Supreme Court Weekly Round-Up: November 10, 2025 To November 16, 2025

JudgmentsS. 45/73 Evidence Act Can Be Invoked Only For Admitted Document To Compare Signature Or Handwriting : Supreme CourtCause Title: Hussain Bin Awaz v. Mittapally Venkataramulu & Ors.Citation: 2025 LiveLaw (SC) 1083The Supreme Court clarified that Section 45 read with Section 73 of the Indian Evidence Act can be invoked only in relation to an admitted document for the purpose of comparison of signatures or handwriting.A bench of Justice MM Sundresh and Justice Satish Chandra Sharma made the observation while setting aside a Telangana High Court order that had permitted a defendant to seek forensic examination of a document forming the basis of the plaintiff's case in a long-standing land dispute.The case arose out of a 50-year-old ownership conflict concerning a parcel of land. The respondent had filed a civil suit in 2015 seeking a declaration of ownership, relying on the outcome of an earlier suit from 1975. The appellant's family disputed the genuineness of a written statement filed in the 1975 suit proceeding, alleging that their grandfather's signature had been forged.Unilateral Termination Of Agreement To Sell Invalid If Contract Doesn't Allow It : Supreme CourtCause Title: K. S. Manjunath and Ors. v. Moorasavirappa @ Muttanna Chennappa Batil Since Deceased By His Lrs and Ors.Citation: 2025 LiveLaw (SC) 1084The Supreme Court (November 10) delivered a significant ruling interpreting the Specific Relief Act, 1963, holding that a party cannot unilaterally terminate a non-determinable agreement to sell, except where the contract itself is expressly determinable in nature under Section 14 of the Act. The Court further clarified that such invalid termination does not oblige the aggrieved party to first seek a separate declaration challenging the termination before pursuing a claim for specific performance.“Unilateral termination of the agreement to sell by one party is impermissible in law, except in cases where the agreement itself is determinable in nature...If such unilateral termination of a non-determinable agreement to sell is permitted as a defence, then virtually every suit for specific performance can be frustrated by the defendant by placing an unfair burden on the plaintiff... who, despite performing his part of the obligations and having showcased readiness and willingness, would require to also seek a separate declaration that the termination was bad in law.", the court said.A bench of Justices JB Pardiwala and R Mahadevan heard the case, which relates to an Agreement to Sell dated April 28, 2000, for 354 acres of agricultural land in Basavanakoppa village, Karnataka. The landowners had agreed to sell the property to a consortium led by the Patadia family and Muttanna for ₹26.95 lakh, receiving an advance of ₹9.45 lakh.Subsequent Purchaser Who Acted Merely On Vendor's Claims Without Verification Not Protected From Enforcement Of Prior Agreement To Sell: Supreme CourtCause Title: K. S. Manjunath and Ors. v. Moorasavirappa @ Muttanna Chennappa Batil Since Deceased By His Lrs and Ors.Citation: 2025 LiveLaw (SC) 1084In a significant ruling interpreting Section 19(b) of the Specific Relief Act, 1963, the Supreme Court has held that a subsequent purchaser who relies unquestioningly on the assertions of the vendor, without exercising due diligence or making reasonable inquiries, cannot claim protection as a bona fide purchaser for value without notice.The Bench of Justices JB Pardiwala and R Mahadevan, rejected the claim of subsequent purchasers who contended that they were entitled to protection under Section 19(b) against a prior agreement to sell. The Court found that the subsequent purchasers were aware of a previous agreement to sell, which was unilaterally cancelled by the vendor. Since the cancellation was unilateral, it was illegal and hence the original vendees had the right to seek specific performance , the Court held.Background Of The CaseCommercial Courts Act | Rejection Of Plaint Appealable; No Appeal Against Order Refusing To Reject Plaint : Supreme CourtCause Title: Mitc Rolling Mills Private Limited and Anr. v. M/S. Renuka Realtors and Ors.Citation: 2025 LiveLaw (SC) 1085Clarifying procedural law under the Commercial Courts Act, 2015 (“Act”), the Supreme Court (November 10) held that an order allowing an application for rejection of a plaint amounts to a decree and is therefore appealable under Section 13(1A) of the Act. However, an order rejecting such an application is not appealable under the same provision and can instead be challenged through a revision or a petition under Article 227 of the Constitution, as the case may be.A bench of Justices Vikram Nath and Sandeep Mehta set aside the Bombay High Court's ruling, which had held that the appellant–plaintiff's appeal under Section 13(1A) of the Commercial Courts Act, challenging the order allowing the respondent–defendant's application for rejection of the plaint, was not maintainable.The appellant had filed a commercial suit ...

Supreme Court Weekly Round-Up: November 10, 2025 To November 16, 2025

Amisha Shrivastava

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