Complete Supreme Court Annual Digest 2025 [Part-V]

Articles 21 and 22 - Requirement to Communicate Grounds of Arrest under Article 22(1) in Warrant-Based and Warrantless Arrests - Held, Article 22(1) is a constitutional safeguard mandating that grounds of arrest be communicated to the arrestee. In warrantless arrests, non-compliance with Article 22(1) renders the arrest illegal, prohibiting further custody. Grounds must pre-exist, be documented, and conveyed meaningfully to the arrestee, preferably with notice to their family, to facilitate release arrangements. In arrests pursuant to a warrant, reading the warrant aloud to the arrestee satisfies Article 22(1), and no separate grounds are required. Police must prove compliance with Article 22(1) if non-communication is alleged, supported by diary entries or documents. Appeal dismissed, affirming compliance with Article 22(1) in warrant-based arrest. (Para 16, 36) Kasireddy Upender Reddy v. State of Andhra Pradesh, 2025 LiveLaw (SC) 628 : 2025 INSC 768Article 21 - Penal Code, 1860; Section 84 - Legal Insanity - Held, a person with mental insanity cannot be held criminally liable as they lack the capacity to exercise their right to self-defense under Article 21. The Court found prosecution witnesses' evidence raised reasonable doubt about the appellant's mental condition at the time of the offence in 2018. Under Section 84 IPC, the accused need only establish reasonable doubt of legal insanity, not conclusive proof. Medical examination conducted in 2023, five years post-incident, was deemed irrelevant. The Court criticized the prosecution's failure to conduct a timely medical examination despite evidence of the appellant's mental instability. Granting the benefit of doubt, the Court acquitted the appellant. Convictions under Sections 302, 352, and 201 IPC set aside due to reasonable doubt regarding the appellant's mental sanity at the time of the offence. (Paras 8, 10) Dashrath Patra v. State of Chhattisgarh, 2025 LiveLaw (SC) 618Article 21 - Human Rights Act, 1993; Section 2(1)(d) - Dignity - FIR Registration - Police Misconduct - Compensation - Every citizen approaching a police station to report a crime is entitled to be treated with dignity. The Supreme Court upheld the State Human Rights Commission's order directing the government to pay ₹2 lakh as compensation, recoverable from a police inspector who refused to register an FIR and used derogatory language against the complainant's mother. The inspector's actions, including failure to register the FIR and use of objectionable language, were held to violate human rights under Section 2(1)(d). The High Court's order affirming the SHRC's decision was upheld, and the petition was dismissed. (Para 6 - 8) Pavul Yesu Dhasan v. Registrar State Human Rights Commission, 2025 LiveLaw (SC) 562 : 2025 INSC 677Article 21 and 243G - Public Interest Litigation - Public Libraries in Villages - The Supreme Court refused to direct State Governments to establish public libraries in rural areas, emphasizing that pressing issues like clean water, sanitation, health, and education under Article 21 (Right to Life) take precedence over library initiatives. The Court highlighted the lack of comprehensive data on rural conditions and financial constraints, noting that resource allocation is a policy matter for governments. While acknowledging the value of libraries in promoting knowledge and democratic values, the Court encouraged States to explore innovative solutions, such as e-libraries and Corporate Social Responsibility (CSR) funds, to address the issue within their means. The petition was disposed of with a call for States to take effective steps to promote library facilities in rural areas. (Paras 3 - 6) Mundona Rural Development Foundation v. Union of India, 2025 LiveLaw (SC) 452Article 21 - Duty of Courts - Courts must zealously protect freedom of expression, a cornerstone of democracy and dignified life under Article 21. The effect of words must be judged by reasonable, strong-minded standards, not weak or insecure ones. Even if a large number of persons dislike the views expressed by another, the right of the person to express the views must be respected and protected. Literature including poetry, dramas, films, stage shows, satire and art, make the life of human beings more meaningful. (Para 38 & 39) Imran Pratapgadhi v. State of Gujarat, 2025 LiveLaw (SC) 362 : 2025 INSC 410Article 21, 51A(e) - Rights of Breast-Feeding Women – Establishment of feeding rooms, child care rooms, and other related facilities for nursing mothers and infants in public places - Court directed the Union of India to issue a reminder communication to all States and Union Territories to ensure compliance with the advisory. The States and Union Territories were urged to incorporate such facilities in existing and upcoming public buildings, ensuring privacy and dignity for nursing mothers. (Para 18 – 23) Maatr Sparsh an initiative by Avyaan Foundation v. Union of India, 2025 LiveLaw (SC) 275 :...

Complete Supreme Court Annual Digest 2025 [Part-V]

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