The Delhi High Court clarified that under Section 154 of the CrPC, police must register a regular FIR if any part of a cognizable offence occurs within their territorial jurisdiction. While the concept of a Zero FIR allows police to register an FIR for offences committed outside their jurisdiction, this provision cannot be misused to transfer cases mechanically when the offence clearly falls within their own area. In this case, the petitioner reported an incident of assault in Adarsh Nagar, Delhi, which gave the local police the authority to investigate. The Court held that transferring the case to Uttar Pradesh was improper and directed the Delhi Police to register a regular FIR and proceed with the investigation. The UP Police was instructed to hand over all related documents to Delhi Police. The ruling reinforces that police have a legal obligation to act when an offence occurs within their jurisdiction and cannot evade responsibility by misclassifying it as a Zero FIR.
The Supreme Court reaffirmed that courts should generally refrain from interfering with the encashment of bank guarantees, except in cases involving fraud or irretrievable injustice, referencing precedents like Hindustan Construction Co. Ltd. v. State of Bihar. However, it took note of key factors: arbitration proceedings were ongoing, the matter had been partly heard by the Commercial Court, Bansal had extended the bank guarantee's validity, and maintaining the status quo caused no prejudice to Jindal Steel. Without deciding on the legal issues, the Court directed the parties to continue arguments before the Commercial Court, which must issue appropriate orders within eight weeks. The bank guarantee is to remain valid until the Section 9 petition is resolved.
Shyam Premchandani filed a criminal revision under Section 438 of the BNSS, 2023, and Section 397 of the CrPC, 1973, challenging the order dated February 19, 2025, by the Additional Sessions Judge, Dewas. The trial court had closed his right to cross-examine the Investigating Officer (IO) due to the absence of his senior counsel, despite a request for adjournment. Although the associate counsel cross-examined another witness, he sought time for the IO’s cross-examination. The High Court held that a fair trial includes a proper opportunity to defend, particularly by cross-examining key prosecution witnesses. Denial of this right seriously affects the accused’s defence. The court termed the closure of the opportunity on the first instance as unjust and harsh. It set aside the trial court’s order and allowed the petitioner to cross-examine the IO.
The Supreme Court quashed criminal proceedings against members of anti-trafficking NGO Guria, who faced charges under Sections 186 and 353 IPC for allegedly obstructing public servants during a 2014 rescue of bonded and child labourers from a Varanasi brick kiln.
The case involved two commercial appeals stemming from a single judgment by the Commercial Court in an arbitration dispute between Ranchi Municipal Corporation (RMC) and M/s A2Z Waste Management (Ranchi) Ltd. The Contractor’s appeal was allowed, and the Commercial Court’s order setting aside the arbitral award was reversed. Meanwhile, RMC’s appeal was dismissed due to the rejection of its application for condonation of delay.
The Supreme Court, relying on its earlier ruling in P. Nallammal v. State (1999), reaffirmed that non-public servants can be prosecuted for abetting offences under Section 13(1)(e) of the Prevention of Corruption Act. It held that abetment under Section 107 IPC includes instigation, conspiracy, or intentional aiding by act or omission. The appellant was found to have concealed disproportionate assets in her name and facilitated her husband's accumulation of illicit wealth. The Court rejected her claim of divorce, noting she was his wife at the time of the offence, and even otherwise, her actions sufficed for abetment. Additionally, the Court noted she was a public servant then. The appeal was dismissed, and she was ordered to surrender within four weeks.
The applicant, a steel plant equipment design company, entered into a contract with the respondent on 28.04.2017 to install a Single Stand Reversing 4-HI Wide Plate Hot Rolling Mill in Hyderabad. The project was delayed by 26 months, which the applicant attributed to the respondent’s lapses, including delays in civil and structural work, readiness of utilities and cranes, equipment delivery, and disruptions caused by the dengue outbreak and COVID-19 pandemic. Despite agreed timeline extensions, the respondent imposed a 10% liquidated damages penalty, which the applicant disputed. Another conflict arose from the respondent’s alleged misuse of the applicant’s proprietary drawings. The court recognized arbitrable issues concerning project delays, imposition of damages, and unauthorized use of confidential materials. Rejecting the respondent’s argument that arbitration should have been initiated through ICADR—now defunct and absorbed into the India International Arbitration Centre—the court invoked a practical interpretation based on Enercon (India) Ltd. v. Enercon Gmbh (2014), supporting arbitration where intent is evident but procedure unworkable. Citing ACC Ltd. v. Global Cements Ltd. (2012), the court held that courts may appoint substitute arbitrators when named institutions no longer function. Accordingly, the court appointed Justice L. Nageswara Rao, Former Supreme Court Judge, as sole arbitrator.
The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, related to an FIR under Sections 498A, 304B, and 34 IPC. The deceased, Shivani Singh, was found hanging within five years of marriage. The prosecution alleged physical abuse, dowry pressure regarding car EMIs, and an extramarital affair. The court applied the test from Rajinder Singh v. State of Punjab for Section 304B IPC and found the dowry link inconclusive: there were no complaints by the deceased, EMIs were paid by the applicant, and video evidence was over a year old. On Section 306 IPC, the court, relying on K.V. Prakash Babu and Parul, ruled that mere suspicion of an extramarital affair isn’t enough to prove cruelty or abetment unless linked directly to harassment. Since key evidentiary thresholds weren’t met, the court granted bail, subject to conditions including a personal bond, non-interference with evidence or witnesses, and regular court appearances.
The applicant was arrested in July 2017 for possession of 3 kg of heroin, leading to an FIR under the NDPS Act. He was allegedly part of a drug trafficking syndicate. A separate FIR under MCOCA followed, alleging organized criminal activity. After over 6.5 years in custody, only 11 of 100 witnesses had been examined. The court considered whether prolonged incarceration could justify bail. Referring to Union of India v. K.A. Najeeb and Mohd. Muslim v. State (NCT of Delhi), it emphasized that the right to a speedy trial under Article 21 prevails even under special laws like MCOCA. The applicant was not the kingpin, had good jail conduct, and had already received bail in the NDPS case. The court granted bail with strict conditions including sureties, travel restrictions, and regular reporting.
The dispute arose from a works contract subject to arbitration under the 1996 Act. The respondent challenged the arbitral award under Section 34, arguing that the Madhya Pradesh Madhyastham Adhikaran Adhiniyam, 1983 (State Act) applied, making the tribunal jurisdictionally incompetent. However, the respondent did not raise this objection during arbitration or in its initial Section 34 petition and only introduced it later, relying on L.G. Chaudhary (II), which held the State Act prevails over the Central Act for works contracts in Madhya Pradesh. Jurisdictional Plea Timing: The Lion Engineering judgment permits raising jurisdictional objections under Section 34 even if not raised under Section 16, as it is a pure legal question. L.G. Chaudhary (II) created an exception that if no jurisdiction plea is raised before the tribunal, the award cannot be annulled solely on this ground. The Court harmonized these rulings to prevent misuse when such pleas are belatedly raised. Waiver Principle: Failure to raise jurisdictional objections before the tribunal generally results in waiver unless a strong reason exists. Final Decision: The High Court wrongly annulled the award based solely on jurisdiction. The Supreme Court restored the award and remanded the matter for other Section 34 issues.
The Supreme Court, invoking its powers under Article 142 of the Constitution, imposed a tiered penalty system to curb illegal tree felling in the Taj Trapezium Zone (TTZ), based on the Central Empowered Committee’s (CEC) recommendations. The penalties include: ₹5,000 per tree for farmers illegally cutting private trees of exempted species; ₹10,000 per tree for illegal felling of restricted species or exempted species by non-farmers; and ₹25,000 per tree for violations under the Indian Forest Act, 1927. The Court instructed the Forest Research Institute (FRI) to submit representations to Uttar Pradesh and Rajasthan for phased fund release to carry out a tree census. The states were ordered to release the necessary funds without delay. The ruling reaffirms the Supreme Court’s active role in environmental PILs and its use of Article 142 to ensure justice, especially in protecting ecologically sensitive and heritage zones.