Supreme Court Daily Digest [26 November 2025]

Sk Md Anisur Rahaman vs The State Of West Bengal 2025 INSC 1360 - Art.141 Constitution - Precedent

Constitution of India - Article 141- The object of Article 141 of the Constitution seems to be this: the pronouncement of a verdict by a bench on a particular issue of law (arising out of the facts involved) should settle the controversy, being final, and has to be followed by all courts as law declared by the Supreme Court. However, if a verdict is allowed to be reopened because a later different view appears to be better, the very purpose of enacting Article 141 would stand defeated. The prospect of opening up a further round of challenge before a succeeding bench, hoping that a change in composition will yield a different outcome, would undermine this Court’s authority and the value of its pronouncements. A matter that is res integra may not be reopened or revisited or else consistency in legal interpretation could be compromised and the special authority that is invested in decisions of this Court, under Article 141, lost. The weight and influence of that special authority depend on the credibility we, the Judges, give to it. As Judges of this Court, we are alive to the position that overturning a prior verdict by a later verdict does not necessarily mean that justice is better served. (Para 48) Judicial discipline, propriety and comity, which are also inseparable parts of a just and proper decision-making process, demand that a subsequent bench of different combination defers to the view expressed by the earlier bench, unless there is something so grossly erroneous on the face of the record or palpably wrong that it necessitates a re-look in exercise of inherent jurisdiction either by a review petition or through a curative petition. (Para 49) [Context: Supreme Court expressed concern about growing trend in Supreme Court of verdicts pronounced by Judges, whether still in office or not and irrespective of the time lapse since pronounced, being overturned by succeeding benches or specially constituted benches at the behest of some party aggrieved by the verdicts prior in point of time.]

Central Bureau of Investigation vs Sarvodaya Highways Ltd. 2025 INSC 1359 - S.482 CrPC - Economic Offences -OTS With Banks

Code of Criminal Procedure 1973 - Section 482 - Economic Offences -One-time settlement - Quashing of proceedings of a criminal case on strength of a compromise prohibited in cases where loss to public exchequer is evident and the offences under the PC Act, 1988 are applied (Para 30) -In cases involving economic offences, it is not merely the Bank that stands defrauded, but the society at large is also impacted - one-time settlement would not fetch the entire amount to which the Bank was otherwise entitled, had the cash credit account been maintained regularly - One-time settlements are, as a rule, effected under circumstances where the Bank under duress is compelled to accept lesser amount in order to secure the maximum possible recovery against the defaulting account. (Para 25-26)

New Delhi Nature Society vs Director Horticulture, DDA 2025 INSC 1358 - Wild life - Deer Population

Wild Life Conservation - The deer population at the Deer Park is a reminder that conservation is not merely the relocation of animals but an exercise in stewardship: preserving species, habitats, and the environmental ethos enshrined in our constitutional framework - Supreme Court issued directions to ensure that the welfare of the deer population is secured in accordance with the statutory framework prevailing in India and internationally accepted conservation guidelines/norms. (Para 22-24)

Constitution of India - Articles 21, 48A and 51A(g) - Articles 48A and 51A(g) embody a collective commitment to safeguard forests and wildlife and to act with compassion for all living beings, while Article 21 has been judicially recognized as encompassing the right to a clean and ecologically balanced environment. (Para 23)

T. Manjunath vs The State of Karnataka; 2025 INSC 1356 -Prevention of Corruption Act - Sanction

Prevention of Corruption Act 1988 - Section 19- The Explanation to Section 19(4) would become relevant and come into play only when the question of validity or otherwise of the sanction is under scrutiny before the appellate or the revisional forum as provided in sub-Section (3) of Section 19. (Para 38)

Criminal Trial - Prevention of Corruption Act - Exoneration in the departmental proceedings does not, ipso facto, furnish a ground for dropping the criminal charges more particularly in Trap Cases.(Para 33) The mere fact that a decoy/complainant in a trap case turns hostile would not adversely affect the case of prosecution and that conviction can be based even on the evidence of the trap laying officer, if found reliable and trustworthy. (Para 30) When a witness deposing on oath in a criminal trial resiles from the original version and does not support the prosecution case, he would be liable to face prosecution for perjury. Under this pressure, the witness may choose to speak the truth. Thus, the mere fact that some of the witnesses did not support the department’s case in the disciplinary proceedings would, by itself, not give any assurance that they would behave in the same manner at the criminal trial. (Para 31)

Nitish Verma v. Union of India- Art.32 Constitution- Service Matters

Constitution of India- Article 32 - Service Matters - Article 32 is not an open highway for every grievance dressed under the garb of a fundamental right violation. It is a sacred constitutional artery to be invoked when the life blood of liberty itself is imperiled, not for routine service matters that find their natural home under Article 226 of the Constitution of India, before the High Courts - A grievance regarding reservation, computation under a recruitment notification cannot be permitted to masquerade as a constitutional crisis. -While this Court stands as the guardian and watchtower of fundamental rights, it must also remind litigants that every knock on the door of Article 32 dilutes it’s sanctity if made without due cause. The constitutional remedy is meant to remain extraordinary, not ornamental, not habitual- Constitutional remedies must not be reduced to procedural shortcuts. The Majesty of Article 32 lies not in its frequency of invocation but in the gravity of the cause that compels it. (Para 3-6)

Sandhya Sahu v. Dharmendra Sahu - Art. 142 - Irretrievable Breakdown Of Marriage

Constitution of India - Article 142 - The power to grant divorce on the ground of irretrievable breakdown rests only with this Court as it is germane from Article 142 of the Constitution of India. (Para 6) [Referred to Shilpa Shailesh v Varun Sreenivasan (2023)14 SCC 231 ]