Supreme Court Weekly Roundup: January 26, 2026 To February 01, 2026

JudgmentsExcessive Land Acquisition Compensation To Some Landowners Cannot Invalidate Others' Compensation : Supreme CourtCase Details: Niraj Jain v. Competent Authority-Cum-Additional Collector, Jagdalpur & Ors.Citation: 2026 LiveLaw (SC) 83The Supreme Court (January 27) observed that an excessive disbursement of compensation to some beneficiaries in collusion with officials would not invalidate the compensation awarded to other beneficiaries.A bench of Justices Sanjay Kumar and K Vinod Chandran heard the case arising out of the Chhattisgarh High Court's decision that had set aside the land acquisition compensation awarded in favour of the Appellant, merely because excessive compensation was disbursed to a handful of people.The case arose from the acquisition of land for the Rowghat–Jagdalpur railway line, notified in August 2017. Compensation awards were passed on February 12, 2018, in favour of around 550 landowners. Following an inquiry by the Collector, it was alleged that a handful of landowners had received compensation far in excess of market value in collusion with revenue officials. FIRs were lodged against those officials and specific beneficiaries.Confession Without Corroboration Cannot Be Basis For Conviction : Supreme CourtCase Details: Bernard Lyngdoh Phawa v. State of MeghalayaCitation: 2026 LiveLaw (SC) 84The Supreme Court (January 27) set aside the conviction in a murder case, upon finding that the conviction was based on the uncorroborated confessional statements made by the accused, in absence of a legal aid, before the magistrate.“…a confession can form a legal basis of a conviction if the Court is satisfied that it was true and was voluntarily made. However, it was also held that a Court shall not base a conviction on such a confession without corroboration.”, observed a bench of Justices Sanjay Kumar and K Vinod Chandran, while setting aside the Meghalaya High Court's judgment that reversed the Trial Court's acquittal, despite the fact that the accused were not represented by any counsel when their confessional statements were recorded.The case arose from the alleged murder of a man in Meghalaya, in which the Appellants were charged under Sections 302 and 201 of the IPC. While the Trial Court had acquitted them, the High Court reversed the acquittal and convicted the accused, placing considerable reliance on their retracted confessional statement recorded under Section 164 of the Cr.P.C.S.175(4) BNSS | Superior's Report Must If Offence Was During Public Servant's Duties : Supreme Court Advises MagistratesCase Details: Xxx v. State of Kerala & OrsCitation: 2026 LiveLaw (SC) 85The Supreme Court (January 27) prescribed the procedure for Magistrates to order an investigation against a public servant under Section 175 (4) of the Bharatiya Nagarik Suraksha Sanhita (BNSS) when the alleged offense arises "in the course of the discharge of his official duties."Unlike Section 156(3) of the Cr.P.C., which does not require a Magistrate to seek a report from the superior officer when the accused is a public servant before directing an investigation, Section 175(4) of the BNSS provides such a procedure.The Court noted that the provision uses the word 'may' and it has to be read as 'may' itself and not "shall".Complaint Under S.175(4) BNSS Against Public Servant Must Comply With Conditions Under S.175(3) : Supreme CourtCase Details: Xxx v. State of Kerala & OrsCitation: 2026 LiveLaw (SC) 85The Supreme Court held that a Magistrate cannot entertain a complaint against a public servant under Section 175(4) of the Bharatiya Nagarik Suraksha Sanhita (BNSS) unless the complainant first complies with Section 175(3), which requires the Magistrate to be satisfied that the complainant has already approached the Superintendent of Police with a written complaint supported by an affidavit.A bench of Justices Dipankar Datta and Manmohan considered the issue of whether Section 175(4) operates independently, allowing a Magistrate to act even on an oral complaint, or whether it is a procedural extension of Section 175(3), thereby importing the safeguards recognised in Priyanka Srivastava v. State of U.P.(2015), which mandate a written complaint accompanied by an affidavit.The Court held that Section 175 BNSS sub-clause (4) is not a standalone provision and must be read harmoniously with preceding sub-clause (3). This means no direct complaint can be filed against a public servant before the magistrate under Section 175(4) to seek an investigation, unless the threshold requirement for a sworn affidavit supporting the complaint (as established in Priyanka Srivastava v. State of U.P.) under Section 175(3) is fulfilled.Prior Written Demand Not Necessary For 'Industrial Dispute' To Exist; Apprehended Dispute Can Be Referred : Supreme CourtCase Details: M/S Premium Transmission Private Limited v. State of Maharashtra and OthersCitation: 2026 LiveLaw (SC) 86The Supreme Court (January 27) observed that a trade union is not...

Supreme Court Weekly Roundup: January 26, 2026 To February 01, 2026

Amisha Shrivastava

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