100 Supreme Court Judgment of 2024 (Part 1)

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100 Supreme Court Judgment of 2024 (Part 1)

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27-Dec-2024

Supreme Court

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 January to April 2024):

Jaipur Vidyut Vitran Nigam Ltd. & Ors. v. Mb Power (Madhya Pradesh) Limited & Ors.

The Supreme Court has held that under the provisions of Article 226 of the Constitution of India, 1950 (COI), the High Court must exercise its discretionary power with great caution.
The court should always keep the larger public interest in mind in order to decide whether its intervention is called for or not.
Only when it comes to a conclusion that overwhelming public interest requires interference, the court should intervene.

Container Corporation of India Ltd. v. Ajay Khera and Ors.

The Supreme Court directed the Union of India to formulate a policy to phase out heavy-duty diesel vehicles and replace them with BS-VI compliant vehicles within six months.
The court observed that the right to a pollution-free environment under Article 21 of the COI applies to all citizens across the country and not just those in Delhi NCR.
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Jay Shri v. The State of Rajasthan

The Supreme Court clarified that a mere breach of contract does not constitute a criminal offense under Sections 420 or 406 of IPC unless fraudulent or dishonest intent is evident at the outset.
The judgment provides the importance of distinguishing between civil and criminal matters to prevent the misuse of criminal proceedings.

Mariam Fasihuddin & Anr. v. State by Adugodi Police Station & Anr.

The Supreme Court held that under Section 482 of the Criminal Procedure Code, 1973 (CrPC), the High Court has inherent powers to quash criminal proceedings to prevent abuse of process or secure the ends of justice.
The judgment observed that courts should exercise this power with caution and only in cases where the allegations in the FIR or charge sheet do not prima facie disclose any offense.
The Court also observed that criminal proceedings should not be pursued as a tool for harassment or to settle personal scores.

Ajeet v. State of Uttar Pradesh

The Supreme Court held that an allegation that the physical relationship was maintained due to false promise given by the appellant to marry, is without basis as their relationship led to the solemnization of marriage.
The court observed there is no sufficient evidence to prove the case of physical relation of false promise to marry against the appellant.

Gurdev Singh Bhalla v. State of Punjab & Ors.

The Supreme Court has upheld an application under Section 319 of the Code of Criminal Procedure, 1973 (CrPC) filed against the police officials accused of corruption.
The court observed that there appears to be prima facie evidence on record to make it a triable case against the appellant.
The Court upheld an application under Section 319 of CrPC filed against the police officials accused of corruption. Thus, the Court is not inclined to interfere with the impugned order.
The Court further made it clear that any observations made in this order will not come in the way of the Trial Court in deciding the trial on its own merits on the basis of the evidence adduced before it, completely uninfluenced by this judgment.

Rajaram Sharma v. The State Of Uttar Pradesh & Anr.

The Supreme Court has held that as per the provisions of Section 482 of the Criminal Procedure Code, 1973 (CrPC), the High Court should examine carefully whether the allegations would constitute the offences alleged against the person accused.
The Court while setting aside an order of a HC which denied to quash the criminal proceedings pending against a person-accused, expressed dissatisfaction with the HC’s order by noting that the ingredients necessary to constitute the offence were not made out

Smruti Tukaram Badade v. The State of Maharashtra and Anr

The Supreme Court gave directions to the High Courts to set up the Vulnerable Witness Deposition Centre (VWDC) in each district by 30th April 2024 and submit an updated status report by the first week of May 2024.
Two High Courts, Odisha and Tamil Nadu, are yet to fully implement the VWDC guidelines.
The court has ordered Justice Mittal to ensure that both High Courts comply by the 30th April, 2024 deadline.

Asma Lateef & Anr. v. Shabbir Ahmad & Ors

Supreme Court observed that interim relief in a civil suit should only be granted after a prima facie determination of the suit's maintainability.
It ruled that courts should not grant relief based on assumptions about maintainability, as this could constitute an improper exercise of power.
The Court stressed that, in extraordinary situations where non-granting interim relief could cause irreparable harm, a provisional order may be passed to prevent undue hardship or ensure the suit is not rendered ineffective.
The case highlights the importance of addressing maintainability issues before deciding on interim relief in civil proceedings.
The SC also held that “mere failure or neglect of a defendant to file a written statement controverting the pleaded facts in the plaint, in all cases, may not entitle him to a judgment in his Favour unless by adducing evidence he proves his case/claim”

Raja Gounder & Ors. V. M. Sengodan & Ors

The Supreme Court held that the children born out of void and voidable marriage shall be considered as legitimate and would be treated as successors in the property of common ancestors.
Court observed that once the common ancestor has admittedly considered the children born of void and voidable marriage as his legitimate children, then such children would be entitled to the same share as the successors in the property of the common ancestor as that of children born out of a valid marriage.
The Court noted that the children born out of void marriages would be treated as successors in the interest of Muthusamy Gounder, and accordingly the shared needs to be worked out.

Rupashree H. R. v. The State of Karnataka & Ors

Supreme Court has held that the right to defend oneself is a fundamental right under the Constitution of India, 1950 (COI).
Court observed that the right to defend oneself is a Fundamental Right under Part III of the COI and further right to appear for a client is also a Fundamental Right being a part of carrying on one’s profession as a lawyer.

Lucknow Nagar Nigam & Ors. v. Kohli Brothers Colour Lab. Pvt. Ltd. & Ors

The Supreme Court has held that the right to property, as enshrined under Article 300A of the Constitution of India, 1950 (COI), extends to persons who are not citizens of India.
Court observed we cannot construe the taking possession of the enemy property for the purpose of administration of the same by the Custodian, as an instance of transfer of ownership from the true owner to the Custodian and thereby to the Union
The expression property is also of a wide scope and includes not only tangible or intangible property but also all rights, title and interest in a property.

Association for Democratic Reforms & Anr. v. Union of India & Ors.

Supreme Court declared Electoral Bond Scheme unconstitutional.
The Electoral Bond Scheme, certain sections of the Representation of the People Act 1951, the Companies Act, and amendments therein, violate Article 19(1)(a) and are unconstitutional.
The removal of the proviso to Section 182(1) of the Companies Act, allowing unlimited corporate contributions to political parties, is arbitrary and breaches Article 14.

M/s Brahmaputra Concrete Pipe Industries Etc. v. The Assam State Electricity Board.

Court held that Registry cannot be vested with power to decide whether a review petition, after being dismissed in open Court hearing, merited relook through the curative jurisdiction.
Refusal to entertain curative petitions does not align with Order XV Rule 5, of the Supreme Court Rules, 2013 nor does it fall under Registry’s purview.
The court cited Order LV Rule 2, emphasizing communication with the chamber judge for instructions.
The court overturned the impugned order but declined to remand, finding no grounds to invoke curative jurisdiction, thus disposing of the appeal accordingly.

Velthepu Srinivas v. State of Andhra Pradesh (Now State of Telangana) & Anr

Supreme Court has held that common intention under the provisions of Section 34 of the Indian Penal Code, 1860 (IPC) cannot be inferred mechanically merely based on the presence of accused near the scene of offence.
The Division Bench of Justices BR Gavai and PS Narasimha observed that there is neither oral nor documentary evidence to attribute accused 3 with the intent to murder. The inference was drawn mechanically under Section 34 merely based on his presence near the scene of offence and his familial relations with the other accused
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Naresh Kumar v. State of Haryana

Supreme Court has held that the mere fact that the deceased committed suicide within a period of seven years of her marriage, the presumption under Section 113A of the Indian Evidence Act, 1872 (IEA) would not automatically apply.
Therefore, before a presumption under Section 113A of IEA is raised, the prosecution must show evidence of cruelty or incessant harassment in that regard.
Court has held that the mere fact that the deceased committed suicide within a period of seven years of her marriage, the presumption under Section 113A of the Indian Evidence Act, 1872 (IEA) would not automatically apply. Therefore, before a presumption under Section 113A of IEA is raised, the prosecution must show evidence of cruelty or incessant harassment in that regard.
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Sheikh Arif v. The State of Maharashtra & Anr.

A case involving the offence rape because of false promise to marry under Indian Penal Code, 1860 (IPC).
Court held that “If it is established that from the inception, the consent by the victim is a result of a false promise to marry, there will be no consent, and in such a case, the offence of rape will be made out”.

Sunder Lal v. The State of Uttar Pradesh & Anr.,

The Supreme Court, has held that a witness can be summoned as a defence witness who was shown in the Prosecution list but not examined by prosecution

Vasantha (Dead) Thr. LR V. Rajalakshmi @ Rajam (Dead) Thr.Lrs.

The Supreme Court has held that under the provisions of Section 34 of the Specific Relief Act,1963 (SRA) a suit for declaration of title without seeking recovery of possession is not maintainable when the plaintiff is not in possession.
The court observed that it is a well-established position of law that under Section 34 of SRA, a suit for declaration of title without seeking recovery of possession is not maintainable when the plaintiff is not in possession.

State of Punjab v. Gurpreet Singh & Ors.

The Supreme Court has held that whil exercising the powers under Article 136 of the Constitution of India, 1950 (COI) the Court can interfere with the order of the acquittal if the acquittal of an accused would lead to a significant miscarriage of justice.
Court held that if the acquittal is based on irrelevant grounds, if the High Court allows itself to be misled by distractions, if the High Court dismisses the evidence accepted by the Trial Court without proper consideration, or if the High Court’s flawed approach leads to the neglect of vital evidence, this Court is obligated to intervene to uphold the interests of justice and address any concerns within the judicial conscience.

Sita Soren v. Union of India

A constitution bench of Chief Justice of India (CJI) D Y Chandrachud, and Justices A S Bopanna, M M Sundresh, P S Narasimha, J B Pardiwala, Sanjay Kumar, and Manoj Misra has held Rajya Sabha as a part of basic structure doctrine of constitution.
SC observed that bribery is not rendered immune under Article 105(2) and the corresponding provision of Article 194 because a member engaging in bribery commits a crime which is not essential to the casting of the vote or the ability to decide on how the vote should be cast.
The same principle applies to bribery in connection with a speech in the House or a Committee.
The offence of bribery is agnostic to the performance of the agreed action and crystallizes on the exchange of illegal gratification.
It does not matter whether the vote is cast in the agreed direction or if the vote is cast at all.
SC finally said that the offence of bribery is complete at the point in time when the legislator accepts the bribe.

High Court Bar Association Allahabad v. State of Uttar Pradesh & Ors

The Supreme Court has overturned the 2018 Asian Resurfacing judgment and set aside the automatic stay vacation rule.
The Supreme Court also issued crucial guidelines on the exercise of its powers under Article 142 of the Constitution of India, 1950 (COI)

Dattatraya v. The State of Maharashtra

The Court converted a punishment for murder into punishment for culpable homicide not amounting to murder.
The Supreme Court found that while the appellant had knowledge of the consequences of his act, there was no intention to cause death.
The Court considered the incident as a sudden fight in the heat of passion, converting the findings of Section 302 IPC to that of Section 304 Part-II IPC.

Kumar @ Shiva Kumar Versus State of Karnataka,

Court has held that a word uttered in a fit of anger or emotion without intending the consequences to actually follow cannot be said to be instigation for committing an offence under the provisions of Section 306 of the Indian Penal Code, 1860 (IPC)
It was further states that merely on the allegation of harassment without there being any positive action proximate to the time of occurrence on the part of the accused which led or compelled the deceased to commit suicide, conviction in terms of Section 306 of IPC would not be sustainable

Smt. Najmunisha, Abdul Hamid Chandmiya alias Ladoo Bapu v. State of Gujarat, Narcotics Control Bureau

The Supreme Court in the matter of Smt Najmunisha, Abdul Hamid Chandmiya alias Ladoo Bapu v. State of Gujarat, Narcotics Control Bureau has held that Article 20(3) of the Constitution of India, 1950 (COI) remains unchanged by the provisions of search and seizure under the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act)

MK Ranjitsinh And Ors. v. Union of India And Ors.

The Supreme Court observed that “The right to equality under Article 14 and the right to life under Article 21 must be appreciated in the context of the decisions of this Court, the actions and commitments of the state on the national and international level, and scientific consensus on climate change and its adverse effects. From these, it emerges that there is a right to be free from the adverse effects of climate change”
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Khengarbhai Lakhabhai Dambhala v. The State of Gujarat

The Supreme Court held that approaching the High Court under Articles 226/227 of the Constitution of India, 1950(COI) for the release of the seized vehicle would not be a proper remedy without approaching the magistrate under Section 451 of the Criminal Procedure Code, 1973 (CrPC)

X v. Y

The Supreme Court has held that denying child-care leaves to mothers of children with disabilities would violate the Constitutional duty to ensure equal women participation in the workforce.

State of Kerala v. Union of India

The legal dispute between the State of Kerala and the Union of India revolves around constitutional provisions governing state borrowing, with significant implications for fiscal federalism and economic governance. At the heart of the matter lies the interpretation of Article 293 and its intersection with the Union’s authority to regulate state finances.

Sandeep Kumar v. Gb Pant Institute of Engineering & Technology Ghurdaure

Court has held that the termination of the services of the employee without holding disciplinary enquiry violates the principles of natural justice.

Pankaj Singh v. State of Haryana

The court held that “Unless there is a specific legislative provision which puts a negative burden on the accused, there is no burden on the accused to lead evidence for proving his innocence. The accused may have some burden to discharge in case of a statutory prescription, such as Section 114A of the Evidence Act. In this case, the burden was on the prosecution to lead evidence to prove the guilt of the accused beyond a reasonable doubt”

Utpal Mandal @ Utpal Mondal v. The State of West Bengal & Anr

The Supreme Court observed that the entire purpose of the Protection of Children from Sexual Offences Act, 2012 (POCSO Act) is to ensure that the identity of the child is not disclosed unless the Special Court for reasons to be recorded in writing permits such disclosure.

Union of India & Anr. v. Jahangir Byramji Jeejeebhoy (D) Throug His LR

The question of limitation is not merely a technical consideration. The rules of limitation are based on the principles of sound public policy and principles of equity. We should not keep the ‘Sword of Damocles’ hanging over the head of the respondent for indefinite period of time to be determined at the whims and fancies of the appellants