SUPREME COURT MONTHLY RECAP: MAY 2025

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As we step into June , it’s essential to reflect on the most impactful judicial pronouncements of May 2025 of Supreme court. This monthly recap below lists a series of significant rulings that have shaped legal discourse across various domains.

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SUPREME COURT MONTHLY RECAP: MAY 2025

NEW DELHI: As we step into June, it’s important to reflect on the most impactful judicial pronouncements of May 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 monthly recap, we examine the most important judgments of May 2025, highlighting their key takeaways, legal reasoning, and potential ramifications.

SUPREME COURT MONTHLY RECAP: MAY 2025

The Supreme Court in Kamla Nehru Memorial Trust & Anr. v. U.P. State Industrial Development Corporation Ltd. & Ors. (2025 INSC 791) upheld the cancellation of allotment of 125 acres of industrial land to Kamla Nehru Memorial Trust (KNMT) by the UPSIDC, finding that KNMT had failed to comply with essential payment terms and did not execute the lease deed despite multiple opportunities.

The Court observed that the allotment was conditional and KNMT, being a chronic defaulter, repeatedly delayed payments even after rescheduling and issued repeated representations to avoid its contractual obligations. The claim that UPSIDC failed to demarcate or hand over possession of the land was rejected, as the record showed that demarcation had been done and possession was to follow only after lease registration, which KNMT failed to pursue.

Addressing procedural compliance, the Court held that UPSIDC had followed the due process laid down under Clause 3.04 of its Manual by issuing three valid legal notices before cancellation. Importantly, the Court invoked the Public Trust Doctrine, stating that the initial swift allotment to KNMT lacked transparency and violated principles of fair and responsible use of public resources.

It further declared the subsequent allotment to M/s Jagdishpur Paper Mills Ltd. illegal and annulled it. The Court directed that any future allotment of the subject land must strictly follow a transparent, competitive, and public interest-oriented procedure, in alignment with administrative propriety and constitutional principles. The appeals were accordingly dismissed with no order as to costs.

Consequently, the Supreme Court upheld the cancellation of KNMT’s land allotment, holding it procedurally valid under Clause 3.04 of the Manual, and emphasized that future public land allotments must follow transparent, fair, and non-discriminatory processes in public interest.

Case Title: Kamal Nehru Memorial Trust & Ars. V. U.P. State Industrial Development Corporation Limited & Ors.

Citation: 2025 INSC 791

SUPREME COURT MONTHLY RECAP: MAY 2025

In landmark judgment, All India Judges Association v. Union of India, (2025 INSC 735), the Supreme Court held that the three-year practice requirement begins from the date of provisional enrolment, not AIBE clearance.

The Court refered to the “Third AIJA Case” and said,

“It can be seen that, in the Third AIJA Case, while this Court had accepted the recommendations of the Shetty Commission, which recommended an increase in the PayScales of the subordinate judiciary, this Court also emphasized the necessity of Judicial Officers becoming more efficient.”

The Court further Observed that,

“It was for that reason, the Shetty Commission had recommnended the establishment Of a Judicial Academy.”

The Supreme Court’s decision to restore the three-year legal practice requirement is a balanced and considered step aimed at improving the quality and effectiveness of India’s subordinate judiciary. It’s ultimate promise is ‘experienced, emotionally intelligent, and better-equipped judicial workforce‘.

This ruling reinforces a vital principle: 

“Wisdom in law is not solely taught in classrooms, it is earned through real-world experience, shaped in courtrooms, and refined through the responsibility of delivering justice.”

Case Title: All India Judges Association v. Union of India

Citation: 2025 INSC 735

SUPREME COURT MONTHLY RECAP: MAY 2025

On 30th May,the Supreme Court of India has cancelled the bail of four people who were accused of attacking a house, vandalising it, and attempting to sexually harass a woman during the post-election violence in West Bengal in 2021.

The Court called this act “grave attack on the root of democracy” and ordered the accused to surrender within two weeks. The Supreme Court was firm in its view and said that the accused must be taken into custody again. It also ordered the trial court to complete the entire trial within six months.

The Court further directed the West Bengal state home secretary and the Director General of Police to ensure the safety and protection of the complainant and all key witnesses in the case. Aditionally, it said that  allowing the accused to remain free on bail could disturb the trial process and affect the fairness of the proceedings.

The bench added that if there are any stay orders passed by any other court, including the high court, on this trial, they will now be considered cancelled.

Case Title: Central Bureau of Investigation v. Sekh Jamir Hossain and Ors

Citation: 2025 INSC 788

SUPREME COURT MONTHLY RECAP: MAY 2025

In this landmark ruling, the Supreme Court set aside the Gauhati High Court’s dismissal of a PIL concerning 171 alleged fake police encounters in Assam between May 2021 and August 2022. The Court observed that while the petitioner failed to conclusively prove violations of the PUCL guidelines, the gravity of the Article 21 concerns justified further inquiry. It also highlighted delays in forensic analysis and inconsistent magisterial inquiries by state authorities.

Recognizing the need for impartial investigation, the Court entrusted the Assam Human Rights Commission headed by a retired Chief Justice—to independently inquire into the alleged encounters. It ordered the AHRC to issue public notices, invite victims’ families to participate confidentially, and, if necessary, initiate further investigation with independent officers. The State of Assam and Legal Services Authority were directed to extend full support and legal aid. The appeal was accordingly allowed.

Acknowledging the need for impartial inquiry, the Court assigned the Assam Human Rights Commission, led by a retired Chief Justice, to investigate the alleged encounters. It directed public notices, victim participation, and independent probes if required, with full state and legal aid support.

Case Title: ARIF MD YEASIN JWADDER Versus THE STATE OF ASSAM AND ORS.

Citation: 2025 INSC 785

SUPREME COURT MONTHLY RECAP: MAY 2025

In Dileep Kumar Pandey v. Union of India & Ors., (2025) INSC 749, the Supreme Court held that the Air Force School, Bamrauli, is not a “State” or “authority” under Article 12 of the Constitution and is therefore not amenable to writ jurisdiction under Article 226.

The Court observed that the school is managed by a private society, primarily funded through non-public sources such as student fees and welfare contributions, without direct financial assistance or administrative control from the government or the Indian Air Force.

It emphasized that while the school imparts education—a public function—this alone does not attract constitutional scrutiny unless there is deep and pervasive state control or statutory obligation, which was not present in this case.

The Court concluded that the teachers’ employment was based on a private contract, and disputes arising from it lacked a public law element. Accordingly, the appeals were dismissed, though other remedies available to the appellants were left open.

Case Title: Dileep Kumar Pandey v. Union of India & Ors.

Citation: 2025 INSC 749

SUPREME COURT MONTHLY RECAP: MAY 2025

In the final judgment delivered on 23 May 2025, the Supreme Court in In Re: Right to Privacy of Adolescents (2025 INSC 778) addressed the systemic failure in protecting the rights of a minor girl who became pregnant at age 14.

The Court observed that the child had been failed not just by the accused, but by the state machinery, legal system, and society at large. Despite the High Court’s acquittal of the accused, the Supreme Court found that the evidence, including a valid birth certificate and DNA report—established guilt under Sections 376(2)(n) and 376(3) IPC, and Section 6 of the POCSO Act.

However, invoking Article 142 of the Constitution, the Court chose not to impose further sentence, considering the victim’s desire to move on with her life, her reconciliation with the accused, and the welfare of the child born from the incident.

The Court expressed deep concern about the lack of timely intervention by the police, Child Welfare Committee, and hospital authorities, noting that the girl delivered a child alone in a shelter home, which highlighted a violation of her dignity and privacy under Article 21. It emphasized the need for comprehensive adolescent sexual health education, child-friendly justice, and strict adherence to the POCSO Act, Juvenile Justice Act, and other protective laws.

The Court issued systemic directions to state authorities, including educational, financial, and medical support for the child and the victim, and mandated the State of West Bengal to file compliance reports. The matter was kept open for further monitoring, with the next hearing scheduled for 25 July 2025.

Case Title: In Re: Right to Privacy of Adolescents

Citation: 2025 INSC 778

SUPREME COURT MONTHLY RECAP: MAY 2025

In its final judgment dated 9 May 2025, the Supreme Court in Wikimedia Foundation Inc. v. ANI Media Pvt. Ltd. [(2025) INSC 656] set aside the Delhi High Court’s direction that required Wikimedia to take down certain user-generated pages and discussions hosted on its platform.

The High Court had found those pages to amount to interference in court proceedings and a violation of the sub judice rule, bordering on contempt. However, the Supreme Court held that the High Court’s reaction was disproportionate and not based on a clear demonstration of real and substantial risk to the administration of justice.

The Court emphasized that freedom of speech and expression under Article 19(1)(a) and the right to know under Article 21 are fundamental to a democracy. Citing prior rulings, including Sahara India and Reliance Petrochemicals.

The Court reiterated that judicial orders restricting speech must meet the tests of necessity and proportionality, and must only be used in the presence of an imminent and real danger to justice. The Bench also referred to Swapnil Tripathi and Naresh Mirajkar to highlight the constitutional importance of open courts and public scrutiny of judicial proceedings.

The Court declined to examine Wikimedia’s status as an “intermediary” under the IT Act, stating that it would not interfere with issues under trial in the pending suit. Nonetheless, it concluded that the High Court’s direction to delete the pages without detailed reasoning or evidence of prejudice, could not be sustained, and therefore set aside the High Court’s order.

Case Title: Wikimedia Foundation Inc. v. ANI Media Pvt. Ltd.

Citation: 2025 INSC 656

SUPREME COURT MONTHLY RECAP: MAY 2025

In its final judgment dated 29 April 2025, the Supreme Court in Rohan & Others v. State of Gujarat [(Criminal Appeal No. 2284 of 2025)] allowed the appeal and quashed the criminal proceedings initiated by the complainant-wife under an FIR filed on 30 September 2023.

The Court observed that the allegations claiming the husband misrepresented himself as an eye surgeon instead of an optometrist and hid his skin condition (leukoderma) were clearly unfounded, as the record showed that the complainant was fully aware of both facts prior to and during the marriage. The Court examined WhatsApp chats and documents and held that there was no attempt by the appellant to deceive the complainant.

The Court remarked that the FIR was lodged for extraneous reasons and that continuing such proceedings would amount to an abuse of the legal process. It held that the High Court erred in dismissing the petition for quashing the FIR under Section 482 CrPC and should have exercised its discretion to prevent misuse of the criminal justice system.

Accordingly, the Court quashed the FIR and criminal proceedings, allowed the appeal, and disposed of all pending applications.

Case Title: Rohan & Others vs. State of Gujarat & Another

Citation: C.A. No. 2284 of 2025

SUPREME COURT MONTHLY RECAP: MAY 2025

In its final judgment dated May 2, 2025, the Supreme Court in Kabir Paharia v. National Medical Commission & Others [(2025) INSC 623] set aside the Delhi High Court’s order and allowed the appeal of the petitioner, a Scheduled Caste candidate with benchmark disability, who was denied admission to the MBBS course despite qualifying NEET-UG 2024 with high merit.

The Court held that the denial of admission—based solely on rigid application of the NMC’s medical norms—was arbitrary, discriminatory, and violated the petitioner’s fundamental rights under Articles 14, 16, and 21 of the Constitution.

The Court relied on precedents from Om Rathod and Anmol cases, reaffirming that reasonable accommodation and use of assistive technologies must be considered while assessing eligibility of persons with disabilities.

Following a prior direction of the Court, the petitioner was re-evaluated by a five-member expert board at AIIMS, New Delhi, which found that he could satisfactorily perform key clinical skills such as chest compressions, intubation, and suturing using functional adaptation techniques. The only minor difficulty noted was in wearing sterilized gloves, which the Court rightly concluded was not a valid ground to deny medical education.

Accordingly, the Court ordered that the petitioner be admitted in the 2025–26 MBBS academic session under the SC-PwBD quota at AIIMS, New Delhi, and exempted him from retaking the NEET-UG exam. The National Medical Commission was also directed to revise its guidelines on disability eligibility in light of constitutional protections and prior rulings—within two months, and before the next admission cycle begins.

The Court emphasized that reasonable accommodation is not a matter of charity but a constitutional obligation, and systemic discrimination against disabled persons must be eliminated through inclusive, individualized assessment and policy reform. The appeal was thus allowed in full, and the impugned orders were set aside.

Case Title: Kabir Paharia vs NMC

Citation: 2025 INSC 623

SUPREME COURT MONTHLY RECAP: MAY 2025

In its final judgment dated April 30, 2025, the Supreme Court in ASF Buildtech Pvt. Ltd. v. Shapoorji Pallonji & Co. Pvt. Ltd. [(2025) INSC 616] dismissed the appeal filed by ASF Buildtech challenging its impleadment in arbitration proceedings.

The Court upheld the Delhi High Court’s order that allowed Shapoorji Pallonji to implead ASF Buildtech—a non-signatory to the arbitration agreement on the basis of the Group of Companies Doctrine. The Court observed that ASF Buildtech, though not a direct party to the agreement, was intimately connected with the performance of the contract and had actively participated in related transactions, justifying its inclusion in arbitration.

Justice J.B. Pardiwala emphasized that arbitral tribunals have jurisdiction to pierce the corporate veil in appropriate cases and implead entities that are part of the same corporate group when they have played a “direct role in the negotiation, performance, or termination of the contract”.

The Court reaffirmed its earlier rulings in Chloro Controls (India) Pvt. Ltd. v. Severn Trent Water Purification Inc. and Cox and Kings Ltd. v. SAP India Pvt. Ltd., recognizing the legitimacy of binding non-signatories in multi-party, multi-agreement disputes where the involvement is commercially and contractually intertwined.

The Court held that mere corporate separation could not be used to avoid arbitral jurisdiction when facts revealed that ASF Buildtech was effectively involved in the transaction structure. Consequently, the appeal was dismissed, and the inclusion of ASF Buildtech in the ongoing arbitration was upheld.

Case Title: ASF Buildtech Private Limited v. Shapoorji Pallonji and Company Private Limited 

Neutral Citation: 2025 INSC 616

SUPREME COURT MONTHLY RECAP: MAY 2025

In its final judgment, the Supreme Court in Aman Bhatia v. State (GNCT of Delhi) [(2025) INSC 618] acquitted the appellant, setting aside his conviction under Sections 7 and 13(1)(d) read with Section 13(2) of the Prevention of Corruption Act, 1988. The appellant had been accused of accepting a bribe from a stamp vendor for official work related to the issuance of identity cards.

However, the Court held that the prosecution failed to prove the essential element of “demand” for illegal gratification, which is a necessary condition for conviction under both Sections 7 and 13(1)(d) of the PC Act.

The Bench, led by Justice J.B. Pardiwala, reiterated settled law that mere possession or recovery of tainted currency is not enough to sustain conviction unless there is clear and independent proof of prior demand.

The Court found contradictions in the prosecution’s version, noted the absence of any reliable corroboration for demand, and observed that the complainant’s testimony was insufficient on its own. Further, the shadow witness’s version lacked consistency.

Accordingly, the Court concluded that the benefit of doubt must go to the accused, and interference with the concurrent findings of the lower courts was justified in the interest of justice. The conviction and sentence were set aside, and the appellant was acquitted of all charges.

Case Title: Aman Bhatiya vs State (GNCT of Delhi)

Neutral Citation: 2025 INSC 618

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author

Aastha

B.A.LL.B., LL.M., Advocate, Associate Legal Editor

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