List of Current Affairs

Source: Supreme Court  

Why in News? 

Recently, Justices Vikram Nath and Prasanna B Varale held that the existence of civil disputes does not justify quashing of criminal proceedings when a prima facie case of fraud and misappropriation is made out. 

• The Supreme Court held this in the matter of Kathyayini v. Sidharth P.S. Reddy & Ors. (2025). 

What was the Background of Kathyayini v. Sidharth P.S. Reddy & Ors., (2025) Case? 

• Kathyayini is the daughter of K.G. Yellappa Reddy and Jayalakshmi, who had eight children together - three sons (Sudhanva Reddy, Guruva Reddy, and Umedha Reddy) and five daughters (Lalitha, Jayashree, Rita, Bhavani, and Kathyayini). The respondents Sidharth P.S. Reddy and Vikram P.S. Reddy are sons of Sudhanva Reddy, making them Kathyayini's nephews. 
• Kathyayini's parents jointly purchased land measuring 19 guntas at Dodda Thogur, Bengaluru through a registered sale deed dated 17th February 1986. Her father K.G. Yellappa Reddy acquired this property using proceeds from the sale of certain ancestral properties. Both parents have since passed away. 
• The Bengaluru Metro Rail Corporation Limited acquired the family land, awarding total compensation of Rs. 33 crores. Kathyayini believed this substantial amount would be distributed equitably among all eight children of her parents. 
• Kathyayini discovered that her elder brother Sudhanva Reddy and his sons (the respondents) had allegedly orchestrated a criminal conspiracy to deprive her and her sisters of their rightful shares. The alleged fraudulent scheme involved: 
• Creating a fabricated family tree dated 18th January 2011 by allegedly bribing village accountant Narasimhaiah. This document showed only the three sons as heirs, completely excluding all five daughters. 
• Preparing an allegedly fake partition deed dated 24th March 2005, dividing the land only among the male heirs - Sidharth P.S. Reddy, Vikram P.S. Reddy, Guruva Reddy, and Umedha Reddy. 
• Based on these allegedly forged documents, the brothers claimed and received Rs. 1.80 crores from the Metro compensation. Subsequently, a total of Rs. 27 crores was released and credited to accounts of Sidharth P.S. Reddy, Vikram P.S. Reddy, Umedha Reddy, and Ashok Reddy. 
• The fraud came to light when Sudhanva Reddy, in a dispute with his son Prajwal Reddy (from his second wife), revealed the truth about the fabricated partition deed. He wrote to the Managing Director of Bengaluru Metro Rail Corporation stating that the partition deed was fabricated by his brothers and sons. This led to KIADB stopping further payments and depositing Rs. 5.59 crores with the trial court. 
• Upon learning of the fraud on 6th October 2017, Kathyayini confronted her brothers, who allegedly threatened to eliminate her. She filed complaints on 14th November 2017 and 20th November 2017 (jointly with sister Jayashree), leading to FIRs being registered against the accused parties. 
• Kathyayini and her sister Jayashree filed civil suits seeking partition of family properties, equal share in compensation, and declaration that the 2005 partition deed is void. Another civil suit was filed seeking an injunction against withdrawal of compensation amounts from bank accounts. 

What were the Court’s Observations? 

• The Supreme Court observed that a prima facie case for criminal conspiracy and cheating exists against the respondents. The court noted that they, along with their uncles, attempted to defraud their aunts by creating forged documents with the motive to gain the entire monetary award while bypassing the appellant and her sisters. 
• The Supreme Court found that the Karnataka High Court erroneously relied upon the Sub-Registrar's statement regarding the genuineness of the partition deed dated 24th March 2005. The court emphasized that this statement had not been subjected to cross-examination, making it unwise to rely on unverified testimony to ascertain the document's genuineness. 
• The court observed that the High Court could not find justification to deny that respondents misrepresented the family tree. The court acknowledged that respondents were bound to disclose the names of all daughters of K.G. Yellappa Reddy and Jayalakshmi in the family tree, and considering that both documents were used to gain monetary compensation, their genuineness must be put to trial. 
• The Supreme Court held that no bar exists against prosecution if offences punishable under criminal law are made out against parties to a civil suit. The court emphasized that criminal law and civil law can run side by side, as the two remedies are not mutually exclusive but coextensive, differing in their content and consequence. 
• The court reiterated that criminal law aims to punish offenders who commit offences against persons, property, or the State, while civil remedies address wrongdoing through different mechanisms. The pendency of civil proceedings on the same subject matter involving the same parties provides no justification to quash criminal proceedings if a prima facie case exists. 
• The court observed that the long chain of events - from creating a family tree excluding daughters, preparing a partition deed among only sons and grandsons, and distributing compensation among respondents - was sufficient to conclude active effort by respondents to reap benefits from the land in question. The alleged threats to the appellant and her sisters further affirmed the respondents' motive. 
• The Supreme Court concluded that all factors suggest a criminal trial is necessary to ensure justice to the appellant. The court emphasized that criminal proceedings must continue to their logical end when prima facie cases are established, regardless of parallel civil disputes. 

What is a Prima Facie Case ? 

• Definition and Concept of Prima Facie Case: 
  • A prima facie case refers to evidence that, on first appearance or on the face of it, establishes sufficient grounds to support a legal claim or charge. In criminal law, it means there exists sufficient evidence which, if unrebutted, would warrant a conviction.  
  • The term literally means "at first sight" or "on first appearance" and represents the minimum threshold of evidence required to proceed with criminal prosecution. 
• Standard for Establishing Prima Facie Case: 
  • Courts do not require proof beyond reasonable doubt at the prima facie stage. Instead, they examine whether there exists reasonable suspicion or probable cause to believe that an offence has been committed by the accused. 
  • The evidence need not be conclusive but must be sufficient to raise a reasonable presumption of guilt that warrants further investigation and trial. 

Why is it Crucial in Criminal Proceedings Despite Pending Civil Disputes? 

• Judicial Approach to Prima Facie Determination: 
  • Courts adopt a cautious approach when determining whether to quash criminal proceedings at the prima facie stage.  
  • They recognize that premature termination of criminal cases can deny justice to victims and undermine the rule of law.
• Burden of Proof at Prima Facie Stage: 
  • At the prima facie stage, the prosecution need not prove guilt beyond reasonable doubt. Instead, they must demonstrate reasonable grounds for suspicion that the accused committed the alleged offences.  
  • This lower threshold ensures that meritorious cases proceed to trial where evidence can be properly examined.
• Protection Against Abuse of Process: 
  • While courts protect against frivolous or malicious prosecutions, they also safeguard against premature dismissal of cases that merit full investigation. 
  • The prima facie standard strikes a balance between protecting accused persons from harassment and ensuring that genuine cases receive proper adjudication. 
• Implications for Case Management: 
  • The principle of continuing criminal proceedings despite civil disputes has significant implications for case management and judicial efficiency. 
  • It prevents accused persons from using civil litigation as a shield to escape criminal liability.
• Prevention of Forum Shopping: 
  • This principle prevents parties from manipulating the legal system by filing civil suits to create grounds for quashing criminal proceedings. 
  • It maintains the integrity of both civil and criminal justice systems by ensuring they operate independently.
• Ensuring Comprehensive Justice: 
  • By allowing concurrent proceedings, the legal system ensures that all aspects of wrongdoing are addressed appropriately.  
  • Victims receive both criminal justice through punishment of offenders and civil justice through compensation for damages. 

Case Laws

• K. Jagadish v. Udaya Kumar G.S. and Another (2020): 
  • The Supreme Court relied on this precedent which established that the same set of facts may give rise to both civil and criminal remedies, and availing civil remedy does not preclude criminal proceedings.
• Pratibha Rani v. Suraj Kumar and Another (1985): 
  • This case established that criminal law and civil law can run side by side as the two remedies are not mutually exclusive but coextensive, differing in their content and consequence.
• Kamaladevi Agarwal v. State of W.B. and Others (2001): 
  • This precedent reinforced that pendency of civil proceedings cannot be grounds for quashing criminal proceedings, and criminal cases must proceed according to prescribed procedures under the Code of Criminal Procedure. 

Source: Madras High Court 

Why in News? 

Recently, Justice Anand Venkatesh held that denying temple entry on the basis of caste is an affront to dignity and violates the rule of law, warranting action under the Tamil Nadu Temple Entry Authorisation Act, 1947. 

• The Madras High Court held this in the matter of Venkatesan v. The District Collector and Others. (2025). 

What was the Background of Venkatesan v. The District Collector and Others. (2025) Case? 

• This case originated from a petition filed by Venkatesan before the Madras High Court. The petitioner sought judicial intervention to secure temple entry and participation rights for members of his community at the Arulmigu Puthukudi Ayyanar Temple in Ariyalur district. 
• Venkatesan approached the court requesting directions to be issued to several authorities, including the District Collector of Ariyalur, the Revenue Divisional Officer, and the Assistant Commissioner of Hindu Religious and Charitable Endowments (HR&CE).  
• The specific relief sought was to permit members belonging to his community to participate in the temple car festival scheduled to be held at the temple. 
• The petitioner also sought permission for his community members to worship at the temple and conduct other religious rituals without any caste-based restrictions.  
• The case arose due to alleged discrimination preventing certain community members from accessing the temple and participating in religious festivities. 
• During the proceedings, the HR&CE Department informed the court that the particular temple in question was not under its administrative control or jurisdiction.  
• This clarification led to the court directing its orders specifically to the District Collector and Revenue Divisional Officer, who had territorial jurisdiction over the area. 

What were the Court’s Observations? 

• Justice Anand Venkatesh made several significant observations regarding caste-based discrimination in temple entry. The court observed that preventing individuals from entering temples based on their caste constitutes a serious affront to human dignity and cannot be tolerated in a nation governed by the rule of law. 
• The court noted that caste and community distinctions are human constructs, while divinity remains neutral and universal. The judge observed that restricting persons from offering prayers solely because they belong to Scheduled Caste communities represents a grave violation of their fundamental dignity. 
• The court emphasised that such discriminatory practices constitute an offence against the principles of equality and justice enshrined in the constitutional framework. The judge observed that no person should face restrictions in accessing places of worship based on their caste identity. 
• The court highlighted the provisions of Section 3 of the Tamil Nadu Temple Entry Authorisation Act 1947, observing that this legislation explicitly grants every Hindu, regardless of caste or sect, the right to enter Hindu temples and offer worship. The court noted that the Act provides for legal action against those who prevent such entry. 
• The court observed that this legislation was enacted following sustained struggles by various leaders who championed the cause of universal temple entry. The judge noted that the law was specifically designed to eliminate disabilities imposed on certain classes of Hindus regarding temple access. 
• The court directed that appropriate legal action should be taken against any person who prevents Scheduled Caste community members from participating in temple festivals, treating such acts as punishable offences under the law. 

What are the Legal Provisions Referred? 

Constitutional Provisions: 

• The right to equality under Article 14 of the Constitution of India, 1950 (COI) prohibits discrimination based on caste in accessing public places of worship. 
• Article 25 guarantees freedom of religion and the right to practice religious activities without caste-based restrictions. 
  • Article 25(1) gives people the freedom to practise, profess, and propagate their religion which is subject to public order, morality, and health.   
  • Article 25(2) allows the state to regulate economic, financial, political, or secular activities linked to religious practices and to enact laws for social welfare, reform, and opening Hindu religious institutions to all classes of Hindus.  
    • Hence, the issue of regulating secular aspects of religious practice is distinct from providing access to worship. 
• Article 17 of the Constitution abolishes untouchability and makes its practice in any form a punishable offence. 

Case Laws: 

Shirur Mutt v. Commissioner, Hindu Religious Endowments, Madras (1954): 

• Religious institutions have autonomous management rights under Article 26(d). 
• State can regulate religious institution administration within constitutional limits. 
• Established precedents for religious freedom and property rights protection. 

Ratilal Panachand Gandhi v. State of Bombay (1954): 

• Religious practices are integral parts of religion deserving constitutional protection. 
• Protection extends only to essential religious practices, not peripheral activities. 
• State can regulate administration of religious trust properties. 

Pannalal Bansilal Pitti vs. State of Andhra Pradesh (1996): 

• Upheld laws abolishing hereditary rights over temple management. 
• Religious reform laws need not apply uniformly across all religions. 
• Hereditary temple succession is not an essential religious practice. 

Stanislaus v. State of Madhya Pradesh (1977): 

• Right to propagate religion under Article 25 excludes right to convert others. 
• Upheld constitutional validity of anti-conversion laws. 
• Distinguished between spreading beliefs and coercive conversion. 

Source: Supreme Court 

Why in News? 

Recently Justices Sanjay Karol and Joymalya Bagchi of the Supreme Court observed that "exclusion of females from inheritance is unreasonable and discriminatory" while allowing women in a tribal family equal rights as men in a dispute relating to succession. 

• The Supreme Court held this in the matter of Ram Charan & Ors. v. Sukhram & Ors. (2025). 

What was the Background of Ram Charan & Ors. v. Sukhram & Ors. (2025) Case? 

• The appellants were the legal heirs of a Scheduled Tribe woman named Dhaiya, who sought a share in the property of her maternal grandfather. 
• The male heirs from the family opposed the claim, asserting that under tribal customs, women were excluded from inheritance. 
• The case involved ancestral property of a tribal family where female heirs were being denied their rightful share. 
• The trial court, first appellate court, and High Court had all rejected the appellants' claim, stating that the appellants failed to prove a custom permitting female inheritance. 
• The courts below held that since the appellants could not establish a positive custom allowing female inheritance, the tribal woman was not entitled to a share. 
• The male heirs contended that tribal customs excluded women from succession rights, though they could not prove any such prohibitive custom. 

What were the Court's Observations? 

• A bench of Justices Sanjay Karol and Joymalya Bagchi observed that "There appears to be no rational nexus or reasonable classification for only males to be granted succession over the property of their forebears and not women." 
• The Supreme Court held that "customs too, like the law, cannot remain stuck in time and others cannot be allowed to take refuge in customs or hide behind them to deprive others of their right." 
• The Court noted that though the Hindu Succession Act is not applicable to Scheduled Tribes, it doesn't mean that tribal women are automatically excluded from inheritance. 
• The Court emphasized that it needs to be seen whether there exists any prevailing custom restricting the female tribal right to share in the ancestral property. 
• The Supreme Court found that gender-based denial of inheritance rights violates Article 14 of the Constitution of India, 1950 (COI), which guarantees equality before the law. 
• The Court held that in the absence of any specific tribal custom or codified law prohibiting women's rights, courts must apply "justice, equity, and good conscience." 

What was the Court's Reasoning on Burden of Proof? 

• The Court observed that the courts below erred in requiring the appellants to prove a custom permitting inheritance by women. 
• Instead, the opposing party should prove a bar to such inheritance rather than requiring positive proof of permissive custom. 
• The Court noted that "no such custom of female succession could be established by the appellant-plaintiffs, but nonetheless it is also equally true that a custom to the contrary also could not be shown in the slightest, much less proved." 
• In the absence of any prohibitive custom, equality must prevail, and denial of rights solely on gender basis is unconstitutional. 

What is the Constitutional Framework for Gender Equality? 

Article 14 - Right to Equality: 

• Article 14 of the Constitution guarantees equality before the law and equal protection of the laws to all persons within the territory of India. 
• The provision prohibits arbitrary discrimination and ensures that similar cases are treated similarly. 
• Gender-based denial of inheritance rights constitutes a violation of Article 14 as there is no rational basis for such discrimination. 
• The Court held that there is no rationale in allowing inheritance only to the male heirs when no prohibitive custom exists. 

Article 15 - Prohibition of Discrimination on grounds of religion, race, caste, sex or place of birth: 

• Article 15(1) states that the State shall not discriminate against any person on grounds of religion, race, caste, sex or place of birth. 
• The Court observed that denying succession to female tribal members in the absence of prohibitory custom violates Article 15. 
• Articles 38 and 46 point to the collective ethos of the Constitution in ensuring that there is no discrimination against women. 
• The constitutional framework emphasizes gender equality and prohibits sex-based discrimination in all spheres including property rights.