Weekly Overview: Supreme Court Judgments (January 2025)

The Supreme Court of India delivered several notable judgments between January 2 and January 3, 2025. These decisions address key legal principles involving property rights, environmental concerns, cheque bounce complaints, motor accident claims, and the quashing of criminal proceedings. Below is a detailed summary of these landmark rulings:

1. Right to Property and Compensation
Case Name: Bernard Francis Joseph Vaz and Others v. Government of Karnataka and Others
Judgment Reference: 2025 INSC 3
In this case, the Supreme Court reaffirmed the constitutional principle that no person can be deprived of their property without just and adequate compensation. The appellants challenged a Karnataka High Court decision that denied them compensation for the acquisition of their land. The Supreme Court held that the right to property, though no longer a fundamental right, is still protected as a constitutional right under Article 300A. Any deprivation of property must follow due process and include fair compensation. This judgment reinforces the judiciary’s role in safeguarding property rights and ensuring legal compliance during acquisitions.

2. Waste-to-Energy Project in Delhi
Case Name: Municipal Corporation Of Delhi v. Gagan Narang & Others
Judgment Reference: 2025 INSC 2
This case involved a challenge to the Municipal Corporation of Delhi’s (MCD) tariff and bidding process for a waste-to-energy project. The project aimed to address Delhi’s mounting waste management issues. The Appellate Tribunal for Electricity had previously ruled against the MCD, citing irregularities in the bidding process. However, the Supreme Court overturned this decision, emphasizing the project’s broader public interest in managing waste disposal in the national capital. The Court also noted that the Appellate Tribunal had erred by failing to consider the environmental and public welfare implications of the project.

3. Maintainability of Cheque Bounce Complaints by Power of Attorney Holders
Case Name: M/s Naresh Potteries v. M/s Aarti Industries And Another
Judgment Reference: 2025 INSC 1
The Court addressed whether a Power of Attorney holder could file a cheque bounce complaint under Section 138 of the Negotiable Instruments Act, 1881. In this case, the complaint was dismissed by the lower courts on the grounds that the complainant lacked the authority to file the complaint. The Supreme Court reinstated the complaint, holding that a Power of Attorney holder can file a cheque bounce case, provided they have personal knowledge of the transaction and explicit authorization from the principal. This judgment clarified the legal position regarding the representation of firms or individuals in cheque-related disputes.

4. Motor Accident Claims and Negligence Assessment
Case Name: ICICI Lombard General Insurance Co. Ltd. v. Rajani Sahoo & Others
Judgment Reference: 2025 INSC 6
In this case, the Supreme Court provided crucial guidance on determining negligence in motor accident claims. The appellants challenged a Motor Accident Claims Tribunal (MACT) decision that awarded compensation to the respondents. The Court emphasized that tribunals must thoroughly examine all available evidence, including police records, to assess negligence accurately. It also directed that due care should be taken in cases involving disputed liability. This ruling strengthens the procedural requirements for MACTs, ensuring that compensation is awarded based on a fair and detailed assessment of negligence.

5. Quashing Criminal Proceedings via Writ Jurisdiction
Case Name: Kim Wansoo v. State of Uttar Pradesh & Others
Judgment Reference: 2025 INSC 8
The Supreme Court quashed an FIR filed against a foreign national accused of misappropriation and fraud. The Allahabad High Court had earlier refused to quash the FIR, prompting the petitioner to approach the apex court. The Supreme Court ruled that criminal proceedings can be terminated under Article 226 or Article 32 of the Constitution if they are deemed unjust or oppressive. It noted that the allegations lacked sufficient merit to warrant a criminal trial, and continuing the proceedings would amount to harassment. This decision underscores the judiciary’s role in preventing misuse of criminal law.

Conclusion
These judgments highlight the Supreme Court’s commitment to upholding constitutional principles, addressing public interest concerns, and ensuring justice in diverse areas of law. From safeguarding property rights to clarifying procedural aspects in cheque bounce and motor accident cases, these rulings reflect the judiciary’s pivotal role in shaping legal discourse in India.

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