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2024 Judgment

100 Supreme Court Judgment of 2024 (Part 3)

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 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 September to December 2024): 

Manilal v. State of Rajasthan 

  • The Supreme Court observed that candidates within the same academic cohort cannot be discriminated against based on their admission date when determining eligibility for job appointments 
  • This ruling raised the issue that the Rajasthan authorities’ 2017 Teacher Grade III Level II recruitment notification set different graduation marks criteria based on the timing of candidates B.Ed course admission. 

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Jasleela Shaji v. Union of India & Ors. 

  • The Supreme Court held that under Article 22(5) of the Constitution, a detained person must be afforded the earliest opportunity to make a representation against the detention order. 
  • The case involved procedural lapses where the detainee’s representation was not transmitted promptly, violating constitutional rights. 

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Somprabha Rana v. The State of Madhya Pradesh 

  • The Supreme Court held that while deciding the writ of habeas corpus in relation to the custody of the child the principle of welfare of child should be considered. 

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Union of India v. Bahareh Bakshi 

  • The Supreme Court ruled that the physical or virtual presence of an Indian spouse is mandatory for processing an Overseas Citizen of India (OCI) card application for foreign nationals, as per Section 7-A(d) of the Citizenship Act, 1955. 

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Nitya Nand v. State of Uttar Pradesh  

  • The Supreme Court held that for the purpose of conviction under Section 149 of the Indian Penal Code, 1860 (IPC) which is now Section 188 of Bharatiya Nyaya Sanhita, 2023 (BNS), no overt act is required, the presence of accused as a part of unlawful assembly is sufficient for conviction. 

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Dhanraj Aswani v. Amar S. Mulchandani & Anr 

  • The Supreme Court held that when a person is in custody for one offence nothing in CrPC precludes him from applying for anticipatory bail with respect to any other offence 

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Jitendra Paswan v. The State of Bihar 

  • The Supreme Court deleted the bail condition providing that the bail condition shall be executed after six months. 

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Mahesh Sitaram Raut v. State of Maharashtra 

  • The Supreme Court emphasized that a detainee's representation must be promptly considered and failure to transmit it expeditiously infringes upon the detainee's constitutional rights under Article 22(5). 
  • This case addressed procedural negligence in processing the detainee's communication to authorities. 

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Suchita Srivastava v. Chandigarh Administration 

  • The Supreme Court held that reproductive rights are part of a woman’s personal liberty under Article 21 of the Constitution, emphasizing her autonomy over decisions like pregnancy termination. 

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Ramesh and another v. State of Karnataka 

  • The Supreme Court observed that Appellate Courts must provide strong reasons when reversing a trial court’s acquittal, as established in the Rajendra Prasad v. State of Bihar (1977) case. 
  • This case emphasizes the need for a careful assessment of witness credibility before changing a trial court’s decision. 

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Just Right for Children Alliance v. S Harish 

  • The Supreme Court explained when ignorance of law can be taken as defence. 
  • The Supreme Court of India has recommended that the Parliament should amend the Protection of Children from Sexual Offences Act,2012 (POCSO) to replace the term “child pornography” with “child sexual exploitative and abuse material” (CSEAM). 
  • The Court stated that the term “child pornography” trivializes the gravity of the crime, as it suggests consent and voluntary acts, whereas CSEAM accurately reflects the exploitation and abuse of children 

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S Vijikumari v. Mowneshwarachari C 

  • The Supreme Court held that the order for modification/ alteration / or setting aside can only be passed when there is change in the circumstances subsequent to the order passed under Section 12 of the Protection of Women from Domestic Violence Act, 2005 (DV) and not otherwise.  

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Ishwar (Since Deceased) Thr. Lrs & Ors. v. Bhim Singh & Anr 

  • The Supreme Court recently ruled that an execution court can extend the time limit to pay the balance amount under Section 28 of the Specific Relief Act, 1963,(SRA) even though such applications are typically decided in the original suit. 
  • The Court upheld the execution court’s decision, noting that the decree lacked specific terms for payment and the decree-holder’s willingness to pay warranted the extension 

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V.S. Palanivel v. P. Sriram CS Liquidator etc 

  • The Supreme Court has held the Rule 12 under Schedule 1 of the Insolvency and Bankruptcy Board of India (Liquidation Process) Regulations, 2016 (IBBIR) is mandatory in nature and the liquidator cannot extent the time limit mentioned under the Rule under his discretion. 

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In Re: Section 6A Citizenship Act 1955 

  • The Supreme Court of India upheld the constitutional validity of Section 6A of the Citizenship Act, which recognizes the Assam Accord, by a 4:1 majority 
  • The majority opinion, led by Chief Justice DY Chandrachud, emphasized the need to balance humanitarian concerns with local population protections, while dissenting Justice Pardiwala argued that the provision had become unconstitutional over time due to its arbitrary nature and ineffective enforcement mechanisms. 

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Suhas Chakma v. Union of India & Others. 

  • A bench of Justice KV Viswanathan and Justice BR Gavai issued guidelines regarding free legal aid to prison inmates. 

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State Of U.P. V. M/S. Lalta Prasad Vaish 

  • A nine-judge Constitution Bench of the Supreme Court ruled 8:1 that States have the authority to regulate denatured spirit or industrial alcohol, classifying it under “intoxicating liquor” as per Entry 8 of the State List 
  • The majority opinion observed that the term should not be narrowly defined, including substances that could be misused for human consumption. 
  • In dissent, Justice Nagarathna argued that industrial alcohol is specifically not meant for human consumption, stated differing interpretations of the term “intoxicating liquor.” 

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Saroj & Ors. v. IFFCO-TOKIO General Insurance Co. & Ors 

  • The Supreme Court has ruled against using the date of birth from an Aadhaar Card to determine the age of a victim in a motor accident compensation case. 
  • Instead, the Court observed that the age should be verified using the date of birth from a school leave certificate, which has statutory recognition under the Juvenile Justice Act 

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Sukanya Shantha v Union of India & Ors. 

  • A bench of Chief Justice DY Chandrachud, Justice JB Pardiwala and Justice Manoj Misra gave slew of directions prohibiting caste-based discrimination in prisons.  

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In Re Manoj Tibrewal Akash  

  • The Supreme Court in the matter of In Re Manoj Tibrewal Akash has denounced the “Bulldozer Justice” trend and the same is against the rule of law. 
  • The Court strongly condemned “bulldozer justice”. 

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Aligarh Muslim University through its registrar Faizan Mustafa v. Naresh Agarwal 

  • The Supreme Court’s recent judgment in the Aligarh Muslim University (AMU) case declare AMU as an “Institution of National Importance” does not strip it of its minority character. 
  • The Court states that the Union’s argument that such a designation should necessitate a more inclusive approach to reservations, emphasizing the need to balance national priorities and protect minority rights. 
  • The decision emphasizes the constitutional recognition of AMU’s distinct identity while ensuring it remains aligned with broader social justice principles. 

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M/s Bajaj Alliance General Insurance Co. Ltd v. Rambha Devi & Ors. 

  • A bench of Chief Justice Dr. DY Chandrachud, Justice Hrishikesh Roy, Justice PS Narsimha, Justice Pankaj Mithal and Justice Manoj Misra laid down the principles when a judgment can be declared as per incuriam. 

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Anjum Kadari and Another v. Union of India and others 

  • A bench of Chief Justice Dr. DY Chandrachud, Justice JB Pardiwala and Justice Manoj Misra upheld the constitutional validity of the Uttar Pradesh Board of Madrassa Education Act, 2004. 

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Property Owners Association v. State of Maharashtra  

  • The Supreme Court, in a 7:2 majority ruling clarified that not all private properties qualify as "material resources of the community" under Article 39(b) of the Constitution.   
  • The Court overruled the 1983 Sanjeev Coke case, which had allowed the State to redistribute all private properties for the common good, also states that only properties meeting specific criteria as "material resources" and "of the community" can be subject to redistribution.   

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Balram Singh v. Union of India 

  • The Supreme Court clarified that the term ‘socialist’ in the Constitution’s Preamble reflects a commitment to being a welfare state and ensuring equality of opportunity, without mandating specific economic policies. 
  • The Court observed India’s mixed economy model, where public and private sectors coexist, benefiting marginalized communities. 

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Rinku Baheti v. Sandesh Sharda  

  • The Supreme Court of India recently expressed concerns about the misuse of domestic violence and dowry laws, cautioning against their abuse in matrimonial disputes for monetary gains. 
  • Addressing alimony, the Court stated that a divorced wife cannot demand permanent alimony to equalize wealth with her ex-husband.   
  • While the wife is entitled to maintenance reflecting her standard of life during marriage, the husband’s improved financial status post-divorce cannot justify higher alimony demands.   

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Ms X v. Union of India & Others 

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Giriyappa & Anr v. Kamalamma & Ors.  

  • A bench of Justice JB Pardiwala and Justice R Mahadevan laid down the conditions requisite for invoking Section 53A of Transfer of Property Act, 1882.    

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M.C. Mehta v. Union of India (Delhi Pollution) 

  • The Supreme Court of India has directed strict adherence to preventive health measures, including wearing masks, as air quality in Delhi-NCR deteriorates. 
  • The Court ordered the implementation of Stage-IV measures under the Graded Response Action Plan (GRAP) due to the AQI crossing 450. 

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Tarun Dhameja v. Sunil Dhameja & Anr 

  • The Supreme Court held that arbitration cannot be considered 'optional' if an agreement contains an arbitration clause. 
  • The bench, led by CJI Sanjiv Khanna and Justice Sanjay Kumar, observed that the arbitration clause cannot be narrowly interpreted, and courts can appoint an arbitrator under Section 11(6) of the Arbitration and Conciliation Act, 1996.  

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Celir LLP v. Ms Sumati Prasad Bafna and other   

  • The Supreme Court has held that a sale that is confirmed cannot be set aside merely based on irregularities except when the concerned matter is based on Fraud, Collusion, Inadequate Pricing, Under-bidding etc. 

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Smt. Naresh Kumari & Others v. Smt. Chameli & Others 

  • A bench of Justice Sudhanshu Dhulia and Justice PB Varale held that although Section 127 of TPA permits onerous transfer, a gift which is occasioned on perpetual rendering of services is violative of the Constitution.     

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Subrata Choudhury @ Santosh Choudhury & Ors. v. The State of Assam & Anr 

  • The Supreme Court has held that a second complaint is maintainable when the final report is found negative but only when the second complaint has some core difference.  

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