Madhya Pradesh High Court Monthly Digest: October 2025

Jayanti Pahwa

23 Nov 2025 10:00 AM IST

  • Madhya Pradesh High Court Monthly Digest: October 2025

    Citations: 2025 LiveLaw (MP) 204 to 2025 LiveLaw (MP) 231Nominal Index YK v State of MP 2025 LiveLaw (MP) 204Himanshu Sarwan v State of MP 2025 LiveLaw (MP) 205Mukesh Kumawat v The State of MP 2025 LiveLaw (MP) 206X v State of MP 2025 LiveLaw (MP) 207Adesh Parihar v State of MP 2025 LiveLaw (MP) 208Savita Yadav v State of MP 2025 LiveLaw (MP) 209Manoj Kumar Ahuja v Gurmej Singh 2025 LiveLaw...

    Citations: 2025 LiveLaw (MP) 204 to 2025 LiveLaw (MP) 231

    Nominal Index 

    • YK v State of MP 2025 LiveLaw (MP) 204
    • Himanshu Sarwan v State of MP 2025 LiveLaw (MP) 205
    • Mukesh Kumawat v The State of MP 2025 LiveLaw (MP) 206
    • X v State of MP 2025 LiveLaw (MP) 207
    • Adesh Parihar v State of MP 2025 LiveLaw (MP) 208
    • Savita Yadav v State of MP 2025 LiveLaw (MP) 209
    • Manoj Kumar Ahuja v Gurmej Singh 2025 LiveLaw (MP) 210
    • Sandeep Singh Parihar v State of MP 2025 LiveLaw (MP) 211
    • Ashish Jain v State of MP 2025 LiveLaw (MP) 212
    • Rohit Pathak v Bar Council of India 2025 LiveLaw (MP) 213
    • Babita Mor v Central Madhya Pradesh Gramin Bank 2025 LiveLaw (MP) 214
    • M/s APS Enterprises v State of MP 2025 LiveLaw (MP) 215
    • X v State of MP 2025 LiveLaw (MP) 216
    • Ramesh Singh v State of Madhya Pradesh 2025 LiveLaw (MP) 217
    • Mohammed Taiyab v State of MP 2025 LiveLaw (MP) 218
    • X v Y 2025 LiveLaw (MP) 219
    • Prosecutrix X v State P 2025 LiveLaw (MP) 220
    • Public Works Department v Panna 2025 LiveLaw (MP) 221
    • Shivram Chaudhary v Verendra Kumar Mishra 2025 LiveLaw (MP) 222
    • Smt Saroj v Rajendra Prasad Patel 2025 LiveLaw (MP) 223
    • V v SS 2025 LiveLaw (MP) 224
    • Rambhuvan Gautam v State 2025 LiveLaw (MP) 225
    • Karan Vinagya v State 2025 LiveLaw (MP) 226
    • Govind Through Legal Representative v Sayarbai and others 2025 LiveLaw (MP) 227 
    • MK v MA 2025 LiveLaw (MP) 228
    • Elora Tobacco Company v Union of India 2025 LiveLaw (MP) 229
    • Pragmatic Infrastructure Pvt Ltd v MP Housing and Infrastructure 2025 LiveLaw (MP) 230
    • Nagendra Singh Gaharwar v Dainik Bhaskar 2025 LiveLaw (MP) 231

    MP High Court Denies Bail To Lawyer Accused Of Raping, Trafficking Minor Girl Citing Specific Allegations Needing Detailed Probe

    The Madhya Pradesh High Court refused to grant bail to an advocate practising in the District Court accused of raping and dragging minor girl into trafficking, who had named the accused after she recollected it later during court proceedings, observing that there were specific allegations levelled against the accused.

    Case Title: YK v State of MP (MCRC-43436-2025)

    Citation: 2025 LiveLaw (MP) 204

    Injuring Vital Body Part Without Intention Not Attempt To Murder: MP High Court Upholds Acquittal Of Accused Who Hit Neighbour's Head

    The Madhya Pradesh High Court upheld a trial court order acquitting two men accused of 'attempt to murder' by hitting the heads of complainants with a wooden log, holding that merely inflicting injury on a vital body part without intention to kill does not attract IPC Section 307.

    Case Title: Himanshu Sarwan v State of MP (CRA-5705-2025)

    Citation: 2025 LiveLaw (MP) 205

    MP High Court Denies Anticipatory Bail To 'Journalists' Accused Of Assaulting, Using Casteist Remarks Against Teacher

    The Madhya Pradesh High Court upheld a trial court order denying anticipatory bail to two men stated to be journalists booked for assaulting and using casteist remarks against a scheduled caste school teacher.

    The court also said that the news article which was published in relation to the teacher described her as a 'Chindi Chor' meaning petty thief and thus the intention to insult the complainant could be inferred from the FIR.

    Case title: Mukesh Kumawat v The State Of Madhya Pradesh (CRIMINAL APPEAL No. 4015 of 2025)

    Citation: 2025 LiveLaw (MP) 206

    'Prolonged Pre-Trial Detention Anathema To Liberty': MP High Court Grants Bail To Rape Accused Where Victim Turned Hostile

    While granting bail to a man accused of rape, the Madhya Pradesh High Court remarked that prolonged pre-trial detention is an anathema to liberty after noting that the trial was not likely to conclude in the near future and that the prosecutrix had turned hostile.

    Case Title: X v State (MCRC-42422-2025)

    Citation: 2025 LiveLaw (MP) 207

    Investigating Officer Can't Keep Probe Pending But Court Can't Give Direction To File Chargesheet: MP High Court

    In a petition seeking directions to the police to file a charge sheet in an attempt to murder case, the Madhya Pradesh High Court underscored that while Investigating Officer cannot keep the investigation pending, however the court cannot direct filing of chargesheet as it amounts to supervising the probe.

    Case Title: Adesh Parihar v State of MP (MCRC-33184-2025)

    Citation: 2025 LiveLaw (MP) 208

    MP High Court Grants Anticipatory Bail To Woman Booked In Cheating FIR For Developing 'Unauthorized Colony'

    The Madhya Pradesh High Court granted anticipatory bail to a woman accused of developing an unauthorised colony and selling plots in Sagar District without the requisite permissions.

    The court directed the applicant to cooperate with the investigating agency and shall also appear on the date and time, as directed by the Investigating Officer. The woman has been booked for cheating (Section 420) IPC and illegal colonization (Section 292-c) of the Municipal Corporation Act.

    Case Title: Savita Yadav v State of MP (MCRC-42646-2025)

    Citation: 2025 LiveLaw (MP) 209

    MP High Court Upholds Order Rejecting Specific Performance Suit Noting That Plaintiff Was Never 'Ready & Willing' To Perform His Part

    The Madhya Pradesh High Court upheld a trial court order which dismissed the plaintiff's suit for specific performance with respect to sale of a property after finding that he was never ready and willing to perform his part of the contract with respect to purchasing the property.

    Case Title: Manoj Kumar Ahuja v Gurmej Singh (F.A. No. 130 of 2002)

    Citation: 2025 LiveLaw (MP) 210

    MP High Court Grants Bail To Man Accused Of Eating Sambar Deer, Says No Link Between Him & Meat Recovered From Spot

    Granting bail to a man accused of cooking and eating the meat of Sambar deer in the PWD guesthouse at Nagod, the Madhya Pradesh High Court observed that the forest officials failed to establish a link between the applicant with the recovered meat as the FSL report was still awaited.

    Case Title: Sandeep Singh Parihar v State of MP (MCRC-40989-2025)

    Citation: 2025 LiveLaw (MP) 211

    'Prima Facie' Observation By Magistrate While Directing Registration Of FIR Under Section 156(3) CrPC Not Cognizance: MP High Court

    The Madhya Pradesh High Court has said that a prima facie observation made by the Magistrate that a cognizable offence is made out while directing registration of an FIR on a private complaint under Section 156(3) would not amount to taking cognizance of the offence.

    Case Title: Ashish Jain v State of MP (MCRC-55135-2024)

    Citation: 2025 LiveLaw (MP) 212

    How Can You Demand Fee For Transferring Lawyer's Enrolment When Advocates Act Bars It? MP High Court To State Bar Council

    The Madhya Pradesh High Court on Tuesday (October 7) orally questioned the State Bar Council for demanding fee from an advocate for transferring his enrolment to the state when the Advocates Act bars such fee demand.

    Case Title: Rohit Pathak v Bar Council of India (WP-35160-2025)

    Citation: 2025 LiveLaw (MP) 213

    MP High Court Orders Release Of Gratuity To Widow Of Bank Employee Terminated For Misappropriating Money, Says No Forfeiture Sans Conviction

    The Madhya Pradesh High Court, on Monday (October 6), ordered the release of gratuity to the widow of a bank employee who was terminated for misappropriating ₹1 lakh from the branch cash chest, noting that since there was no criminal prosecution, the bank cannot forfeit gratuity.

    Case Title: Babita Mor v Central Madhya Pradesh Gramin Bank (WP 21393 of 2021)

    Citation: 2025 LiveLaw (MP) 214

    MP High Court Directs Factory Owner To Plant 25 Saplings For Failing To Cure Defects In Plea Despite Grant Of Sufficient Time

    The Madhya Pradesh High Court directed the proprietor of a factory to plant 25 saplings of native plants/trees within the factory premises as a condition for restoring its writ petition, which was earlier dismissed for non-compliance with a peremptory order.

    Case Title: M/s APS Enterprises v State of MP [MCC-2653-2025]

    Citation: 2025 LiveLaw (MP) 215

    'Revengeful & Vulgar': MP High Court Upholds Expulsion Of School Student For Posting Derogatory, Abusive Content About Teacher Online

    The Madhya Pradesh High Court, on Thursday (October 9) dismissed a father's plea challenging school's decision to expel his child following the discovery of an Instagram page where the boy created and posted memes of teachers using abusive and derogatory language.

    Case Title: X v State of MP [WP-22258-2025]

    Citation: 2025 LiveLaw (MP) 216

    Collector Can't Reopen Land Ownership After Decades Without Inquiry: Madhya Pradesh High Court

    The Madhya Pradesh High Court observed that in the absence of a specific limitation period under Section 50 of the MP Land Revenue Code, 1959, the mutation and ownership records cannot be reopened after decades under the guise of revisional power, that too without conducting any full-fledged enquiry.

    Case Title: Ramesh Singh v State of Madhya Pradesh [MP-5747-2022]

    Citation: 2025 LiveLaw (MP) 217

    'Right To Practice Religion Has No Nexus With Particular Place': MP High Court Rejects Plea To Rebuild Ujjain's Takiya Masjid

    Dismissing a plea seeking reconstruction of Ujjain's Takiya Masjid by litigants who used to offer namaaz there, the Madhya Pradesh High Court reiterated that right to practice religion has no nexus with a particular place and this right is not infringed by acquisition of a land having a mosque.

    The high court referred to Allahabad High Court's decision in Mohammad Ali Khan v Special Land Acquisition Office (1978) which had held that "profession, practice and propagation of religion guaranteed in Article 25 is a personal right which has to be exercised by the individual. It has no nexus with the place or territory where it has to be exercised".

    Case Title: Mohammed Taiyab v State of MP [WA-2782-2025]

    Citation: 2025 LiveLaw (MP) 218

    Wife's Anger Doesn't Entitle Her To Tarnish Husband's Reputation With False Allegations Of Infidelity: MP High Court Grants Divorce

    The Madhya Pradesh High Court has observed that making baseless and false allegations of moral turpitude against one's spouse amounts to cruelty and can be a ground for divorce.

    The court also said that wife's anger does not entitle her to tarnish her husband's image by making baseless allegations and thus granted divorce to the husband, setting aside trial court decree which had granted judicial separation but not divorce.

    Case Title: X v Y [FA-930-2024]

    Citation: 2025 LiveLaw (MP) 219

    MP High Court Denies Termination Of Rape Survivor's 9-Month Pregnancy; Directs CWC To Take Custody Of Child After 15 Days

    The Madhya Pradesh High Court has denied permission to terminate a 9-month pregnancy of a rape survivor, noting that the fetus is in a live condition and would endanger the life of the survivor. The court also directed the Child Welfare Committee to take custody of the child within 15 days of its birth and to take every care and caution for the upbringing of the child.

    Case Title: Prosecutrix X v State of MP [WP-40010-2025]

    Citation: 2025 LiveLaw (MP) 220

    MP High Court Quashes Labour Court Order Allowing PWD Employee To Continue Service Post Retirement

    The Madhya Pradesh High Court on Tuesday (October 7) set aside an order of the Labour court allowing a Public Works Department employee to continue service after his retirement.

    The court observed that the employee's claim of an alternate date of birth post-retirement could not be permitted as the employee had, with open eyes, signed various service documents which contained the disputed date of birth.

    Case Title: Public Works Department v Panna [MP-480-2019]

    Citation: 2025 LiveLaw (MP) 221

    MP HC Declines Accident Compensation To Wedding Party Travelling In Tractor, Says Use Of Vehicle Contrary To Insured Purpose Is Violation

    The Madhya Pradesh High Court has set aside an order by the Additional Motor Accidents Tribunal directing the insurance company to pay the claimants who were injured in an accident, observing that the driver and owner insured the vehicle (tractor) for agricultural purposes but used it to carry baratis.

    In doing so, the court emphasized that if the vehicle is used for any purpose other than the insured one, then the individual breaks their solemn promise under the insurance contract and thus, absolves the insurance company of its liability.

    Case Title: Shivram Chaudhary v Verendra Kumar Mishra [MA-448-2008]

    Citation: 2025 LiveLaw (MP) 222

    Motor Accident Tribunal Can Grant Compensation To Deceased's Cohabitant Who Lived Like Spouse: MP High Court

    The Madhya Pradesh High Court has held that the Motor Accident Claims Tribunal may award compensation to a cohabitant who lived with the deceased like a spouse, provided that the claimant can establish a long-term stable relationship, financial dependency and that the relationship had the character of marriage, even if not formalized.

    Case Title: Smt Saroj v Rajendra Prasad Patel [MA-3464-2012]

    Citation: 2025 LiveLaw (MP) 223

    Husband Obligated To Support Wife's Education, Empower Her: MP High Court Grants Maintenance To Wife Pursuing MD Homeopathy

    The Madhya Pradesh High Court on Wednesday (October 15), granted maintenance to a woman living separately from her husband and pursuing her MD in Homoeopathy, observing that a husband also has a duty to help complete the course that would enhance his wife's capabilities and empower her.

    In doing so, the bench also set aside the order of the family court that rejected the woman's application for maintenance.

    Case Title: V v SS [2025:MPHC-IND:30316]

    Citation: 2025 LiveLaw (MP) 224

    MP High Court Directs State To Strictly Implement Provisions Of Pre-Conception & Pre-Natal Diagnostic Techniques Act

    The Madhya Pradesh High Court, on Monday (October 14), directed the State to strictly comply with the provisions of the Pre-Conception and Pre-Natal Diagnostic Techniques (Prohibition of Sex Selection) Act, 1994 and Rules of 2014 regarding the qualification of doctors and staff doing sonography of pregnant women.

    Case Title: Rambhuvan Gautam v State [WP-36098-2025]

    Citation: 2025 LiveLaw (MP) 225

    MP High Court Grants Bail To Man Booked For Defrauding Ramakrishna Mission Ashram Official Of ₹2.5 Crore

    The Madhya Pradesh High Court on Tuesday (October 14) granted bail to a man allegedly involved in a cyber fraud case where an official of Ramakrishna Mission Ashram was cheated of Rs. 2 crore by persons who impersonated police officials and used forged documents.

    Case Title: Karan Vinagya v State of Madhya Pradesh [MCRC-45353-2025]

    Citation: 2025 LiveLaw (MP) 226

    Compromise Deed Affecting Rights Of Multiple Parties Must Reflect Voluntary & Informed Consent Of All To Be Legally Valid: MP High Court

    The Madhya Pradesh High Court has held that any compromise deed affecting the rights and interests of multiple parties must reflect the voluntary and informed consent of all parties to attain legal sanction.

    Case Title: Govind Through Legal Representative v Sayarbai and others [S.A. No.2217/2025]

    Citation: 2025 LiveLaw (MP) 227

    MP High Court Grants Divorce To Husband After Wife Makes False Allegations Of Alcohol Addiction

    The Madhya Pradesh High Court has granted a decree of divorce to a man on the grounds of cruelty, observing that the wife made false allegations of alcohol addiction against him.

    In doing so, the court set aside the judgment and decree of the Family Court of Mandla, which rejected the husband's divorce petition on grounds of desertion and cruelty.

    Case Title: MK v MA [2025:MPHC-JBP:52433]

    Citation: 2025 LiveLaw (MP) 228

    MP High Court Imposes ₹2 Lakh Cost On Tobacco Company For Stalling GST Proceedings

    The Madhya Pradesh High Court has imposed ₹2 lakh costs on an Indore-based tobacco company for attempting to stall the proceedings initiated against it by the GST authorities.

    The company came under the scanner of the Director General of GST Intelligence back in May 2020, following an investigation into large-scale tax evasion in the pan masala and tobacco industry in Indore.

    The probe allegedly uncovered a tax evasion racket exceeding ₹200 crore involving Elora Tobacco Company Limited, the Petitioner here.

    Case Title: Elora Tobacco Company v Union of India [WP-14694-2025]

    Citation: 2025 LiveLaw (MP) 229

    State Becomes Repository Of Public Faith When Inviting Tenders, Must Act With Utmost Fairness & Transparency: MP High Court

    In a tender dispute relating to the construction of a residential-cum-commercial project in Gwalior, the Madhya Pradesh High Court held that the State, while inviting tenders, acts as a repository of public faith and must therefore conduct the process with the highest standard of fairness and transparency.

    The court emphasized that cancelling a tender after its completion and restarting the process undermines its credibility and prejudices entrepreneurship development, thus, proliferating 'corruption, nepotism and crony-capitalism'.

    Case Title: Pragmatic Infrastructure Pvt Ltd v MP Housing and Infrastructure [WP no.11842 of 2025]

    Citation: 2025 LiveLaw (MP) 230

    Private Parts Blurred, No Obscenity: MP High Court Dismisses Plea Against Dainik Bhaskar For Allegedly Publishing Photo Of Naked Woman

    The Madhya Pradesh High Court has dismissed a petition filed against the Chief Editor of Dainik Bhaskar Newspaper for allegedly running an ad featuring photo of a nude woman.

    Justice Achal Kumar Paliwal noted that though body of the lady shown in the advertisement did not have any clothes but, the breast and genitals part were sufficiently blurred and some words were also written on those parts.

    Case Title: Nagendra Singh Gaharwar v Dainik Bhaskar [M.Cr.C. No. 4891 of 2014]

    Citation: 2025 LiveLaw (MP) 231

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