSC 239
- Judgment Date: February 18, 2025
- Bench: Justice Abhay S Oka and Justice Ujjal Bhuyan
READ JUDGEMENT HERE:
Media Professionals Must Exercise Caution and Responsibility: SC Quashes Defamation Case Against TOI Editorial Director
The Supreme Court quashed a defamation case against Times of India‘s former Editorial Director, Jaideep Bose, emphasizing that media professionals, especially those in key positions, must act with utmost responsibility when publishing news, opinions, or statements. The Court overturned the Karnataka High Court’s decision that had refused to quash the defamation proceedings.
- Case: Jaideep Bose v. M/S. Bid And Hammer Auctioneers Private Limited
- Neutral Citation: 2025 INSC 241
- Judgment Date: February 18, 2025
- Bench: Justice JB Pardiwala and Justice R Mahadevan
READ JUDGEMENT HERE:
Bail Rejections Under Section 437(6) CrPC Require Stronger Justifications Than Initial Bail Denials
The Supreme Court granted bail to an accused in a cryptocurrency scam, clarifying that the reasons for rejecting a bail application under Section 437(6) CrPC must be more substantial than those at the initial stage of bail refusal. The accused was directed to deposit ₹35 lakh with the Trial Court as a bail condition. The case involved an alleged scam where approximately 2000 investors lost nearly ₹4 crore.
- Case: Subhelal @ Sushil Sahu v. The State Of Chhattisgarh
- Neutral Citation: 2025 INSC 242
- Judgment Date: February 18, 2025
- Bench: Justice JB Pardiwala and Justice R Mahadevan
READ JUDGMENT HERE:
ALSO READ: SUPREME COURT MONTHLY RECAP: JANUARY 2025
Supreme Court Summarizes Principles on the Registration of a Second FIR
The Court outlined key principles regarding the admissibility of a second FIR while hearing a Criminal Appeal against a Rajasthan High Court ruling that had quashed an FIR at the accused’s request.
- Case: State of Rajasthan v. Surendra Singh Rathore
- Neutral Citation: 2025 INSC 248
- Judgment Date: February 19, 2025
- Bench: Justice Sanjay Karol and Justice Prashant Kumar Mishra
READ JUDGEMENT HERE:
SC Grants Bail to PMLA Accused, Citing V. Senthil Balaji’s Case
The Supreme Court granted bail to a person accused under the Prevention of Money Laundering Act (PMLA), highlighting that the accused had already spent over a year in incarceration and the trial was unlikely to conclude soon. The appeal challenged the accused’s prolonged detention under Section 3 of PMLA.
- Case: Udhaw Singh v. Enforcement Directorate
- Neutral Citation: 2025 INSC 247
- Judgment Date: February 17, 2025
- Bench: Justice Abhay S. Oka and Justice Ujjal Bhuyan
READ JUDGMENT HERE:
Preliminary Inquiry Not Mandatory Under Prevention of Corruption Act in All Cases
The Court ruled that a preliminary inquiry is not obligatory under the Prevention of Corruption Act if a superior officer finds prima facie evidence of a cognizable offence. It reinstated an FIR against a BESCOM officer accused of possessing disproportionate assets worth over ₹3 crore, overturning a Karnataka High Court order that had quashed the FIR.
- Case: State Of Karnataka v. T.N. Sudhakar Reddy
- Neutral Citation: 2025 INSC 229
- Judgment Date: February 17, 2025
- Bench: Justice Dipankar Datta and Justice Sandeep Mehta
READ JUDGEMENT HERE :
No Mandatory Personal Appearance in DV Act Proceedings Unless Protection Order is Violated
The Supreme Court clarified that personal presence in cases under the Domestic Violence Act, 2005 is not required unless there is a breach of a Protection Order. This ruling arose in a Criminal Appeal where the husband challenged a Calcutta High Court judgment that dismissed his sister’s plea on his behalf.
- Case: ABC v. XYZ
- Neutral Citation: 2025 INSC 254
- Judgment Date: February 20, 2025
- Bench: Justice Pankaj Mithal and Justice Sandeep Mehta
READ JUDGEMENT HERE:
Section 106 IEA Cannot Compensate for Prosecution’s Failure to Prove Circumstances: Supreme Court
The Supreme Court held that Section 106 of the Indian Evidence Act, 1872, cannot be used to compensate for the prosecution’s failure to produce evidence establishing the guilt of the accused. The Court ruled that the burden of proof remains on the prosecution, and only when a prima facie case is established can the accused be called upon to explain circumstances specifically within their knowledge. The judgment overturned the Madhya Pradesh High Court’s acquittal and reinstated the conviction of an accused husband in a murder case.
- Case Title: The State of Madhya Pradesh v. Balveer Singh
- Neutral Citation: 2025 INSC 261
- Date of Judgment: February 25, 2025
- Coram: Justice J.B. Pardiwala and Justice Manoj Misra
READ JUDGEMENT HERE:
Supreme Court Directs States to Ensure Compliance with Rule 170 of Drugs and Cosmetics Act in Misleading Medical Advertisements Case
The Supreme Court, while hearing the Indian Medical Association’s (IMA) plea against misleading advertisements related to allopathic medicines, directed states to ensure strict compliance with Rule 170 of the Drugs and Cosmetics Rules, 1945. The Court criticized several states for their failure to prosecute violators and ordered detailed affidavits regarding enforcement measures. It also reaffirmed that non-compliance with its orders could lead to contempt proceedings. The Bench stressed the duty of states to take proactive action against misleading medical claims.
- Case Title: Indian Medical Association v. Union of India
- Neutral Citation: 2025 INSC 645
- Date of Judgment: February 24, 2025
- Coram: Justice Abhay S. Oka & Justice Ujjal Bhuyan
![[RG Kar Rape-murder case] Indian Medical Association to File Plea to Intervene in SC's Suo motu case](https://i0.wp.com/lawchakra.in/wp-content/uploads/2024/08/image-91-2.png?resize=759%2C422&ssl=1)
Supreme Court Summarizes Principles for Evaluating Child Witness Testimony
The Supreme Court allowed the State of Madhya Pradesh’s appeal and convicted the accused under Sections 302, 201, and 34 IPC, overturning the High Court’s acquittal. The Court laid down key principles for assessing the testimony of child witnesses, reaffirming that:
- Competency of Child Witnesses: The Evidence Act does not prescribe a minimum age for witnesses; a child witness’s testimony cannot be rejected solely due to age.
- Preliminary Examination: Trial courts must assess a child’s ability to understand the sanctity of testimony before recording evidence.
- Judicial Satisfaction: Courts must explicitly state their satisfaction regarding the child’s understanding of truthfulness.
- Recording Demeanor: The demeanor and coherence of child witnesses should be documented.
- Admissibility: If found competent, a child’s testimony is admissible and can be the sole basis for conviction.
- Need for Corroboration: Corroboration is required only if the testimony appears tutored or inconsistent.
- Risk of Tutoring: Courts must ensure child witnesses are not influenced or manipulated.
The Court also reaffirmed principles for evaluating circumstantial evidence and set aside the High Court’s acquittal, convicting the accused.
- Case Title: The State of Madhya Pradesh v. Balveer Singh
- Neutral Citation: 2025 INSC 261
- Date of Judgment: February 25, 2025
- Coram: Justice J.B. Pardiwala & Justice Manoj Misra
READ JUDGEMENT HERE:
Supreme Court: Section 114 Evidence Act Cannot Be Invoked If Mistaken Identification Is Possible
The Supreme Court set aside the conviction of the appellant under Sections 120B and 411 IPC, ruling that Section 114 of the Evidence Act cannot be invoked when mistaken identification is a possibility. The case involved alleged fraudulent remittances of ₹6.7 crores through fake telegraphic transfers at Vijaya Bank, with a subsequent seizure of 205 gold bars from the appellant’s shop.
The Trial Court convicted the appellant but directed the return of the seized gold. The Bombay High Court upheld the conviction and ordered confiscation of the gold bars. The Supreme Court, however, found that the prosecution failed to establish a conclusive link between the seized gold and the alleged fraud. It emphasized that suspicion cannot substitute proof beyond reasonable doubt and held that the appellant was entitled to the return of the gold bars.
Accordingly, the Court allowed the appeal, acquitted the appellant, and directed the return of the 205 gold bars.
Case Title: Hiralal Babulal Soni v. State of Maharashtra & Ors.
Neutral Citation: 2025 INSC 266
Date: February 27, 2025
Bench: Justice B.R. Gavai, Justice Prashant Kumar Mishra, Justice K.V. Viswanathan
READ JUDGEMENT HERE:
Supreme Court Upholds Validity of Arrest Provisions Under Customs and GST Acts
The Supreme Court has upheld the constitutional validity of the provisions granting authorized officers the power to arrest under the Customs Act, 1962, and the Central Goods and Services Tax Act, 2017 (GST Act). A three-judge bench comprising CJI Sanjiv Khanna, Justice M.M. Sundresh, and Justice Bela M. Trivedi dismissed the challenge, clarifying the preconditions and proper exercise of arrest powers.
The case stemmed from legal controversy arising from Om Prakash v. Union of India (2011), which had held that customs and excise offences were non-cognizable and bailable. However, the Court noted that subsequent amendments (2012, 2013, and 2019) had explicitly made certain offences cognizable and non-bailable under Section 104 of the Customs Act. It also affirmed that a person arrested under the Act has the right to meet an advocate during interrogation but not throughout.
Regarding the GST Acts, the Court rejected challenges to Sections 69 and 70, affirming that the power to summon and arrest is an essential aspect of tax enforcement under Article 246-A of the Constitution. It clarified that summons under Section 70 do not automatically confer accused status under Article 20(3) of the Constitution.
In a concurring opinion, Justice Bela Trivedi emphasized the need for judicial review of arrests under Special Acts to be exercised cautiously, ensuring a balance between individual liberty and societal interests.
- Case Title: Radhika Agarwal v. Union of India & Ors.
- Neutral Citation: 2025 INSC 272
- Date: February 27, 2025
- Bench: CJI Sanjiv Khanna, Justice M.M. Sundresh, Justice Bela M. Trivedi
READ JUDGEMENT HERE:
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