The Supreme Court of India considered compliance with its earlier directions in State of Uttar Pradesh v. Ajmal Beg concerning prosecution of dowry death and cruelty cases. The case involved allegations that a married woman had suffered repeated demands for a colour television, motorcycle or scooter and ₹15,000 in cash, followed by her death in a burning incident. The accused had originally been convicted under Section 304-B IPC, Section 498-A IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961, but the High Court acquitted them. The Supreme Court examined the implementation of safeguards intended to ensure effective investigation and trial of such cases. The Court stressed the importance of prompt framing of charges, avoiding unnecessary adjournments, proper investigation and monitoring of serious dowry-related offences. The matter illustrates the statutory requirements of dowry death, cruelty, “soon before death,” Section 304-B IPC, Section 498-A IPC and the Dowry Prohibition Act.
The Rajasthan High Court initiated suo motu proceedings concerning the welfare and future of Gen Z, Gen Alpha and Gen Beta. The Court examined systemic issues affecting education, employment, health and development of younger generations, particularly students in government schools. Concerns included inadequate infrastructure, shortage of trained personnel, limited access to technology, the education-employment gap, examination-paper leaks, excessive screen time, digital burnout and insufficient mental-health support. The Court also considered the impact of Artificial Intelligence on education and the need to preserve foundational skills such as reading, handwriting, reasoning and original writing. It directed governmental authorities to submit status reports and action plans addressing these issues, including safe and nutritious food and implementation of applicable FSSAI regulations. The proceedings remain at a preliminary stage and do not constitute a final determination. The matter raises important issues concerning Article 21, right to education, child welfare, State responsibility and public interest litigation.
The Allahabad High Court dismissed a petition filed by a Muslim student seeking permission to wear a hijab/headscarf with the prescribed school uniform. The petitioner argued that wearing the headscarf was an essential religious practice and that the school’s refusal violated Articles 14 and 19(1)(a) of the Constitution. The Court held that the petitioner failed to establish through sufficient pleadings or authoritative religious material that wearing a headscarf inside the classroom was obligatory or essential to Islam. The Court also held that the school had a legitimate authority to prescribe a uniform, bona fide and non-discriminatory dress code for maintaining discipline, equality and institutional identity. Earlier tolerance by the school did not create an enforceable right or estoppel. The Court considered the Karnataka High Court’s hijab ruling persuasive, while noting that the Supreme Court’s earlier split verdict had not finally settled the broader issue.
The Supreme Court of India cancelled the bail granted to two accused in a serious murder case, holding that bail cannot be granted mechanically where the prosecution material discloses a grave offence. The case arose from an incident in which the deceased was allegedly assaulted, restrained and set on fire using petrol. The Court found that the accused had allegedly arrived together, carried petrol in advance and acted in circumstances suggesting preparation and common intention. The Supreme Court stressed that a bail order must demonstrate proper application of judicial mind to the gravity of the offence, prima facie evidence, individual roles, criminal antecedents and the possibility of influencing witnesses or obstructing the trial. The Court also clarified that parity cannot be applied mechanically: an accused cannot claim bail merely because a co-accused received bail, particularly when the earlier order ignored material evidence. The judgment reinforces bail jurisprudence, prima facie case, common intention, parity, judicial discretion and cancellation of bail.
The Supreme Court of India quashed domestic-violence proceedings concerning claims that had already been voluntarily settled between the parties. The husband and wife had entered into a Settlement Agreement in 2016 resolving their matrimonial and financial disputes. The wife expressly agreed not to make future monetary or maintenance claims and subsequently confirmed the settlement through an affidavit before the Family Court during mutual-consent divorce proceedings. Despite this, proceedings under the Protection of Women from Domestic Violence Act, 2005 were later initiated concerning acts that allegedly occurred before the settlement. The Supreme Court held that a voluntary and unequivocal waiver, reaffirmed before a court, cannot ordinarily be used to revive previously relinquished claims. Mere allegations of coercion or duress were insufficient when no substantive proceeding had been initiated to set aside the settlement. However, the Court protected the daughter’s independent legal rights, since she was not a party to the settlement. The ruling concerns settlement, waiver, maintenance, DV Act, Section 482 CrPC and abuse of process.
The Supreme Court of India acquitted Ravi Kumar Singh Malhotra after finding that the prosecution failed to establish guilt beyond reasonable doubt. The prosecution alleged that the appellant had murdered his wife and one child by strangulation, while another child, aged approximately four-and-a-half years, was presented as the principal eyewitness. The prosecution also relied on last-seen evidence, alleged abscondence, recoveries and circumstantial evidence. The Supreme Court found the child witness’s testimony unreliable because of inconsistencies and circumstances suggesting possible tutoring. Certain allegations made by the child were also inconsistent with medical evidence. The Court held that the remaining circumstances did not form a complete and unbroken chain of circumstantial evidence. The High Court had improperly reversed the trial court’s acquittal without sufficient justification. The decision reinforces the principles of proof beyond reasonable doubt, child witness testimony, corroboration, circumstantial evidence, last-seen theory and benefit of doubt.
The Delhi High Court held that a child victim of sexual assault cannot be expected to describe the incident using precise legal or anatomical terminology. In State v. Munna Kumar, the case involved a young child who had alleged sexual assault. The Trial Court had acquitted the accused of rape while convicting him for a lesser offence, partly relying upon the absence of specific terminology describing penetration. The High Court held that testimony of a child must be assessed in the context of the child's age, understanding and circumstances of the incident. A young child cannot reasonably be expected to understand or reproduce technical legal concepts. The Court also considered the medical and forensic material available on record and held that evidence should be examined cumulatively rather than by isolating individual statements. The Court emphasised that investigation deficiencies do not automatically destroy otherwise reliable evidence. It consequently interfered with the finding concerning the more serious offence. The judgment is significant for appreciation of child testimony, medical corroboration, evidentiary standards and cases involving sexual offences against children.
The Supreme Court considered whether criminal proceedings could be quashed after the parties reached a settlement in a case involving non-heinous offences. In The State of Punjab v. Avtar Singh & Ors., the Court upheld the exercise of inherent jurisdiction to bring the proceedings to an end after considering the nature of the dispute and the settlement between the parties. The Court explained that the power under Section 482 CrPC is distinct from the statutory power of compounding offences under Section 320 CrPC. In appropriate circumstances, proceedings involving essentially private or non-heinous disputes may be quashed to secure the ends of justice, even where the matter has progressed substantially. However, the Court reiterated that serious offences such as murder and rape, particularly offences affecting society at large, cannot ordinarily be terminated merely because the victim and accused have entered into a private settlement. The decision discusses compromise, inherent jurisdiction, Section 482 CrPC, Section 320 CrPC and the distinction between private disputes and serious crimes.
The Supreme Court held that a Trial Court cannot remain a passive spectator when crucial witnesses are necessary for deciding a criminal case fairly. In Anil Singh @ Anil Kumar Singh v. State of Bihar & Ors., the prosecution had failed to examine important witnesses, including an injured witness, the treating doctor and the Investigating Officer. The Court relied on Section 311 CrPC, which empowers courts to summon, examine or recall any person whose evidence appears essential for a just decision. The Court clarified that exercising this power does not necessarily amount to filling a lacuna in the prosecution case. Instead, it may be necessary to ensure that relevant evidence is placed before the court and that the accused receives a fair opportunity to respond. The Court directed the Trial Court to examine the material witnesses and thereafter conduct the Section 313 CrPC proceedings afresh. The judgment highlights the importance of judicial intervention, fair trial, material witnesses and the duty of courts to discover the truth.
The Supreme Court set aside a conviction in a kidnapping and murder case after finding significant deficiencies in the prosecution evidence. In Kondapaka Sridhar @ Shekar v. State of Telangana, the prosecution relied upon electronic evidence, the last-seen theory and circumstantial evidence. The Court noted that the electronic evidence was not properly supported by the mandatory certification required under Section 65B of the Evidence Act. The concerned Nodal Officer was also not examined. The Court further questioned the reliability of identification evidence because the witness had been shown photographs of suspects before the Test Identification Parade. This affected the evidentiary value of the subsequent identification. The prosecution also failed to establish important foundational facts connecting the accused with the premises where the body was recovered. The Court reiterated that Section 106 of the Evidence Act does not shift the primary burden of proving the prosecution's case onto the accused. The prosecution must first establish the basic facts forming its case. The judgment is significant for electronic evidence, Section 65B certification, identification procedures, circumstantial evidence and Section 106.
The Supreme Court held that a claim of juvenility can be raised at any stage of criminal proceedings, including after conviction and final disposal of a case. In Mahavir @ Avnish v. State of Madhya Pradesh, the appellant claimed that he was below 18 years of age when the alleged offence was committed. The Court treated the question of juvenility as a jurisdictional issue rather than merely a procedural defence. It held that if a person was a child on the date of the offence, the ordinary criminal court could not exercise jurisdiction over that person in the same manner as an adult accused. The Court also examined the conviction under Section 201 IPC and found that the prosecution had failed to establish the underlying offence sufficiently. Consequently, the conviction could not independently survive. The judgment emphasises the protective purpose of the Juvenile Justice framework and confirms that procedural finality cannot defeat a genuine claim of juvenility. It is important for understanding Section 7A of the Juvenile Justice Act, age determination and jurisdiction concerning children in conflict with law.
The Supreme Court directed payment of family pension from the date on which the entitlement arose rather than from the later date when the widow approached the authorities or court. In Maya Banerjee v. Union of India & Ors., the appellant's husband, a Railway employee, had died in 2000. Despite his death, disciplinary proceedings were subsequently continued and issues relating to his service status affected the release of pensionary benefits. The High Court had recognised the widow's entitlement but restricted the arrears to a later period. The Supreme Court observed that pension and family pension are statutory and valuable rights and cannot be treated merely as discretionary benefits. The Court held that the widow's entitlement arose from the relevant date following her husband's death and directed payment of arrears with interest. The decision also considered the consequences of administrative delay in processing pensionary benefits. The judgment reinforces principles concerning family pension, pensionary rights, recurring causes of action and the obligation of authorities to process legitimate pension claims without unjustified delay.
The Supreme Court considered whether a company can be prosecuted for criminal offences when the individual officer allegedly responsible for the company's conduct has not been separately arraigned as an accused. In Sanofi India Ltd. v. Central Bureau of Investigation, the Court rejected the argument that prosecution of a corporate entity necessarily fails unless a particular natural person is simultaneously made an accused. The Court recognised that a company, although a juristic person, acts through its officers and employees, and the conduct and state of mind of relevant individuals may, where legally permissible, be attributed to the company. The Court also examined the distinction between corporate criminal liability and the separate liability of individuals responsible for the company's conduct. The judgment is significant for the doctrine of attribution and corporate criminal responsibility. It also discusses allegations involving conspiracy and cheating and the scope of the High Court's inherent jurisdiction under Section 482 CrPC. The ruling provides important guidance on prosecuting companies and determining when individual officers must additionally be proceeded against.
The Supreme Court reiterated that a person can raise a claim of juvenility even after the conclusion of criminal proceedings. In Mahavir @ Avnish v. State of Madhya Pradesh, the Court considered evidence concerning the appellant's age on the date of the alleged offence and found that he was below 18 years. The Court treated juvenility as a jurisdictional fact because the status of the accused at the time of the offence determines the applicability of the Juvenile Justice framework. The Court held that the passage of time or finality of earlier proceedings does not by itself prevent consideration of a genuine juvenility claim. The judgment also considered the conviction under Section 201 IPC and held that the offence of causing disappearance of evidence cannot be sustained independently when the prosecution has failed to establish the underlying offence. The decision reinforces the protective nature of juvenile justice law and the principle that children must be dealt with under the statutory framework applicable to juveniles. It is relevant to age determination, Section 7A of the Juvenile Justice Act and jurisdiction of criminal courts.
The Supreme Court quashed criminal proceedings under Section 69 of the Bharatiya Nyaya Sanhita concerning an alleged promise to marry. In Kunal Rameshbhai Kalyani v. State of Gujarat & Anr., the complainant alleged that the accused established a physical relationship with her after expressing an intention to marry but later refused marriage because of opposition from his mother. The Court examined whether the allegations disclosed the deceitful conduct contemplated by Section 69 BNS. It reiterated that a promise to marry becomes criminally relevant only where it is established that the promise was false from the very beginning and was made without any intention of being fulfilled. A subsequent failure to marry does not, by itself, establish that the original promise was fraudulent. The Court found that the FIR described a relationship that developed through mutual interaction and that the accused's later refusal was attributed to his mother's objection. The allegations therefore did not establish the required initial fraudulent intent. The Supreme Court consequently allowed the appeal and quashed the FIR and proceedings.