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2024 Judgment
100 Supreme Court Judgments of 2024 (Part 2)
« »27-Dec-2024
The Supreme Court of India has delivered several landmark verdicts in 2024, addressing a range of crucial issues that have significant social, legal, and constitutional implications. These Judgment span various domains, including family law, constitutional rights, criminal justice, contract law, etc. Some of the notable cases include (ranging from May to August 2024):
Karnail Singh v. State of Haryana & Ors.
- The Supreme Court observed that ignoring the law laid down by the Constitution Bench of this Court and taking a view totally contrary to the same itself would amount to a material error, manifest on the face of the order.
Ajay Ishwar Ghute & Ors v. Meher k. Patel & Ors. Case
- The Supreme Court set aside the order passed by the Bombay High Court and said that the High Court has failed to make an elementary enquiry and the order only on the base of Minutes of Order is entirely illegal.
Supreme Court Bar Association v. B.D. Kaushik Case
- The Supreme Court directed reforms in the Supreme Court Bar Association, mandating reservation for women in its Executive Committee. It reserved specific seats for women, including one office-bearer post, to ensure adequate representation.
Kolkata Municipal Corporation & Anr. v. Bimal Kumar Shah & Ors. Case
- The Supreme Court ruled that the Kolkata Municipal Corporation's acquisition of private property without due process was illegal. The Court upheld the right to property under Article 300A of the Constitution, identifying key sub-rights, including the right to notice, fair compensation, and public purpose.
Shivraj Reddy (Died) v. Raghuraj Reddy & Ors. Case
- The Supreme Court reiterated the importance of adhering to the limitation period under Section 3 of the Limitation Act, 1963. The Court dismissed a time-barred suit filed long after the dissolution of a partnership firm due to the death of a partner.
Shento Varghese v. Julfikar Husen & Ors.
- The Supreme Court held that when it is not the mandate of the law that the act should be done within a fixed time, it would mean that the act must be done within a reasonable time It was held in the context of Section 102 (3) of Code of Criminal Procedure, 1973 (CrPC).
Anees v. The State Govt of NCT
- The Supreme Court has expounded the principles relating to the application of Section 106 of the Indian Evidence Act, 1872 (IEA) which are as follows:
- The Court should apply Section 106 of the IEA in criminal cases with care and caution. It cannot be said that it has no application to criminal cases.
- This Section cannot be invoked to make up for the inability of the prosecution to produce evidence of circumstances pointing to the guilt of the accused.
- This Section cannot be used to support a conviction unless the prosecution has discharged the onus by proving all the elements necessary to establish the offence.
- It does not absolve the prosecution from the duty of proving that a crime was committed even though it is a matter specifically within the knowledge of the accused and it does not throw the burden on the accused to show that no crime was committed.
- This Section has no application to cases where the fact in question, having regard to its nature, is such as to be capable of being known not only to the accused but also to others, if they happened to be present when it took place.
- This Section would apply to cases where the prosecution could be said to have succeeded in proving facts from which a reasonable inference can be drawn regarding guilt of the accused.
Sharif Ahmed & Anr. v. State Of Uttar Pradesh & Ors
- The Supreme Court has held that non-bailable warrants should not be issued, unless the accused is charged with a heinous crime, and is likely to evade the process of law or tamper or destroy the evidence.
M/S Sas Infratech Pvt Ltd v The State of Telangana & Anr
- The Supreme Court has held that a magistrate cannot be said to have taken cognizance of any offence when he in the exercise of his judicial discretion directs investigation under Section 156(3) of Criminal Procedure Code, 1973 (CrPC).
Vijay Kumar v. The State of Himachal Pradesh
- The Supreme Court (SC) emphasized the importance of aligning accused statements with prosecution evidence and noted the failure to challenge the victim’s testimony regarding consent during cross-examination, highlighting the significance of thorough evaluation in sexual assault cases.
Dasari Srikanth v. State of Telangana
- The Supreme Court’s decision to quash the conviction of the man for stalking and criminal intimidation, based on his marriage to the complainant during the appeal process, raises questions about the intersection of personal relationships and legal proceedings. Additionally, the case highlights the importance of considering evolving circumstances, such as marriage, in judicial decisions.
Ravikumar Dhansukhlal Maheta & Anr. v. High Court of Gujarat & Ors
- The Supreme Court upheld the promotion process implemented by the High Court of Gujarat for District Judge vacancies, emphasizing the absence of an inherent right to demand promotion among government employees.
- It emphasized that promotion policies are primarily the prerogative of the legislature or executive, with judicial review limited to instances of violation of equality principles under Article 16 of the Constitution of India , 1950 (COI)
XYZ. v. The State of Karnataka & Ors.
- 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.
Madhusudan & Ors. v. The State of Madhya Pradesh
- A bench comprising of Justices Hrishikesh Roy and Satish Chandra Sharma held that in the event of alteration of charges, opportunity must be given under Section 217 of the Criminal Procedure Code, 1973 (CrPC), both to the prosecution and the defence, to recall or reexamine witnesses in reference to such altered charges.
Ankur Chaudhary v. State of Madhya Pradesh
- The Supreme Court granted bail under the Narcotic Drugs and Psychotropic Substances Act (NDPS) 1985 despite not meeting the stringent criteria of Section 37 has garnered attention.
- It emphasizes that prolonged incarceration due to undue trial delays contradicts the fundamental right under Article 21 of the Constitution, thus allowing conditional liberty to supersede statutory restrictions in such cases.
Government of NCT of Delhi & Anr. v. M/s BSK Realtors LLP & Anr.
- The Supreme Court 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.
Delhi Development Authority v. Tejpal & Ors
- A bench of Justices Surya Kant, Dipankar Datta and Ujjal Bhuyan held that “if subsequent change of law is allowed as a valid ground for condonation of delay, it would open a Pandora’s Box where all the cases that were subsequently overruled, would approach this Court and would seek a relief based on the new interpretation of law”.
Kasthuripandian v. RBL Bank Limited
- The Supreme Court ruled on the transfer petition related to Section 138 of the Negotiable Instruments Act, 1881(NI Act). Justices AS Oka and Rajesh Bindal dismissed the accused’s plea to transfer the complaint, affirming that such decisions typically rest with the complainant, not the accused.
- This decision clarifies the boundaries of court jurisdiction in such matters while allowing the accused to seek exemptions from personal appearance as necessary.
State of Uttar Pradesh and Anr. v. Virendra Bahadur Katheria and Ors
- The Supreme Court has resolved a 22-year-old dispute over pay scales for education department officials in Uttar Pradesh, potentially impacting thousands of employees.
- The Court invoked its extraordinary powers under Article 142 of the Constitution to settle the matter, balancing the interests of retired officials and the state government. This judgment clarifies the application of the doctrine of merger and res judicata in cases involving multiple rounds of litigation between the High Court and the Supreme Court.
Ashok Daga v. Directorate of Enforcement
- The Supreme Court has held that calling an accused for admitting or denying the genuineness of the document would not amount to violation of his right against self-incrimination.
Gaurav Kumar v. Union of India
- The Supreme Court has ruled that the high enrollment fees imposed by State Bar Councils are unconstitutional as they infringe on aspiring lawyers’ right to practice and undermine principles of equality.
- The Court mandated a cap on these fees, setting Rs.750 for general category advocates and Rs.125 for SC/ST advocates, emphasizing that such fees should not discriminate against marginalized groups.
State of West Bengal v. Union of India
- The Supreme Court has held that the Supreme Court shall have the original jurisdiction to deal with the present case and suit filed by the state is maintainable under Article 131 of the Constitution.
Frank Vitus v. Narcotics Control Bureau
- The Supreme Court addressed the legality of bail conditions that required accused individuals to share their location via Google Maps, arguing that such conditions infringed upon the right to privacy guaranteed by Article 21of the Indian Constitution.
- The case challenging these stringent conditions imposed by the Delhi High Court.
- The decision underscored the importance of balancing bail restrictions with constitutional rights, particularly concerning foreign nationals facing legal proceedings in India.
Dr. Bhim Rao Ambedkar Vichar Manch Bihar, Patna v. The State of Bihar
- The Supreme Court has invalidated the Bihar Government’s 2015 resolution merging the “Tanti-Tantwa” community from the Extremely Backward Castes list into the Scheduled Caste list, citing lack of authority under Article 341.
- The court criticized the state’s action as mala fide and directed those appointments made under the resolution be reverted to the Scheduled Castes quota.
- It emphasized that any changes to Scheduled Castes lists require parliamentary legislation and not executive orders.
Mineral Area Development v. M/S Steel Authority of India & Ors
- The Supreme Court ruled that States have the authority to levy taxes on mineral rights under Entry 50 of List II of the Constitution of India, 1950 (COI), despite the regulatory powers of the Union under Entry 54 of List I. The Court emphasized that taxing powers must be explicitly granted and cannot be inferred from general regulatory entries.
- It also confirmed that the Mines and Minerals (Development and Regulation) Act, 1957 (MMDR Act) does not restrict States’ taxation powers on mineral rights or lands, maintaining the constitutional distribution of legislative competencies.
- The Judgment is pronounced by 9 Judges Constitution Bench which consists of Hon’ble Dr Justice Dhananjaya Y Chandrachud, Chief Justice of India pronounced the judgment on behalf of himself, Hon’ble Mr Justice Hrishikesh Roy, Hon’ble Mr Justice Abhay S Oka, Hon’ble Mr Justice J B Pardiwala, Hon’ble Mr Justice Manoj Misra, Hon’ble Mr Justice Ujjal Bhuyan, Hon’ble Mr Justice Satish Chandra Sharma and Hon’ble Mr Justice Augustine George Masih.
Gene Campaign & Anr. v. Union of India & Ors
- The Supreme Court delivered a split verdict on petitions challenging the Union Government’s approval for genetically modified mustard.
- Justice BV Nagarathna invalidated the approval, citing public interest concerns and procedural flaws, while Justice Sanjay Karol upheld it, emphasizing scientific development.
- With differing opinions, the bench referred the matter to the Chief Justice to constitute a larger bench, delaying implementation pending further review, despite the government’s agreement not to proceed with the decision.
State of Punjab and Ors. v. Davinder Singh and Ors.
- Seven judges bench upheld the sub-classifications among the Scheduled Castes/Scheduled Tribes so that benefits of reservation can reach to the weaker of the weakest sections of the society.
- The Supreme Court allowed the States to sub-classify Scheduled Castes (SCs) to provide separate quotas for more backward groups within the SC category. But Justice Trivedi dissented, arguing that this sub-classification interferes with the Presidential list of SCs established under Article 341, which can only be modified by parliamentary law.
- She expressed concern that such sub-classification could introduce political factors into the SC-ST list, undermining its original intent to prevent political influence.
Harsh Bhuwalka & Ors v. Sanjay Kumar Bajoria.
- Justices Dipankar Datta and Prashant Kumar Mishra have issued a new practice direction regarding Special Leave Petitions (SLPs), effective from 20th August 2024.
- This direction requires that any SLP seeking exemption from filing a certified copy of an impugned order must include a receipt from the High Court confirming the request for the certified copy, state that the application for the copy is still valid and provide an undertaking to submit the certified copy promptly. This aims to streamline the process and ensure timely submission of necessary documents.
Ramnaresh @ Rinku Kushwah v. State of Madhya Pradesh & Others.
- A bench of Justice BR Gavai and Justice KV Viswanathan held that the appellants cannot be denied admission when they were meritorious and could have been admitted against the unreserved category.
Rekha Sharma v. The Rajasthan High Court, Jodhpur & Anr.
- A bench of Justice Bela M. Trivedi and Justice Satish Chandra Sharma held that the reservation provided to persons with disability was in the form of overall horizontal reservation and hence there was no need for a separate cutoff.
Nirmala & Ors. v. Canara Bank & Anr.
- The Supreme Court set aside Canara Bank’s showcause notices to employees who were appointed under the Scheduled Castes (SC) quota based on valid caste certificates. The notices had been issued after a 1977 government circular, which equated the ‘Kotegara’ community with an SC category, was later deemed invalid following the Supreme Court’s ruling in State of Maharashtra v. Milind (2000).
- The Court clarified that only the President can modify SC and ST lists under Articles 341 and 342 of Constitution of India, 1950, rendering the state government’s modification void.
Mineral Area Development Authority v. Steel Authority of India (MADA Judgment)
- The Supreme Court rejected the plea for prospective overruling of MADA judgment (July 2024).
- However, it laid down some conditions to balance the interests of states and assessees:
- States cannot levy taxes under the relevant entries for transactions before 1st April 2005.
- Payment of tax demands to be staggered over 12 years starting 1st April 2026.
- Interest and penalties on demands for the period before 25th July 2024 to be waived for all assessees.
Kishorchandra Chhanganlal Rathod v. Union of India and Ors.
- The Supreme Court has upheld its power to review Delimitation Commission orders if they are deemed clearly arbitrary or in violation of constitutional principles. Although judicial review in delimitation cases is typically restricted, the Court can intervene when an order severely conflicts with constitutional values.
Allarakha Habib Memon v. State of Gujarat.
- A bench of Justice BR Gavai and Justice Sandeep Mehta held that the circumstance regarding the identification of place of incident is inadmissible because the crime scene was already known to the police.