In February 2025, the Supreme Court of India delivered several landmark judgments that have significantly influenced various facets of law and society. Here’s an overview of some of the most notable decisions:
1. Upholding Fundamental Rights During Arrest
In Vihaan Kumar vs. State of Haryana & Anr., the Supreme Court addressed the critical issue of an individual's rights during arrest. The Court ruled that failing to inform the arrested person of the grounds for their arrest is unconstitutional. Additionally, the Court condemned the inhumane treatment of the appellant, who was handcuffed and chained to a hospital bed, emphasizing that dignity is integral to Article 21 of the Constitution.
2. Compassionate Appointments Limited to 'Hand-to-Mouth' Situations
In Canara Bank vs. Ajithkumar G.K., the Court clarified that compassionate appointments are intended only for cases where the deceased's family is in extreme financial distress, struggling to meet basic expenses such as food, rent, and utilities. It ruled that merely facing a decline in the standard of living does not qualify for such appointments.
3. Permanent Alimony in Void Marriages
In Sukhdev Singh vs. Sukhbir Kaur, the Supreme Court held that a spouse from a marriage declared void under the Hindu Marriage Act is still entitled to permanent alimony or maintenance. The Court also affirmed that even if a marriage is voidable, a spouse can seek interim maintenance under certain conditions.
4. Doctrine of Proportionality in Commercial Contracts
In M/S. ABCI Infrastructures Pvt. Ltd. v. Union of India & Ors., the Supreme Court reiterated that while courts should exercise restraint in reviewing commercial contracts, the doctrine of proportionality applies when an error is evident. The Court set aside the forfeiture of a bank guarantee in a tender dispute, emphasizing pragmatic decision-making in such cases.
5. Application of Res Judicata to Writ Petitions
In Puja Ferro Alloys P Ltd. v. State of Goa & Ors., the Court reaffirmed that the principle of res judicata applies even in writ jurisdiction under Article 226 of the Constitution. It ruled against companies that attempted to re-litigate an issue regarding a 25% rebate on electricity tariffs, reinforcing the finality of judicial decisions.
6. Clarification on Common Intention Under Section 34 IPC
In Vasant @ Girish Akbarasab Sanavale & Anr. v. The State of Karnataka, the Supreme Court clarified that for Section 34 of the IPC to apply, the accused must share both the 'criminal act' and 'common intention.' The Court upheld the conviction of a mother-in-law who set her daughter-in-law on fire but acquitted the husband, ruling that mere presence in the house was insufficient to prove shared criminal intent.7. Striking Down Discriminatory Medical Admission Criteria
The Supreme Court struck down the 'both hands intact' rule for MBBS admissions, deeming it discriminatory and unconstitutional. The Court emphasized the need for reasonable accommodation under the Rights of Persons with Disabilities Act to ensure that capable individuals are not unfairly barred from pursuing medical education.
8. Personal Presence Not Mandatory in Domestic Violence Cases
The Court ruled that personal presence is not required in cases under the Domestic Violence Act, recognizing that these proceedings are quasi-criminal and do not entail penal consequences except for breaches of protection orders. This decision aims to reduce the burden on individuals involved in such cases and streamline the judicial process.
9. Emphasizing Timely Gubernatorial Assent to State Bills
The Supreme Court questioned the delay by the Tamil Nadu Governor in granting assent to bills passed by the state legislative assembly, stating that "he seems to have adopted his own procedure." This observation underscores the importance of adhering to constitutional protocols to maintain the balance between state and central authorities. These judgments from February 2025 reflect the Supreme Court’s commitment to upholding constitutional rights, ensuring fairness in legal procedures, and adapting legal interpretations to contemporary societal values.
