Narcotic Control Bureau vs. Lakhwinder Singh
Citation: 2025 INSC 190; Bench: Justice Abhay S. Oka, Justice Ujjal Bhuyan
Background
Lakhwinder Singh was convicted under the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act) and sentenced to 10 years of rigorous imprisonment. After serving approximately 4.5 years, Singh appealed his conviction in 2021. The High Court, noting that his appeal was unlikely to be heard before he completed his sentence, granted suspension of sentence and bail. The Narcotic Control Bureau (NCB) challenged this order before the Supreme Court, arguing that under Section 37 of the NDPS Act and the precedent set by the Supreme Court Legal Aid Committee case, bail should not be granted unless the convict has served at least half of the sentence.
Supreme Court’s Analysis
Section 37 NDPS Act:
Section 37 imposes strict conditions on granting bail for NDPS offences, especially when the punishment is 10 years or more. The NCB contended that bail should not be granted unless the convict has served at least half the sentence.
No Rigid Rule:
The Supreme Court clarified that there is no absolute or rigid rule requiring an accused to serve half the sentence before being eligible for bail pending appeal. The Court emphasized that each case must be judged on its merits, and the right to appeal should not be rendered illusory by procedural rigidity. If appeals are not likely to be heard before the sentence is completed, denying bail would violate Article 21 of the Constitution, which protects the right to life and personal liberty.
Appellate Courts’ Power:
The Court observed that appellate courts are not powerless to grant suspension of sentence and bail in deserving cases, even if the accused has not served half the sentence. The only guiding principle is that the relief must be justified on the facts and circumstances of the case. The Supreme Court warned against a rigid approach, as it could result in convicts serving their entire sentence before their appeal is heard, defeating the right to appeal.
Case-Specific Findings:
In Singh’s case, the Supreme Court noted that he had already served a substantial part of his 10-year sentence, and his appeal was unlikely to be heard soon. The Court found no reason to interfere with the High Court’s order granting bail. However, it clarified that if Singh misused the liberty granted, the NCB could seek cancellation of bail.
Decision
The Supreme Court dismissed the NCB’s appeal, upholding the High Court’s order granting suspension of sentence and bail to Lakhwinder Singh. The Court reiterated that bail can be granted in NDPS cases even if half the sentence is not served, provided the facts warrant such relief and the right to appeal is preserved.
Significance
This decision is a landmark clarification that the “half sentence rule” is not an inflexible mandate under the NDPS Act. The judgment upholds the primacy of Article 21 and the right to a meaningful appeal, ensuring that procedural technicalities do not override substantive justice in cases of prolonged incarceration pending appeal.
Independent Sugar Corporation Ltd. Vs. Girish Sriram Juneja [January 29, 2025] summary 400 words citaion
Independent Sugar Corporation Ltd. Vs. Girish Sriram Juneja [January 29, 2025] summary 400 words citaion
Independent Sugar Corporation Ltd. vs. Girish Sriram Juneja [Supreme Court, January 29, 2025] — 400-Word Summary
Citation: 2025 INSC 124; Supreme Court of India
Bench: Justice Hrishikesh Roy (majority), Justice Sudhanshu Dhulia (concurring), Justice S.V. Bhatti (dissenting)
Background
This landmark case arose from the insolvency resolution process of Hindustan National Glass and Industries Ltd. (HNGIL), a major player in the glass packaging sector. AGI Greenpac Ltd., another dominant company in the industry, submitted a resolution plan that would result in a significant market combination. Independent Sugar Corporation Ltd. (INSCO), a competing resolution applicant, challenged the process after the Resolution Professional (RP) allowed AGI Greenpac’s plan to be considered by the Committee of Creditors (CoC) without first obtaining approval from the Competition Commission of India (CCI), as required for combinations under the Competition Act, 2002.
The National Company Law Tribunal (NCLT) and National Company Law Appellate Tribunal (NCLAT) had previously held that CCI approval could be obtained after CoC approval, treating the requirement as directory rather than mandatory.
Key Legal Issues
Is prior approval from the CCI mandatory before the CoC considers a resolution plan involving a combination under the Insolvency and Bankruptcy Code, 2016 (IBC)?
Can unsuccessful resolution applicants challenge procedural irregularities in the insolvency process?
Supreme Court’s Ruling
Mandatory CCI Approval:
The Supreme Court, by a 2:1 majority, held that obtaining CCI approval before submitting a resolution plan to the CoC is a mandatory requirement under the proviso to Section 31(4) of the IBC. The Court reasoned that this interpretation upholds the integrity of both the insolvency process and competition law, ensuring that anti-competitive combinations do not receive creditor approval without regulatory scrutiny.
Strict Compliance and Transparency:
The judgment emphasized that procedural compliance and transparency are essential in insolvency proceedings. By requiring CCI approval at the pre-CoC stage, the Court sought to prevent market distortions and protect consumer interests.
Locus Standi of Unsuccessful Applicants:
The Court affirmed that unsuccessful resolution applicants have the standing to challenge violations of mandatory procedures, promoting fairness and accountability in the corporate insolvency framework.
Overruling NCLT/NCLAT:
The Court expressly overruled the NCLT and NCLAT’s view that CCI approval is merely directory, clarifying that the statutory language and legislative intent require strict adherence to the sequence of approvals.
Justice S.V. Bhatti dissented, favoring a more flexible, directory approach to the timing of CCI approval.
Significance
This decision resolves a long-standing interpretational conflict and sets a binding precedent that CCI clearance is a legal precondition for CoC approval of resolution plans involving combinations. The judgment reinforces procedural discipline, protects competition, and strengthens the rights of all stakeholders in insolvency processes. Review petitions against this decision are pending.
s Krishnadatt Awasthy Vs. State of Madhya Pradesh [January 29, 2025] summary 400 words citation
s Krishnadatt Awasthy Vs. State of Madhya Pradesh [January 29, 2025] summary 400 words citation
Krishnadatt Awasthy vs. State of Madhya Pradesh [Supreme Court, January 29, 2025] — 400-Word Summary
Citation: 2025 INSC 126; Bench: Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, Justice S.V.N. Bhatti
Background
The case arose from the selection and appointment of Shiksha Karmi Grade III teachers in Janpad Panchayat, Gaurihar, Chhatarpur District, Madhya Pradesh, dating back to 1998. Fourteen candidates, including Krishnadatt Awasthy and other appellants, were selected and subsequently appointed. It was later discovered that these individuals were close relatives of members of the selection committee, raising serious allegations of nepotism and bias in the process.
The selection was challenged by unsuccessful candidates, notably Archana Mishra, leading to the Collector’s order canceling the appointments on June 2, 1999. The appellants argued they were not given notice nor made parties to the proceedings that led to the annulment of their appointments, thereby violating their right to a fair hearing (audi alteram partem).
Key Legal Issues
Whether the cancellation of appointments due to bias (nemo judex in causa sua) can stand when the selected candidates were not given an opportunity to be heard (audi alteram partem).
Whether the principles of natural justice require impleadment and notice to affected candidates in service matters, especially where specific allegations are made.
Supreme Court’s Analysis
The case led to a split verdict in a two-judge bench, with one judge emphasizing the rule against bias and the other upholding the right to a fair hearing. The matter was referred to a three-judge bench for resolution.
The Supreme Court, in its final judgment, held that both limbs of natural justice—freedom from bias and the right to a fair hearing—are foundational and must be harmonized. The Court found that since the allegations of nepotism were specific, identifiable, and limited to 14 out of 249 selected candidates, it was both possible and necessary to give notice and an opportunity to be heard to those affected. The failure to do so amounted to a “gross violation” of natural justice.
The Court cited precedents such as J.S. Yadav v. State of Uttar Pradesh and Prabodh Verma v. State of Uttar Pradesh, reiterating that in service jurisprudence, selected candidates against whom specific allegations are made must be impleaded and heard, even if the overall number is large.
Decision
The Supreme Court allowed the appeals, set aside the Collector’s order canceling the appointments, and directed that the appellants be given a fair hearing before any adverse action is taken against them. The judgment reaffirmed that the right to a fair hearing cannot be sacrificed even in the face of proven bias, and that both principles of natural justice must be respected.
Significance
This decision is a landmark on the interplay between the rule against bias and the right to a fair hearing. It clarifies that in service matters, especially where specific allegations of nepotism or corruption are made, affected parties must be given notice and an opportunity to defend themselves before their appointments are annulled. The ruling strengthens procedural fairness and sets a precedent for future administrative and service law disputes.
Dr. Tanvi Behl Vs. Shrey Goel [January 29, 2025] summary 400 words citation
Dr. Tanvi Behl Vs. Shrey Goel [January 29, 2025] summary 400 words citation
Dr. Tanvi Behl vs. Shrey Goel [Supreme Court, January 29, 2025] — 400-Word Summary
Citation: 2025 INSC 125; Supreme Court of India
Background
The case challenged the validity of residence-based (domicile-based) reservation in postgraduate (PG) medical courses at Government Medical College and Hospital, Chandigarh. The college prospectus reserved 64 PG seats in its State quota, with 50% for residents of the Union Territory of Chandigarh and 50% for students with institutional preference (those who completed MBBS at the college). Petitioners, including Dr. Tanvi Behl, argued that this scheme violated the constitutional guarantee of equality and Supreme Court precedents.
Issues
Is residence-based reservation in PG medical courses constitutionally valid under Article 14?
Can State quota seats in PG medical admissions be filled on the basis of domicile/residence?
Supreme Court’s Reasoning
The Supreme Court, comprising Justices Hrishikesh Roy, Sudhanshu Dhulia, and SVN Bhatti, held that residence-based reservation in PG medical courses is unconstitutional and violative of Article 14 (equality before law). The Court relied heavily on the Constitution Bench judgment in Saurabh Chaudri v. Union of India (2003), which distinguished between permissible institutional preference and impermissible residence-based reservation in higher education.
Institutional Preference vs. Residence-Based Reservation:
The Court reiterated that while a reasonable degree of institutional preference (for students who completed MBBS at the same college) is constitutionally valid, reservation solely on the basis of residence or domicile is not. The rationale is that PG medical education is a field of higher learning where the most meritorious candidates should be selected, and residence does not constitute a reasonable classification under Article 14.
Application to Chandigarh Quota:
Of the 64 State quota seats, the 32 filled by institutional preference were upheld as valid. However, the 32 seats reserved for U.T. Chandigarh residents were found to be unconstitutional and must be filled strictly on the basis of merit in the All India examination.
Precedents Cited:
The Court referenced multiple prior judgments, including D.P. Joshi v. State of Madhya Bharat, Jagadish Saran v. Union of India, and Pradeep Jain v. Union of India, all of which stressed the importance of merit and the limited scope for reservation in higher education.
Decision
The Supreme Court struck down the residence-based reservation for PG medical seats in Chandigarh as unconstitutional, upholding only the institutional preference component. All State quota seats, except those validly reserved for institutional preference, must be filled on merit.
Significance
This judgment reaffirms that domicile or residence-based reservations in PG medical courses violate the equality principle and must yield to merit, with only limited institutional preference being permissible under the Constitution.
S. Vishnu Ganga Vs. M/s. Oriental Insurance Company Ltd. represented by its Divisional Manager [January 29, 2025] summary 400 words citation
S. Vishnu Ganga Vs. M/s. Oriental Insurance Company Ltd. represented by its Divisional Manager [January 29, 2025] summary 400 words citation
S. Vishnu Ganga vs. M/s. Oriental Insurance Company Ltd. [Supreme Court, January 29, 2025] — 400-Word Summary
Citation: 2025 INSC 123; Bench: Justice Sudhanshu Dhulia, Justice Ahsanuddin Amanullah
Background
This case arose from a tragic road accident in which the parents of the appellants (four siblings) died while traveling in a Tempo Traveler vehicle after it was struck by an uninsured bus. The deceased parents were running a family business (a mill), and after their deaths, the children, aged 24, 22, 18, and 18, were made partners in the firm. The Motor Accidents Claims Tribunal (MACT) awarded compensation to the appellants, considering the loss of parental guidance, business management, and future income.
The Oriental Insurance Company Ltd. challenged the award before the Madras High Court, which drastically reduced the compensation, holding that since the children had become partners in the firm, they had not suffered any pecuniary loss. The children appealed to the Supreme Court.
Supreme Court’s Analysis
Pecuniary Loss and Partnership:
The Supreme Court rejected the High Court’s reasoning that the children, by stepping into the shoes of their deceased parents as partners, had not suffered a pecuniary loss. The Court emphasized that mere formal admission as partners does not equate to the ability to manage or sustain the business profitably, especially given the appellants’ youth and lack of experience at the time of their parents’ deaths. The loss of parental guidance and business acumen was deemed a real and substantial loss.
Compensation Principles:
The Court reaffirmed that the Motor Vehicles Act is a welfare legislation designed to provide stability and continuity to victims’ families, not just to compensate for past loss but to secure their future. The compensation must reflect the actual impact on the claimants’ lives, including the likely downturn in business profitability due to the loss of experienced management.
Restoration of MACT Award:
The Supreme Court found the MACT’s award to be “well-considered” and in line with established legal principles. The High Court’s reduction of compensation was criticized as unjustified and contrary to settled law. The Court restored the original compensation awarded by the MACT, holding that the High Court’s approach was superficial and failed to account for the realities faced by the claimants.
Decision
The Supreme Court set aside the High Court’s order and restored the compensation awarded by the MACT to the appellants. The judgment underscores that loss of parental guidance and business management cannot be undervalued, and that compensation under the Motor Vehicles Act must ensure future security for dependents.
Significance
This ruling clarifies that mere succession in a family business by minors or young adults does not negate pecuniary loss in fatal accident claims. The judgment reinforces the forward-looking, welfare-oriented nature of compensation under the Motor Vehicles Act and protects the rights of dependents to just recompense.
H. Anjanappa Vs. A. Prabhakar [January 29, 2025] summary 400 words citaion
H. Anjanappa Vs. A. Prabhakar [January 29, 2025] summary 400 words citaion
H. Anjanappa vs. A. Prabhakar [Supreme Court, January 29, 2025] — 400-Word Summary
Citation: 2025 INSC 121; Bench: Justice J.B. Pardiwala, Justice R. Mahadevan
Background
The case revolved around a suit for specific performance of a sale agreement concerning agricultural land in Karnataka. The plaintiffs (Anjanappa and others) had entered into an agreement to purchase the property from the original owner, Smt. Daisy Shanthappa. During the pendency of the suit, despite an injunction, a portion of the property was sold to third parties (Respondents 1 and 2, i.e., subsequent purchasers), who later sold it further. The trial court decreed specific performance in favor of the plaintiffs. The subsequent purchasers, who were not parties to the suit, sought to be impleaded, but their application was rejected and not appealed. After the decree, they sought leave from the High Court to appeal the decree, which was granted after condoning a significant delay. The plaintiffs challenged this before the Supreme Court.
Key Legal Issues
Whether a pendente lite transferee (a person who purchases property during the pendency of a suit) has an inherent right to be impleaded or to appeal against a decree without being a party to the suit.
The application of Section 52 of the Transfer of Property Act (doctrine of lis pendens).
Under what circumstances can a stranger to a suit seek leave to appeal in property disputes.
Supreme Court’s Analysis
No Inherent Right for Pendente Lite Transferees:
The Court held that a pendente lite transferee does not have an automatic right to be impleaded in a suit or to appeal against the decree unless exceptional circumstances exist where their rights are directly and prejudicially affected. The injury complained of must not be remote or indirect.
Bound by Decree:
Such transferees are bound by the outcome of the litigation due to Section 52 of the Transfer of Property Act. They cannot challenge the correctness of the decree in subsequent proceedings if they did not seek to be properly impleaded or appeal the rejection of their impleadment application.
Leave to Appeal:
The Supreme Court clarified that a stranger may seek leave to appeal only if they are bound by the decree and could not have attacked its correctness otherwise. However, in this case, Respondents 1 and 2 had failed to appeal the rejection of their impleadment and waited for years before seeking leave to appeal, making their challenge untenable.
Condonation of Delay:
The Court found the High Court erred in condoning the protracted delay and granting leave to appeal to the subsequent purchasers, as they were not parties to the suit and the issue of their impleadment had attained finality.
Decision
The Supreme Court allowed the appeal, set aside the High Court’s order granting leave to appeal and condoning delay for the subsequent purchasers, and upheld the decree for specific performance in favor of the plaintiffs. The Court advised the subsequent purchasers to seek remedy against the sellers if they felt aggrieved.
Significance
This judgment reaffirms the doctrine of lis pendens and clarifies that pendente lite transferees cannot bypass procedural limitations to challenge decrees unless directly and prejudicially affected, and only with the court’s leave in exceptional cases. It strengthens the finality of litigation and procedural discipline in property disputes.
M/s. J.M. Laboratories Vs. State of Andhra Pradesh [January 30, 2025] summary 400 words citatioon
M/s. J.M. Laboratories Vs. State of Andhra Pradesh [January 30, 2025] summary 400 words citatioon
M/s. J.M. Laboratories vs. State of Andhra Pradesh [Supreme Court, January 30, 2025] — 400-Word Summary
Citation: 2025 INSC 127; Bench: Justice B.R. Gavai, Justice Augustine George Masih
Background
The case arose from a criminal complaint filed by the Drugs Inspector, Kurnool Urban, under Section 32 of the Drugs and Cosmetics Act, 1940. The complaint alleged that M/s. J.M. Laboratories, its managing partner, and three silent partners had manufactured and distributed a substandard drug, MOXIGOLD-CV 625 (Amoxycillin & Potassium Clavunate Tablets IP), violating Section 18(a)(i) read with Section 16 of the Act, punishable under Section 27(d). The complaint was based on a September 2018 government analyst’s report declaring the drug “not of standard quality”.
The Judicial Magistrate, First Class, Kurnool, issued a summoning order against the appellants. The company challenged the proceedings before the Andhra Pradesh High Court under Section 482 CrPC, arguing that the case was time-barred under Section 468(2) CrPC (three-year limitation) and that the summoning order was non-speaking and lacked judicial reasoning. The High Court dismissed their petition, leading to the appeal before the Supreme Court.
Supreme Court’s Analysis
Requirement for Reasoned Summoning Orders:
The Supreme Court held that summoning an accused is a serious judicial function, not a mere formality. The Magistrate must apply judicial mind and record valid reasons for issuing process. The bench found that the summoning order in this case was “totally a non-speaking one,” lacking any reasoning or indication of judicial application of mind.
Precedents Cited:
The Court relied on key precedents such as Pepsi Foods Ltd. v. Special Judicial Magistrate (1998), Sunil Bharti Mittal v. CBI, and Mehmood Ul Rehman v. Khazir Mohammad Tunda, all of which mandate that summoning orders must reflect judicial scrutiny and cannot be issued mechanically.
Limitation Issue:
While the appellants argued that the prosecution was barred by limitation, the Supreme Court did not find it necessary to address this ground, as the appeal could be allowed solely on the failure of the Magistrate to provide reasons for summoning.
Decision
The Supreme Court allowed the appeal, quashed the summoning order and the entire criminal proceedings in C.C. No. 1051 of 2023, and set aside the High Court’s judgment. The Court reaffirmed that a non-speaking summoning order is legally unsustainable and cannot form the basis for criminal prosecution.
Significance
This judgment is a strong reaffirmation that issuing process in criminal cases is a serious judicial act requiring clear, reasoned orders. It protects individuals and companies from arbitrary prosecution and strengthens procedural safeguards in criminal law, especially in regulatory offences under the Drugs and Cosmetics Act.
Shripal Vs. Nagar Nigam, Ghaziabad [January 31, 2025] summary 400 words citaion
Shripal Vs. Nagar Nigam, Ghaziabad [January 31, 2025] summary 400 words citaion
Shripal vs. Nagar Nigam, Ghaziabad [Supreme Court, January 31, 2025] — 400-Word Summary
Citation: 2025 INSC 144; Civil Appeal No. 8157 of 2024 with connected appeals
Bench: Justice Vikram Nath, Justice Prasanna B. Varale
Background
The case arose from the termination of long-serving gardeners (Malis) employed by the Horticulture Department of Ghaziabad Nagar Nigam (Municipal Corporation). The appellant workmen, engaged since 1998–99, claimed to have performed perennial municipal duties—such as planting, maintaining parks, and beautifying public spaces—under direct supervision of the employer, without formal appointment letters, minimum wages, or statutory benefits. In July 2005, their services were terminated orally, allegedly during pending conciliation proceedings, without notice or retrenchment compensation.
Legal Issues
Whether the termination of the workmen during conciliation proceedings violated Section 6E of the U.P. Industrial Disputes Act, 1947.
Whether the workmen, having performed perennial duties akin to permanent posts, were entitled to regularization and statutory benefits.
Whether the High Court erred in restricting relief to daily-wage re-engagement instead of full reinstatement with continuity and back wages.
Supreme Court’s Analysis
Illegality of Termination:
The Supreme Court held that the termination was illegal, as it occurred during conciliation proceedings, violating Section 6E of the U.P. Industrial Disputes Act, 1947, and without compliance with Section 6N (retrenchment compensation and notice).
Right to Reinstatement and Back Wages:
The Court restored the Labour Court’s award, directing reinstatement of the workmen with continuity of service and 50% back wages for the period of illegal termination. The Court found that the High Court erred in limiting relief to daily-wage re-engagement, disregarding the workers’ long service and the principle of “equal pay for equal work”.
Regularization of Service:
Recognizing that the workmen had performed perennial duties akin to those of permanent employees, the Court directed the employer to initiate a fair and transparent process for regularization within six months from the date of reinstatement, considering their long and continuous service.
Ban on Recruitment:
The Court clarified that any ban on recruitment cannot override statutory labor rights and constitutional protections, especially where workers have been engaged directly and continuously by the municipal employer.
Decision
The Supreme Court allowed the appeals of the workmen, dismissed the employer’s appeals, and ordered:
Reinstatement with continuity of service
50% back wages for the period of illegal termination
Initiation of regularization process within six months from reinstatement
The Court reinforced that termination in violation of labor laws and constitutional principles cannot be sustained.
Significance
This judgment is a landmark affirmation of labor rights, especially for temporary and contract workers in government institutions. It upholds the principles of fair employment, “equal pay for equal work,” and the right to regularization for long-serving employees performing perennial duties, setting a strong precedent against arbitrary termination and exploitation of vulnerable workers.
Rakesh Kumar Charmakar Vs. State of Madhya Pradesh [January 31, 2025] summary 400 words icitation
Rakesh Kumar Charmakar Vs. State of Madhya Pradesh [January 31, 2025] summary 400 words icitation
Rakesh Kumar Charmakar vs. State of Madhya Pradesh [Supreme Court, January 31, 2025] — 400-Word Summary
Citation: 2025 INSC 136; Civil Appeal Nos. 8613-8614 of 2022
Bench: Justice Vikram Nath, Justice Prasanna B. Varale
Background
This case involved Rakesh Kumar Charmakar and other part-time sweepers employed by the Veterinary Department of Madhya Pradesh under a Special Recruitment Drive. Although engaged on a temporary basis, they were appointed against regular, sanctioned posts and performed duties akin to permanent employees. The appellants sought regular pay scale benefits as per government circulars and the 1979 Rules, arguing that they had completed the requisite period of service and satisfied all conditions for regularization.
Their claim was initially accepted by a Single Judge of the Madhya Pradesh High Court in 2019, but a Division Bench later reversed this, holding them ineligible for regular pay scale benefits. The employees appealed to the Supreme Court, contending that their designation as “part-time” did not affect their entitlement, as they were appointed against sanctioned posts and met all stipulated requirements.
Supreme Court’s Analysis
Eligibility for Regular Pay Scale:
The Supreme Court emphasized that the appellants were recruited through a proper selection process for regular, sanctioned posts. Their status as “temporary” or “part-time” did not detract from the fact that they fulfilled all conditions under the relevant government circulars, including the completion of three years’ service on Collector’s wages with the recommendation of the District Level Recruitment Committee.
Government Accountability:
The Court criticized the State for attempting to deny benefits through delays in convening screening committees or by relying on technicalities. It held that government authorities cannot arbitrarily withhold financial benefits from employees who meet the criteria established by law and policy.
Precedent and Parity:
The Court found that the appellants’ situation was analogous to that of the petitioners in Ram Naresh Prajapati, who were similarly appointed under a Special Recruitment Drive and granted regular pay scale benefits. The Division Bench’s attempt to distinguish the present case was held to be erroneous.
Legal Principle:
The judgment reinforced that temporary or daily wage workers appointed against sanctioned posts are entitled to the same benefits as regular employees once they fulfill the prescribed conditions, and that administrative inaction cannot deprive them of their rights.
Decision
The Supreme Court allowed the appeals, set aside the Division Bench’s judgment, and restored the Single Judge’s order granting regular pay scale benefits to the appellants. The State was directed to ensure compliance and extend all consequential benefits to the employees.
Significance
This ruling is a landmark for contractual and temporary government workers, affirming their right to fair wages and regularization when appointed against sanctioned posts. It prevents arbitrary denial of benefits, strengthens legal protections for underprivileged employees, and compels state authorities to uphold their obligations under established policy and law.
Kuldeep Singh Vs. State of Punjab [January 31, 2025] summary 400 words citation
Kuldeep Singh Vs. State of Punjab [January 31, 2025] summary 400 words citation
Kuldeep Singh vs. State of Punjab [Supreme Court, January 31, 2025] — 400-Word Summary
Citation: 2025 INSC 130; Bench: Justice Vikram Nath, Justice Prasanna B. Varale
Background
This case involved Kuldeep Singh, who was accused of abduction, rape (Section 376 IPC), and criminal intimidation (Section 506 IPC) by his wife (Respondent No. 3) following a consensual marriage. The FIR (No. 148 of 2022) was filed by the victim’s cousin, alleging that Kuldeep Singh had abducted and raped the victim. The appellant contended that he and Respondent No. 3 had married of their own free will on June 15, 2022, in accordance with Sikh rites, against the wishes of her family. The couple had jointly sought protection from the High Court, which was granted, and the victim had not alleged rape or forced marriage in her written statement in restitution proceedings.
Key Legal Issues
Whether a husband can be prosecuted for rape under Section 376 IPC in light of Exception 2 to Section 375 IPC (marital rape exception).
Whether the FIR and subsequent criminal proceedings were sustainable given the consensual nature of the marriage and absence of contemporaneous allegations of rape or force.
Supreme Court’s Analysis
Marital Rape Exception:
The Court noted that Exception 2 to Section 375 IPC specifically exempts sexual intercourse by a man with his own wife from the definition of rape. The appellant’s marriage to the complainant was found to be legally valid and consensual, and thus, the charge of rape could not be sustained.
Conduct of the Parties:
The Supreme Court emphasized that the couple had jointly sought protection from the High Court, and the victim had not made any allegations of rape or coercion in her reply to the restitution petition. The subsequent allegations were made only after she returned to her parental home, raising doubts about their veracity.
Absence of Prima Facie Case:
The Court found that no prima facie case was made out against Kuldeep Singh under Sections 376 or 506 IPC. The FIR and chargesheet were based on unsubstantiated allegations, with the evidence on record supporting the appellant’s claim of a consensual marriage.
Decision
The Supreme Court allowed the appeal, quashed the FIR and all consequential proceedings against Kuldeep Singh, and set aside the order of the Punjab and Haryana High Court. The Court held that the marital rape exception applied, and there was no evidence to support the charges of rape or criminal intimidation.
Significance
This judgment reaffirms the current legal position in India that sexual intercourse between a husband and wife, within a valid marriage, does not constitute rape under Section 375 IPC due to Exception 2. The decision underscores the necessity of prima facie evidence for sustaining criminal charges and protects individuals from prosecution based on uncorroborated or delayed allegations in the context of consensual marriages.
Karuppudayar Vs. State represented by the Deputy Superintendent of Police, Lalgudi Trichy [January 31, 2025] summary 400 words citation
Karuppudayar Vs. State represented by the Deputy Superintendent of Police, Lalgudi Trichy [January 31, 2025] summary 400 words citation
Karuppudayar vs. State represented by the Deputy Superintendent of Police, Lalgudi Trichy [Supreme Court, January 31, 2025] — 400-Word Summary
Citation: 2025 INSC 132; 2025 LawText (SC) (1) 314
Bench: Justice B.R. Gavai, Justice Augustine George Masih
Background
Karuppudayar was accused under Sections 3(1)(r) and 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC-ST Act) for allegedly using a caste-based insult against a police inspector. The incident reportedly occurred inside an office chamber, not in a public place. The appellant sought quashing of the criminal proceedings, arguing that the alleged abuse did not occur “within public view,” a necessary element for offences under the cited sections of the SC-ST Act.
The Madras High Court dismissed the appellant’s petition under Section 482 CrPC, declining to quash the charge sheet and allowing the criminal trial to proceed. Karuppudayar appealed to the Supreme Court.
Supreme Court’s Analysis
Requirement of 'Public View':
The Supreme Court emphasized that for an offence under Sections 3(1)(r) and 3(1)(s) of the SC-ST Act, the alleged insult or abuse by caste name must occur “in any place within public view.” The Court relied on its prior decisions in Swaran Singh v. State (2008) and Hitesh Verma v. State of Uttarakhand (2020), which clarified that a “public place” is not synonymous with “public view”—the crucial factor is whether members of the public were present and witnessed the incident at the time it occurred.
Application to the Present Case:
The Court found that the alleged incident took place inside a private office chamber, where no members of the general public were present. The subsequent arrival of colleagues after the incident did not satisfy the “public view” requirement. The Court held that an office chamber, unless accessible to the public at the relevant time, does not constitute a place within public view.
Exercise of Inherent Powers:
Applying the principles from State of Haryana v. Bhajan Lal (1992), the Supreme Court held that even if the allegations were accepted at face value, they did not prima facie constitute an offence under the relevant sections of the SC-ST Act. The case fell within the first category of cases warranting quashing under Bhajan Lal.
Critique of High Court’s Approach:
The Supreme Court noted that the High Court had failed to consider the settled law regarding the public view requirement and thus erred in dismissing the petition for quashing.
Decision
The Supreme Court allowed the appeal, quashed the High Court’s judgment, and set aside the charge sheet and all criminal proceedings against Karuppudayar in Special S.C. No. 7 of 2022. The Court reaffirmed that the “public view” requirement is essential for prosecution under Sections 3(1)(r) and 3(1)(s) of the SC-ST Act, and that criminal proceedings cannot be sustained where this element is absent.
Significance
This judgment reinforces the necessity of the “public view” element for SC-ST Act offences, clarifies the distinction between public place and public view, and upholds the principle that criminal law must not be invoked where statutory requirements are not met. It also demonstrates the Supreme Court’s readiness to exercise its inherent powers to prevent abuse of process and protect individual rights.
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