Instituted under Article 32 to protect the Great Indian Bustard (Godawan) and Lesser Florican from extinction due to collisions with high-tension power transmission lines in Rajasthan and Gujarat. The Court addressed the "Green vs. Green" dilemma, balancing biodiversity preservation with solar/wind renewable energy infrastructure.
Judicial Analysis & Statutory Reasoning
Interpreting Sections 135 and 166(2) of the Companies Act, 2013, the Court established that Corporate Social Responsibility (CSR) includes Corporate Environmental Responsibility (CER). Commercial power developers operating in sensitive habitats are 'guests' in wildlife domains and must bear mitigation costs as an environmental trust under Article 21.
Ultimate Ruling & Directives
Priority habitat refined to 14,013 sq. km (Rajasthan) and 740 sq. km (Gujarat).
Mandatory undergrounding of 80 km of 33 kV lines and ~250 km of critical WII corridors.
Ban on new solar/wind plants exceeding 2 MW in core priority habitats.
Certified Bird Flight Diverters (BFDs) required on lines 400 kV+ within 12 months.
A 20-year-old bride died unnaturally within seven years of marriage following continuous physical abuse for a motorcycle and cash. The High Court acquitted the husband and mother-in-law (Jamila Beg, aged 94), prompting a State appeal.
Judicial Analysis
The Court observed that the evil of dowry has hollowed out the empowering Muslim institution of mehr, violating Article 14. Setting aside the High Court acquittal, the Court restored convictions under Section 304-B/498-A IPC. Balancing Article 21 dignity, incarcerating a 94-year-old frail woman was held inhumane, waiving her jail time while ordering husband Ajmal Beg to surrender immediately.
Directives: Deploy and train specialized Dowry Prohibition Officers under Section 8B DPA; integrate gender equality into school curricula; request High Courts to track and expedite all 304-B cases.
An IRS officer challenged the authority of an ICC constituted at the victim IAS officer's department, claiming only his parent department could inquire into his conduct.
Purposive Ruling: The Court rejected departmental siloing. 'Workplace' and 'employee' under the POSH Act are intentionally expansive. An ICC where harassment occurs holds cross-departmental jurisdiction to conduct the preliminary inquiry, transmitting its final findings to the harasser's employer for mandatory service-rule action within 60 days.
Constitutional Law & FederalismCase 04
4. Special Reference No. 1 of 2025
Presidential Reference | Citation: 2025 INSC 1333
A 5-judge Constitution Bench led by Gavai, CJI, clarified gubernatorial powers under Article 200. Held that Governors exercise independent constitutional discretion regarding Bill assent. Article 142 cannot grant 'deemed assent', but Article 361 personal immunity does not shield prolonged, unconstitutional legislative inaction from limited judicial review.
Criminal Procedure (BNSS/CrPC)Case 05
5. Mihir Rajesh Shah v. State of Maharashtra & Another
Extending Pankaj Bansal, supplying written grounds of arrest is a mandatory constitutional requirement under Article 22(1) and Sec 47 BNSS (Sec 50 CrPC) across all criminal offenses. 'Conscious awareness' cannot substitute written grounds.
Binding Timeline: Full written grounds of arrest must be served on the arrestee at least 2 hours prior to producing them for first remand before a magistrate.
Non-disclosure of an active conviction under Section 138 NI Act in election affidavits amounts to material suppression and undue influence on voters. Eligibility is evaluated strictly as of the nomination submission date; subsequent appellate acquittal does not cure the initial disqualification.
Legal Ethics & Attorney PrivilegeCase 07
7. Suo Motu Writ Petition (Crl.) No. 2 of 2025
Suo Motu Reference | Citation: 2025 INSC 1275
Investigating officers cannot directly summon practicing advocates under Sec 179 BNSS to disclose client communications. Professional privilege under Section 132 BSA is sacrosanct. Any such summons requires prior written approval from an officer not below Superintendent of Police. In-house counsel are excluded from Sec 132 privilege and governed by Sec 134 BSA.
Banking & Cheque Bounce ReformsCase 08
8. In Re: Section 138 Negotiable Instruments Act Guidelines
Criminal Judicial Guidelines
Addressing over 6.5 lakh pending cheque bounce cases in Delhi alone, the Court held that because the NI Act is a self-contained code, Magistrates are NOT required to hold pre-cognizance hearings under Section 223 BNSS before issuing summons. Issued standardized filing formats nationwide.
Education & Minority RightsCase 09
9. Anjuman Ishaat-e-Taleem Trust v. State of Maharashtra
Expressing doubts on Pramati (2014), the Court referred the blanket exemption of minority schools from the RTE Act to a 7-judge Constitution Bench. Binding direction issued: ALL teachers across minority and non-minority institutions must qualify TET by Dec 31, 2025, or lose promotion eligibility/face compulsory retirement.
A woman's right to make reproductive choices is part of Article 21 personal liberty. Capping maternity leave benefits based on biological children from a dissolved prior marriage whose custody remains with the ex-spouse is unconstitutional. Maternity benefits are a constitutional guarantee, not mere administrative largesse.
Subordinate Judiciary RulesCase 11
11. All India Judges Association v. Union of India
WP (C) No. 1022 of 1989 | Citation: 2025 INSC 735
Restored the 25% LDCE promotion quota for Civil Judges (Senior Division) to District Judge cadre. Re-instated the mandatory requirement of 3 years minimum Bar practice for entry as Civil Judge (Junior Division), halting direct entry of raw law graduates without courtroom exposure.
Upheld liquidated damages clauses in Public Sector Bank employment bonds with reasonable lock-in periods (e.g. ₹2 Lakhs for resigning within 3 years). Such terms protect public recruitment investments and do not constitute restraint of trade under Section 27 Contract Act.
Arbitration & Conciliation ActCase 13
13. Gayatri Balasamy v. M/s. ISG Novasoft Technologies Ltd.
Upheld revised pecuniary jurisdiction limits under Consumer Protection Act, 2019. Introduced the concept of a 'Performance Audit' for legislative implementations, directing the CCPA to audit commission infrastructure and eliminate chronic vacancies.
Displaying a Municipal Council building's name in Urdu script alongside the official Marathi script does not violate the Maharashtra Local Authorities Official Languages Act, 2022. Official language statutes do not prohibit supplementary linguistic displays for public harmony.
Copyright suits concerning engineering drawings cannot be summarily rejected under Order VII Rule 11 CPC on preliminary claims of industrial application under the Designs Act. Reaffirmed the prohibition against partial plaint rejection.
Quashed an FIR registered for posting a poetry recitation video. The standard for judging spoken or written words under Sec 196 BNS must be based on courageous, firm individuals, not weak minds perceiving criticism as hatred. Article 19(1)(a) fully protects artistic protest.
Reaffirmed mandatory FIR registration under Sec 154 CrPC when complaints disclose SC/ST caste harassment. Summary inquest inquiries under Sec 174 CrPC cannot replace regular investigations. Constituted a National Task Force to combat student suicide epidemics in higher educational institutions.
Extended PMLA arrest safeguards (Kejriwal/Pankaj Bansal) to Section 104 Customs Act and Section 69 GST Act. Written 'reasons to believe' and 'grounds of arrest' MUST be furnished to arrestees prior to magistrate production.
Legislative Immunity & ProportionalityCase 20
20. Dr. Sunil Kumar Singh v. Bihar Legislative Council
Article 212(1) immunity does not shield arbitrary legislative expulsion from judicial review. Expulsion of an MLC for unparliamentary speech breached the test of proportionality; reduced punishment to the 7 months already served and ordered immediate reinstatement.
Family Law & MaintenanceCase 21
21. Sukhdev Singh v. Sukhbir Kaur
3-Judge Bench Reference | Citation: 2025 INSC 197
A spouse of a marriage declared null and void under Section 11 Hindu Marriage Act IS jurisdictionally entitled to claim permanent alimony and maintenance under Section 25 HMA. Differentiated Section 25 civil remedies from restrictive Sec 125 CrPC definitions.
Custodial Dignity & Human RightsCase 22
22. Vihaan Kumar v. State of Haryana & Anr.
Criminal Appeal | Citation: 2025 INSC 162
Handcuffing and chaining an ailing arrestee to a hospital bed is a barbaric violation of Article 21 human dignity. Declared arrest illegal, awarded state compensation, and mandated strict guidelines prohibiting handcuffing without prior court authorization.
Domicile/residence-based reservation in Post-Graduate Medical seats is constitutionally invalid under Article 14. Institutional preference is permissible, but local residential quotas at the PG level violate national merit.
Quashed trafficking charges against employer under Article 142. Addressing the nationwide legal vacuum concerning domestic workers, directed the Ministry of Labour to establish an Expert Committee to draft statutory protections within 6 months.
Access to clean sanitation in court complexes is a fundamental facet of Article 21 dignity. Mandated separate male, female, PwD, and transgender toilets, sanitary napkin dispensers, and outsourced professional maintenance across all Indian courts.
A husband securing a civil decree for restitution of conjugal rights does NOT automatically disentitle the wife from Section 125 CrPC maintenance if she has sufficient reason (e.g. fear of abuse) for living separately.
Arbitration & Limitation ActCase 27
27. My Preferred Transformation v. M/s Faridabad Implements
Section 4 Limitation Act (court holiday extensions) applies ONLY to the primary 3-month limitation period under Section 34(3) ACA, NOT to the discretionary 30-day condonable window. Courts have no power to extend condonation beyond strict limits.
Property gifted by a senior citizen on the condition of receiving care can be statutorily declared void under Section 23 of the Senior Citizens Act, 2007 if the transferee fails to maintain them. Restored deed cancellation and ordered property possession back to the elderly mother.
