Supreme Court June 2025: Judicial Rulings and Latest Judgment| SCC Times

As June comes to a close, it’s time to reflect on the latest judgments, orders, and developments from the Supreme Court from June 2025. This roundup provides an overview of the top stories, important cases, and key updates that made headlines this month. It also highlights a “Know Thy Judge” feature. Do not miss out on the latest Supreme Court Judgments published in SCC Weekly.

Uttar Pradesh Gangsters & Anti-Social Activities (Prevention) Act, 1986

Supreme Court quashes case under UP Gangsters Act; Slams ‘rubber-stamping’ approval of gang-chart without application of mind

In two criminal appeals filed against the judgment passed by the Allahabad High Court, whereby the High Court rejected the application filed by the accused under Section 482 of the Code of Criminal Procedure, 1973 (‘CrPC’) for quashing of the proceedings of Special Sessions Trial arising out of First Information Report (‘FIR’) under Sections 2 and 3 respectively of the Uttar Pradesh Gangsters & Anti-Social Activities (Prevention) Act, 1986 (‘Act of 1986’), the division bench of JB Pardiwala* and Manoj Misra,JJ. viewed that continuation of criminal proceedings against the accused would result in undue harassment when there is no material against him and will result in the abuse of process of law. Accordingly, the impugned judgment and order of the High Court, as well as the order rejecting the application for recall of non-bailable warrants, were set aside. Consequently, the criminal proceedings were quashed.Read more

[Vinod Bihari Lal v. State of U.P., 2025 SCC OnLine SC 1216]

Did You Know? According to National Judicial Data Grid, there are 1146 cases pending before the three-judge bench, 208 cases before the five-judge bench, 35 cases before the seven-judge bench, and 70 cases before the nine-judge bench of the Supreme Court.¹

All Industry Rate Scheme

‘CBEC circular on 1% duty drawback not prospective’; SC clarifies retrospective entitlement under All Industry Rate Scheme

In a civil appeal against Madras High Court’s decision whereby the applicability of Customs Circular No. 35/2010-Cus. Dated 17-09-2010 for the purposes of All Industry Rate (AIR) Duty Drawbacks was held to be prospective in nature, the Division Bench of B.V. Nagarathna and Satish Chandra Sharma*, JJ. relating to the applicability of duty drawback provisions for exporters, held that the Circular issued by the Central Board of Excise and Customs (CBEC), must be retrospectively applied. The Court ruled in favour of Suraj Impex (India) Pvt. Ltd. (appellant) restoring their entitlement to 1% AIR customs duty drawback for Soyabean Meal (SBM) exports made prior to 20-09-2010. Read more

[Suraj Impex (India) (P) Ltd. v. Union of India, 2025 SCC OnLine SC 1226]

Section 11 of the SARFAESI Act

Explained | Supreme Court decision on scope & ambit of Section 11 of the SARFAESI Act

While considering a matter involving a dispute between two nationalised banks which touched upon the technicalities of Section 11 of the Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 (SARFAESI Act), the Division Bench of J.B. Pardiwala* and Pankaj Mithal, JJ., had to consider the following issues: Read more

[Bank of India v. Sri. Nangli Rice Mills (P) Ltd., 2025 SCC OnLine SC 1229]

Did You Know? According to National Judicial Data Grid, there were 6,023 cases disposed of by the Supreme Court last month.²

Can Investigating Agencies directly summon counsel in an ongoing case?

Investigating Agencies’ authority to summon Lawyers under scrutiny, as SC refers issue to CJI for detailed consideration

In a special leave petition raising a question of grave public importance, namely, whether and under what circumstances Investigating Agencies can directly summon a counsel representing a party in an ongoing case, the Division Bench of K.V. Viswanathan and N.K. Singh, JJ. observed that the issue, along with other related questions that may arise, required comprehensive consideration, as it directly impacts the efficacy of the administration of justice and the ability of lawyers to discharge their professional duties conscientiously and without fear. Read more

[Ashwinkumar Govindbhai Prajapati v. State of Gujarat, Petition(s) for Special Leave to Appeal (Crl.) No(s).9334/2025]

Permanent alimony

Divorced, not re-married & living independently: Supreme Court enhances permanent alimony from Rs 20,000 to 50,000

While considering an appeal wherein a woman challenged the quantum of permanent alimony of Rs. 20,000 fixed by Calcutta High Court; the Division Bench of Vikram Nath* and Sandeep Mehta, JJ., modified the impugned judgment and determined that a permanent alimony of Rs. 50,000 per month would be just, fair and reasonable to ensure financial stability for the woman. The Court opined that the woman, who remained unmarried and is living independently, was entitled to a level of maintenance that is reflective of the standard of living she enjoyed during the marriage, and which reasonably secures her future. Furthermore, the inflationary cost of living and her continued reliance on maintenance as the sole means of financial support necessitated a reassessment. Read more

[Rakhi Sadhukhan v. Raja Sadhukhan, 2025 SCC OnLine SC 1259]

Sections 498-A IPC

‘Allegations are generic and rather ambiguous’; SC quashes S. 498A IPC case against husband and in-laws for lack of prima facie evidence

In a set of two criminal appeals against Delhi High Court’s decision, whereby the Trial Court’s decision to discharge the accused-husband of the offences under Sections 498-A of the Penal Code, 1860 (‘IPC’) was set aside, the Division Bench of B.V. Nagarathna and Satish Chandra Sharma, JJ. held that the allegations made by the wife were generic and unsubstantiated, and no prima facie case of cruelty was made out. It further clarified that the complaint filed in 2002 was within the limitation period as per Section 468 of the CrPC and quashed the proceedings in exercise of powers under Article 142 of the Constitution. Read more

[Ghanshyam Soni v. State (NCT of Delhi), 2025 SCC OnLine SC 1301]

Guidelines for retention and destruction of records

Supreme Court issues comprehensive Guidelines for retention and destruction of records

The Supreme Court of India issued elaborate Guidelines for Retention and Destruction of Records, 2025 (the Guidelines) with the objective to promote coherence, accountability, and efficiency in managing administrative records, including institutional decisions, policy implementations, inter-departmental correspondences, audits, and engagements with external stakeholders. Introducing the Guidelines, CJI B.R Gavai stated that over the years, the Registry of the Supreme Court has witnessed a significant increase in the volume and diversity of administrative records generated across its multiple branches. The CJI elucidated that the Guidelines aim to establish a rational framework for retention, classification, and destruction across all Registry wings, promoting consistency and clarity while eliminating ambiguities. The Guidelines were prepared after a detailed discussion among Registrars and officials of the Registry. Read here

Howrah Court assault case

Supreme Court stays Calcutta High Court’s suo motu contempt proceedings against police officials in 2019 Howrah Court assault case

In a Special Leave Petition filed against the order of the Calcutta High Court, which had initiated suo motu criminal contempt proceedings against police officials allegedly involved in the 2019 Howrah District Court assault on lawyers, the division bench of Ujjal Bhuyan and Manmohan, JJ. stayed the High Court’s order. Read more

[Vishal Garg v. Registrar General, 2025 SCC OnLine SC 1363]

Rs. 21 Crore MSP fraud case

Discharge order based on defence material held impermissible by SC in Rs. 21 Crore MSP fraud case involving Cotton Corporation of India officer

In a batch of civil appeals by the Central Bureau of Investigation against Andhra Pradesh High Court’s decision, the Division Bench of Pankaj Mithal and SVN Bhatti delineated the contours of a magistrate’s discretion under Section 239 of the CrPC, and set aside concurrent findings of discharge by the Special Court and High Court, reiterated that reliance on material produced by the accused at the stage of discharge is impermissible in law. The Court emphasised that the threshold under Section 239 must be assessed solely on the basis of the police report and accompanying documents filed under Section 173 CrPC. Read more

[State v. Eluri Srinivasa Chakravarthi, 2025 SCC OnLine SC 1215]

Andhra Pradesh liquor scam case

Supreme Court finds no illegality in arrest of prime accused in Andhra Pradesh liquor scam case; Upholds High Court Judgment

In an appeal filed against the judgment passed by the Andhra Pradesh High Court, which had dismissed a writ petition seeking a writ of habeas corpus on the ground that the petitioner’s son had been illegally arrested by the CID and was in unlawful detention, the division bench of J.B. Pardiwala* and R. Mahadevan,JJ. having examined the grounds of arrest, the Court concluded that the requirements set out in Vihaan Kumar v. State of Haryana, 2025 SCC OnLine SC 269, had been duly met. Accordingly, finding no merit in the appeal, the Court dismissed it. Read more

[Kasireddy Upender Reddy v. State of A.P., 2025 SCC OnLine SC 1228]

Did You Know? According to National Judicial Data Grid, there were 84,644 total cases pending before the Supreme Court.³

Conviction of lawyer

Supreme Court upholds conviction of lawyer for outraging modesty of female judge during court proceedings

In a Special Leave Petition challenging the judgment of the Delhi High Court, which upheld the conviction of a lawyer for using abusive and inappropriate language towards a female judge during proceedings in a challan matter, the Division Bench of Prashant Kumar Mishra and Manmohan, JJ. declined to grant any relief to the petitioner and refused to interfere with the impugned orders. However, at the request of counsel for the petitioner, the Court granted the petitioner two weeks’ time to surrender. Read more

[Sanjay Rathore v. State (Govt. of NCT Delhi), 2025 SCC OnLine SC 1351]

Right to close business

Right to close business protected under Art. 19(1)(g), but subject to reasonable restrictions; SC strikes down state action against closure as unconstitutional

The Division Bench of Sanjay Karol and Prashant Kumar Mishra, JJ. held that the fundamental right guaranteed under Article 19(1)(g) of the Constitution, the right to practise any profession or to carry on any occupation, trade or business, includes the right not to carry it on as well, thereby extending constitutional protection to decisions of voluntary closure by businesses. Read more

[Harinagar Sugar Mills Ltd. v. State of Maharashtra, 2025 SCC OnLine SC 1303]

Narco-analysis test

‘Under no circumstances, is an involuntary or forced narco-analysis test permissible under law’; SC sets aside Patna High Court’s order permitting involuntary test

Supreme Court: In a criminal appeal against Patna High Court’s decision, which had allowed narco-analysis testing of accused persons during an ongoing criminal investigation, the Division Bench of Sanjay Karol and Prasanna B. Varale, JJ. held that compelling an accused to undergo such a test without free consent violates their fundamental rights under Articles 20(3) and 21 of the Constitution. Reaffirming its decision in Selvi v. State of Karnataka, (2010) 7 SCC 263, the Court reiterated that involuntary administration of narco-analysis tests is unconstitutional and any information obtained therefrom cannot be used as evidence. Read more

[Amlesh Kumar v. State of Bihar, 2025 SCC OnLine SC 1326]

Acquittal in murder case

Two acquitted in 43-year-old murder case as SC slams suppression of evidence and unfair probe

In a criminal appeal against Allahabad High Court’s decision in a 43-year-old murder case, whereby the conviction of the two accused persons for the offences punishable under Section 302 and Section 307 read with Section 34 of the Penal Code, 1860 (‘the IPC’), the Division Bench of Abhay S. Oka and Augustine George Masih, JJ. allowed the appeal and acquitted the accused persons. Read more

[Sakhawat v. State of U.P., 2025 SCC OnLine SC 1205]

Circumstantial Evidence

Circumstantial Evidence | Inability to explain certain situations can’t be made a basis to relieve prosecution from discharging its primary burden: SC

While considering a matter wherein the appellant (convict) who was convicted for murdering his friend had challenged his conviction, the Division Bench of B.V. Nagarathna and Satish Chandra Sharma*, JJ., took note of the inconsistent version of events presented by the prosecution and opined that accused person’s inability to explain certain circumstances, could not be made the basis to relieve the prosecution from discharging its primary burden of proving the case against the accused beyond reasonable doubt. Read more

[Vaibhav v. State of Maharashtra, 2025 SCC OnLine SC 1304]

Bail

Misappropriation of bail surety amount | SC grants anticipatory bail to former Nagaland Principal District Judge

While considering the instant petition challenging Gauhati High Court’s decision to deny anticipatory bail to a former District Judge in Nagaland pertaining to alleged misappropriation of bail surety amounts, the Division Bench of Ujjal Bhuyan and Manmohan, JJ., granted pre-arrest ailbail the accused former District Judge stating that since Gauhati High Court had deemed it appropriate to call for the case diary for further examination, the petitioner should have been granted the benefit of pre-arrest bail till the matter is decided by the High Court. Read more

[Inalo Zhimomi v. State of Nagaland, 2025 SCC OnLine SC 1364]

Supreme Court Steps In: Grants bail to man arrested under Uttarakhand Anti-Conversion Law in interfaith marriage case

In an appeal filed against the judgment passed by the Uttaranchal High Court, which had rejected the bail application of a Muslim man arrested by under the Uttarakhand anti-conversion law following his marriage to a Hindu woman, the division bench of BV Nagarathna and Satish Chandra Sharma, JJ. granted bail to the accused. Read more

[Aman Siddiqui v. State of Uttarakhand, 2025 SCC OnLine SC 1346]

Environment Law

Supreme Court appoints Committee to address concerns regarding Critical Tiger Habitat in Ranthambhore Tiger Reserve

While considering the instant application seeking directions to the State of Rajasthan and the Central Government to take immediate and effective steps to regulate and restrict public access and vehicular traffic to Trinetra Ganesh Temple and other religious sites located within the Critical Tiger Habitat (CTH)/core zone of the Ranthambhore Tiger Reserve; the 3- Judge Bench of B.R Gavai, CJ., A.G. Masih and A.S Chandurkar, JJ., appointed a Committee to address the concerns with regard to the issue in Ranthambore Tiger Reserve and recommend solutions in a phased manner. It was directed that the following, will be the Member of the said Committee: (i) The Collector, Sawai Madhopur (ii) The Field Director, Ranthambore Tiger Reserve; and (iii) A member of the Central Empowered Committee (CEC). Read more

[In re: TN. Godavarman v. Union of India, Writ Petition(s)(Civil) No(s). 202/1995]

Contract Law

Explained | Why SC upheld validity of restrictive covenant with indemnity clause of Rs 2 Lakhs in case of premature resignation from Vijaya Bank’s service

While considering the instant appeal revolving around the validity of a restrictive covenant in the appointment letter issued by Vijaya Bank, whereby an indemnity bond of Rs 2 Lakh was required to be furnished in case respondent resigns prematurely; the Division Bench of P.S. Narasimha and Joymalya Bagchi*, JJ., upheld the validity of the restrictive clause stating that it does not amount to restraint of trade nor is it opposed to public policy. The Court opined that Vijaya Bank is a public sector undertaking and cannot resort to private or ad-hoc appointments through private contracts. An untimely resignation would require the Bank to undertake a prolix and expensive recruitment process involving open advertisement, fair competitive procedure lest the appointment falls foul of the constitutional mandate under Articles 14 and 16 of the Constitution. Read more

[Vijaya Bank v. Prashant B Narnaware, 2025 SCC OnLine SC 1107]

Intellectual Property Law

Whether stay on Delhi HC’s 15th April order in PPL v. Azure Hospitality copyright case is binding on both parties? SC clarifies

While considering the instant petition seeking clarification of the Court’s previous order dated 21-4-2025, wherein it had put a stay on Delhi High Court’s order dated 15-4-2025, in Azure Hospitality (P) Ltd. v. Phonographic Performance Ltd., 2025 SCC OnLine Del 2407 (impugned judgment); the Division Bench of Ujjal Bhuyan and Manmohan, JJ., clarified that stay granted via Order dated 21-4-2025, on directions issued in Para 27 of the impugned judgment, would be binding inter-se between Phonographic Performance Ltd (PPL) and Azure Hospitality. Read more

[Phonographic Performance Ltd. v. Azure Hospitality (P) Ltd, Special Leave to Appeal (C) No(s). 10977/2025]

Rape under false promise of marriage

‘Complainant’s manipulative nature clearly established’; SC quashes FIR against person accused of sexual intercourse under false promise of marriage

While considering the instant appeal challenging Telangana High Court’s refusal to quash the FIR filed against the accused in a false promise for marraige case for offences punishable under Section 376(2)(n) of the Penal Code, 1860 and Section 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989; the Division Bench of Vikram Nath and Sandeep Mehta*, JJ., set aside the impugned judgment and quashed the FIR against the accused. Perusing the facts of the case, the Court opined that allowing prosecution of the accused to continue in the impugned FIR would be nothing short of a travesty of justice in addition to being a gross abuse of the process of Court. The Court held that the impugned FIR was nothing but a bundle of lies full of fabricated and malicious unsubstantiated allegations levelled by the complainant. “The facts on record clearly establish the vindictive and manipulative tendencies of the complainant and these aspects have a great bearing on the controversy”. Read more

[Batlanki Keshav (Kesava) Kumar Anurag v. State of Telangana, 2025 SCC OnLine SC 1258]

‘A consensual relationship turning sour not ground for criminal prosecution’: Supreme Court quashes rape case against 25-year-old

In an appeal filed against the judgment of the Bombay High Court , wherein the petition under Section 482 of the Code of Criminal Procedure, 1973 (‘CrPC’) seeking quashing of criminal proceedings was dismissed, involving allegations under Sections 376, 376(2)(n), 377, 504, and 506 of the Penal Code (‘IPC’), 1860, the Division Bench of B.V. Nagarathna and Satish Chandra Sharma*, JJ. observed that the present case did not involve a false promise to marry from the outset. The Court held that a consensual relationship, which subsequently deteriorates or results in estrangement between the parties, cannot form the basis for invoking the criminal machinery of the State. It further emphasised that such actions unnecessarily burden the courts and irreversibly damage the reputation of individuals accused of serious offences. Read more

[Amol Bhagwan Nehul v. State of Maharashtra, 2025 SCC OnLine SC 1230]