The High Court of Judicature at Allahabad clarified the scope of Section 216 of the Code of Criminal Procedure, holding that neither the complainant nor the accused has any legal right to seek alteration or addition of charges, as this power is exclusively vested in the court. The case arose when the complainant filed an application under Section 216 Cr.P.C. seeking addition of POCSO charges against the accused after the chargesheet had been filed and evidence concluded. The trial court allowed the application, prompting the accused to challenge the order. Allowing the revision, the High Court emphasized that Section 216 Cr.P.C. is an enabling provision for the court alone, permitting it to alter or add charges suo motu at any stage before pronouncement of judgment, based on the material on record. The provision does not create any vested or enforceable right in favour of the prosecution, complainant, or accused to demand such alteration through an application. The Court reasoned that permitting party-driven applications under Section 216 would encourage repeated litigation, delay trials, and undermine the principle of a speedy trial. The correct procedure is for the court itself to assess the evidence and decide whether alteration of charges is necessary. Accordingly, the trial court’s order entertaining the complainant’s application was held to be legally unsustainable and was set aside.
The High Court of Madhya Pradesh, Jabalpur Bench, upheld the Family Court’s refusal to grant divorce, reiterating settled principles on cruelty and desertion under matrimonial law. The husband alleged that his wife was rude, neglected marital duties, and deserted the matrimonial home. The wife denied these claims, stating she was compelled to leave due to mental harassment and remained willing to resume cohabitation. The Court held that cruelty must be proved through specific, cogent evidence. General and unsubstantiated allegations such as quarrelling, mobile phone use, or refusal to attend social functions do not constitute legal cruelty. The husband failed to produce documentary or medical evidence to support his claims. On desertion, the Court emphasized that mere separation is insufficient. Desertion requires animus deserendi—a clear and settled intention to permanently abandon the marital relationship. Since the wife expressed willingness to return, this intention was not established. The Court also rejected divorce on the ground of irretrievable breakdown alone, holding that a recognized matrimonial wrong must be proved. The appeal was accordingly dismissed.
The Supreme Court of India held that witnesses turning hostile in departmental proceedings is no ground to seek discharge in a criminal trial under the Prevention of Corruption Act, 1988. The case concerned a Motor Vehicles Inspector accused of accepting a bribe, where a trap was laid and prosecution was sanctioned. Although the accused was exonerated in the departmental inquiry due to the complainant and key witnesses turning hostile, the trial court discharged him, citing invalid sanction. The High Court reversed this decision, leading to an appeal before the Supreme Court. The Supreme Court clarified that departmental proceedings and criminal trials operate independently. The standard of proof in departmental inquiries is based on the preponderance of probabilities, whereas criminal trials require proof beyond reasonable doubt. Witnesses who turn hostile in departmental proceedings may still testify truthfully in criminal trials due to the risk of perjury. Importantly, the Court reiterated that conviction in trap cases can rest solely on the credible testimony of the trap-laying officer. On the issue of sanction, the Court noted a factual dispute regarding the competent appointing authority. Since this issue was not conclusively established, the matter was remitted to the trial court to examine appointment records and determine the validity of sanction. The judgment reinforces that departmental exoneration does not shield an accused from criminal prosecution.
The Supreme Court of India clarified the scope of sanction and departmental exoneration under the Prevention of Corruption Act, 1988, in T. Manjunath v. State of Karnataka. The appellant, a senior Motor Vehicles Inspector, was discharged by the trial court on the grounds of invalid sanction under Section 19 of the PC Act and his exoneration in departmental proceedings. The High Court reversed this decision and directed the trial to proceed. Allowing the appeal in part, the Supreme Court held that exoneration in departmental proceedings does not bar criminal prosecution, especially in trap cases. The Court emphasized that departmental inquiries and criminal trials operate on different standards of proof and that even if complainants or witnesses turn hostile, conviction can rest solely on the credible testimony of the trap-laying officer. On the issue of sanction, the Court ruled that Sections 19(3) and 19(4) of the PC Act become irrelevant when the trial court itself quashes the sanction as invalid at the threshold. Since there was a factual dispute regarding whether the appellant was appointed by the State Government or the Commissioner, the matter was remitted to the trial court to determine the competent appointing authority and reassess the validity of sanction accordingly.
The High Court of Kerala, Ernakulam, upheld the constitutional validity of the Kerala Clinical Establishments (Registration and Regulation) Act, 2018, affirming that hospitals must display treatment rates and cannot deny emergency care for non-payment of advance charges. The case arose from writ appeals filed by associations of private hospitals and doctors challenging provisions mandating registration of clinical establishments, disclosure of fees and package rates, and compulsory emergency medical treatment. The appellants argued that these provisions were vague, impractical, burdensome, and violative of fundamental rights under Articles 14, 19(1)(g), and 21 of the Constitution. Dismissing the appeals, the Division Bench reiterated the presumption of constitutionality of welfare legislation and applied the doctrine of proportionality, holding that the Act pursues legitimate public objectives such as transparency, patient safety, and access to healthcare. The Court emphasized that the right to health and emergency medical care forms an integral part of Article 21, and reasonable regulatory restrictions on private hospitals are constitutionally permissible. The Court clarified that “package rates” under Section 39 are baseline tariffs for standard procedures, allowing additional charges for unforeseen complications with proper disclosure. On emergency care, it held that obligations are capacity-based, but no clinical establishment can deny immediate care solely due to non-payment. The appeals were dismissed, and the Act was upheld as intra vires the Constitution.
In State of Gujarat v. Rajeshbhai Pitamberbhai Parmar & Ors., the Gujarat High Court upheld the acquittal of the husband and in-laws in a case involving allegations under Sections 498A, 306, 304B, 201 and 176 IPC arising from the suicide of the wife within two years of marriage. The Court held that the prosecution failed to establish wilful, persistent cruelty under Section 498A, noting that witness testimonies were vague, inconsistent, and lacked corroboration. It observed that the act of not allowing the deceased to accompany the family on a temple visit amounted to ordinary matrimonial wear and tear and could not be treated as cruelty. The Court further held that abetment of suicide under Section 306 IPC was not proved, as there was no evidence of instigation, conspiracy, or intentional aid, and the husband’s conduct in taking the deceased to hospital negated any mens rea. It clarified that the presumption under Section 113A of the Evidence Act is discretionary and can arise only after cruelty is proved, which was not the case. Allegations of dowry demand “soon before death” were also not established, leading to rejection of the charge under Section 304B IPC. Finding the trial court’s view to be reasonable and not perverse, the High Court dismissed the State’s appeal.
In Hindustan Construction Company Ltd. v. Bihar Rajya Pul Nirman Nigam Ltd. the Supreme Court reaffirmed the principle of finality of orders appointing arbitrators under Section 11 of the Arbitration and Conciliation Act, 1996. The dispute arose from a 2014 contract containing an arbitration clause. After the respondent failed to appoint an arbitrator for a fresh dispute, the Patna High Court appointed a sole arbitrator under Section 11(6). Both parties participated in the arbitration for over three years, held more than 70 hearings, and jointly sought extensions of the arbitrator’s mandate under Section 29A. Subsequently, the respondent sought review of the appointment order, which the High Court allowed, effectively terminating the arbitration. The Supreme Court set aside this decision, holding that no review or appeal lies against a Section 11 appointment order, as the court becomes functus officio thereafter. It clarified that defects in a unilateral appointment mechanism are severable and do not negate the arbitration agreement itself. Further, by actively participating and seeking mandate extensions, the respondent waived its objections under Section 4. The Court directed appointment of a substitute arbitrator to continue proceedings from the final-argument stage.
directing the Uttar Pradesh Legislative Assembly Secretariat to pay ₹5.37 crore with interest and costs over a cancelled recruitment examination dispute. In the Section 34 challenge under the Arbitration and Conciliation Act, 1996, the High Court dismissed the Secretariat’s petition attacking the award. The Tribunal had held that termination of the contract was illegal because TCS had substantially performed its contractual obligations in conducting the online recruitment process for Review Officers and Assistant Review Officers. The Court rejected the Secretariat’s arguments that the contract was frustrated or that the Secretariat was a separate entity from the State. It underscored that Section 56 of the Contract Act (frustration) does not apply where obligations have been fulfilled, and technical objections on impleading the State were untenable. The award of ₹5.37 crore with monthly interest and costs was upheld, reinforcing judicial reluctance to interfere with commercial arbitration awards where the arbitral tribunal’s findings are based on plausible evidence and contractual performance.
In Rousanara Begum v. S.K. Salahuddin & Anr., the Supreme Court held that a divorced Muslim woman is entitled to recover gifts, dowry articles, gold ornaments and other properties given at or around the time of marriage, including those given to the husband, under Section 3(1) of the Muslim Women (Protection of Rights on Divorce) Act, 1986. The Court ruled that the High Court erred in disbelieving the woman’s claim by giving undue importance to contradictions drawn from a separate Section 498A IPC case, while ignoring reliable evidence such as the Marriage Registrar’s testimony. Emphasising the object and purpose of the 1986 Act, the Court held that it must be interpreted in a purposive manner to ensure dignity, equality and financial security of divorced Muslim women in line with Article 21 of the Constitution. The Court underscored that judicial interpretation should counter patriarchal discrimination rather than reinforce it. Allowing the appeal, the Supreme Court set aside the High Court’s order and directed the husband to refund the claimed amount to the appellant, with 9% annual interest in case of default.
In J&K Service Selection Board v. Sudesh Kumar & Ors., the Supreme Court reaffirmed that evaluation criteria in a recruitment process cannot be altered after candidates have completed all stages of selection, particularly after interviews are concluded. The case concerned recruitment to Forester posts where the minimum eligibility was 10+2 with Science, and the original scheme awarded uniform weightage to B.Sc. Forestry degrees. After interviews, the Board arbitrarily modified the criteria by assigning different marks to 3-year and 4-year B.Sc. Forestry degrees, disadvantaging certain candidates. The Court held that such post-interview changes violate principles of fairness, transparency, and non-arbitrariness, and lack rational nexus with the object of recruitment, especially when the post primarily emphasized physical standards and viva voce. Relying on K. Manjusree and the Constitution Bench decision in Tej Prakash Pathak, the Court ruled that “rules of the game” cannot be changed mid-way. Upholding the High Court’s decision, the Supreme Court directed adjustment of affected candidates against vacant or additional posts while protecting those already appointed from displacement.
In Sagar v. State of U.P. & Anr., the Supreme Court held that bail cannot be granted solely on the ground of parity with co-accused without assessing the specific role of the accused. The case arose from a village dispute resulting in the murder of the complainant’s father, where one accused fired the fatal shot while others allegedly instigated the act, blocked the victim’s escape, and were armed. The Court clarified that parity in bail matters relates to the role and position of the accused in the crime, not merely their inclusion in the same FIR. Accused with distinct and more serious roles cannot claim parity with others granted bail. The Court further emphasized that bail orders, though not requiring elaborate reasoning, must be reasoned and non-mechanical, as non-speaking orders violate principles of natural justice. Courts must consider factors such as gravity of the offence, nature of allegations, severity of punishment, risk of witness or evidence tampering, criminal antecedents, and prima facie involvement. Applying these principles, the Supreme Court set aside the bail granted to one accused and remanded another bail order for fresh consideration with proper reasoning.
In Y D Transport Company & Anr. v. SREI Equipment Finance Ltd., the Calcutta High Court set aside an arbitral award under Section 34 of the Arbitration and Conciliation Act, 1996, holding it null and void due to improper constitution of the tribunal. The Court clarified that the limitation period for filing a Section 34 challenge begins from the actual receipt of the signed award, not its date of issuance, and the petition filed was within time. Addressing jurisdiction, the Court held that Section 42 does not bar the seat court from entertaining a Section 34 application even if execution under Section 36 is pending elsewhere. Crucially, the tribunal was unilaterally appointed by the respondent, violating Section 12(5) read with the Seventh Schedule and principles of impartiality and equality under Section 18. No express written waiver existed, and mere participation could not cure the defect. Following precedents like Perkins Eastman, the Court ruled the award was contrary to public policy and tainted by bias, and allowed the Section 34 petition, setting aside the award.
In Poonam Wadhwa v. Ajay Wadhwa & Ors., the Supreme Court reiterated that a parent’s work-from-home status alone cannot determine child custody, as the paramount consideration is the welfare of the child. The Court held that working from home does not automatically make one parent better suited, since both parents may need to work to support the family. Factors such as distance from the child’s school in metropolitan areas and a parent’s travel during the Covid-19 period were found to be irrelevant or non-decisive. The Court placed significant weight on the child’s preference, stability, and settled environment, noting that the minor son was comfortable living with his father and enjoyed support from the extended family. While acknowledging the importance of maintaining sibling bonds, the Court held that it could not override the child’s present emotional security and routine. Upholding the High Court’s decision granting custody to the father, the Supreme Court refused to interfere, but also protected the mother’s visitation rights, emphasizing that custody arrangements can be revisited before the Family Court if circumstances materially change.
In Bumba v. State of West Bengal, the Supreme Court stressed that police and courts must act as initial filters to prevent criminal prosecutions that have no reasonable prospect of conviction, especially where disputes are predominantly civil in nature. Examining the scope of discharge under Section 227 CrPC, the Court reiterated that a judge must apply judicial mind to determine whether the material raises grave suspicion, not mere conjecture, and is not expected to act as a post office for the prosecution. On merits, the Court held that Section 354C IPC (voyeurism) was not attracted as there was no allegation of the complainant being engaged in a “private act,” and photographs taken in a common area do not constitute voyeurism. Section 506 IPC was also not made out due to absence of any specific threat, while Section 341 IPC failed as the appellant was enforcing a lawful injunction and the complainant had no enforceable right of entry. The Court cautioned against mechanical prosecutions arising from civil disputes, noting that such cases burden the justice system and undermine fair trial rights. Consequently, the accused was discharged.
In Sathyan Naravoor v. Union of India & Ors., the Supreme Court issued pan-India directions to safeguard the rights of prisoners with disabilities (PwD), emphasizing compliance with the Rights of Persons with Disabilities Act, 2016. The Court mandated that all States and Union Territories implement the 15-point framework from L. Muruganantham v. State of Tamil Nadu (2025), covering identification of disability at admission, accessible infrastructure, tailored healthcare and diet, staff training on disability rights, and amendment of prison manuals within six months. Additional directions include establishing accessible grievance redressal mechanisms, providing inclusive education with accommodations, ensuring assistive devices like wheelchairs and hearing aids, and granting enhanced visitation rights for inmates with benchmark disabilities. Non-compliance may attract penalties under Section 89 of the RPwD Act. States and UTs are required to submit compliance reports within four months, with the next review hearing scheduled for 7th April 2026, ensuring nationwide monitoring and protection of the rights and dignity of disabled prisoners.