As we step into April , it’s essential to reflect on the most impactful judicial pronouncements of March 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 April , it’s important to reflect on the most impactful judicial pronouncements of March 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 March 2025, highlighting their key takeaways, legal reasoning, and potential ramifications.
Supreme Court Quashes Rape Case, Holds 16-Year Consensual Relationship Indicates Absence of Force or Deceit
In Rajnish Singh @ Soni v. State of U.P. & Anr. (Neutral Citation: 2025 INSC 308), the Supreme Court quashed a rape case, ruling that a prolonged 16-year sexual relationship between the parties was sufficient to conclude that there was no element of force or deceit.
The Court set aside the order of the Allahabad High Court, which had dismissed the appellant’s petition under Section 482 of the CrPC seeking to quash proceedings under Sections 376, 384, 323, 504, and 506 of the IPC. The complainant had alleged that the appellant engaged in a physical relationship with her for 16 years under false assurances of marriage.
The judgment was delivered on March 3, 2025, by a bench comprising Justice Vikram Nath and Justice Sandeep Mehta.
CASE TITLE: Rajnish Singh @ Soni v. State of U.P. & Anr.
Neutral Citation: 2025 INSC 308
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Supreme Court Reinstates Two Terminated Women Judges, Holds Termination Punitive and Stigmatic
In Sarita Choudhary v. High Court of Madhya Pradesh & Connected Matters (W.P. (C) No. 142/2024), the Supreme Court set aside the termination of two female civil judges from Madhya Pradesh, ruling that their dismissal during probation was punitive, arbitrary, and illegal.
The Bench of Justice B.V. Nagarathna and Justice N.K. Singh directed their reinstatement within 15 days, with their probation aligned with their juniors and monetary benefits calculated notionally for pensionary purposes.
The Court found contradictions in the adverse confidential reports (ACRs) and held that the judges were not given a fair opportunity to respond to complaints, making the termination stigmatic. Addressing broader concerns, the Court emphasized the need to protect women judges from discrimination related to pregnancy and miscarriage.
Additionally, any pending complaints against them must be resolved as per the law. The judgment, delivered on February 28, 2025, commended Senior Advocate Gaurav Agarwal for his role as amicus curiae.
CASE TITLE: Sarita Choudhary v. High Court of Madhya Pradesh & Connected Matters
Neutral Citation: W.P. (C) No. 142/2024
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Supreme Court Sets Aside Death Sentence, Citing Insufficient Evidence in Rape-Murder Case
In Sanjay v. State of Uttar Pradesh (Neutral Citation: 2025 INSC 317), the Supreme Court set aside the conviction and death sentence of a man accused of raping and murdering a four-year-old girl, holding that the prosecution failed to establish guilt beyond reasonable doubt.
The Court overturned the Allahabad High Court’s judgment, which had confirmed the appellant’s conviction under Sections 302 and 376(2)(G) of the IPC and sentenced him to death.
The three-judge Bench comprising Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta observed that the only circumstance against the accused was the “last-seen theory,” which alone cannot form the basis of conviction. The Court found inconsistencies in witness testimonies and noted that the prosecution’s evidence was neither clear nor unimpeachable.
It reiterated that conviction must be based on legal proof rather than moral conviction. The judgment was delivered in March 2025, with Senior Advocate S. Muralidhar representing the appellant and Senior AAG Garima Prasad along with ASG Suryaprakash V. Raju appearing for the State.
CASE TITLE: Sanjay v. State of Uttar Pradesh
Neutral Citation: 2025 INSC 317
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Supreme Court Mandates Completion of Execution Proceedings Within Six Months, Holds Presiding Officers Accountable
In Periyammal (Dead) Through LRs & Ors. v. V. Rajamani & Anr. Etc. (Neutral Citation: 2025 INSC 329), the Supreme Court directed all High Courts to collect data on pending execution petitions and issue administrative orders ensuring their disposal within six months, with presiding officers held accountable for delays.
The Court overturned the Madras High Court’s judgment, which had rejected the appellants’ revision petitions and upheld the Additional Subordinate Judge’s (ASJ) orders allowing an application under Section 47 of the CPC while rejecting an amendment to the execution petition. The case stemmed from a 1983 suit for specific performance concerning a sale agreement, where the trial court ruled in favor of the appellants. Subsequent appeals and legal battles delayed execution, with the respondents claiming lack of notice in execution proceedings.
The Supreme Court found that the High Court erred in its ruling and emphasized that execution courts must enforce decrees efficiently. It ordered vacant and peaceful possession of the property to be handed over to the appellants within two months, even with police aid if necessary, while also directing High Courts to submit reports on execution delays to the Supreme Court Registry.
The judgment was delivered by a bench comprising Justice J.B. Pardiwala and Justice Pankaj Mithal.
CASE TITLE: Periyammal (Dead) Through LRs & Ors. v. V. Rajamani & Anr. Etc.
Neutral Citation: 2025 INSC 329
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Supreme Court Upholds Conviction Under POCSO Act, Clarifies Scope of Sections 42 and 42A
In Gyanendra Singh @ Raja Singh v. State of UP (Neutral Citation: 2025 INSC 335), the Supreme Court upheld the conviction of a man for sexually assaulting his minor daughter, ruling that Section 42A of the POCSO Act cannot override the mandate of Section 42, which prescribes applying the law with the greater degree of punishment when an offence falls under both the IPC and POCSO Act. The appellant challenged the Allahabad High Court’s dismissal of his Jail Appeal against conviction under Sections 376(2)(f) and 376(2)(i) of the IPC and Sections 3/4 of the POCSO Act.
The trial court sentenced him to life imprisonment, which the High Court upheld while specifying that it would extend for the remainder of his natural life. The Supreme Court, while affirming the conviction, modified the sentence, clarifying that life imprisonment does not necessarily mean imprisonment for the convict’s entire natural life unless expressly mandated by law.
Referring to Veerendra v. State of Madhya Pradesh (2008), the Court held that a fixed term of 30 years would suffice. The bench of Justice Vikram Nath and Justice Sandeep Mehta reinstated the trial court’s sentence without the stipulation of life imprisonment till the appellant’s natural life, imposing a fine of ₹5,00,000, with a default sentence of two years.
CASE TITLE: Gyanendra Singh @ Raja Singh v. State of UP
Neutral Citation: 2025 INSC 335
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Supreme Court Stays Lokpal’s Jurisdiction Over Sitting High Court Judges: Constitutional Autonomy at Stake
In IN RE: ORDER DATED 27/01/2025 PASSED BY LOKPAL OF INDIA AND ANCILLARY ISSUES, SMW(C) No. 2/2025, the Supreme Court stayed a Lokpal order attempting to bring sitting High Court judges under its jurisdiction, raising concerns over judicial independence. The Lokpal, in response to a complaint against an Additional Judge of a High Court, ruled that judges of High Courts established by an Act of Parliament fall within its jurisdiction under Section 14 of the Lokpal and Lokayuktas Act, 2013.
However, the Supreme Court took suo moto cognizance, expressing serious reservations about the ruling’s implications on the separation of powers and judicial autonomy. The Bench, comprising Justices B.R. Gavai, Surya Kant, and A.S. Oka, emphasized that statutory bodies like the Lokpal cannot investigate sitting judges, citing Article 50 of the Constitution and the precedent set in K. Veeraswamy v. Union of India (1991).
CASE TITLE: IN RE: ORDER DATED 27/01/2025 PASSED BY LOKPAL OF INDIA AND ANCILLARY ISSUES
Neutral Citation: SMW(C) No. 2/2025
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Supreme Court Overturns Acquittal in 1986 Rape Case, Reinstates Conviction for Accused in Landmark Judgment
In a landmark decision, the Supreme Court of India reinstated the conviction of an accused man who had been acquitted by the Rajasthan High Court in a 1986 rape case. The victim, a minor at the time, had remained silent during her testimony, shedding only tears, which the Court acknowledged as a manifestation of trauma rather than inconsistency.
The Supreme Court emphasized that
“Such silence should not be used to discredit the victim’s case, especially in cases of child sexual abuse. Reaffirming the need for sensitivity towards victims of trauma”
the Court held that
“A victim’s silence, coupled with medical and circumstantial evidence, could still support a conviction”
The ruling highlighted the judiciary’s responsibility to consider all available evidence and not rely solely on the victim’s direct testimony, thus reinstating the original conviction and sentence. This judgment highlights the importance of judicial commitment to justice for victims of sexual violence, particularly when trauma affects their ability to testify.
CASE TITLE: State of Rajasthan v. Chatra
Neutral Citation: 2025 INSC 360
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Supreme Court Clarifies Procedure for Invoking Section 156(3) CrPC
In a significant ruling, the Supreme Court reaffirmed the procedural requirements for invoking Section 156(3) of the Criminal Procedure Code, 1973 (CrPC). The Court emphasized that a complainant must first approach the Officer In-Charge of the police station under Section 154(1) and, if refused, escalate the matter under Section 154(3) before seeking directions under Section 156(3).
The judgment quashed an order that had directed the registration of an FIR, as the complainant had initially addressed the complaint to the Inspector General of Police, bypassing the prescribed procedure. The Court reiterated
“the importance of complying with Section 154(1) and 154(3) and stressed that the absence of such compliance renders an application under Section 156(3) premature”
The ruling serves as a reminder of the necessity for procedural discipline in criminal law remedies and the requirement for supporting affidavits to ensure accountability in the complaints process.
CASE TITLE: Ranjith Singh Bath & Anr. v. Union Territory of Chandigarh & Anr.
Neutral Citation: Criminal Appeal No. 4313/2024
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Supreme Court Prioritizes Appeals for Elderly Accused and Long-Pending Cases in Expedited Hearings
The Supreme Court of India has emphasized the need to prioritize certain appeals against conviction, particularly in cases involving elderly accused individuals who have been on bail for a prolonged period, and appeals that have been pending for an extended time.
The Court made this observation while dismissing the State of Madhya Pradesh’s appeal in a 36-year-old murder case. The Court highlighted the necessity of balancing justice by considering the advanced age of the accused and the significant time that has passed since the offense. In this case, the accused, who were initially sentenced to life imprisonment, had already served their sentence.
The Madhya Pradesh High Court had acquitted them, considering their age and the nature of the injuries inflicted, which were not deemed to be life-threatening. Upon reviewing the case, the Supreme Court found no conclusive medical evidence linking the assault to the death of the victim and upheld the High Court’s decision. This ruling reinforces the principle that long-pending criminal appeals involving elderly individuals on bail should be expedited to prevent undue hardship due to delays in the judicial process.
Case Title: State of Madhya Pradesh v. Shyamlal & Ors.
Neutral Citation: 2025 INSC 377
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Supreme Court Mandates FIR Registration for Cognizable Offences; No Preliminary Inquiry Allowed
In a landmark ruling in Amit Kumar & Ors. v. Union of India & Ors. (2025 INSC 384), the Supreme Court reinforced the mandatory registration of an FIR under Section 154 of the CrPC for cognizable offences, eliminating the scope for preliminary inquiries. The case arose from the tragic suicides of two IIT Delhi students, where the families alleged caste-based discrimination, but the police had dismissed the claims after a preliminary inquiry.
The Court directed the registration of an FIR, emphasizing that law enforcement must act promptly and transparently when a cognizable offence is disclosed. The Court also issued
“guidelines for mandatory FIR registration, time-bound preliminary inquiries, and accountability for police officers who fail to register an FIR”
Additionally, the ruling highlighted the increasing trend of student suicides and ordered the formation of a National Task Force to address mental health issues in academic institutions, underscoring the need for institutional responsibility in safeguarding student welfare.
Case Title: Amit Kumar & Ors. v. Union of India & Ors.
Neutral Citation: 2025 INSC 384
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ALSO READ: SUPREME COURT MONTHLY RECAP: FEBRUARY 2025
Supreme Court Reaffirms That Delay in Witness Statements Does Not Benefit Accused
In Firoz Khan Akbarkhan v. The State of Maharashtra (2025 INSC 387), the Supreme Court ruled that a delay in recording witness statements does not automatically benefit the accused, provided the delay is satisfactorily explained.
The case involved the conviction of Firoz Khan Akbarkhan for murder under Sections 302 and 34 of the IPC, following a fatal altercation with the deceased. The Court upheld the Trial and High Court’s decisions, noting the credibility and consistency of the eyewitness testimonies.
It emphasized that
“minor discrepancies in witness statements do not weaken the prosecution’s case, and that intent to kill was evident from the manner of the attack”
The Court also addressed premature release, directing the State to examine the appellant’s request for remission.
This ruling reinforces the notion that procedural delays in witness testimony must be considered in context, and a conviction for murder under Section 302 IPC can only be altered on compelling legal grounds.
Case Title: Firoz Khan Akbarkhan v. The State of Maharashtra
Neutral Citation: 2025 INSC 387
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Supreme Court Acquits Murder Accused, Citing Investigative Lapses and Unreliable Evidence
In Arun & Ors. v. State of Madhya Pradesh, 2025 INSC 406, the Supreme Court of India acquitted four individuals previously convicted of murder, citing unreliable witness testimonies and investigative delays that undermined the prosecution’s case.
The Court highlighted that
“the unexplained delay in recording key witness statements raised concerns about their credibility. Additionally, inconsistencies between the First Information Report and trial testimonies, along with contradictions in medical evidence regarding the cause of death, further weakened the prosecution’s narrative“
Emphasizing the principle that convictions cannot rest solely on doubtful testimonies, the Court set aside the convictions and sentences, underscoring the necessity for timely investigations and credible evidence in criminal trials.
Case Title: Arun & Ors. v. State of Madhya Pradesh
Neutral Citation: 2025 INSC 406
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Supreme Court Upholds Free Speech, Quashes FIR Against Imran Pratapgadhi
In a landmark ruling, the Supreme Court quashed an FIR against Congress MP Imran Pratapgadhi over a social media post, reaffirming the fundamental right to free speech and emphasizing that expression should be countered with discourse, not suppression.
The Bench, comprising Justice Abhay S. Oka and Justice Ujjal Bhuyan, ruled that
“the allegations did not constitute a cognizable offense under Section 173(1) of the Bharatiya Nyaya Sanhita (BNS), stressing that law enforcement must diligently assess speech-related complaints before initiating legal proceedings”
The Court reiterated that free expression is essential for a dignified life under Article 21 of the Constitution, cautioning against the arbitrary use of legal provisions to stifle dissent. Highlighting the importance of debate over suppression, the ruling strengthens India’s democratic framework by ensuring restrictions on speech are reasonable and justifiable.
Case Title: Imran Pratapgadhi v. State of Gujarat 2025 INSC 410
Neutral Citation: 2025 INSC 410
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