Monthly Magazine MAY

Lexpedia · 31 May 2025 · 25 min read

The Court emphasized the separation of powers between the Magistrate and the High Court, especially during the investigative phase of a case. The High Court should not evaluate investigative findings before a trial has even started.
The Court reasserted that the High Court's powers under Section 482 CrPC should be used sparingly and cautiously, focusing on FIR allegations and undisputed facts not on investigation reports.
By allowing the High Court’s reliance on an investigation report, there was a risk of prejudicing the Magistrate’s independent evaluation, which could affect the fairness of the trial.
The Court's reliance on Pratibha v. Rameshwari Devi was significant in reinforcing that only the Magistrate has the authority to evaluate the investigation report, ensuring the due process of law is followed.

✅ SHENBAGAVALLI & ORS. v. THE INSPECTOR OF POLICE & ANR., 2025

The ruling reinforces strict evidentiary standards for invoking Section 306 IPC, avoiding criminalisation of isolated insults or marital tensions.
The Court emphasized proportionality in criminal law and cautioned against emotional or retaliatory misuse of abetment charges.
It echoed prior rulings that criminal proceedings should not continue where essential ingredients of the offence are missing.
The judgment aligns with the Court’s view in other cases that police need to be sensitized before invoking serious charges like abetment to suicide.

The Court’s reasoning highlights the need for direct evidence of intent to establish abetment under Section 306 of the IPC.
It makes a clear distinction between verbal abuse and criminal instigation that leads to suicide. Mere use of hurtful words, even if offensive, does not suffice to make out an offence of abetment to suicide.
The judgment reinforces that mens rea (the intention to instigate or aid suicide) is a critical element in determining whether Section 306 applies.
The decision also safeguards against overreach by law enforcement and courts, ensuring that criminal proceedings are not initiated merely based on family disputes or allegations of verbal insults.

✅ Sri Malakappa & Ors. v. IFFCO Tokio General Insurance Co. Ltd. & Anr., 2025

The judgment promotes a progressive and gender-neutral approach to dependency in motor accident claims.
It corrects a flawed presumption that a man must be financially independent simply because he is physically capable.
Reinforces that evidence not assumption must guide the determination of dependency.
Sets a legal precedent that able-bodied spouses can still be recognized as dependents under the Motor Vehicles Act.
Protects the right to fair compensation for families where traditional gender roles may not apply.
It Helps avoid exclusionary practices that undermine the intent of social welfare-oriented compensation law.

✅ K.R. Suresh v. R. Poornima & Ors., 2025

The forfeiture clause in the agreement was found to be justified since the earnest money served to bind the contract and ensure the purchaser's compliance.
Section 74 of the Indian Contract Act does not apply to earnest money forfeiture since it is not a penalty.
The seller’s action was deemed justified due to the breach of contract by the purchaser.
The Court emphasized that such clauses should be fair and not unconscionable to be enforceable.
The Supreme Court dismissed the appellant's appeal, affirming the forfeiture of Rs. 20 lakh as earnest money, in line with the terms of the Advance Sale Agreement.

✅ M/S J N REAL ESTATE VERSUS SHAILENDRA PRADHAN & ORS., 2025

The Supreme Court ruled that the appellant, as a subsequent purchaser, can be considered a proper party in the suit since his rights over the property may be affected by the adjudication.
The Court emphasized that even though the appellant was not a "necessary party", his impleadment was important for a fair and comprehensive resolution of all disputed matters.
A necessary party is defined as one whose absence would prevent the court from passing an effective decree.
A proper party, although not essential, is one whose presence is required to ensure a complete and adequate adjudication of the case.
The Court observed that the transaction between the appellant and the original defendant is in dispute, and resolving it could impact the outcome of the suit.
Since the plaintiff did not oppose the appellant’s inclusion, the Court ruled that his impleadment would facilitate an effective adjudication of the case.
The Court cited the Sumtibai v. Paras Finance Co. (2007) case, reinforcing that if a third party has a plausible claim over the property, they can seek impleadment in a specific performance suit under Order 1, Rule 10(2) of the CPC.
The Supreme Court allowed the appeal and reinstated the trial court's decision permitting the appellant's impleadment as a proper party.

✅ Aman Bhatia vs State (GNCT of Delhi), 2025

The judgment expands the definition of public servants under the Prevention of Corruption Act, now covering private individuals performing public duties and receiving government remuneration.
The Court clarified the link between public duties and remuneration: stamp vendors receive government compensation via discounts on stamp papers, thus falling within the ambit of public servants.
The vending of stamp papers is essential to the government’s collection of stamp duty, reinforcing the role of stamp vendors in fulfilling public duties.
Evidence Standard: While the Court ruled that stamp vendors are public servants, it also emphasized the importance of evidence in proving criminal liability, leading to the overturning of the conviction.
The Court referred to previous rulings, such as State of Gujarat vs Mansukhbhai Kanjibhai Shah, to highlight that remuneration tied to public duties qualifies individuals as public servants, irrespective of whether they are formally employed by the government

✅ Raju @ Umakant vs. The State of Madhya Pradesh, 2025

The judgment reinforces the principle that the law considers not only physical participation in the crime but also the shared criminal intent in determining liability for gang rape. Even if an accused does not directly engage in the penetrative act, their involvement in the conspiracy or shared intention to commit the crime makes them equally liable.
The Supreme Court's reliance on the Ashok Kumar case strengthens the legal understanding that a gang rape charge can be upheld when the accused have a common intention, irrespective of their personal participation in the act of rape. This sets a clear precedent for similar future cases.
The Court's interpretation of "common intention" in this case clarifies that for crimes like gang rape, the shared intention to commit the crime is sufficient to hold all participants liable, thus ensuring that no individual involved in the conspiracy or commission of the crime is let off based on the lack of direct involvement in the penetrative act.
This judgment emphasizes that even in cases where not all accused directly engage in the act of rape, the collective participation in the crime and the intent to sexually assault the victim will lead to the same level of punishment for all. This strengthens the victim’s position and ensures that all parties responsible for the crime are held accountable.

✅ P. Kumarakurubaran v. P. Narayanan & Ors., 2025

The Court reinforced the principle that Order VII Rule 11 should be applied sparingly, only when it's abundantly clear from the plaint itself that the suit is barred by any law (such as limitation).
It clarified that Article 59 Limitation Act requires courts to consider when the plaintiff first became aware of the cause of action, which often involves factual inquiry.
The judgment promotes procedural fairness by preventing courts from prematurely dismissing suits where triable issues exist.
The ruling is consistent with prior SC judgments like Daliben Valjibhai (2024) and Popat and Kotecha Property v. State Bank of India Staff Association (2005).

✅ Shubhkaran Singh v. Abhayraj Singh & Ors., 2025

This decision reaffirms the limited scope of Order XVIII Rule 17 CPC, echoing earlier rulings such as K.K. Velusamy v. N. Palanisamy, (2011) 11 SCC 275.
The court emphasized the need to prevent misuse of procedural provisions that could allow parties to fill gaps in their evidence after the trial has progressed.
The judgment strikes a balance between judicial efficiency and fair trial principles, by allowing recall only in exceptional situations through inherent powers, ensuring that this does not become a tool for delay or abuse of process.

✅ Santosh Devi v. Sunder, 2025

The Court emphasized a strict interpretation of Section 17 to prevent abuse of the limitation laws.
It drew a clear distinction between alleging that a deed was fraudulent and proving that the fraud concealed the cause of action.
The decision promotes the principle that legal remedies must be pursued within statutory time limits unless compelling reasons justify the delay.
The judgment reinforces that mere suspicion or delay in acting is not a ground for condonation, especially where the plaintiff was in a position to verify the facts earlier.

✅ Harjinder Singh v. The State of Punjab & Anr., 2025

The Supreme Court highlighted the importance of prima facie evidence in the summoning stage, asserting that the focus should be on whether the accused's involvement is apparent from the evidence, rather than whether guilt has been proven beyond a reasonable doubt.
The court addressed the procedural aspect, emphasizing that the defence of alibi is a matter of defence and must be proven at trial. The documents submitted as alibi evidence were deemed untested at the summoning stage, which led the court to reject them as conclusive.
This judgment clarifies the threshold for summoning an additional accused under Section 319 Cr.P.C., ensuring that the court only looks at whether there is sufficient evidence to require the presence of the accused at trial. It also reinforces the principle that the burden of proving a defence like alibi lies on the accused during the trial.

✅ Muruganandam v. Muniyandi (Died) through LRs., 2025

The Supreme Court allowed the appeal and set aside the judgments of both the trial court and the High Court.
It held that the unregistered agreement could be used to prove the existence of a contractual relationship between the parties under the proviso to Section 49.
Cited the precedent in S. Kaladevi v. V.R. Somasundaram, which upheld the use of an unregistered document to prove an oral contract for specific performance.

✅ RENUKA PRASAD VERSUS THE STATE, 2025

The Supreme Court's reasoning underscores the importance of adhering to procedural rules about the admissibility of evidence in criminal cases.
By distinguishing between the use of police testimony for physical recoveries (which can be reliable) and testimony regarding witness statements under Section 161 Cr.P.C. (which cannot be used substantively), the Court protected the integrity of the criminal justice system.
The decision reinforces that hostile witnesses who do not stand by their earlier statements recorded by the police cannot be substituted by the investigating officer’s narration of those statements. This judgment safeguards the rights of the accused and ensures that convictions are only based on lawful, substantive evidence.
The Court's analysis calls attention to the abuse that could occur if statements made to the police, especially when they are not recorded in the presence of a magistrate, are relied upon as credible evidence in a trial.
It also highlights the limits of police authority in using witness statements, ensuring that Section 161 Cr.P.C. statements cannot be given legal weight unless independently verified during the trial.

✅ State of Lokayuktha Police, Davanagere v. C B Nagaraj, 2025

The judgment reiterates the settled principle of law from earlier cases like B. Jayaraj v. State of Andhra Pradesh (2014) that demand is essential to sustain conviction under PC Act.
The burden of rebuttal under Section 20 does not arise unless demand is first proved beyond doubt by the prosecution.
The Court's careful scrutiny of evidentiary gaps, especially regarding the complainant’s credibility, shows its commitment to upholding due process in criminal prosecution.
The Court also restated the doctrine of chain completeness: demand → acceptance → recovery must all be proved.
It serves as a guiding precedent that mere possession of marked currency is not enough for conviction.

✅ MA v. Superintendent of Police, 2025

The Court took a progressive view of family structures, extending legal recognition beyond heteronormative models.
The judgment emphasized the evolution of legal understanding post-NALSA and Navtej Singh Johar, incorporating international human rights norms like the Yogyakarta Principles.
The judges expressed discomfort with the term “queer”, critiquing its linguistic implications and advocating for normalization of non-heterosexual identities.
The ruling strengthens the jurisprudence on bodily autonomy, adult choice, and civil unions, and further underlines the role of state accountability.
It also points to a systemic gap in the police’s sensitivity and responsiveness in handling LGBTQIA+ cases.

✅ M/s Celestium Financial v. A Gnanasekaran, 2025

The definition of “victim” under Section 2(wa) CrPC is interpreted broadly, encompassing anyone who has suffered harm or injury due to the crime, including cheque dishonour cases.
The proviso to Section 372 CrPC, inserted in 2009, was intended to empower victims and remove procedural hurdles in accessing justice.
Unlike Section 378(4) which requires leave of the court for appeals against acquittals by complainants, the proviso creates a separate pathway for victims, free from such conditions.
The Parliament deliberately chose not to amend Section 378 to cover victims under the same umbrella as complainants, thereby indicating a legislative intent to provide greater rights to victims.
In cases under Section 138 NI Act, which are private complaints, the State’s involvement is minimal. Hence, the victim-complainant is central to seeking redress and must be given direct appellate rights.
The Court aligned the victim’s right to appeal with the accused’s right to appeal under Section 374 CrPC, establishing equality in appellate rights.

✅ STATE OF RAJASTHAN v. GOPAL & ORS., 2025

The Court’s ruling clarifies the competency of an In-Charge SHO to carry out a search under the NDPS Act, even in the absence of the designated SHO. This decision ensures that the provisions of the NDPS Act are not interpreted in a restrictive manner, thus upholding the efficiency and authority of police officers entrusted with maintaining law and order.
The decision strengthens the application of Section 42 of the NDPS Act by affirming that the powers to search and seize under this section can be exercised by temporary or In-Charge officers as well, based on the State Government's notification.

✅ JKB v. KSB, 2025

The Court reinforced that compensation under Section 22 of DV Act must be meaningful and proportional to the extent of abuse and the economic status of the parties.
It rejected the notion that a woman must recall exact dates of domestic violence, recognizing the private nature of such abuse.
The Court emphasized that capacity to earn does not disqualify a victim of domestic violence from claiming maintenance.
The ruling advances gender justice and financial empowerment for survivors, ensuring relief is not merely symbolic.

✅ Thangavel v. The State, 2025

The Court reaffirmed the legal position that mens rea is a necessary ingredient in establishing abetment to suicide.
The judgment reflects judicial restraint in criminalising professional conduct without intent or recklessness.
It serves as a reminder that criminal law should not be invoked merely due to emotional or societal pressure when essential legal requirements are not met.
The ruling also implicitly cautions against the overreach of criminal investigations in educational or institutional settings without due cause.

✅ Rakhi Sadhukhan v. Raja Sadhukhan, 2025

The Court reinforced that maintenance is not just subsistence but must preserve dignity and lifestyle parity.
It acknowledged inflationary pressures, financial disclosures, and the importance of economic independence for a separated spouse.
The ruling highlights the balance between financial capability of the husband and the future security of the wife.
It reflects a progressive interpretation of spousal support and reinforces the principle that divorced spouses should not face financial destitution.

✅ BATLANKI KESHAV (KESAVA) KUMAR ANURAG VERSUS STATE OF TELANGANA & ANR., 2025

The Court’s reasoning hinged heavily on digital evidence (chats) showing the complainant’s intent and manipulative patterns.
It reaffirmed that false promise of marriage as a ground for rape charge requires genuine intent and absence of coercion, which was missing here.
The late introduction of SC/ST offences indicated malicious intent to invoke harsher laws.
The judgment emphasizes the importance of credibility and conduct of complainants in sexual offence cases, balancing protection against misuse of laws.
It highlights judicial caution to prevent abuse of criminal laws to harass individuals under false allegations.

✅ Vedpal Singh Tanwar v. Directorate of Enforcement, 2025

The ruling highlights the Supreme Court's growing concern over judicial delays in bail matters, especially post-2020, when the Court has increasingly emphasized expedited adjudication of liberty-related issues.
The decision strengthens the precedent set in similar cases, such as:
- Hussain v. Union of India (2017) – where right to speedy trial was declared integral to Article 21.
- Siddique Kappan case – where delays by the HC in bail were similarly deprecated.
The Court’s reiteration signals a clear accountability mandate for subordinate courts to prioritize bail and liberty.

✅ Manish Agarwal v. State of Orissa & Anr., 2025

The Supreme Court has followed a balanced approach—respecting the High Court's discretion while ensuring that the petitioner is not incarcerated unnecessarily before trial.
This case involves a sensitive balance between:
- Allegations of institutional cover-up,
- Protection of public servants from frivolous prosecution, and
- Ensuring justice for the deceased and his family.
The dropping of murder charges shows a lack of strong medical or forensic support.
However, the retention of Sections 306 and 120-B suggests a potential theory of institutional pressure, mental harassment, or abetment via conduct.
The interim bail relief prevents pre-trial incarceration, respecting the principle of presumption of innocence.

✅ Agniraj & Others vs. State, 2025

The Supreme Court reaffirmed the well-settled principle that child witnesses are inherently vulnerable and susceptible to influence or tutoring.
Section 118 imposes a “condition precedent”: before a child testifies, the court must be satisfied about their capacity to understand and respond to questions.
The absence of a competency test and failure to conduct a TIP showed serious procedural lapses.
This judgment safeguards the rights of the accused from unreliable child testimony and strengthens due process requirements when dealing with minor witnesses.
It also sends a message to trial courts to strictly adhere to procedural protocols when examining vulnerable witnesses.

✅ Sachin vs. State of Maharashtra, 2025

The judgment upholds the legislative mandate under the 2019 amendment to the POCSO Act, which raised the minimum punishment for aggravated sexual assault.
It emphasizes that courts cannot override statutory minimum sentences even under Article 136, absent express legislative provision or miscarriage of justice.
This ruling sends a strong signal about the non-negotiable nature of punishments in heinous crimes against children.
The Court also rejected common mitigating arguments (youth, delay in FIR) as insufficient when the law mandates minimum penal consequences.

✅ State (Through CBI) vs. Eluri Srinivasa Chakravarthi & Others, 2025

It Reaffirms principle in State of Orissa v. Debendra Nath Padhi (2005) that defense documents cannot be used at the discharge stage.
It Prevents trial courts from conducting premature evaluations of the accused’s defense.
It Strengthens prosecutorial rights and reinforces the procedural boundary of Section 239 CrPC.
This is Important for economic and corruption-related offenses, where conspiracy is central and evidence is often circumstantial.

✅ Mohd Maqbool Mir v. Ghulam Ahmad Pahloo, 2025

The Court emphasized the importance of strictly following the procedural mandates in summary suits under Order 37 CPC.
Summary suits provide a swift and simplified mechanism; deviation from the prescribed procedure converts the matter into an ordinary suit.
This protects the right of the defendant to seek remedies under the appropriate procedural rules of ordinary suits, such as appeal or setting aside ex parte decrees under Order 9 Rule 13 CPC.
The Court clarified the limitations on invoking Order 37 Rule 4 once summary procedure is lost, reinforcing procedural discipline in civil litigation.
The decision highlights the significance of procedural safeguards and proper legal channels for setting aside ex parte decrees.
It also demonstrates judicial caution against allowing litigants to bypass statutory procedural safeguards by misapplying provisions designed for summary suits.

✅ Padman Bibhar v. State of Odisha, 2025

The Supreme Court allowed the appeal and set aside the conviction of the appellant under Section 302 IPC.
The Court reiterated that in a case based purely on circumstantial evidence, every link in the chain of events must be established beyond reasonable doubt.
It held that the “last seen together” theory, without other corroborative evidence, is insufficient to convict a person for murder.
The prosecution failed to explain the time gap between the last sighting of the deceased with the accused and the discovery of the body.
The alleged motive based on suspicion of the appellant’s wife’s infidelity was found to be weak and unconvincing.
The blood-stained stone recovered from the scene was neither forensically linked to the deceased nor recovered at the instance of the accused.
No exclusive opportunity was proven that would make it probable that only the accused could have committed the crime.
The conviction based on suspicion, even if strong, cannot substitute proof beyond reasonable doubt in criminal law.
The Court relied on the precedent set in Kanhaiya Lal v. State of Rajasthan, emphasizing the weak evidentiary value of “last seen together” evidence when unaccompanied by other proof.
Therefore, the Supreme Court found the conviction to be unsustainable and acquitted the appellant.

✅ Dashrath Patra v. State of Chhattisgarh, 2025

The Supreme Court ruled that the testimonies of prosecution witnesses clearly indicated long-standing mental illness.
It emphasized that the accused need not conclusively prove insanity; rather, it is enough to create reasonable doubt about sanity.
The 2023 medical report was held irrelevant for evaluating the mental condition during the 2018 incident.
The appeal was allowed, and the conviction and sentence were set aside.

✅ Sameer Sandhir v. Central Bureau of Investigation, 2025

The Court took a pragmatic and fair approach, favoring substantive justice over procedural rigidity.
By citing R.S. Pai, the Court clarified that procedural lapses can be rectified, provided the accused's right to a fair trial is not compromised.
This decision reinforces prosecutorial flexibility while emphasizing judicial oversight to guard against abuse.
It sets a precedent for post-charge sheet submission of omitted evidence where due process is followed.
Balances investigative thoroughness and accused’s rights, ensuring judicial efficiency without miscarriage of justice.

✅ K. Umadevi v. Government of Tamil Nadu, 2025

The Supreme Court set aside the Division Bench’s ruling, restoring the Single Judge’s judgment.
It held that maternity benefits are part of reproductive rights, and maternity leave is integral to such rights.
The Court emphasized that rights under the Maternity Benefit Act override service rules due to Section 27 and Article 254 of the Constitution.
It ruled that the appellant's third child (first in her second marriage and after entering service) qualified her for maternity leave, irrespective of her earlier two children.
The Court harmonized population control policy and maternity benefit policy, noting they must coexist rationally and purposively.

✅ Vijaya Bank & Anr. Vs. Prashant B Narnaware

The Supreme Court set aside the High Court’s judgment and upheld the validity of the ₹2 lakh penalty clause.
The Court ruled that such exclusivity clauses do not violate Section 27 of the Contract Act since they do not restrict future employment, but rather impose liquidated damages for not fulfilling the contractual term.
The clause was deemed reasonable and necessary, especially considering the public nature of the employer and the costs of re-recruitment.

✅ XXX v. State of Punjab and Another, 2025

The Court emphasized that the alleged offence outraging the modesty of a woman in a public setting — is inherently serious in nature.
It was not a case of a private dispute, such as a domestic or financial disagreement, but one that occurred in a public gathering (Dussehra mela).
Such conduct disrupts public order, threatens social morality, and affects the safety and dignity of women in public spaces.

The Court clarified that not every FIR can be quashed merely on the basis of a compromise.
In particular, Section 354 IPC (assault or criminal force on a woman) is non-compoundable and intended to safeguard women’s bodily autonomy and dignity.
Public offences involving outraging modesty, especially where force was used, cannot be resolved privately through settlements.

While the petitioners were young (aged 21, 25, and 25), the Court held that age alone does not mitigate the seriousness of the crime.
The law must equally apply to all, especially in offences that threaten the public's sense of security.
Reformation and leniency may be considered during sentencing, not at the stage of quashing serious allegations.

The complainant’s husband was allegedly attacked with a metal bracelet (kara) when he tried to protect his wife.
The act of causing hurt (Section 323 IPC), especially with a weapon-like object, added to the violent and deliberate nature of the offence.
It reflected group aggression and an intent to overpower, intimidate, and cause harm.

The Court made a clear legal distinction between:
- Private offences (e.g., matrimonial disputes, personal financial disagreements), which may be quashed on compromise, and
- Public offences, which impact social fabric and public morality, and are not suitable for such quashing.
Outraging modesty of a woman in public falls firmly in the latter category.

The Court reiterated that quashing of FIR under Section 528 BNSS (inherent powers) is discretionary, not a matter of right.
Each case must be evaluated individually, considering:
- The seriousness of the allegations,
- The public interest involved,
- The stage of the proceedings, and
- Whether compromise negates the social harm caused by the offence.

Monthly Magazine

Monthly Magazine MAY

✅ Ashok Kumar Jain v. State of Gujarat & Anr., 2025

✅ Sri Malakappa & Ors. v. IFFCO Tokio General Insurance Co. Ltd. & Anr., 2025

✅ K.R. Suresh v. R. Poornima & Ors., 2025

✅ M/S J N REAL ESTATE VERSUS SHAILENDRA PRADHAN & ORS., 2025

✅ Aman Bhatia vs State (GNCT of Delhi), 2025

✅ Raju @ Umakant vs. The State of Madhya Pradesh, 2025

✅ P. Kumarakurubaran v. P. Narayanan & Ors., 2025

✅ Santosh Devi v. Sunder, 2025

✅ Harjinder Singh v. The State of Punjab & Anr., 2025

✅ Muruganandam v. Muniyandi (Died) through LRs., 2025

✅ RENUKA PRASAD VERSUS THE STATE, 2025

✅ State of Lokayuktha Police, Davanagere v. C B Nagaraj, 2025

✅ MA v. Superintendent of Police, 2025

✅ M/s Celestium Financial v. A Gnanasekaran, 2025

✅ STATE OF RAJASTHAN v. GOPAL & ORS., 2025

✅ JKB v. KSB, 2025

✅ Thangavel v. The State, 2025

✅ Rakhi Sadhukhan v. Raja Sadhukhan, 2025

✅ BATLANKI KESHAV (KESAVA) KUMAR ANURAG VERSUS STATE OF TELANGANA & ANR., 2025

✅ Vedpal Singh Tanwar v. Directorate of Enforcement, 2025

✅ Manish Agarwal v. State of Orissa & Anr., 2025

✅ Agniraj & Others vs. State, 2025

✅ Sachin vs. State of Maharashtra, 2025

✅ State (Through CBI) vs. Eluri Srinivasa Chakravarthi & Others, 2025

✅ Mohd Maqbool Mir v. Ghulam Ahmad Pahloo, 2025

✅ Padman Bibhar v. State of Odisha, 2025

✅ Dashrath Patra v. State of Chhattisgarh, 2025

✅ Sameer Sandhir v. Central Bureau of Investigation, 2025

✅ K. Umadevi v. Government of Tamil Nadu, 2025

✅ Vijaya Bank & Anr. Vs. Prashant B Narnaware

✅ XXX v. State of Punjab and Another, 2025

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