1). Supreme Court: Direct Master-Servant Relationship Must Be Established for Employment Claims

Case Background

The dispute arose when Raj Kumar Mishra, a Junior Assistant at CBSE, alleged that his services were illegally terminated through an oral order in 1999.

1. Conciliation proceedings failed, and the matter was referred to the Central Industrial Tribunal, Kanpur.
2. The tribunal found that Raj Kumar had worked for CBSE and was entitled to ₹1 lakh compensation, but denied reinstatement.
3. Raj Kumar challenged this in the Allahabad High Court, arguing that since his termination violated Section 25(F) of the Industrial Disputes Act, 1947, he should be reinstated.
4. The High Court found the tribunal's decision arbitrary and sent the case back to the Labour Court for fresh hearing.
5. CBSE appealed to the Supreme Court, arguing that Raj Kumar was never its direct employee but was hired through a contractor, M/s Manpower Security Services.

Issues Before the Court

1. Was Raj Kumar an employee of CBSE, or was he engaged through a contractor?
2. Can supervisory and jurisdictional control alone establish a master-servant relationship?
3. Did the High Court err in remanding the case to the Labour Court?

Court Observations

Bench Composition

The case was heard by Justice Ahsanuddin Amanullah and Justice Prashant Kumar Mishra.

1. Master-Servant Relationship Must Be Established on Paper

• The Court ruled that for a person to claim employment under an organization, there must be a direct employer-employee relationship proven through proper documentation.
• In this case, the only document available showed that Raj Kumar was posted at different locations performing various tasks. This was not enough to prove he was directly employed by CBSE.

2. Supervisory Control Alone Does Not Prove Employment

• Raj Kumar argued that CBSE exercised control over his work, assigning him duties and transferring him between locations.
• However, the Court rejected this argument, stating that supervisory and jurisdictional control alone does not automatically create an employer-employee relationship.

3. CBSE Proved That Raj Kumar Was Hired Through a Contractor

• CBSE submitted bills from M/s Manpower Security Services, listing Raj Kumar as one of its workers.
• It also demonstrated that payments were made to the contractor, not directly to Raj Kumar.

4. No Need to Send Case Back to Labour Court

• The Supreme Court held that remanding the case to the Labour Court would be pointless, as Raj Kumar had failed to prove direct employment with CBSE.
• It ruled that had there been substantial evidence supporting his claim, it would not have interfered with the High Court’s order.

Court Rulings & Decisions

1. A master-servant relationship must be proven through clear documentation.
2. Supervisory control does not automatically create an employer-employee relationship.
3. CBSE correctly proved that Raj Kumar was engaged through a contractor.
4. The High Court's order remanding the case to the Labour Court was set aside.
5. No further legal orders were required, as the tribunal’s award had already been quashed.

Legal Provisions 

1. Industrial Disputes Act, 1947
   • Section 25(F) – Conditions for retrenchment of workmen.
2. Labour Laws related to Employer-Employee Relationship
3. Judicial Precedents on Master-Servant Relationships

Significance of the Judgment

1. Strengthens the Legal Requirement for Employer-Employee Claims
   • This ruling confirms that employment claims must be backed by proper documentation and not just supervisory control.
2. Clarifies Employer-Contractor-Employee Dynamics
   • If a worker is engaged through a contractor, the organization that avails their services is not automatically their employer.
3. Prevents Unjustified Employment Claims
   • The decision protects organizations from false claims of direct employment, ensuring that only genuine employees receive legal benefits.

The Supreme Court ruled that for a person to claim employment, there must be clear documentation proving a direct employer-employee relationship. It rejected the argument that supervisory control alone establishes employment and upheld CBSE’s defense that Raj Kumar was hired through a contractor.

As a result, the Court quashed the High Court’s order to reconsider the case and ruled in favor of CBSE. This judgment reinforces the importance of clear legal contracts in employment disputes.

Case Title: Joint Secretary, Central Board Of Secondary Education vs Raj Kumar Mishra

Case No: SPECIAL LEAVE PETITION(CIVIL)NO. 19648 OF 2023

2). Supreme Court Dismisses Writ Petition Challenging Allahabad High Court's Order:  Grabbing Breasts and Breaking Pyjama String Not Attempt to Rape

Case Background

In this case, two accused, Pawan and Akash, were alleged to have grabbed the breasts of an 11-year-old girl, broken the string of her pyjama, and tried to drag her beneath a culvert. The trial court treated this as an attempt to rape or penetrative sexual assault and framed charges under Section 376 (rape) read with Section 18 (attempt to commit an offence) of the Protection of Children from Sexual Offences (POCSO) Act, 2012.

However, the Allahabad High Court ruled that these acts did not amount to an attempt to rape. Instead, it directed that the accused be charged under Section 354-B IPC (assault or use of criminal force with intent to disrobe) and Sections 9/10 of the POCSO Act (aggravated sexual assault). This decision sparked widespread public criticism.

A writ petition was filed in the Supreme Court challenging the High Court’s order. However, the petitioner was not directly involved in the criminal case.

Issues of the Case

1. Whether the Allahabad High Court was correct in reducing the charges from attempt to rape to aggravated sexual assault under the POCSO Act.
2. Whether a writ petition under Article 32 of the Constitution was maintainable to challenge a High Court's judgment.

Supreme Court Observations

Bench Composition

The case was heard by a two-judge bench of Justice Bela M. Trivedi and Justice P.B. Varale.

Court Proceedings

• When the petitioner’s lawyer began arguing by referring to the slogan "Beti Padhao, Beti Bachao," Justice Bela M. Trivedi interrupted, stating that the Court would not allow “lecture baazi” (unnecessary speeches).
• The Court also noted that neither the petitioner nor the Advocate on Record (AOR) was present in court.

Supreme Court Ruling

• The writ petition under Article 32 was dismissed as it was not maintainable.
• The Court clarified that a High Court's decision should be challenged through a Special Leave Petition (SLP) under Article 136, not through a writ petition under Article 32.
• The petitioner had wrongly named the Union Government, Ministry of Women and Child Welfare, and the Allahabad High Court as respondents.

Allahabad High Court's Legal Reasoning

The High Court made a distinction between preparation and attempt to commit an offence:

• It held that the acts of the accused did not amount to an “attempt” to rape because the prosecution failed to prove that the crime had gone beyond preparation.
• The Court relied on the principle that an attempt requires a greater degree of determination than mere preparation.

Legal Provisions 

1. Article 32 of the Constitution – Provides the right to approach the Supreme Court for enforcement of fundamental rights. However, it cannot be used to challenge High Court decisions.
2. Article 136 of the Constitution – Allows filing of a Special Leave Petition (SLP) to challenge High Court decisions in the Supreme Court.
3. Section 376 IPC & Section 18 POCSO Act – Related to rape and attempt to commit penetrative sexual assault.
4. Section 354-B IPC & Sections 9/10 POCSO Act – Related to assault or use of criminal force with intent to disrobe and aggravated sexual assault.

Significance of the Case

• This case clarifies that a writ petition under Article 32 cannot be used to challenge High Court orders and that an SLP under Article 136 is the correct legal remedy.
• It highlights the judicial interpretation of “attempt” in criminal law, reinforcing that an attempt requires a clear move beyond preparation.
• The case has generated a wider public debate on how courts interpret sexual assault laws and the threshold for attempt to rape.

The Supreme Court dismissed the writ petition as it was not maintainable. The Allahabad High Court’s decision to reduce the charges remains in effect, though it remains a topic of public and legal debate. If the decision is to be challenged, it must be done through the proper legal channel (SLP under Article 136).

Case Details: ANJALE PATEL v. UNION OF INDIA AND ORS.|Diary No. 15118-2025

3). Supreme Court Sets Up National Task Force to Address Mental Health Concerns in Colleges Amid Rising Student Suicides 

Case Background

This case was filed by the parents of two students from IIT Delhi who allegedly died by suicide due to caste-based discrimination and academic pressure. The petitioners argued that their children faced institutional harassment, which was ignored by the authorities. They also claimed that despite repeated complaints, the police failed to register an FIR (First Information Report), forcing them to seek legal intervention.

The Supreme Court took note of increasing suicides in Higher Educational Institutions (HEIs) across India, including IITs, National Institutes of Technology (NITs), and Indian Institutes of Management (IIMs). The Court highlighted concerns such as caste discrimination, ragging, academic pressure, and financial stress as major causes of student suicides.

Issues of the Case

1. Whether higher educational institutions have a legal duty to take action when students face discrimination, harassment, or mental health crises.
2. Whether institutions must register an FIR in cases of student suicides.
3. Whether the existing legal and institutional framework is sufficient to prevent suicides in HEIs.
4. How to improve student mental health and prevent future suicides in educational institutions.

Supreme Court Observations

Bench Composition

The case was heard by a two-judge bench of Justice J.B. Pardiwala and Justice R. Mahadevan.

Key Observations

• Universities are not just places of learning; they must ensure students' well-being and safety.
• There is an urgent need for proactive intervention in student mental health cases.
• Institutions must register an FIR if a student suicide occurs on campus.
• The current legal and institutional framework is inadequate in preventing suicides and addressing student mental health concerns.

Supreme Court Ruling

1. Formation of National Task Force

The Court directed the formation of a National Task Force to tackle mental health issues and prevent student suicides in HEIs.

Composition of the Task Force

The 10-member Task Force will be chaired by Former Supreme Court Judge, Justice S. Ravindra Bhat. Other members include:

1. Dr. Alok Sarin – Psychiatrist, Sitaram Bhartia Institute, New Delhi
2. Prof. Mary E. John – Former Director, Centre for Women's Development Studies
3. Mr. Arman Ali – Executive Director, National Centre for Promotion of Employment for Disabled People
4. Prof. Rajendar Kachroo – Founder, Aman Satya Kachroo Trust
5. Dr. Aqsa Shaikh – Professor, Hamdard Institute of Medical Sciences, New Delhi
6. Dr. Seema Mehrotra – Professor of Clinical Psychology, NIMHANS
7. Prof. Virginius Xaxa – Visiting Professor, Institute for Human Development, New Delhi
8. Dr. Nidhi S. Sabharwal – Associate Professor, Centre for Policy Research in Higher Education
9. Ms. Aparna Bhat – Senior Advocate (Amicus Curiae)

2. Role and Responsibilities of the Task Force

The Court directed the Task Force to submit:

• An interim report within 4 months
• A final report within 8 months

The Task Force will:

• Identify causes of student suicides (ragging, caste/gender-based discrimination, academic pressure, financial stress, etc.).
• Review existing policies related to student welfare and mental health.
• Recommend legal reforms to strengthen protections under the SC/ST (Prevention of Atrocities) Act, 1989, and other relevant laws.
• Conduct surprise inspections in universities to assess student support systems.
• Develop a national action plan for mandatory mental health services in HEIs.

3. Mandatory FIR Registration in Student Suicide Cases

The Court ruled that all educational institutions must register an FIR if a student suicide occurs on campus.

4. State and Central Government’s Role

The Court directed the Chief Secretaries of all States and Union Territories to:

• Appoint a nodal officer (not below the rank of Joint Secretary) in the Department of Higher Education.
• Ensure all concerned authorities cooperate with the Task Force.
• Provide necessary data and assistance.

The Union Government, State Governments, and Universities were ordered to fully cooperate with the Task Force.

5. Authority of the Task Force

The Task Force can:

• Conduct surprise inspections at any HEI.
• Make additional recommendations beyond its initial mandate.
• Seek opinions from student unions, university representatives, and state governments.
• Use questionnaires to gather student feedback.

6. Financial Allocation for Task Force Operations

The Court directed the Union of India to deposit ₹20 lakhs within two weeks as initial funding for the Task Force.

The Ministry of Education will bear further financial and administrative responsibilities.

7. Future Court Proceedings

• The case will remain part-heard until the Task Force submits its interim report.
• The Supreme Court registry will notify the matter after four months for further hearings.

Legal Provisions 

1. SC/ST (Prevention of Atrocities) Act, 1989 – Protects students from caste-based discrimination.
2. Indian Penal Code (IPC) – Includes laws against harassment, ragging, and abetment of suicide.
3. University Grants Commission (UGC) Regulations – Guidelines on student welfare and anti-ragging measures.

Significance of the Case

• First Supreme Court-mandated Task Force on Student Mental Health.
• Establishes legal responsibility of universities in student suicide cases.
• Brings mental health into focus as a key concern for HEIs.
• Strengthens student protection laws and ensures better accountability from educational institutions.
• Encourages direct student participation in policymaking.

The Supreme Court has taken a historic step to address student suicides by creating a National Task Force. This case highlights the urgent need for mental health awareness, student safety measures, and legal accountability in HEIs. The Court’s directives will likely lead to stronger student support systems and policy reforms in higher education.

Case Title: AMIT KUMAR & ORS. VERSUS UNION OF INDIA & ORS.

4). Supreme Court Urges Liberal Stand on Condoning Delay in Cases Requiring Merit Examination

Case Background

This case involved a dispute over a piece of land classified as grazing land under the ownership of the Madhya Pradesh Government and allocated for public purposes.

The Appellant claimed ownership over the land and won the case at the trial court, which declared him the rightful owner. However, the State Government challenged this decision by filing a belated second appeal before the High Court after a delay of 1537 days (over four years).

The High Court condoned the delay and allowed the second appeal, reasoning that the case involved government land allocated for public use, and therefore, the appeal should be heard on merits rather than be dismissed on technical grounds of delay.

The Appellant then challenged this decision before the Supreme Court, arguing that the delay should not have been condoned.

Issues of the Case

1. Whether courts should adopt a liberal approach in condoning delays when the merits of the case require consideration.
2. Whether the High Court was justified in allowing the State’s appeal despite a 1537-day delay.
3. Whether a limitation period should strictly bar a case or be relaxed in certain situations.

Supreme Court Observations

Bench Composition

The case was heard by a two-judge bench comprising:

• Justice Sudhanshu Dhulia
• Justice Ahsanuddin Amanullah

Key Observations

• Delay cannot be condoned without sufficient cause. However, if a case has strong merits, it should not be dismissed merely on limitation grounds.
• Courts should take a liberal approach when the limitation period obstructs substantial justice.
• Since the land in dispute belonged to the government and was allocated for public purposes, the State’s claim needed proper examination.

Supreme Court Ruling

1. Upholding the High Court’s Decision

The Supreme Court agreed with the High Court and ruled that the delay should not prevent substantial justice in cases involving important public interest issues, such as government land disputes.

2. Condonation of Delay in Cases Involving the State

• The Court referred to past precedents where delays were condoned in cases involving the State.
• Case Reference:
  • Ramchandra Shankar Deodhar v. State of Maharashtra (1974) – Emphasized that substantial justice is more important than procedural technicalities.
  • Sheo Raj Singh v. Union of India (2023) – Advocated for a liberal approach when the State is the appellant.

3. Public Interest Consideration

• The Court noted that the disputed land was in the State’s possession and had been allocated for public purposes(Youth Welfare Department and Collectorate).
• Since the land was not in the appellant’s possession, the State’s claim could not be ignored.

4. Dismissal of the Appeal

• The Supreme Court dismissed the appellant’s case, ruling that the High Court rightly condoned the delay and allowed the second appeal to be heard on merits.

Legal Provisions 

1. Limitation Act, 1963 – Governs the time limits within which cases must be filed in courts.
2. Civil Procedure Code (CPC), 1908 – Provides guidelines for appeals and condonation of delay in filing cases.
3. Government Land Laws – Related to ownership and public use of government property.

Significance of the Case

• Clarifies that technical grounds like limitation should not override substantial justice.
• Strengthens the approach that State appeals should not be rejected purely on delay if public interest is involved.
• Provides relief to the government in cases where administrative delays occur in filing appeals.
• Sets a precedent for allowing appeals even after long delays if they involve public land or other important public interest issues.

The Supreme Court reaffirmed that substantial justice must take priority over procedural delays. While delays should not be excused without reason, they should not be used to dismiss cases that require serious examination—especially in government land disputes. The ruling ensures that public interest cases are not unfairly rejected due to procedural limitations.

Case Title: INDER SINGH VERSUS THE STATE OF MADHYA PRADESH

5). Supreme Court: Consumers Can Seek Relief in Consumer Forum Despite Arbitration Agreement

Case Background

This case was about a dispute over the sale of a mortgaged flat and the payment of the balance sale amount.

• The Respondent (Consumer) had purchased a flat with a housing loan of ₹17,64,644 from ICICI Bank.
• Mubarak Vahid Patel (Borrower) wanted to buy the flat for ₹32,00,000.
• The Appellant (Citicorp Finance) gave the borrower a loan of ₹23,40,000.
• Since the flat was mortgaged with ICICI Bank, the borrower asked Citicorp Finance to pay ₹17,80,000 directly to ICICI Bank to release the flat.

Consumer Complaint

• The Respondent filed a complaint before the National Consumer Disputes Redressal Commission (NCDRC).
• He claimed that Citicorp Finance failed to pay him the balance sale amount of ₹13,20,000.
• He argued that a tripartite agreement existed between him, the borrower, and Citicorp Finance, under which the entire sale consideration should have been paid to him.

NCDRC’s Decision

The NCDRC ruled in favor of the Respondent, directing Citicorp Finance to:

1. Refund ₹13,20,000 with interest.
2. Pay ₹1,00,000 as litigation costs.

Appeal to Supreme Court

• Citicorp Finance challenged the NCDRC’s ruling before the Supreme Court.
• They argued that the tripartite agreement contained an arbitration clause, which meant the dispute should be settled through arbitration, not in the Consumer Forum.

Issues of the Case

1. Can a consumer be forced into arbitration if an agreement contains an arbitration clause?
2. Does the consumer have the right to choose between arbitration and the Consumer Forum?
3. Was the tripartite agreement legally valid and enforceable?

Supreme Court Observations

Bench Composition

The case was heard by a two-judge bench:

• Justice Sudhanshu Dhulia
• Justice Ahsanuddin Amanullah

Key Observations

• A consumer cannot be forced to opt for arbitration just because an agreement contains an arbitration clause.
• Consumers have the exclusive right to choose between arbitration and the Consumer Forum.
• The existence of the tripartite agreement itself was doubtful, making the arbitration clause inapplicable.

Supreme Court Ruling

1. Arbitration Clause Cannot Override Consumer Rights

The Court referred to the cases:

• Emaar MGF Land Ltd. v. Aftab Singh (2019) 12 SCC 751
• M. Hemalatha Devi v. B. Udayasri (2024)

The Court ruled that:

• Consumer disputes are non-arbitrable unless the consumer voluntarily opts for arbitration.
• The Consumer Protection Act is a welfare law, and consumer disputes should be resolved in public forums, not private arbitration.
• The consumer’s choice is more important than the arbitration clause in the agreement.

2. Validity of the Tripartite Agreement Was Doubtful

• The Supreme Court questioned the existence of the tripartite agreement.
• Citicorp Finance was not a consumer under the Consumer Protection Act, so it could not demand arbitration.

3. Consumer Protection Act Prevails Over Arbitration Agreement

The Court reiterated that:

• A consumer cannot be forced into arbitration just because of an arbitration clause.
• Consumer disputes should be heard in the Consumer Forum unless the consumer willingly chooses arbitration.
• Even if an arbitration clause exists, the consumer’s decision takes priority.

4. Appeal Dismissed

The Supreme Court upheld the NCDRC’s decision, confirming that:

• Citicorp Finance must refund ₹13,20,000 with interest.
• Citicorp Finance must pay ₹1,00,000 as litigation costs.

Legal Provisions 

1. Consumer Protection Act, 2019 – Protects consumers’ rights and provides public dispute resolution forums.
2. Arbitration and Conciliation Act, 1996 – Governs arbitration agreements and dispute resolution through arbitration.
3. Contract Law Principles – Related to the enforceability of contractual arbitration clauses.

Significance of the Case

• Strengthens consumer rights by confirming that consumers cannot be forced into arbitration.
• Clarifies that arbitration clauses in agreements do not override the Consumer Protection Act.
• Ensures that consumers have the freedom to choose between arbitration and the Consumer Forum.
• Prevents companies from forcing consumers into arbitration through unfair contract terms.

The Supreme Court reaffirmed that consumer rights are more important than arbitration agreements. A consumer cannot be forced into arbitration and has the right to approach the Consumer Forum. This ruling protects consumers from unfair contract terms and ensures that consumer disputes are resolved in public forums rather than private arbitration panels.

Case Title: M/S CITICORP FINANCE (INDIA) LIMITED VERSUS SNEHASIS NANDA

6). Supreme Court: No Need to Name Person as Accused to Retain Seized Property Under PMLA Section 8(3)

Case Background

This case involved a challenge to the retention of electronic items, documents, and cash under the Prevention of Money Laundering Act, 2002 (PMLA).

• In 2017, the Enforcement Directorate (ED) registered an Enforcement Case Information Report (ECIR)against the respondent and others for alleged money laundering.
• During the search, the ED seized various electronic items, documents, and cash.
• The Adjudicating Authority later passed an order under Section 8(3) of the PMLA confirming the retention of the seized property on April 4, 2018.
• Meanwhile, a complaint was filed under Section 44 of the PMLA, and the Special Court took cognizance of the case on February 19, 2018.

Respondent’s Appeal

• The respondent challenged the retention order before the Appellate Authority and the High Court.
• The High Court held that, under the amended Section 8(3)(a) of PMLA (effective from April 19, 2018), the retention order would lapse after 90 days.
• Dissatisfied with this decision, the ED appealed to the Supreme Court.

Issues of the Case

1. Does Section 8(3)(a) of PMLA apply even if the person is not named as an accused in the complaint?
2. Was the High Court correct in applying the amended provision, which introduced a 90-day time limit for retention?
3. Can seized items be retained beyond 90 days if proceedings under PMLA are still pending?

Supreme Court Observations

Bench Composition

The case was heard by a two-judge bench:

• Justice Abhay S. Oka
• Justice N. Kotiswar Singh

Key Observations

1. A person need not be named as an accused for Section 8(3)(a) to apply.
   • The Court clarified that Section 8(3)(a) applies as long as a complaint under Section 3 of PMLA is pending.
   • It is not necessary that the person affected by the retention order be named as an accused in the complaint.
   • The Court emphasized that cognizance is taken of the offense, not of specific individuals.
2. The correct version of Section 8(3)(a) applies based on the date of the order.
   • The Court held that the version of Section 8(3)(a) applicable from May 14, 2015, to April 18, 2018, governed the case.
   • This version did not impose a 90-day limit on retention—instead, retention continued until the conclusion of the proceedings.
3. Even if the amended version (after April 19, 2018) was applied, the retention order remains valid.
   • The Court noted that the amended provision allowed retention for 90 days OR until proceedings under PMLA were pending.
   • Since the complaint was still pending, the retention order did not automatically expire after 90 days.

Supreme Court Ruling

1. High Court and Appellate Authority decisions set aside.
   • The Court overruled the High Court’s interpretation that the retention order automatically expired after 90 days.
2. Retention order of April 4, 2018, restored.
   • The Supreme Court reinstated the order passed by the Adjudicating Authority, allowing the ED to retain the seized items.
3. Retention will continue until the complaint is disposed of.
   • The Court clarified that the retention order remains valid until the complaint under Section 44 of PMLA is finally decided.

Legal Provisions 

1. Section 3 of PMLA – Defines the offense of money laundering.
2. Section 4 of PMLA – Provides punishment for money laundering.
3. Section 8(3)(a) of PMLA – Governs the retention of seized property during pending proceedings.
4. Section 17(4) of PMLA – Deals with seizure and freezing of property during investigation.
5. Section 44 of PMLA – Provides for filing of complaints and trial of offenses under the Act.

Significance of the Case

• Clarifies that retention of property under PMLA does not require a person to be named as an accused.
• Ensures that enforcement agencies can retain evidence until the conclusion of proceedings, even if an amended law introduces time limits.
• Prevents premature return of seized items in ongoing money laundering cases.
• Strengthens PMLA’s enforcement by ensuring that crucial evidence remains available for trial.

The Supreme Court upheld the ED’s power to retain electronic items, documents, and cash under PMLA. It ruled that a person need not be named as an accused for retention to continue and that the retention order remains valid as long as proceedings under PMLA are pending. The decision reinforces the enforcement mechanism under PMLA and prevents premature return of seized items.

Case Title: Union of India v. J.P. Singh, CRIMINAL APPEAL No.1102 of 2025