As we step into February, it’s essential to reflect on the most impactful judicial pronouncements of January 2025. This month witnessed a series of significant rulings that have shaped legal discourse across various domains, including constitutional law, criminal justice, corporate regulations, and human rights. From Supreme Court verdicts setting new precedents to High Court rulings with far-reaching implications, these decisions play a crucial role in interpreting and evolving the legal landscape.
NEW DELHI: As we step into February, it’s essential to reflect on the most impactful judicial pronouncements of January 2025. This month witnessed a series of significant rulings that have shaped legal discourse across various domains, including constitutional law, criminal justice, corporate regulations, and human rights. From Supreme Court verdicts setting new precedents to High Court rulings with far-reaching implications, these decisions play a crucial role in interpreting and evolving the legal landscape.
In this recap, we analyze the most important judgments of January 2025, breaking down their key takeaways, legal reasoning, and potential ramifications.
State Government’s consent not required for CBI to register FIR under a Central Act solely because a Central Government employee operates within the State’s territory.
The Supreme Court ruled that the consent of the State Government is not required for the CBI to register an FIR in connection with an offence under a Central Act, solely because the accused is a Central Government or Central Government Undertaking employee working within the State’s territory. This observation was made while deciding criminal appeals filed by the Central Bureau of Investigation (CBI) against a common judgment of the Andhra Pradesh High Court.
Case Title: The State, Central Bureau of Investigation v. A. Satish Kumar & Ors.
Neutral Citation: 2025 INSC 11
Date of Judgment: January 2, 2025
Coram: Justice C.T. Ravikumar and Justice Rajesh Bindal
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Adoption by Widow Relates Back to Husband’s Death: SC Declares Gift Deed Null & Void
The Supreme Court, applying the Doctrine of Relation Back, held:
“an adoption by the widow takes effect from the date of her husband’s death“
Consequently, the Court declared a Gift Deed null and void. The ruling came in civil appeals challenging a common judgment of the Karnataka High Court, Dharwad Bench, which arose from the judgment and decree of the Additional Senior Civil Judge.
Case Title: Mahesh v. Sangram & Ors.
Neutral Citation: 2025 INSC 14
Date of Judgment: January 2, 2025
Coram: Justice C.T. Ravikumar and Justice Prashant Kumar Mishra
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Validity of Will’s Execution Different from Its Genuineness: SC
The Supreme Court observed that determining a Will’s valid execution is distinct from affirming its genuineness. This observation was made while hearing an appeal against a Bombay High Court Division Bench judgment, which had overturned the decision of a Single Judge in a testamentary suit.
Case Title: Lilian Coelho & Ors. v. Myra Philomena Coelho
Neutral Citation: 2025 INSC 7
Date of Judgment: January 2, 2025
Coram: Justice C.T. Ravikumar and Justice Sudhanshu Dhulia
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Litigant Cannot Seek Relief Without Clean Hands: SC
The Supreme Court reaffirmed that a litigant who does not approach the Court with clean hands is not entitled to be heard or granted relief. This ruling came in civil appeals challenging a common judgment of the Karnataka High Court, which had dismissed the writ appeals.
Case Title: M/s. Maxim India Integrated Circuit Design (P) Ltd. v. Andappa (D) By LRs. & Ors.
Neutral Citation: 2025 INSC 17
Date of Judgment: January 2, 2025
Coram: Justice C.T. Ravikumar and Justice Sanjay Kumar
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Written Complaint by Public Servant Mandatory for Cognizance Under Section 186 IPC: SC
The Supreme Court ruled that a written complaint by a public servant is a prerequisite for a court to take cognizance of an offence punishable under Section 186 of the Indian Penal Code (IPC). This ruling was made in a criminal appeal challenging an Allahabad High Court judgment that had dismissed a plea seeking to quash the chargesheet, cognizance order, summons, and proceedings under Sections 353 and 186 IPC.
Case Title: B.N. John v. State of U.P. & Anr.
Neutral Citation: 2025 INSC 4
Date of Judgment: January 2, 2025
Coram: Justice B.V. Nagarathna and Justice N. Kotiswar Singh
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Intent to Outrage Modesty Essential for Section 354 IPC: SC Quashes Case
The Supreme Court quashed a case under Section 354 of the Indian Penal Code (IPC) against the accused, emphasizing that the application of force must be accompanied by intent to outrage a woman’s modesty. This ruling came in a criminal appeal challenging an Allahabad High Court judgment that had rejected the accused’s plea to quash the chargesheet and proceedings under Sections 354 and 506 IPC.
Case Title: Naresh Aneja @ Naresh Kumar Aneja v. State of Uttar Pradesh & Anr.
Neutral Citation: 2025 INSC 19
Date of Judgment: January 2, 2025
Coram: Justice C.T. Ravikumar and Justice Sanjay Karol
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ALSO READ: Supreme Court Review 2024: Constitution Bench decisions
Section 174A IPC is a Substantive Offence, Can Continue Even After Proclamation Under Section 82 CrPC Ends: SC
The Supreme Court ruled that Section 174A of the IPC is an independent and substantive offence that can persist even if the proclamation under Section 82 CrPC ceases to be in effect. While proceedings under Section 174A IPC cannot commence without a proclamation under Section 82 CrPC, they may continue even after the proclamation is extinguished.
Case Title: Daljit Singh v. State of Haryana & Anr.
Neutral Citation: 2025 INSC 21
Date of Judgment: January 2, 2025
Coram: Justice C.T. Ravikumar and Justice Sanjay Karol
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“Falsus in Uno, Falsus in Omnibus” Not Applicable in Indian Criminal Jurisprudence: SC
The Supreme Court reiterated that the principle of “falsus in uno, falsus in omnibus” (false in one thing, false in everything) does not apply to Indian criminal jurisprudence. The observation was made while upholding the murder conviction of certain individuals in a 2002 case. The ruling came in a criminal appeal challenging a Kerala High Court judgment that had acquitted some accused while convicting others.
Case Title: Edakkandi Dineshan @ P. Dineshan & Ors. v. State of Kerala
Neutral Citation: 2025 INSC 28
Date of Judgment: January 6, 2025
Coram: Justice Sudhanshu Dhulia and Justice Prasanna B. Varale
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SC Grants Effect to Compromise in Exceptional Circumstances After Affirming Conviction Under Section 326 IPC
The Supreme Court allowed a petition seeking the compounding of an offence under Section 326 IPC based on a compromise reached between the parties after the dismissal of the Special Leave Petition. The Court noted that the exceptional circumstances of the case, including the voluntary settlement, justified the exercise of its inherent powers to give effect to the compromise.
Case Title: H. N. Pandakumar v. The State of Karnataka
Neutral Citation: 2025 INSC 37
Date of Judgment: January 7, 2025
Coram: Justice Vikram Nath and Justice Prasanna B. Varale
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ALSO READ: Suo Moto Cases At An All-Time High: Supreme Court Review 2024
Article 113 Limitation Act: Suit Must Be Filed Within 3 Years from Date Right to Sue Accrues, Not Event Occurrence
The Supreme Court ruled that under Article 113 of the Limitation Act, a suit must be filed within 3 years from the date the right to sue accrues, rather than from the occurrence of the event, as stated in Article 54. The Court addressed whether a second suit for the specific performance of an agreement, filed after the rejection of a previous suit, could be maintained under the law.
Case Title: Indian Evangelical Lutheran Church Trust Association v. Sri Bala & Co.
Neutral Citation: 2025 INSC 42
Date of Judgment: January 8, 2025
Coram: Justice B.V. Nagarathna and Justice Nongmeikapam Kotiswar Singh
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SC Directs Centre to Implement ‘Golden Hour’ Cashless Treatment Scheme for Accident Victims by 14 March 2025
The Supreme Court directed the Centre to establish the ‘Golden Hour’ scheme for cashless treatment of motor accident victims by 14 March 2025. The Court highlighted that
“Section 162 of the Motor Vehicles Act, which mandates the creation of a scheme for providing cashless treatment during the golden hour, is aimed at safeguarding the right to life guaranteed under Article 21 of the Constitution.“
Additionally, the Court instructed the General Insurance Corporation (GIC) to expedite the creation of a portal that will inform States about any document deficiencies.
Case Title: S. Rajaseekaran v. Union of India & Ors.
Neutral Citation: 2025 INSC 45
Date of Judgment: January 8, 2025
Coram: Justice Abhay S. Oka and Justice Augustine George Masih
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Existence of Arbitration Agreement Essential for Enforceability of Award: SC
The Supreme Court observed that the ‘existence’ of an arbitration agreement is a necessary condition for an award to be enforceable under the law. This appeal was filed against an order passed by a Division Bench of the Allahabad High Court in a First Appeal.
Case Title: State of Uttar Pradesh and Another v. R.K. Pandey & Another
Neutral Citation: 2025 INSC 48
Date of Judgment: January 9, 2025
Coram: Chief Justice Sanjiv Khanna, Justice Sanjay Kumar, and Justice R. Mahadevan
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Witnesses Turning Hostile Doesn’t Automatically Discredit Their Evidence: SC
The Supreme Court stated that just because witnesses turn hostile, their entire evidence should not be disregarded. Portions of their testimony that support the prosecution can still be considered. This observation was made in a criminal appeal against a High Court judgment that upheld the conviction and sentence of two individuals under Section 302 read with Section 34 of the Indian Penal Code (IPC) and acquitted a third accused.
Case Title: Goverdhan & Anr. v. State of Chhattisgarh
Neutral Citation: 2025 INSC 47
Date of Judgment: January 9, 2025
Coram: Justice B.R. Gavai, Justice K.V. Viswanathan, and Justice N. Kotiswar Singh
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Wife’s Refusal to Return to Matrimonial Home Does Not Disqualify Her from Maintenance Under Section 125(4) CrPC: SC
The Supreme Court observed that a husband’s success in obtaining a decree for restitution of conjugal rights does not absolve him from providing maintenance to his wife under Section 125(4) of the CrPC, even if she refuses to return to the matrimonial home. The Court overturned the Jharkhand High Court’s decision, which had denied the wife maintenance, citing the husband’s decree for restitution of conjugal rights in his favor.
Case Title: R v. D & Anr.
Neutral Citation: 2025 INSC 55
Date of Judgment: January 10, 2025
Coram: Chief Justice Of India Sanjiv Khanna and Justice Sanjay Kumar
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SC Emphasizes Limitation period should not be Overlooked in the name of liberal or Justice-Oriented Approaches
The Supreme Court set aside the Karnataka High Court’s judgment, which had condoned a delay of approximately 2200 days, and reminded both the district judiciary and High Courts that concepts like “liberal approach,” “justice-oriented approach,” and “substantial justice” should not be used to bypass or negate the substantive law of limitation. The appeal arose from a High Court decision that overturned an order rejecting an application under Order 9 Rule 13.
Case Title: H. Guruswamy & Ors. v. A. Krishnaiah Since Deceased by LRs.
Neutral Citation: 2025 INSC 53
Date of Judgment: January 8, 2025
Coram: Justice J.B. Pardiwala and Justice R. Mahadevan
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SC Clarifies Principles for Evaluating Circumstantial Evidence in Criminal Cases
The Supreme Court, while upholding the conviction of a man for the rape and murder of a nine-year-old girl, outlined the principles that courts must follow when appreciating and evaluating evidence in cases based on circumstantial evidence. The Court made these observations in Criminal Appeals against the Kerala High Court’s judgment in an appeal and death sentence reference arising from the Sessions Court’s ruling.
Case Title: Abdul Nassar v. State of Kerala & Anr.
Neutral Citation: 2025 INSC 35
Date of Judgment: January 7, 2024
Coram: Justice B.R. Gavai, Justice K.V. Viswanathan, and Justice Sandeep Mehta
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SC Discusses Principles Underlying Order II Rule 2 CPC to Prevent Multiplicity of Suits
The Supreme Court examined the general principles behind Order II Rule 2 of the Civil Procedure Code, 1908 (CPC), which aims to prevent the filing of multiple suits on the same cause of action. The Court made these observations while deciding appeals against the Madras High Court’s judgment, which had allowed a second appeal and restored the plaint.
Case Title: Cuddalore Powergen Corporation Ltd. v. M/s Chemplast Cuddalore Vinyls Limited and Anr.
Neutral Citation: 2025 INSC 73
Date of Judgment: January 15, 2025
Coram: Justice J.B. Pardiwala and Justice R. Mahadevan
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SC Directs Construction of Separate Toilet Facilities for Males, Females, PwD, and Transgender Persons in All Courts and Tribunals
The Supreme Court directed all High Courts, State Governments, and Union Territories to ensure the construction and availability of separate toilet facilities for males, females, persons with disabilities (PwD), and transgender individuals in all Court premises and Tribunals across the country. The Court was addressing a Public Interest Litigation (PIL) filed under Article 32 of the Constitution, seeking basic toilet facilities in all Courts and Tribunals for men, women, handicapped persons, and transgender individuals. Emphasizing that inadequate washroom facilities undermine equality and obstruct the fair administration of justice, the Court issued directives for the provision of such facilities.
Case Title: Rajeeb Kalita v. Union of India & Ors.
Neutral Citation: 2025 INSC 75
Date of Judgment: January 15, 2025
Coram: Justice J.B. Pardiwala and Justice R. Mahadevan
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Court Stresses on Reforming Prison Administration to Uphold Prisoners’ Right to Dignified Life
The Court highlighted the need for reforms in prison administration to create a better environment and culture within prisons, ensuring that prisoners enjoy their Right to Dignified Life under Article 21 of the Constitution. The Court made this observation while deciding a Criminal Appeal involving the transfer of gangster Vikash Tiwary from one prison to another. The Court emphasized that while discipline and order must be maintained firmly, it should not exceed what is necessary for safe custody and well-ordered community life, ensuring respect for prisoners’ rights.
Case Title: The State of Jharkhand & Others v. Vikash Tiwary @ Bikash Tiwary @ Bikash Nath
Neutral Citation: 2025 INSC 79
Date of Judgment: January 17, 2025
Coram: Justice J.B. Pardiwala and Justice R. Mahadevan
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Court Asserts that Conjectures or Hypothetical Inconsistencies Cannot Be the Basis for Acquittal When Evidence Supports Guilt
The Court held that mere conjectures or hypothetical inconsistencies cannot be used as grounds for acquittal when the evidence clearly points to the guilt of the accused. This ruling came in a Criminal Appeal filed under Section 2(a) of the Supreme Court (Enlargement of Criminal Appellate Jurisdiction) Act, 1970, read with Section 379 of the CrPC, challenging the conviction judgment.
Case Title: Baban Shankar Daphal & Ors. v. The State of Maharashtra
Neutral Citation: 2025 INSC 97
Date of Judgment: January 22, 2025
Coram: Justice Vikram Nath and Justice Prasanna B. Varale
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Supreme Court Warns Against Granting Interim Bail for Election Campaigns in Tahir Hussain Case
The Supreme Court, while considering the Special Leave Petition (SLP) filed by former AAP (Aam Aadmi Party) Councillor and accused in the Delhi riots, Mohd. Tahir Hussain, expressed concerns about granting interim bail to convicts for election campaigning. In its judgment, the Court delivered a split verdict but concurred on the point that allowing convicts or under-trial prisoners to seek release for election purposes could potentially open a Pandora’s box.
Case Title: Mohd. Tahir Hussain v. State of NCT of Delhi
Neutral Citation: 2025 INSC 100
Date of Judgment: January 22, 2025
Coram: Justice Pankaj Mithal and Justice Ahsanuddin Amanullah
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Supreme Court: Mere Allegation of ‘Filthy Language’ Insufficient to Prove Offence under Section 509 IPC
The Supreme Court ruled that a mere assertion of “filthy language” in a complaint is not adequate to establish the commission of an offence under Section 509 of the IPC. The Court set aside the Karnataka High Court’s order, which had dismissed the Criminal Petition filed under Section 482 of the CrPC by the management officials (Appellants) of a company. The petition sought the quashing of criminal proceedings initiated by a former employee under Sections 323, 504, 506, 509, and 511 of the IPC.
Case Title: Madhushree Datta v. The State Of Karnataka & Anr.
Neutral Citation: 2025 INSC 105
Date of Judgment: January 24, 2025
Coram: Justice Dipankar Datta and Justice Prashant Kumar Mishra
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Supreme Court: Revenue Authority Lacks Jurisdiction to Review Final Orders; Jurisdiction Cannot Be Created by Consent
The Supreme Court clarified that the Chief Controlling Revenue Authority (CCRA) does not possess the statutory authority to review its own final orders, emphasizing that jurisdiction cannot be conferred by consent or waiver. The Court allowed an appeal challenging the Bombay High Court’s decision, which had upheld the rejection of the Appellants’ claim for a refund of stamp duty under the Maharashtra Stamp Act, 1958. The High Court had ruled that the refund claim was time-barred.
Case Title: Harshit Harish Jain & Anr. v. The State of Maharashtra & Ors.
Neutral Citation: 2025 INSC 104
Date of Judgment: January 24, 2025
Coram: Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta
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Supreme Court Orders Acquittal in 24-Year-Old Murder Case Due to Negligence in Investigation
The Supreme Court ordered the acquittal of the accused in a 24-year-old murder case, highlighting the sheer negligence and dereliction of duty by both the Investigating Agency and the Public Prosecutor for failing to conduct a Test Identification Parade (TIP). The Court was considering an appeal against the Karnataka High Court’s judgment, which had upheld the conviction of the accused-appellants. One of the three accused passed away during the pendency of the case, and his appeal was dismissed as abated.
Case Title: Thammaraya and Another v. The State of Karnataka
Neutral Citation: 2025 INSC 108
Date of Judgment: January 22, 2025
Coram: Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta
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Supreme Court: High Court Should Not Comment on Merits When Appeal Only Concerns Condonation of Delay
The Supreme Court restored two appeals filed by the appellants-allottees to the Maharashtra Real Estate Appellate Tribunal and observed that the Bombay High Court should not have commented on the merits of the orders when the scope of the appeal was limited to examining the correctness of the order declining the condonation of delay.
The Bench, comprising Justice Pamidighantam Sri Narasimha and Justice Manoj Misra, emphasized that the High Court should not have delved into the merits of the orders in question, particularly since the Appellate Tribunal had not addressed them. The appellants had filed complaints with RERA for possession of flats in the “Lodha Venezia” and “Lodha Azzuro” complexes. Following the dismissal of their complaints by RERA, the appellants filed appeals before the Maharashtra Real Estate Appellate Tribunal, seeking condonation of delay. The Tribunal dismissed the appeals on the grounds of limitation, a decision which was later upheld by the Bombay High Court.
Case Title: Surendra G. Shankar & Anr. v. Esque Finamark Pvt. Ltd & Ors.
Neutral Citation: 2025 INSC 102
Date of Judgment: January 24, 2025
Coram: Justice Pamidighantam Sri Narasimha and Justice Manoj Misra
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SC Commutes Death Sentence for Man Convicted of Killing Wife & 4 Minor Daughters to Life Imprisonment till last breath
The Supreme Court commuted the death sentence of a man convicted for the brutal murder of his wife and four minor daughters, replacing it with life imprisonment till last breath. The Court emphasized that while the crime was heinous, the convict showed potential for reform, and there was no evidence suggesting he posed a perpetual threat to society.
The Bench highlighted that
“capital punishment is an exception, and when reform is possible, a lesser sentence should be preferred”
The Appellant’s lack of criminal history and prison conduct were key mitigating factors. The Court upheld the conviction but modified the sentence to life imprisonment until last breath.
Case Title: Deen Dayal Tiwari v. State of Uttar Pradesh
Neutral Citation: 2025 INSC 111
Date of Judgment: January 28, 2025
Coram: Justice Vikram Nath, Justice Sanjay Karol, Justice Sandeep Mehta
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SC Acquits Man in Rape & Murder Case, Sets Aside Death Penalty Based on Weak Extra-Judicial Confession
The Supreme Court acquitted a man convicted for the rape and murder of a 23-year-old woman, setting aside the death penalty imposed by the Trial Court and upheld by the Bombay High Court.
The Court emphasized that
“extra-judicial confessions, being inherently weak evidence, could not be solely relied upon for conviction.”
The prosecution’s case, based on CCTV footage and the confession, lacked corroborative material. The Bench, noting the unreliability of the confession, allowed the appeal and ordered the appellant’s immediate release, acquitting him of all charges.
Case Title: Chandrabhan Sudam Sanap v. The State of Maharashtra
Neutral Citation: 2025 INSC 116
Date of Judgment: January 29, 2025
Coram: Justice BR Gavai, Justice Prashant Kumar Mishra, Justice KV Viswanathan
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SC Acquits Rape & Murder Convict, Sets Aside Death Penalty Over Lack of 65B Certificate
The Supreme Court acquitted a man convicted for the rape and murder of a 23-year-old woman, setting aside the death penalty imposed by the Trial Court and upheld by the Bombay High Court.
The Court ruled that
“A certificate under Section 65B(4) of the Indian Evidence Act, essential for the admissibility of electronic records, was missing.”
The prosecution failed to produce this certificate for the CCTV footage that allegedly showed the appellant with the victim. Citing its 2014 decision in Anvar P.V. v. P.K. Basheer, the Court held that such evidence could not be relied upon and allowed the appeal, acquitting the appellant.
Case Title: Chandrabhan Sudam Sanap v. The State of Maharashtra
Neutral Citation: 2025 INSC 116
Date of Judgment: January 29, 2025
Coram: Justice BR Gavai, Justice Prashant Kumar Mishra, Justice KV Viswanathan
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SC Directs Centre to Consider Legal Framework for Protection of Domestic Workers’ Rights
The Supreme Court has urged the Central Government to consider introducing a legal framework to protect the rights of domestic workers, acknowledging their vulnerability to exploitation. This direction came while hearing appeals related to the wrongful confinement and trafficking allegations against a female domestic worker. The Court emphasized that despite the growing demand for domestic workers, they remain highly susceptible to abuse and lack legal protection. It called for a committee to be formed by various ministries to explore the possibility of creating a legal framework for their regulation and protection.
Case Title: Ajay Malik v. State of Uttarakhand and Anr.
Neutral Citation: 2025 INSC 118
Date of Judgment: January 29, 2025
Coram: Justice Surya Kant, Justice Ujjal Bhuyan
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Domicile-Based Reservation in PG Medical Courses Is Constitutionally Impermissible: Supreme Court
The Supreme Court has ruled that
“Domicile or residence-based reservation for Postgraduate (PG) Medical courses is unconstitutional, as it violates Article 14 of the Constitution”
The Court held that such reservation at the higher education level is impermissible, rejecting the practice of reserving PG Medical seats in the State quota based on residence.
The ruling arose from challenges to the admissions process at the Government Medical College and Hospital, Chandigarh, which had reserved all 64 seats under the State quota for candidates with ties to Chandigarh.
The Court’s decision was based on the prior judgment in Saurabh Chaudri v. Union of India (2003), where a Five Judge Bench had already declared domicile-based reservations in PG Medical courses as unconstitutional. The ruling reaffirmed the necessity for a limited institutional preference in admissions but rejected any form of residence-based quotas.
Case Title: Dr. Tanvi Behl v. Shrey Goel & Ors.
Neutral Citation: 2025 INSC 125
Date of Judgment: January 30, 2025
Coram: Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, Justice S.V.N. Bhatti
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