List of Current Affairs

Source: Supreme Court 

Why in News? 

Recently, the Supreme Court of India in the matter of Chirag Sen and Another v. State of Karnataka and Another. (2025) has quashed criminal proceedings against Olympian badminton players for alleged age fraud, holding that continuation of such proceedings would amount to abuse of process when competent authorities had already examined and closed the matter. 

What was the Background of Chirag Sen and Another v. State of Karnataka and Another. (2025) Case? 

• The case arose from a complaint dated 27th June 2022 lodged by Shri Nagaraja M.G. before the Police Inspector, High Grounds Police Station, Bengaluru, alleging that Chirag Sen and Lakshya Sen had misrepresented their date of birth to qualify for tournaments in the Under-13 and Under-15 categories. 
• It was alleged that the players had gained wrongful selection and monetary rewards through this misrepresentation, with their parents—and coach conspiring to forge and fabricate records. 
• When no FIR was registered on the initial complaint, Respondent No. 2 filed a private complaint under Section 200 the Criminal Procedure Code, 1973 (CrPC) before the VIII Additional Chief Metropolitan Magistrate, Bengaluru, registered as P.C.R. No. 14448/2022. 
• By order dated 16th November 2022, the learned Magistrate directed investigation under Section 156(3) of CrPC following which FIR No. 194/2022 was registered on 01St December 2022 invoking Sections 420, 468, 471, and 34 of the Indian Penal Code, 1860 (IPC).  
• The appellants challenged the proceedings through three separate writ petitions before the High Court of Karnataka under Articles 226 and 227 of the Constitution of India, 1950 (COI) read with Section 482 of CrPC, which were dismissed by a common judgment.  
• The appellants contended that identical allegations had been raised nearly a decade earlier and were subjected to scrutiny by competent statutory authorities including the Sports Authority of India (SAI), Central Vigilance Commission (CVC), and Education Department of Karnataka. 
• The CVC had observed on 06th February 2018 via Official Memorandum No.017/EDN/038/370760 that Birth Certificate and 10th Class Certificate are final, and accordingly SAI closed the case against the appellants in view of the CVC recommendation. 
• The entire complaint was based on a solitary 1996 GPF nomination form which allegedly showed different birth dates, but this form was neither authenticated nor subjected to forensic scrutiny and did not even bear Lakshya Sen's name (who was not born in 1996). 
• The complainant's grievances commenced only after his daughter was denied admission to the Badminton Academy in 2020, with the FIR being registered in 2022 after a gap of nearly eight years. 
• The players had undergone bone ossification and dental examination tests at government-run hospitals including AIIMS, Delhi, and the findings supported the birth years as recorded in official documents.

What were the Court’s Observations?

• The bench comprising Justices Sudhanshu Dhulia and Aravind Kumar observed that the present case falls squarely within the category of exceptional circumstances warranting interference at the threshold to prevent abuse of the criminal process. 
• Justice Aravind Kumar noted that the entire edifice of the complaint is built upon a solitary document - the 1996 GPF nomination form - which is not only bereft of authentication but also fails to establish any fraudulent intent or act attributable to the appellants. 
• The Court observed there is an evident pattern of vindictiveness that permeates the complaint, as the complainant's grievances commenced only after his daughter was denied admission to the academy in 2020, with the delay, absence of new material, and apparent personal grudge collectively undermining the bona fides of the complaint. 
• The Court emphasized that the allegations are based on conjecture and surmises and are manifestly intended to malign the appellants, with no dishonest inducement or gain demonstrated, nor any wrongful loss caused to the State or third party. 
• Justice Kumar stated that allowing proceedings to continue despite institutional clearance by SAI, Badminton Authority of India, and CVC would cause grave prejudice to the appellants' sporting careers and undermine public confidence in investigative findings. 
• Regarding the applicability of criminal provisions, the Court observed that the complaint does not disclose basic elements required to attract Sections 420, 468, and 471 IPC, with no allegation that appellants forged documents or knowingly used forged documents as genuine. 
• The Court noted that no person or authority was dishonestly induced to part with property or confer a benefit, and even taking the GPF form at face value, it was neither demonstrated how the players (who were minors at the time) or their coach had any role in its preparation. 
• The Court referenced Pepsi Foods Ltd. v. Special Judicial Magistrate (1998), to reiterate that summoning an accused in a criminal proceeding is a serious matter and should not be undertaken lightly, stating that "the present case is illustrative of how criminal process may be misused to achieve a collateral objective under the guise of legality." 
• The Court held that compelling sportspersons of national standing who have maintained an unblemished record and brought distinction to the country through sustained excellence, having represented India in international tournaments and earned multiple accolades including medals at Commonwealth Games and BWF international events, to undergo criminal trial in absence of prima facie material would not subserve the ends of justice. 
• Consequently, the Supreme Court allowed the appeals, set aside the High Court's order and quashed all further proceedings

What are the Legal Provisions in Relation to Age Fabrication in Sports? 

About:  

Age fraud in sports means the act where an athlete misrepresents their age in sports events so that they can have an advantage when it comes to age-restricted competitions. In other words, age fraud means and constitutes the action of deliberately misrepresenting one's age while producing fabricated or fake documentation starting from birth certificates, school certificates, PAN cards, and Aadhaar cards, to passports. 

Reasons for Age Fabrication in Sports: 

The reasons for committing age fraud can include: 

• Gaining the opportunity to participate in age-restricted competitions. 
• Taking advantage of physical maturity over younger athletes. 
• Accessing various opportunities like scholarships, government jobs, and reserved seats in educational institutes. 
• Sometimes all of this results, and aid in even breaking national records. 

Existing Legal Framework to Deal with Age Fabrication: 

National Code Against Age Fraud in Sports (NCAAFS) 2010: 

This code of NCAAFS was introduced by the Ministry of Youth Affairs and Sports (MYAS) in the year 2010, to uphold and substantiate core values in sports, including honesty, fair play, and team spirit and eventually eliminating the act of committing age fraud. 

Key Provisions of NCAAFS 2010: 

• Rule 4.2: National Sports Federations may lose recognition or government funding if they violate the code. 
• Rule 5: All athletes must undergo mandatory medical tests (physical, dental, radiological, MRI/CT) for age verification; an I-Card is issued based on the results. 
• Rule 8: The I-Card is the sole valid age proof for age-group events and remains valid throughout the athlete's sports career. 
• Rule 7.4: The government will bear the cost of these medical examinations.

Sports Federation Specific Measures:

Source: Supreme Court  

Why in News? 

Recently, the bench of Chief Justice BR Gavai and Justice AG Masih has held that when determining compensation for compulsorily acquired land, courts must consider the highest bona fide sale transaction among available exemplars rather than averaging different sale prices. 

• The Supreme Court held this in the matter of Manohar and Others v. State of Maharashtra & Others. (2025). 

What was the Background of Manohar and Others v. State of Maharashtra & Others. (2025) Case? 

• The appellants were farmers who owned agricultural land measuring 16 hectares and 79 acres situated at Village Pungala in Parbhani District, Maharashtra. 
• The state government acquired their land in the 1990s under the Maharashtra Industrial Development Act, 1961 for establishing an industrial area near Jintur town.  
• The Land Acquisition Officer initially awarded compensation of merely Rs. 10,800 per acre in 1994, which the farmers considered grossly inadequate for their prime agricultural land. 
• Dissatisfied with the meager compensation, the landowners filed a reference under Section 18 of the Land Acquisition Act, 1894 seeking enhancement of the awarded amount. 
• The Reference Court in 2007 increased the compensation to Rs. 32,000 per acre but refused to consider a 1990 sale exemplar showing much higher value of Rs. 72,900 per acre for similar land in the vicinity. 
• The farmers' land was strategically located just 2 kilometers from Jintur town, adjacent to the Nashik-Nirmal State Highway, and had significant non-agricultural potential. 
• The Reference Court had before it ten sale exemplars of similar lands, with prices ranging from Rs. 25,000 to Rs. 72,900 per acre, but chose to ignore the highest transaction without providing adequate reasoning.  
• The Bombay High Court in 2022 upheld the Reference Court's decision, prompting the farmers to approach the Supreme Court.  
• The case provides the fundamental issue of whether courts can arbitrarily exclude the highest bona fide sale transaction when determining fair market value for acquired land. 

What were the Court’s Observations? 

• The Supreme Court observed that it is well-settled law that compensation payable to landowners is determined by reference to the price which a seller might reasonably expect from a willing purchaser in the market.  
• The court noted that when several exemplars of similar land transactions exist, the highest bona fide transaction should ordinarily be considered rather than taking an average of different sale prices.  
• The apex court found that the land in question was situated at a prime location, being adjacent to Jintur town with market facilities, dairy business and other basic amenities available within 2 kilometers. 
• The court observed that the acquired land was located near the T-point of Nashik-Nirmal State Highway and possessed significant non-agricultural potential, with a percolation tank providing sufficient water supply just opposite to the property.  
• The Supreme Court noted that the Reference Court had erroneously ignored the sale exemplar dated 31st March 1990 showing Rs. 72,900 per acre without recording any reasons for excluding this bona fide transaction.  
• The court observed that averaging of sale prices is permissible only when several sales of similar lands have marginal price variations within a narrow bandwidth. 
• The Supreme Court found that the High Court had made contradictory observations, first acknowledging that the Reference Court did not consider the highest sale exemplar, then incorrectly stating that it had been considered.  
• The court observed that the sale instances at serial numbers 9 and 10 from Jintur showed prices of Rs. 61,500 and Rs. 60,000 respectively, which were closer to the highest exemplar than to the lower-priced transactions used for averaging. 
• The apex court concluded that the farmers deserved compensation based on the highest sale exemplar, with only a reasonable 20% deduction for bulk transaction, resulting in enhanced compensation of Rs. 58,320 per acre. 

What are the Legal Provisions Referred? 

Land Acquisition Act, 1894: 

• Section 18   
  • This provision allows landowners to file a reference for enhancement of compensation when they are dissatisfied with the amount awarded by the Land Acquisition Officer.  
  • The farmers in this case successfully invoked this section to challenge the inadequate compensation of Rs. 10,800 per acre initially awarded in 1994. 
• Section 4  
  • This section deals with the publication of preliminary notification for land acquisition, and the court held that land must be valued with reference to its condition at the time of this notification. 
  • The market value determination date is crucial as it fixes the point in time for assessing comparable sale transactions in the vicinity. 
• Section 51A  
  • This section provides that certified copies of documents have presumptive value as evidence of transactions recorded therein.  
  • The court relied on this provision to accept the sale exemplars as valid evidence since the state did not produce any rebuttal evidence to challenge their authenticity. 
• Section 23(1-A) - 
  • This provision deals with solatium (additional amount) payable over and above the market value as compensation. The Supreme Court directed that all consequential benefits under this section be granted to the appellants along with the enhanced compensation amount. 
• Section 23(2) 
  • This section provides for additional amount for compulsory acquisition, and the court ensured that farmers receive this statutory benefit. The provision recognizes that compulsory acquisition deserves higher compensation than voluntary sale transactions between willing parties. 
• Section 28  
  • This provision deals with interest payable on compensation amount from the date of taking possession until actual payment.  
  • The Supreme Court specifically directed that interest on enhanced compensation be calculated and paid under this section to compensate for delayed payment.

Source: Allahabad Court  

Why in News? 

Recently, the bench of Chief Justice Arun Bhansali and Justice Kshitij Shailendra has held that a claim for interim relief under Section 9 of the Arbitration and Conciliation Act, 1996 cannot be granted when approached after an unreasonable delay of 27 years without justifiable explanation. 

• The Allahabad High Court held this in the matter of Messrs Law Publishers & Another v. Sri Virender Sagar & 3 Others (2025). 

What was the Background of Messrs Law Publishers and another v. Sri Virender Sagar and 3 others. (2025) Case? 

• The dispute arose from a family-run partnership business called 'Messers Law Publishers' at Allahabad, which was engaged in publishing and sale of law books. 
• The partnership was initially formed in 1976 with multiple family members as partners.  
• After the death of partner B.L. Sagar in April 1996, a new partnership deed was executed on 16th April 1996.  
• Smt. Vibha, claiming to be a sleeping partner since 1976, alleged that other partners were attempting to alienate the firm's immovable properties.  
• She sent a legal notice in October 2023 and subsequently filed an application under Section 9 of the Arbitration Act seeking interim relief.  
• The respondents contested her claim, alleging that she had retired from the partnership in 1996 and transferred her share to another partner.  
• They also disputed the genuineness of the partnership deed relied upon by the appellant, terming it forged and fabricated. 

What were the Court’s Observations? 

• The Court observed that the appellant's claim suffered from fatal flaws regarding the essential ingredients required for granting interim injunctive relief. 
• The Court noted that there was an unexplained delay of 27 years in approaching the court, during which the appellant remained completely inactive despite being a businessperson running similar operations in Delhi.  
• The Court found that being family members, it was inconceivable that the appellant was unaware of the partnership's ongoing business activities.  
• The Court applied the doctrine of laches, citing that "delay defeats equities" and that unreasonable delay disentitles a person from obtaining discretionary equitable relief.  
• Regarding the three essential conditions for interim relief, the Court held that : 
  • no prima facie case was established due to the prolonged unexplained delay, 
  • the balance of convenience did not favour the appellant as she had no involvement in the business operations,  
  • there was no irreparable injury since her monetary rights, if established, could be compensated even if properties were alienated.  
• The Court concluded that the appellant's "surprise appearance" immediately when properties were allegedly being transferred, after 27 years of silence, demonstrated the absence of a genuine claim deserving interim protection. 

What is Section 9 of the Arbitration and Conciliation Act, 1996? 

• Section 9 empowers courts to grant interim measures of protection before, during, or after arbitral proceedings but before enforcement of the arbitral award. 
• Any party to an arbitration agreement can approach the court seeking interim relief for various protective measures during the arbitration process. 
• The court can appoint guardians for minors or persons of unsound mind specifically for the purposes of arbitral proceedings under this provision. 
• Courts are authorized to preserve, provide interim custody, or order sale of goods that form the subject-matter of the arbitration agreement. 
• The provision allows courts to secure the amount in dispute in arbitration to ensure effective enforcement of the final award. 
• Courts can order detention, preservation, or inspection of any property related to the arbitration dispute and authorize entry into premises for necessary observations or experiments. 
• Interim injunctions and appointment of receivers can be granted by courts under this section to maintain the status quo during arbitration. 
• Once an arbitral tribunal is constituted, courts cannot entertain Section 9 applications unless circumstances exist that render Section 17 remedies (tribunal's interim measures) inefficacious. 
• If interim measures are granted before arbitration commences, the arbitral proceedings must begin within 90 days of the court order, or within such extended time as the court may determine.