Supreme Court Weekly Round-up: May 26, 2025 To June 1, 2025

Reports/JudgmentsProsecution Can Be Allowed To Produce Documents Which Were Omitted To Be Submitted Along With Chargesheet : Supreme CourtCase Details: Sameer Sandhir v. Central Bureau of InvestigationCitation : 2025 LiveLaw (SC) 627The Supreme Court held that a bona fide omission by the prosecution to submit relied-upon documents to the magistrate does not prevent it from producing those documents after the charge sheet is filed, regardless of whether they were gathered before or after the investigation.The court said that procedural lapses in submitting evidence can be remedied post-chargesheet, provided there is no prejudice to the accused.if there is an omission on the part of the prosecution in forwarding the relied upon documents to the learned Magistrate, even after the chargesheet is submitted, the prosecution can be permitted to produce the additional documents which were gathered prior to or subsequent to the investigation.”, the court observed.If Arrest Is Made On Warrant, No Separate Grounds Of Arrest Need To Be Given : Supreme CourtCase Details: Kasireddy Upender Reddy v. State Of Andhra Pradesh And Ors.Citation : 2025 LiveLaw (SC) 628The Supreme Court held that when a person is arrested pursuant to a warrant, the obligation to separately communicate the grounds of arrest under Article 22(1) of the Constitution does not arise, as the warrant itself constitutes the grounds for the arrest to be supplied to the arrestee under Article 22(1).“If a person is arrested on a warrant, the grounds for reasons for the arrest is the warrant itself; if the warrant is read over to him, that is sufficient compliance with the requirement that he should be informed of the grounds for his arrest.”, the court observed.The Court clarified that when an arrest warrant is issued, it presupposes judicial scrutiny of the grounds for arrest as it contains the details about the offence charged, the reason for arrest (e.g., evasion of trial, threat to evidence/witnesses), and the identity of the accused. Therefore, a separate "grounds" document isn't required as the act of reading the warrant aloud fulfills the constitutional obligation to inform the arrestee of the reasons.Air Force School Not A 'State' Under Article 12; Teachers' Writ Petitions Against Dismissals Not Maintainable: Supreme CourtCase Details: Dileep Kumar Pandey v. Union of India & Ors.Citation : 2025 LiveLaw (SC) 629The Supreme Court dismissed appeals against Allahabad High Court judgments holding that the Air Force School in Bamrauli, Allahabad, is not a “State” or “authority” under Article 12 of the Constitution, and writ petitions against it by its employees are not maintainable under Article 226 of the Constitution.A bench of Justice Abhay S Oka, Justice Ahsanuddin Amanatullah(dissenting) and Justice Augustine George Masih passed the judgment in two civil appeals filed by teachers challenging adverse employment decisions. “A finding of fact was recorded that there is no material to show that the Government or the IAF has any control over the management of the school. It is not possible for us to take a contrary view. 24. In the circumstances, we are unable to find any fault with the view taken by the Division Bench of the High Court. The relationship between the appellants and the said school is in the realm of private contract. Assuming that there was a breach of private contract, the same does not involve any public law element”, the Court held.While Justice Oka authored the majority opinion dismissing the appeals, Justice Amanullah dissented, holding that the school was amenable to writ jurisdiction and the Indian Air Force (IAF) has deep and pervasive control on it.Order VII Rule 11 CPC | Plaint Cannot Be Rejected Just Because One Relief Is Barred If There's Another Cause Of Action : Supreme CourtCase Details: Vinod Infra Developers Ltd. v. Mahaveer Lunia & Ors.Citation : 2025 LiveLaw (SC) 630The Supreme Court held that a plaint cannot be dismissed in its entirety merely because one of the reliefs sought is legally untenable, provided that other reliefs are maintainable and arise from independent causes of action.The Court clarified that when deciding an application for rejection of a plaint under Order VII Rule 11 of the Civil Procedure Code (CPC), it is not permissible to selectively sever prayers where distinct causes of action are pleaded and backed by separate sets of facts. This is because a plaintiff may raise multiple grievances, and even if one claim is unsustainable, the presence of another triable claim means that rejecting the entire plaint would unjustly deny the plaintiff access to justice.Supreme Court Affirms Adani Power's Entitlement For Compensation Due To Change In Law; Dismisses JVVNL AppealCase Details: Jaipur Vidyut Vitran Nigam Ltd. & Ors. v. Adani Power Rajasthan Ltd. & Anr.Citation : 2025 LiveLaw (SC) 631The Supreme Court has affirmed that power generators are entitled to claim compensation and Late Payment Surcharge...

Supreme Court Weekly Round-up: May 26, 2025 To June 1, 2025

Amisha Shrivastava

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