List of Current Affairs

Source: Allahabad High Court

Why in News?

A bench of Justice Rajesh Singh Chauhan observed that it is well-settled that to constitute an offense of rape, complete penetration of the penis with emission of semen and rupture of the hymen is not necessary.

• The Allahabad High court gave this observation in the case of Pradum Singh v. State of U P.

What is the Background of Pradum Singh v. State of U P Case?

• The application was filed by applicant in jail for case registered against him under Sections 376AB and 506 of Indian Penal Code, 1860 (IPC) coupled with Sections 5/6 of the Protection of Children from Sexual Offences Act, 2012 (POCSO).
• As per the prosecution, the applicant, who is the neighbor of the complainant, called the 10-year-old daughter (as per First Information Report) or 12-year-old daughter (as per educational documents) of the complainant in the evening at around 9:30 PM on the pretext that his mother was calling her.
• After some time, when the complainant and her husband went to search for their daughter, they found the applicant and the daughter without clothes.
• The daughter later disclosed that the applicant had committed oral sex with her and penetrated his penis.
• The applicant filed a bail application in the High Court, claiming that he was falsely implicated and that there was no independent eyewitness or last seen evidence.
• The prosecution opposed the bail application, citing the heinous nature of the offence. The medical report also supported the prosecution's case, indicating that the victim's hymen was torn.

What were the Court’s Observations?

• The Court discussed in detail the legal position that even partial penetration or attempt at penetration is sufficient to constitute rape.
• It relied on the victim's statements, medical evidence, and Supreme Court precedents to hold that prima facie, the offence of rape is made out against the applicant, and the solitary testimony of the victim can be sufficient for conviction if it is reliable and trustworthy.
• The Court noted that "the hymen is not usually ruptured, but may become red and congested along with the inflammation and bruising of the labia. If considerable violence is used, there is often laceration of the fourchette and the perineum".
• The High Court dismissed the bail application, observing that the victim's statement and the medical examination report supported the allegations against the applicant.
• The High Court directed the Trial Court to conclude the trial within 9 months from the date of receipt of the order, taking recourse to Section 309 Code of Criminal Procedure, 1973 (CrPC) by fixing short dates or day-to-day hearings, if necessary.
  • The High Court also granted liberty to the applicant to file another bail application if the trial is not concluded within the stipulated time.

What is Definition of Rape?

Under Section 375 of IPC and Section 63 of Bharatiya Nyaya Sanhita, 2023 (BNS): A man is said to commit rape if he-

a) penetrates his penis into the vagina, mouth, urethra or anus of a woman or makes her do so with him or any other person; or

b) inserts any object or a part of the body into the vagina, urethra or anus of a woman or makes her do so with him or any other person; or

c) manipulates any part of the body of a woman so as to cause penetration into the vagina, urethra, anus or any part of the body; or

d) applies his mouth to the vagina, anus, urethra of a woman.

What are Seven Description of Offence of Rape?

• First
  • This covers cases where the woman did not consent to the sexual act and it was done by force against her will.
• Secondly
  • This includes situations where there was no active consent given by the woman for the sexual act.
• Thirdly
  • This vitiates the woman's consent if it was obtained by instilling fear of death, hurt or injury to her or someone she has an interest in.
• Fourthly
  • This covers rape by impersonation, where the woman consented believing the man was her husband.
• Fifthly
  • This includes cases where the woman's consent was obtained when she was of unsound mind, mentally incapacitated or intoxicated and unable to understand the nature of her actions.
• Sixthly
  • This makes any sexual act with a woman under 18 years of age statutory rape, even if she consented.
• Seventhly
  • This covers situations where the woman was unable to consent or communicate her non-consent, such as being unconscious.

What are the Punishments for Offences Related to Rape?

• Punishment for Rape:
  • Section 376 (1) of IPC and Section 64 (1) of BNS.
  • Rigorous imprisonment of not less than 10 years but may extend to life imprisonment, and fine.
• Aggravated Rape:
  • Section 376 (2) of IPC and Section 64 (2) of BNS.
  • Rigorous imprisonment of not less than 10 years but may extend to life imprisonment which shall mean imprisonment for the remainder of that person's natural life, and shall also be liable to fine.
• Aggravated Rape with Women under Sixteen Years:
  • Section 376 (3) of IPC and Section 65 of BNS.
  • Rigorous imprisonment for a term which shall not be less than 20 years, but which may extend to imprisonment for life, which shall mean imprisonment for the remainder of that person's natural life, and shall also be liable to fine.
• Rape Causing Death/Persistent Vegetative State:
  • Section 376A of IPC and Section 66 of BNS.
  • Rigorous imprisonment of not less than 20 years, may extend to death/life imprisonment.
• Rape of a Girl under 12 years:
  • Section 376AB of IPC and Section 65 (2) of BNS.
  • Rigorous imprisonment of not less than 20 years, may extend to life imprisonment or death penalty.
• Rape by Husband during Separation:
  • Section 376B of IPC and Section 67 of BNS.
  • Imprisonment of 2-7 years and fine.
• Sexual Intercourse by a Person in Authority:
  • Section 376C of IPC and Section 68 of BNS.
  • Rigorous imprisonment of either description for a term which shall not be less than five years, but which may extend to ten years, and shall also be liable to fine.
• Gang Rape:
  • Section 376D of IPC and Section 70 of BNS.
  • Rigorous imprisonment of not less than 20 years, may extend to life imprisonment which shall mean imprisonment for the remainder of that person's natural life and fine to meet victim's medical expenses.
• Punishment for Gang Rape on Woman under Sixteen years of age:
  • Section 376DA of IPC.
  • Imprisonment for life, which shall mean imprisonment for the remainder of that person's natural life, and with fine.
  • Fine to meet medical expenses of victim.
• Punishment for Rang Rape on Woman under Twelve years of age:
  • Section 376DB of IPC.
  • Imprisonment for life, which shall mean imprisonment for the remainder of that person's natural life, and with fine, or with death.
  • Fine to meet medical expenses of victim.
• Repeat Offenders:
  • Section 376E of IPC and Section 71 of BNS.
  • Imprisonment for life or death penalty.

What are the Major Recommendations and Amendments in Rape Law?

• 84^th Law Commission Report (1980):
  • Recommended substituting 'consent' with 'free and voluntary consent' in the definition of rape under Section 375 IPC.
  • Suggested adding threat of injury to victim or others as vitiating consent under Section 375 IPC.
  • Recommended raising age of consent to 18 years under Section 375 IPC.
  • Proposed new sections 376C, D, E to cover custodial rape by persons in authority.
• Criminal Law (Amendment) Act, 1983:
  • Introduced concept of ‘aggravated rape’ with higher punishments under Section 376(2) IPC.
  • Covered custodial rape by staff under Sections 376B, 376C, 376D IPC.
  • Shifted burden of proof on accused in custodial/gang rapes under Section 114A IEA.
• From 172^nd Law Commission Report (2000):
  • Recommended making rape laws gender neutral.
  • Suggested expanding definition of rape under Section 375 IPC to include non-penile penetration.
  • Proposed retaining marital rape exception but raising wife's age to 16 under Exception to Section 375.
  • Recommended new Section 376E IPC for 'unlawful sexual contact'.
  • Suggested provisions for recording victim statements by female officers under Section 160 CrPC.
• Justice Verma Commitee (2012):
  • Include all non-consensual penetrative acts as rape, beyond just vaginal, oral, or anal penetration.
  • Remove the marital rape exception, treating it as any other rape.
  • The relationship between victim and accused should not impact the determination of consent.
  • Life imprisonment for rape, opposing the death penalty.
  • Discontinue the two-finger test for assessing rape victims.
  • Establish a cell to provide immediate legal assistance upon FIR filing.
  • Train police officers to handle sexual offences appropriately and sensitively.
• Criminal Law (Amendment) Act, 2013:
  • Expanded definition of rape under Section 375 IPC.
  • Raised age of consent to 18 years under Section 375 IPC.
  • Introduced Sections 376A (rape causing vegetative state/death), 376D (gang rape), 376E (repeat offenders).
  • Added provisions under Section 327 CrPC for in-camera trials.
  • Introduced Section 53A IEA rendering past sexual history irrelevant.
• Criminal Law (Amendment) Act, 2018:
  • Introduced death penalty for rape of girls below 12 years (Sections 376AB, 376DB, IPC).
  • Increased minimum punishments for various rape offenses (Sections 376, 376AB, 376DA, IPC).

What are Landmark Cases on Rape?

• Tukaram and Ganpat v. State of Maharashtra (1972):
  • This case is also known as Mathura rape case.
  • The judgment of the trial court favored the accused, stating that Mathura's consent was voluntary since she was accustomed to sexual intercourse.
  • However, the Bombay High Court set aside the judgment and sentenced the accused to imprisonment.
  • The Supreme Court (SC) later acquitted the accused, sparking public outrage. This case highlighted the need for reforms in rape laws.
• State of Punjab v. Gurmit Singh (1984):
  • The Supreme Court advised the lower judiciary not to describe a victim as having a loose character even if she is shown to be habituated to sex.
  • The judgment emphasized the need to focus on the act of rape and not on the victim's character.
• Delhi Domestic Working Women v. Union of India (1995):
  • The SC laid down important guidelines in this case:
    • Providing legal representation to complainants of sexual assault cases.
    • Ensuring legal assistance and guidance of a lawyer at the police station.
    • Maintaining the anonymity of the victim in rape trials.
    • Establishing a Criminal Injuries Compensation Board.
    • Providing interim compensation to rape victims.
    • Providing medical help and allowing abortion if the victim becomes pregnant due to the rape.
• Vishaka and Others v. State of Rajasthan (1997):
  • The Supreme Court laid down guidelines to prevent sexual harassment at workplaces, in the absence of a legislative framework.
• Vijay Jadhav v. State of Maharashtra and Anr (2013):
  • This case is also known as Shakti Mills rape case.
  • The Bombay High Court declared Section 376E of the IPC, as constitutionally valid.
• Mukesh & Anr. v. State for NCT of Delhi & Ors. (2017):
  • This case is known as Nirbhaya rape case.
  • The Supreme Court upheld the death penalty awarded to the accused and stated that the case fell under the “rarest of rare” category.
  • This incident brought the 2013 criminal law amendment.

Source: Supreme Court

Why in News?

Recently, the Supreme Court in the matter of XYZ. v. The State of Karnataka & Ors., has held that refusal on part of the accused in sexual offence case to undergo a medical examination would amount to non-cooperation with the investigation.

What was the Background of XYZ. v. The State of Karnataka & Ors. Case?

• In this case, the respondent no. 2 has been accused of sexual assault of a 9-year-old girl (victim).
• The respondent no. 2 refused to undergo medical examination for the purpose of Investigation.
• The Karnataka High Court passed an order which required respondent no. 2 to cooperate with the Investigating Officer for the purpose of investigation and, subject to the same, the respondent-Police were directed not to take any coercive action against him.
• Pursuant thereto, the Investigating Officer issued a notice under Section 41-A of the Criminal Procedure Code, 1973(CrPC), on 17^th May 2024, requiring respondent no. 2 to undergo a medical examination for the purpose of investigation in the case.
• He was directed to appear at the Police Station on 18^th May 2024.
• He filed an application before the High Court stating that the Investigating Officer was threatening him with arrest if he did not tender himself for medical examination at the same hospital where the victim was examined. Following that, the High Court stayed the notice which mandated the accused to undergo medical examination.
• Aggrieved by the final judgment and order passed by the Karnataka High Court, the petitioner (mother of the victim) filed a petition before the Supreme Court.
• The Counsel appearing for the petitioner before the submitted that the impugned order overlooked the medical report which indicated sexual intercourse and the victim's statement under Section 164 CrPC which implicated the accused.
• The Supreme Court directed the respondent no. 2 to appear before the Investigating Officer for being subjected to medical examination.

What were the Court’s Observations?

• The bench comprising Justices PV Sanjay Kumar and Augustine George Masih observed that in any event, his clear statement to the effect that he did not want to be subjected to medical examination shows that he is not willing to cooperate with the investigation.
• It was further stated that the respondent no.2 has to comply with Section41-A of CrPC notice and subject himself to medical examination as directed by the Investigating Officer. He cannot voice apprehensions about the medical facility that he is being referred to without any tenable basis.

What are the Relevant Legal Provisions in Relation to Medical Examination?

About:

• Medical examination of the accused and victims of sexual assault finds statutory recognition in the Indian legal system.
• The medical examination is done to know the true facts about the incident that happened. It provides a substantial piece of evidence to the police officers which helps them to expedite the process of investigation.

Medical Examination of the Accused:

Section 53 of CrPC:

• This Section deals with the examination of accused by medical practitioner at the request of police officer. It states that -

(1) When a person is arrested on a charge of committing an offence of such a nature and alleged to have been committed under such circumstances that there are reasonable grounds for believing that an examination of his person will afford evidence as to the commission of an offence, it shall be lawful for a registered medical practitioner, acting at the request of a police officer not below the rank of sub-inspector, and for any person acting in good faith in his aid and under his direction, to make such an examination of the person arrested as is reasonably necessary in order to ascertain the facts which may afford such evidence, and to use such force as is reasonably necessary for that purpose.

(2) Whenever the person of a female is to be examined under this section, the examination shall be made only by, or under the supervision of, a female registered medical practitioner.

Explanation. —In this section and in sections 53A and 54 —

(a) “Examination” shall include the examination of blood, blood stains, semen, swabs in case of sexual offences, sputum and sweat, hair samples and finger nail clippings by the use of modern and scientific techniques including DNA profiling and such other tests which the registered medical practitioner thinks necessary in a particular case.

(b) “Registered medical practitioner” means a medical practitioner who possesses any medical qualification as defined in clause (h) of section 2 of the Indian Medical Council Act, 1956 (102 of 1956) and whose name has been entered in a State Medical Register.

Section 53A of CrPC:

• This Section deals with the examination of person accused of rape by medical practitioner. It states that —

(1) When a person is arrested on a charge of committing an offence of rape or an attempt to commit rape and there are reasonable grounds for believing that an examination of his person will afford evidence as to the commission of such offence, it shall be lawful for a registered medical practitioner employed in a hospital run by the Government or by a local authority and in the absence of such a practitioner within the radius of sixteen kilometres from the place where the offence has been committed, by any other registered medical practitioner, acting at the request of a police officer not below the rank of a sub-inspector, and for any person acting in good faith in his aid and under his direction, to make such an examination of the arrested person and to use such force as is reasonably necessary for that purpose.

(2) The registered medical practitioner conducting such examination shall, without delay, examine such person and prepare a report of his examination giving the following particulars, namely: —

(i) The name and address of the accused and of the person by whom he was brought.

(ii) The age of the accused.

(iii) Marks of injury, if any, on the person of the accused.

(iv) The description of material taken from the person of the accused for DNA profiling.

(v) Other material particulars in reasonable detail.

(3) The report shall state precisely the reasons for each conclusion arrived at.

(4) The exact time of commencement and completion of the examination shall also be noted in the report.

(5) The registered medical practitioner shall, without delay, forward the report to the investigating officer, who shall forward it to the Magistrate referred to in section 173 as part of the documents referred to in clause (a) of sub-section (5) of that section.

Medical Examination of the Arrested Person:

Section 54 of CrPC:

• This Section deals with the examination of arrested person by medical officers. It states that—

(1) When any person is arrested, he shall be examined by a medical officer in the service of Central or State Government, and in case the medical officer is not available, by a registered medical practitioner soon after the arrest is made: Provided that where the arrested person is a female, the examination of the body shall be made only by or under the supervision of a female medical officer, and in case the female medical officer is not available, by a female registered medical practitioner.

(2) The medical officer or a registered medical practitioner so examining the arrested person shall prepare the record of such examination, mentioning therein any injuries or marks of violence upon the person arrested, and the approximate time when such injuries or marks may have been inflicted.

(3) Where an examination is made under sub-section (1), a copy of the report of such examination shall be furnished by the medical officer or registered medical practitioner, as the case may be, to the arrested person or the person nominated by such arrested person.

Medical Examination of the Victim of Rape:

Section 164A of CrPC:

• This Section deals with the medical examination of the victim of rape. It states that—

(1) Where, during the stage when an offence of committing rape or attempt to commit rape is under investigation, it is proposed to get the person of the woman with whom rape is alleged or attempted to have been committed or attempted, examined by a medical expert, such examination shall be conducted by a registered medical practitioner employed in a hospital run by the Government or a local authority and in the absence of such a practitioner, by any other registered medical practitioner, with the consent of such woman or of a person competent to give such consent on her behalf and such woman shall be sent to such registered medical practitioner within twenty-four hours from the time of receiving the information relating to the commission of such offence.

(2) The registered medical practitioner, to whom such woman is sent, shall, without delay, examine her person and prepare a report of his examination giving the following particulars, namely: —

(i) The name and address of the woman and of the person by whom she was brought.

(ii) The age of the woman.

(iii) The description of material taken from the person of the woman for DNA profiling.

(iv) Marks of injury, if any, on the person of the woman.

(v) General mental condition of the woman.

(vi) Other material particulars in reasonable detail.

(3) The report shall state precisely the reasons for each conclusion arrived at.

(4) The report shall specifically record that the consent of the woman or of the person competent to give such consent on her behalf to such examination had been obtained.

(5) The exact time of commencement and completion of the examination shall also be noted in the report.

(6) The registered medical practitioner shall, without delay forward the report to the investigating officer who shall forward it to the Magistrate referred to in section 173 as part of the documents referred to in clause (a) of sub-section (5) of that section.

(7) Nothing in this section shall be construed as rendering lawful any examination without the consent of the woman or of any person competent to give such consent on her behalf.

Treatment of Victims:

• Section 357C of CrPC deals with the treatment of victims.
• It states that all hospitals, public or private, whether run by the Central Government, the State Government, local bodies or any other person, shall immediately, provide the first-aid or medical treatment, free of cost, to the victims of any offence covered under section 326A, 376, 4 [376A, 376AB, 376B, 376C, 376D, 376DA, 376DB] or section 376E of the Indian Penal Code (45 of 1860), and shall immediately inform the police of such incident.

What is Section 41-A of CrPC?

• This Section deals with notice of appearance before police officer. It states that -

(1) The police officer shall, in all cases where the arrest of a person is not required under the provisions of sub-section (1) of section 41, issue a notice directing the person against whom a reasonable complaint has been made, or credible information has been received, or a reasonable suspicion exists that he has committed a cognizable offence, to appear before him or at such other place as may be specified in the notice.

(2) Where such a notice is issued to any person, it shall be the duty of that person to comply with the terms of the notice.

(3) Where such person complies and continues to comply with the notice, he shall not be arrested in respect of the offence referred to in the notice unless, for reasons to be recorded, the police officer is of the opinion that he ought to be arrested.

(4) Where such person, at any time, fails to comply with the terms of the notice or is unwilling to identify himself, the police officer may, subject to such orders as may have been passed by a competent Court in this behalf, arrest him for the offence mentioned in the notice.

Source: Supreme Court

Why in News?

Supreme Court in the matter of Government of NCT of Delhi & Anr. v. M/s BSK Realtors LLP & Anr., ruled in favor of the Delhi government, stating that the principle of res judicata may not strictly apply in cases where public interest is at stake.

• The court emphasized the need for a flexible approach in such matters, recognizing their broader implications beyond individual disputes.
• This observation by the bench of Justices Surya Kant, Dipankar Datta, and Ujjal Bhuyan highlights the importance of considering public interest in legal proceedings.

What was the Background of Government of NCT of Delhi & Anr. v. M/s BSK Realtors LLP & Anr.?

• Land acquisition proceedings were initiated by the Delhi government between 1957 and 2006 under the Land Acquisition Act, 1894.
• The Land acquisition act 2013 Act replaced the 1894 Act, introducing Section 24 which deemed land acquisition proceedings lapsed under certain conditions.
• The Delhi High Court, relying on decisions like Pune Municipal Corporation, declared some acquisition proceedings lapsed.
• Delhi government authorities, including Delhi Metro Rail Corporation (DMRC) and Delhi Development Authority (DDA), appealed these decisions to the Supreme Court.
• In 2020, the Indore Development Authority decision clarified the conditions for lapse under Section 24.
• The Delhi government sought reconsideration of High Court decisions based on the new interpretation.
• The Supreme Court granted leave for reconsideration, with a Civil Appeal by M/s BSK Realtors LLP as the lead matter.
• The Delhi High Court had declared the acquisition proceedings lapsed, based on Section 24(2) of the Land Acquisition Act, 2013.
• DDA's appeal against this decision was dismissed by the Supreme Court in 2016.
• GNCTD filed a Special Leave Petition (SLP) before the Supreme Court, seeking reconsideration due to the Indore Development Authority decision.
• M/s BSK Realtors LLP raised a preliminary objection regarding the maintainability of the SLP, citing the merger of previous orders and GNCTD's participation in earlier litigation.
• The appellant-authorities argued that the decision in Manoharlal applied retrospectively from 1^st January 2014, making the Supreme Court orders in the first round ineffective under the principle of res judicata in Civil Procedure Code 1908 (CPC), as the law had changed.
  • They contended that they were only formally involved in the first round and were not adequately heard.
• The landowners argued that res judicata applied, emphasizing that the acquiring authorities, the ring authorities Government of National Capital Territory of Delhi (GNCTD) and the beneficiary (DDA, etc.) shared a common interest in land acquisition for public purposes. They suggested that the dismissal of a civil appeal by one authority in the first round acted as res judicata against the other authority in subsequent litigation.
  • The landowners asserted that when one party litigates, it is considered to litigate on behalf of all interested parties.

What were the Court’s Observations?

• The court observed that the decision in the first round of litigation could not serve as res judicata to bar the second round, especially considering situations where larger public interest is at stake.
  • It noted that GNCTD and DDA did not have conflicting interests either before the High Court or before the Supreme Court.
  • There were no disputed issues between them in the first round.
• Considering public interest concerns, most appeals filed by the Delhi government were allowed, and directions were issued.
  • Separate orders were passed in other cases.
• The bench of Justices Surya Kant, Dipankar Datta and Ujjal Bhuyan said that in such cases, "a more flexible approach ought to be adopted by courts, recognizing that certain matters transcend individual disputes and have far-reaching public interest implications."

What is Res Judicata?

• Res Judicata – Res means ‘Thing’ and Judicata means ‘Already Decided’ so Res Judicata simply means ‘A thing which has been decided’.
• The principle is based upon maxims:
  • Interest Republicae Ut Sit Finis Litium - It is to the interest of the state that there should be a limit to litigation.
  • Nemo Debet Bis Vexari Pro Una Et Eadem Causa - No one shall be vexed twice for the same cause.
  • Res judicata pro veritate accipitur - A judicial decision must be accepted as correct.
• The Concept is enshrined under Section 11 of CPC.

What is Section 11 of CPC?

• Section 11 of CPC – Res Judicata - No Court shall try any suit or issue in which the matter directly and substantially in issue has been directly and substantially in issue in a former suit between the same parties, or between parties under whom they or any of them claim, litigating under the same title, in a Court competent to try such subsequent suit or the suit in which such issue has been subsequently raised, and has been heard and finally decided by such Court.
• Explanation I - The expression former suit shall denote a suit which has been decided prior to a suit in question whether or not it was instituted prior thereto.
• Explanation II - For the purposes of this section, the competence of a Court shall be determined irrespective of any provisions as to a right of appeal from the decision of such Court.
• Explanation III - The matter referred to above must in the former suit have been alleged by one party and either denied or admitted, expressly or impliedly, by the other.
• Explanation IV - Any matter which might and ought to have been made ground of defence or attack in such former suit shall be deemed to have been a matter directly and substantially in issue in such suit.
• Explanation V - Any relief claimed in the plaint, which is not expressly granted by the decree, shall for the purposes of this section, be deemed to have been refused.
• Explanation VI - Where persons litigate bona fide in respect of a public right or of a private right claimed in common for themselves and others, all persons interested in such right shall, for the purposes of this section, be deemed to claim under the persons so litigating.
• Explanation VII - The provisions of this section shall apply to a proceeding for the execution of a decree and references in this section to any suit, issue or former suit shall be construed as references, respectively, to a proceeding for the execution of the decree, question arising in such proceeding and a former proceeding for the execution of that decree.
• Explanation VIII - An issue heard and finally decided by a Court of limited jurisdiction, competent to decide such issue, shall operate as res judicata in a subsequent suit, notwithstanding that such Court of limited jurisdiction was not competent to try such subsequent suit or the suit in which such issue has been subsequently raised.

What are the Relevant Landmark Cases Involved in It?

• Pune Municipal Corporation & Anr. v. Harakchand Misirimal Solanki & Ors.,(2014)
  • In a landmark judgment delivered by the Supreme Court held that the acquisition would be deemed to have lapsed and would be covered under the 2013 law entitling the landowners to higher compensation, if compensation for land acquired under the 1894 Act has not been paid to the land owner or deposited with a competent court and retained in the treasury.
• Indore Development Authority v. Manoharlal, (2020)
  • The Court held that land owners cannot insist that the amount should be deposited in Court so as to sustain the land acquisition proceedings under the old Act on the commencement of the new land acquisition law with effect from January 1, 2014.