As part of its annual tradition, LiveLaw presents its curated list of the 100 most significant Supreme Court judgments of the year, a feature keenly awaited by our readers each year.The judgments have been selected on the basis of the following broad criteria:(i) their importance to the general public;(ii) their role in settling or clarifying contested questions of law; and(iii) their...
As part of its annual tradition, LiveLaw presents its curated list of the 100 most significant Supreme Court judgments of the year, a feature keenly awaited by our readers each year.
The judgments have been selected on the basis of the following broad criteria:
(i) their importance to the general public;
(ii) their role in settling or clarifying contested questions of law; and
(iii) their practical utility for practising lawyers, judges and law students.
It is clarified that inclusion in this list does not imply that these are necessarily the “best” or most commendable judgments of the year. Some of the decisions are controversial, and several have generated strong counter-views. Nevertheless, each of them merits attention and discussion, given its wider significance and its impact on litigation, governance, and the broader socio-political landscape. It is for these reasons that the judgments find place in this compilation.
The judgments are arranged in chronological order, and the reports on each decision are hyperlinked in the respective titles.
The list of 100 judgments will be published in four parts. This is the first part.
Case Details: Satender Kumar Antil v. CBI
Citation: 2025 LiveLaw (SC) 112
The Supreme Court has directed that police should not serve notice for appearance to the accused/suspect as per Section 41A of the Code of Criminal Procedure (Section 35 of the Bharatiya Nagarik Suraksha Sanhita) through WhatsApp or other electronic modes.
The Court made it amply clear that the service of notice through WhatsApp or other electronic modes cannot be considered or recognised as an alternative or substitute to the mode of service recognised and prescribed under the CrPC, 1973/BNSS, 2023.
The Court also directed that notices under Section 160 of CrPC/Section 179 of BNSS, 2023 and Section 175 of CrPC/Section 195 of BNSS to the accused persons or otherwise can be issued only through the mode of service as prescribed under the CrPC/BNSS.
A bench comprising Justice MM Sundresh and Justice Rajesh Bindal passed these directions in the Satender Kumar Antil v. CBI case in which it had issued directions to prevent unnecessary arrests and to ease the grant of bail to deserving undertrial prisoners. The Court had been posting this matter from time to time to monitor the compliance of the States and High Courts with the directions.
2. Supreme Court Asks Union To Consider Bringing Law To Protect Domestic Workers' Rights
Case Details: Ajay Mallik v. State of Uttarakhand | SLP(Crl) 8777/2022
Citation: 2025 LiveLaw (SC) 120
The Supreme Court directed the Union Government to consider the enactment of a law to protect the rights of domestic workers.
A bench comprising Justice Surya Kant and Justice Ujjal Bhuyan directed the Ministry of Labour & Employment and the related Ministries to constitute an expert committee to look into the feasibility of such a law on domestic workers and submit a report within six weeks. After the report of the committee is received, the Union Government should make efforts to bring a law to uphold the dignity and safety of the domestic workers.
The bench observed that though domestic workers are an essential workforce, there was no pan-India legislation to protect their rights. Therefore, they are vulnerable to exploitation by employers and agencies.
Case Details: Mahabir and others v. State of Haryana
Citation: 2025 LiveLaw (SC) 121
The Supreme Court bemoaned the trend of Governments appointing Government Pleaders and Public Prosecutors in High Courts on political considerations. The Court said that "favouritism and nepotism" should not be factors while appointing Government Pleaders and Public Prosecutors.
A bench comprising Justice JB Pardiwala and Justice R Mahadevan observed :
"This judgement is a message to all the State Governments that the AGPs and APPs in respective High Courts should be appointed solely on the merit of the person. The State Government owes a duty to ascertain the ability of the person; how proficient the person is in law, his overall background, his integrity etc."
The Supreme Court asked the State of Haryana to pay a compensation of Rs 5 lakhs each to three accused who were illegally sentenced in a murder case.
The Punjab and Haryana High Court had, in its revisional jurisdiction, reversed the acquittal of appellants and convicted them of murder. Although the State had not filed any appeal against the acquittal by the trial court, the father of the deceased filed a revision petition. Despite the High Court having no power to reverse an acquittal in revisional jurisdiction, it did so.
4. Residence-Based Reservation In PG Medical Courses Impermissible, Violates Article 14: Supreme Court
Case Details: Tanvi Behl v. Shrey Goel and others | C.A. No. 9289/2019
Citation: 2025 LiveLaw (SC) 122
The Supreme Court held that domicile-based reservations in PG Medical seats is impermissible as it is unconstitutional for being violative of Article 14 of the Constitution.
"Residence-based reservation in PG medical courses is clearly violative of Article 14 of the Constitution," pronounced a bench comprising Justice Hrishikesh Roy, Justice Sudhanshu Dhulia and Justice SVN Bhatti.
The bench held that providing for domicile residence-based reservations in admission in PG medical courses within the State quota is constitutionally impermissible.
The Court held that State quota seats are to be filled up on the basis of merit in the NEET exam. Answering a reference, the three-judge bench stated that it was reiterating the law laid down in the previous judgments in Pradeep Jain, Saurabh Chandra cases.
Also from the judgment - All Indians Have Only One Domicile- 'Domicile Of India'; No State Or Provincial Domicile In Our Legal System: Supreme Court
5. Judicial Officers' Pay: Supreme Court Asks High Courts To Form Committees For Service Conditions Of District Judiciary Within 4 Weeks
Case Details: All India Judicial Association v. Union of India W.P.(C) No. 643/2015
Citation: 2025 LiveLaw (SC) 130
The Supreme Court urged all High Courts to ensure the constitution of the "Committee for Service Conditions of the District Judiciary" (CSCDJ) in terms of the directions issued in the All India Judges Association case in January 2024 to deal with the grievances of judicial officers regarding the implementation of the Second National Judges Pay Commission (SNJPC).
A bench comprising Justice BR Gavai, Justice Augustine George Masih and Justice K Vinod Chandran passed the direction after being informed by Senior Advocate K Paremeshwar, the amicus curiae in the All-India Judges Association case, that many High Courts are yet to constitute the CSCDJs. Even in many High Courts where the Committees have been formed, they are not holding regular meetings, the amicus said, resulting in many judicial officers filing applications in the Supreme Court raising their individual grievances. Also, in many High Courts, nodal officers have not been appointed for the CSCDJs.
The Supreme Court urged the High Court judges to record the Annual Confidential Reports (ACRs) of judicial officers promptly so that they do not lose opportunities of promotion. The Court directed the High Courts and State Governments to frame rules regarding the increase of posts of District Judges in the Selection Grade and Super Time Scale categories. The Court reiterated that judicial officers, who have got the benefit of Annual Career Progression (ACP), are also entitled to the additional increment due to the acquisition of a higher qualification.
6. Trial Courts Wrongly Convicting Persons For Dowry Death Misapplying S.304B IPC; Time For Judicial Academies To Step In: Supreme Court
Case Details: Karan Singh v. State of Haryana., Criminal Appeal No. 1076 of 2014
Citation: 2025 LiveLaw (SC) 135
The Supreme Court, while overturning the appellant/ accused's conviction under Section 304-B (Dowry death) of the IPC, noted that while the Court has repeatedly laid down this provision's ingredients, the Trial Courts were committing the same mistakes repeatedly. It is for the State Judicial Academies to step in., the Court said.
Essentially, the allegations against the appellant were for committing dowry death and cruelty to his wife who died by suicide. As a result, he was convicted for these offences and was sentenced to rigorous imprisonment for eight years in total. The High Court confirmed this sentence. Challenging these judgments, he approached the Apex Court.
The bench of Justices Abhay S. Oka and Ujjal Bhuyan, at the outset, discussed the essential ingredients of Section 304-B. Firstly, the death must have been caused by any burns or bodily injury or must have occurred otherwise than under normal circumstances. The same must have been within seven years of her marriage. Further, she must have been subjected to cruelty or harassment, for dowry's demand, soon before her death.
It further noted that even to invoke presumption under Section 113-B of the Evidence Act, it is essential to prove that the appellant was subjected to cruelty or harassment soon before her death.
7. S.156(3) CrPC v. S.175(3) BNSS | BNSS Mandates Magistrate To Hear Police Officer On Refusal To Register FIR, Ensures Reasoned Order: Supreme Court
Case Details: Om Prakash Ambadkar v. State of Maharashtra & Ors.
Citation: 2025 LiveLaw (SC) 139
The Supreme Court criticized the routine use of Section 156(3) Cr.P.C. to order police investigations, even in simple cases where the court could proceed directly to trial, stressing that magistrates should act judicially, not mechanically as a mere post office.
The Court clarified that the magistrate can direct the police investigation only “where the assistance of the Investigating Agency is necessary and the Court feels that the cause of justice is likely to suffer in the absence of investigation by the police.”
The aforesaid observation came by a bench of Justices JB Pardiwala and R Mahadevan while hearing an appeal filed against the Bombay High Court's Nagpur Bench decision refusing to set aside the magistrate's order directing the registration of FIR against the Appellant/Police official herein for the offence punishable under Sections 323, 294, 500, 504 & 506 respectively of the Indian Penal Code (for short, “the IPC”).
8. Supreme Court Issues Directions To Ensure Toilet Facilities In Court Premises For Women, Disabled & Transgender Persons
Case Details: Rajeeb Kalita v. Union of India and Ors. W.P.(C) No. 538/2023
Citation: 2025 LiveLaw (SC) 72
The Supreme Court issued a set of directions for the construction of toilet facilities especially for women, specially-abled persons and transgender persons in Court premises and tribunals across the country.
A bench comprising Justice JB Pardiwala and Justice R Mahadevan pronounced the judgment in a writ petition filed by Rajeeb Kalita in 2023.
"We have given enough number directions for the construction and maintenance of toilets and all other facilities for women, physically disabled persons, transgender persons, etc. The State Governments and of toilets and Union Territories shall allocate sufficient funds for the construction, maintenance and cleanliness of toilet facilities within the court premises, which shall be periodically reviewed in consultation with a committee constituted by the High Courts. A status report shall be filed by all the States, UTs and High Courts within a period of four months," Justice Mahadevan said while reading out the operative part.
The Supreme Court held that toilet facilities are not merely a matter of convenience, but a facet of human rights. Access to proper sanitation is recognized as a fundamental right under Article 21 (right to life) of the Constitution. This Article encompasses a right to a safe and hygienic environment.
The Supreme Court noted that the same would protect privacy and remove threats to ladies and transgender persons.
9. Supreme Court Relaxes Conditions To Appoint Ad Hoc Judges In High Courts, Says Vacancies Needn't Be More Than 20%
Case Details: Lok Prahari Through Its General Secretary v. Union of India
Citation: 2025 LiveLaw (SC) 144
Relaxing the conditions to appoint ad hoc judges in High Courts, the Supreme Court kept in abeyance the condition in its April 2021 judgment that ad hoc judges as per Article 224 of the Constitution can be appointed only if the vacancies are more than 20% of the sanctioned strength.
As per Article 224A, retired High Court judges can be appointed as High Court Judges.
A bench comprising Chief Justice of India Sanjiv Khanna, Justice BR Gavai and Justice Surya Kant passed the direction so as to ease the appointment of ad-hoc judges considering the high rise in the pendency of cases, especially criminal appeals. This order was further modified on December 18.
10. Supreme Court Flags Stringent Limitation Provisions Curtailing Arbitration Appeal Remedies, Urges Parliament To Address Issue
Case Details: My Preferred Transformation & Hospitality Pvt. Ltd. & Anr. v. M/S Faridabad Implements Pvt. Ltd.
Citation: 2025 LiveLaw (SC) 49
The Supreme Court raised concerns about the interpretation of limitation statutes in arbitration cases and observed that the rigid application of the law could curtail the limited remedy available under Section 34 of the Arbitration and Conciliation Act, 1996 to challenge arbitral awards.
“In our view, the above construction of limitation statutes is quite stringent and unduly curtails a remedy available to arbitrating parties to challenge the validity of an arbitral award. This must be addressed by the Parliament”, the Court observed.
A bench of Justice PS Narasimha and Justice Pankaj Mithal dismissed an appeal filed by a company against a Delhi High Court judgment rejecting its challenge to an arbitral award as barred by limitation under Section 34.
Justice Narasimha observed that remedies available under Sections 34 and 37 of the Arbitration Act, which deal with challenging arbitral awards and appeals, are inherently limited due to statutory prescription and advocated for liberal interpretation of limitation provisions to preserve the limited window for parties to contest an award. A rigid approach, he warned, could result in denying remedies and discourage arbitration as a dispute resolution mechanism.
The Supreme Court in a judgment authored by Justice Pankaj Mithal called for legislative reforms to ensure uniform limitation periods across statutes, enabling courts to condone delays beyond rigid limits in cases where sufficient cause is shown.
11. Supreme Court Allows All Disabled Candidates To Take Scribe In Exams Without Meeting Benchmark Disabilities
Case Details: Gulshan Kumar v. Institute of Banking Personnel Selection | W.P.(C) No. 1018/2022
Citation: 2025 LiveLaw (SC) 151
The Supreme Court allowed a writ petition filed by a candidate suffering from Focal Hand Dystonia(a type of a writ's camp), seeking to avail the benefit of the scribe by relying on landmark Vikas Kumar v. UPSC (2021) in which it held that benchmark disability is not the precondition to obtaining a scribe.
The Court has held that the facility of scribe and other necessary facilities should be extended to all disabilities thereby upholding the right of inclusive education of persons with disability to participate in examinations with necessary accommodations.
A bench of Justices J.B. Pardiwala and R. Mahadevan passed the judgment by reiterating the Vikas Kumar judgment in which a UPSC candidate, who suffered from Writer's camp, was allowed to avail scribe as against the Civil Services Examination Rules, 2018, in which it was stated that a scribe could be provided only to blind candidates and candidates with locomotor disability or cerebral palsy with an impairment of at least 40%.
12. 'Uma Devi' Judgment Can't Justify Exploitative Engagements: Supreme Court Allows Regularisation Of Long-Serving Daily Wagers
Case Details: Shripal & Anr. v. Nagar Nigam, Ghaziabad
Citation: 2025 LiveLaw (SC) 153
The Supreme Court criticized the practice of public institutions hiring workers on daily wages (temporary contracts) to avoid providing them with permanent benefits. The Court reaffirmed that long-serving temporary workers appointed to sanctioned positions cannot be denied regularization simply because their initial appointments were temporary.
While acknowledging the precedent set in State of Karnataka v. Uma Devi (2006), which established that daily wage workers cannot claim permanent employment without meeting constitutional requirements and the existence of sanctioned vacancies, the Court clarified that this ruling cannot be used to deny long-serving workers their rights when the work they perform is inherently permanent.
“Uma Devi cannot serve as a shield to justify exploitative engagements persisting for years without the Employer undertaking legitimate recruitment.”, the court observed.
13. Arrest Illegal If Reasons Not Informed; When Art 22(1) Is Violated, Court Must Grant Bail Despite Statutory Restrictions: Supreme Court
Case Details: Vihaan Kumar v. State of Haryana and Anr, SLP(Crl) No. 13320/2024
Citation: 2025 LiveLaw (SC) 169
Noting that informing an arrested individual of the grounds for their arrest is a fundamental right under Article 22(1) of the Constitution, the Supreme Court stressed that this information must be conveyed clearly and effectively. The Court also emphasized the magistrate's duty to ensure compliance with Article 22(1) during remand, noting that any violation could warrant the person's release or justify the granting of bail, even in cases with statutory restrictions.
“Even if statutory restrictions on grant of bail exist, the statutory restrictions do not affect the power of the court to grant bail when violation of Article 21 and 22 of the Constitution is established.”, the Court observed.
A bench of Justices Abhay S Oka and N Kotiswar Singh delivered separate but concurring judgments discussing the mandatory nature of informing an arrested person of the grounds for their arrest, as guaranteed by Article 22(1) of the Indian Constitution.
The Supreme Court clarified that informing persons' relatives about their arrest does not exempt the police or investigating agency from their legal and constitutional obligation to inform the arrested persons themselves of the grounds for their arrest.
14. Permanent Alimony & Interim Maintenance Can Be Granted Even When Marriage Is Void Under Hindu Marriage Act: Supreme Court
Case Details: Sukhdev Singh v. Sukhbir Kaur
Citation: 2025 LiveLaw (SC) 195
Answering a reference, the Supreme Court ruled that permanent alimony and interim maintenance under the Hindu Marriage Act, 1955 can be granted even when the marriage has been declared void.
“A spouse whose marriage has been declared void under Section 11 of the 1955 Act is entitled to seek permanent alimony or maintenance from the other spouse by invoking Section 25 of the 1955 Act. Whether such a relief of permanent alimony can be granted or not always depends on the facts of each case and the conduct of the parties. The grant of relief under Section 25 is always discretionary”, the Court held.
Regarding the grant of interim maintenance under Section 24 of HMA, the Court observed:
“Even if a court comes to a prima facie conclusion that the marriage between the parties is void or voidable, pending the final disposal of the proceeding under the 1955 Act, the court is not precluded from granting maintenance pendente lite provided the conditions mentioned in Section 24 are satisfied. While deciding the prayer for interim relief under Section 24, the Court will always take into consideration the conduct of the party seeking the relief, as the grant of relief under Section 24 is always discretionary.”.
A bench comprising Justices Abhay S. Oka, Ahsanuddin Amanullah, and Augustine George Masih delivered the ruling in response to a reference made by a 2-judge bench led by Justice Vikram Nath last year.
Also from the judgment - Calling A Woman 'Illegitimate Wife' Or 'Faithful Mistress' Violates Her Rights: Supreme Court Criticises Misogynistic Language In Judgment
15. S.437(6) CrPC/S.480(6) BNSS | Be Liberal While Deciding Bail When Magistrate Trial Hasn't Concluded In 60 Days : Supreme Court
Case Details: Subhelal @ Sushil Sahu v. State of Chhattisgarh., Criminal Appeal No. 818/2025
Citation: 2025 LiveLaw (SC) 223
The Supreme Court observed that courts should adopt a liberal approach while dealing with applications under Section 437(6) of CrPC in cases where there is no chance of evidence tampering, absconding, or accused delaying the trial.
“Differently put, where there is absence of positive factors going against the accused showing possibility of prejudice to prosecution or accused being responsible for delay in trial, application under Section 437(6) has to be dealt with liberal hands to protect individual liberty as envisaged under the Constitution.,” the bench of Justices J.B. Pardiwala and R. Mahadevan added.
16. 'Both Hands Intact' Condition For MBBS Admission Of Persons With Disabilities Arbitrary : Supreme Court
Case Details: Anmol v. Union of India & Ors | Civil Appeal No. 14333 of 2024
Citation: 2025 LiveLaw (SC) 236
The Supreme Court held that the eligibility condition prescribed by the National Medical Commission's guidelines that candidates with disabilities must have “both hands intact, with intact sensation and sufficient strength” for admission to MBBS course was arbitrary and antithetical to the Constitution.
The Guidelines regarding admission of students with “Specified Disabilities”, which constitute Appendix H-1 to the Graduate Medical Education Regulations (Amendment), 2019, stated one of the conditions to be as:
“Both hands intact, with intact sensations, sufficient strength and range of motion are essential to be considered eligible for medical course.”
Finding this condition to be against the Rights of Persons with Disabilities Act, 2016 and also the Constitution, the bench comprising Justice BR Gavai and Justice KV Viswanathan allowed the petitioner, a candidate with disability, to secure admission to MBBS course in the Government Medical College, Sirohi, Rajasthan.
17. BNSS/CrPC Provisions On Rights Of Arrested Persons Applicable To GST & Customs Acts : Supreme Court
Case Details: Radhika Agarwal v. Union of India and Ors., W.P.(Crl.) No. 336/2018 (and connected matters)
Citation: 2025 LiveLaw (SC) 255
The Supreme Court on Thursday(February 27) delivered a significant ruling on the powers of arrest under the Goods and Services Tax Act and the Customs Act.
The Court held that the provisions of the Code of Criminal Procedure (now Bharatiya Nagarik Suraksha Sanhita) on the rights of accused persons are equally applicable to the arrests made both under the Customs Act and the GST Act.
The dictum in the Arvind Kejriwal case that the arrest under the Prevention of Money Laundering Act must be made only if there are “reasons to believe” has been applied in the context of GST and Customs arrests as well. Section 19(1) of the PMLA and Section 104 of the Customs Act are virtually the same, the Court noted. Both provisions deal with the power of arrest. The Court held the same for the arrest provision under the GST Act as well.
The Court also held that the circulars issued by the GST department regarding arrest must be strictly adhered to. The Court also rejected the argument that customs officers are police officers.
Other reports about the judgment can be read here.
18. Supreme Court Sets Aside Dismissal Of Two Women Judicial Officers In MP, Says Sensitivity Must Be Shown To Women's Difficulties
Case Details: In Re: Termination of Civil Judge, Class-II (Jr. Division) Madhya Pradesh State Judicial Service, SMW(C) No. 2/2023
Citation: 2025 LiveLaw (SC) 261
The Supreme Court set aside the termination of services of two women judicial officers in Madhya Pradesh, after finding it to be “punitive, arbitrary and illegal.”
A bench of Justices B.V. Nagarathna and NK Singh directed the reinstatement of the two officers within a period of fifteen days in accordance with their seniority they possessed. The Court directed the Madhya Pradesh Government and the Madhya Pradesh High Court to declare the probation of the two officers as on the date their juniors were confirmed (13.05.2023). Monetary benefits of the period of termination shall be calculated notionally for the purpose of pensionary benefits.
The Supreme Court underscored the importance of being sensitive to the gender-specific difficulties faced by women, while assessing their performance.
“While gender is not a rescue for poor performance, it is a critical condition which may weigh for holistic decision-making at certain times and stages of women judicial officers,” the bench observed.
19. Stay On Discharge Orders Should Not Be Granted Unless Circumstances Are Exceptional : Supreme Court
Case Details: Sudershan Singh Wazir v. State (NCT of Delhi) and Ors.
Citation: 2025 LiveLaw (SC) 262
The Supreme Court held that High Courts should not ordinarily stay the discharge orders passed by the trial courts in criminal cases.
“Stay on discharge should never be granted unless circumstances are exceptional,” the Court stated.
The Court further held that even when the appellate court invokes Section 390 CrPC to arrest an accused while considering an appeal against acquittal, then also bail should be rule.
20. 'None Should Be Excluded From Judicial Service Only Because Of Disability': Supreme Court Strikes Down MP Rule Barring Visually Impaired Candidates
Case Details: In Re Recruitment of Visually Impaired In Judicial Services v. Registrar General High Court of Madhya Pradesh, SMW(C) No. 2/2024
Citation: 2025 LiveLaw (SC) 274
The Supreme Court held that no person can be denied consideration for recruitment in the judicial service solely on account of their physical disabilities.
The Court held that persons with disabilities must not face any discrimination in their pursuit of judicial service recruitments and that the State must provide them affirmative action to ensure an inclusive framework. "Any indirect discrimination that results in the exclusion of Person with Disabilitiess, whether through cutoff or procedural barriers must be interfered with in order to uphold substantive equality," the Court pronounced.
"No candidate can be denied consideration solely on account of their disability," the Court stated. Accommodation must be provided to them while assessing their eligibility in terms of the Rights of Persons with Disabilities Act, 2016.
Holding so, the Supreme Court struck down a rule of the Madhya Pradesh Judicial Services Rules to the extent it barred visually impaired and low vision candidates from judicial service.
The Court emphatically held that "visually impaired and low vision candidates are eligible to participate in the selection for posts under the judicial service.
A bench of Justices JB Pardiwala and R. Mahadevan delivered the verdict in a suo motu case regarding Rule 6A of the Madhya Pradesh Services Examination (Recruitment and Conditions of Services) Rules 1994.
21. 'Breastfeeding In Public & Work Places Shouldn't Be Stigmatised': SupremeCourt Issues Directions Regarding Nursing & Child Care Rooms
Case Details: Maatr Sparsh An Initiative By Avyaan Foundation v. Union of India & Ors. | Writ Petition (Civil) No.950/2022
Citation: 2025 LiveLaw (SC) 275
While asking the States/Union Territories to act upon an advisory issued by the Union Government regarding the creation of feeding and child care rooms in public buildings, the Supreme Court observed that the practice of breastfeeding in public places and workplaces should not be stigmatised.
"It would not be wrong at this instance to remind the citizens of this nation of their duty to “renounce practices derogatory to the dignity of women”, as enshrined in Article 51A(e) of the Constitution of India. Over and above the duty of the State to facilitate the exercise of the right of nursing mothers to breast-feed their children, the citizens must ensure that the practice of breastfeeding in public places and at workplaces is not stigmatized."
A bench of Justices B.V. Nagarathna and P.B. Varale pronounced the judgment in a petition seeking directions to construct feeding and child care rooms and creche at public spaces and buildings.
22. Specific Relief Act | Appellate Court Must Specify Time Period To Deposit Sale Consideration For Specific Performance: Supreme Court
Case Details: Ram Lal v. Jarnail Singh (Now Deceased) Through Its Lrs & Ors.
Citation: 2025 LiveLaw (SC) 283
The Supreme Court advised Appellate Courts to specify the time limit for depositing the balance sale consideration, as required under Order XX Rule 12A of the CPC, in cases of specific performance involving the sale or lease of immovable property.
Order XX Rule 12A of Code of Civil Procedure, 1908 (“CPC”) states that where a decree for the specific performance of a contract for the sale or lease of immovable property orders that the purchase-money or other sum be paid by the purchaser or lessee, the court shall specify the period within which the payment shall be made.
The Court ruled that due to operation of doctrine of merger, the decree passed by the trial court specifying the time limit to deposit the balance sale consideration gets merged with the Appellate Court's order, and if the Appellate Court fails to specify the time limit to deposit the balance sale consideration, it would be unjust to deny execution of the decree just because there was belated deposit of balance sale consideration.
23. Courts To Dispose Execution Petitions Within 6 Months, Presiding Officer Liable On Failure: Supreme Court
Case Details: Periyammal (Dead Thr. Lrs.) and Ors v. v. Rajamani and Anr. Etc | SLP(C) No. 8490-8492/2020
Citation: 2025 LiveLaw (SC) 293
The Supreme Court(March 6) directed all High Courts to call for information on all pending execution petitions in the district judiciary. It passed the directions after observing that the executing Courts are taking three to four years to pass appropriate orders, thereby, frustrating the entire decree which is in the favour of the decree-holder.
The Court directed the High Courts to issue an administrative circular asking the trial courts to ensure that pending execution petitions are decided within six months. On failure to do so, the Presiding Officer will be answerable to the High Court on the administrative side.
A bench comprising Justice JB Pardiwala and Justice Pankaj Mithal noted that in Rahul S Shah vs. Jinendra Kumar Gandhi (2021), the Court had directed that the execution proceedings be completed within six months fromthe date of filing. Same direction was reiterated in Bhoj Raj Garg v. Goyal Education and Welfare Society & Ors.(2022). Despite these directions, execution petitions are facing inordinate delays, the Court lamented.
The Court also observed that an application filed under Section 47 of CPC relating to the determination of questions related to the execution of the decree would be deemed as an application filed under Order XXI Rule 97 if it raises questions of right, title, or interest in the property.
24. Motor Accident Claims | Supreme Court Asks High Courts/Tribunals To Direct Transfer Of Compensation To Claimants' Bank Accounts
Case Details: Parminder Singh v. Honey Goyal and Others
Citation: 2025 LiveLaw (SC) 318
The Supreme Court (March 18) emphasized the need for the direct transfer of motor accident claim compensation to claimants' bank accounts to minimize delays and ensure timely payments.
“The general practice followed by the insurance companies, where the compensation is not disputed, is to deposit the same before the Tribunal. Instead of following that process, a direction can always be issued to transfer the amount into the bank account(s) of the claimant(s) with intimation to the Tribunal.”, the Court observed.
In this regard, the bench comprising Justice JK Maheshwari and Justice Rajesh Bindalstreamlined the process for the transfer of the claim amount to the claimant's bank account. It stated that the claimants should provide bank account details at the initial stage of the claim process so that tribunals can issue directions for direct transfers after the passing of awards. Further, for minors or cases requiring fixed deposits, the Court said that banks should ensure compliance and report to the Tribunal.
25. Prioritise Criminal Appeals Of Elderly Accused On Bail, Especially When Crime Is Old: Supreme Court To High Courts
Case Details: State of Madhya Pradesh v. Shyamlal and others
Citation: 2025 LiveLaw (SC) 333
The Supreme Court advised the High Courts to give adequate priority to criminal appeals, where the accused are on bail. If the accused persons have remained on bail, especially in cases involving life sentences, and the appeal is ultimately dismissed after several years, then sending the accused back to prison might be difficult, particularly when they have attained old age.
The Court noted that generally, the High Courts prioritise appeals where the accused are in prison. However, there should be a balance struck so as to give adequate priority to the appeals where the accused are on bail, especially when the accused are aged and a long time has passed since the crime.
"The old age of the accused and the long lapse of time from the commission of the offence can always be a ground available to give some priority to the appeals against conviction of the accused on bail," the Court said.
A bench comprising Justice Abhay S Oka, Justice Ahsanuddin Amanullah and Justice AG Masih made these observations while deciding an appeal filed by the State of Madhya Pradesh regarding a crime which occurred in 1989.
Part 2 can be read here. Part 3 (51-75) can be read here. Part 4 can be read here.