The year 2025 proved to be a watershed moment in Indian jurisprudence. The Supreme Court of India delivered several judgments that not only resolved long-standing legal controversies but also refined constitutional principles, procedural safeguards, and statutory interpretations. This editorial examines five of the most significant decisions rendered in 2025, presented in the chronological and thematic sequence in which they have come to dominate academic discussions and judicial service examinations.
No. 1. Amlesh Kumar v. State of Bihar
Voluntary Narco-Analysis and the Boundaries of Articles 20(3) and 21
The Supreme Court’s ruling in Amlesh Kumar v. State of Bihar revisited one of the most sensitive areas of criminal investigation: the constitutional validity of scientific techniques such as narco-analysis, polygraph, and brain-mapping tests.
Reaffirming the 2010 landmark ruling in Selvi v. State of Karnataka, the Court unanimously held that administering these tests without the informed, voluntary, and revocable consent of the individual violates the protection against self-incrimination under Article 20(3) and the right to privacy and bodily integrity under Article 21. Results obtained involuntarily remain inadmissible as substantive evidence.
Yet the 2025 judgment introduced important clarifications:
- Discoveries made pursuant to statements during such tests (e.g., recovery of a weapon) continue to be admissible under Section 27 of the Indian Evidence Act, 1872, provided the recovery is independently corroborated.
- Statements made during the test cannot form the sole or primary basis of conviction; they retain only corroborative value.
- Most notably, an accused may voluntarily request to undergo narco-analysis to demonstrate innocence. Such a request, however, does not constitute an absolute or indefeasible right. Courts retain the discretion to permit or deny it after evaluating the totality of circumstances, including the necessity, reliability, and potential for abuse of the process.
This nuanced balancing act preserves the Selvi prohibition on state-compelled testing while recognising limited consensual use in exceptional cases. For students of criminal law and constitutional law, Amlesh Kumar is indispensable reading on the evolving interface between scientific investigation and fundamental rights.
No. 2 & 3. State of Tamil Nadu v. Governor of Tamil Nadu and the Subsequent Presidential Reference (Fourteen Questions Case)
Redefining the Constitutional Role of Governors and the President in the Law-Making Process
Few constitutional disputes in recent years have attracted as much public and academic attention as the confrontation between state governments and Governors over reserved bills. The twin judgments of 2025 – State of Tamil Nadu v. Governor of Tamil Nadu (March 2025) and the subsequent advisory opinion on the President’s Reference under Article 143 (November 2025) – have substantially clarified (and in some respects recalibrated) the law under Articles 200, 201, 163, and 142.
The controversy arose when the Governor of Tamil Nadu kept multiple bills passed by the state legislature in abeyance for years and subsequently referred them to the President without disposing of them. The Supreme Court, in its first judgment, held:
- Indefinite inaction by a Governor on bills amounts to unconstitutional interference with the state’s legislative functioning.
- Governors are bound to act on the aid and advice of the Council of Ministers (Article 163) except in narrowly defined areas of discretion.
- Exercising extraordinary powers under Article 142, the Court granted “deemed assent” to ten long-pending bills, effectively converting them into law.
The March verdict triggered widespread debate about separation of powers. In response, the President of India sought an advisory opinion under Article 143, posing fourteen questions on the scope of gubernatorial and presidential powers.
A five-judge bench delivered a comprehensive clarification in November 2025:
- While indefinite delay remains unconstitutional and is subject to judicial review, no rigid statutory or constitutional timeline can be prescribed for Governors or the President. Action must be taken within a “reasonable time”, the determination of which depends on the facts of each case.
- The extraordinary remedy of “deemed assent” granted in the Tamil Nadu case was declared a one-time exercise under Article 142 and cannot be treated as precedent. The judiciary cannot substitute itself for the Governor or President in the ordinary course.
- Governors retain independent discretion in deciding whether to assent, withhold assent, or reserve a bill for presidential consideration. The aid and advice of the Council of Ministers, while influential, is not binding in these spheres. Consequently, the ultimate decision of the Governor is not amenable to routine judicial review.
Taken together, the two judgments restore a degree of executive discretion to constitutional heads while retaining the ultimate power of judicial intervention in cases of manifest arbitrariness. They represent required reading for any student appearing for examinations involving federalism and separation of powers.
No. 4. Gayatri Balaswamy v. Novus Technologies Pvt. Ltd.
The Power to Modify (Rather than Merely Set Aside) Arbitral Awards
Indian arbitration law witnessed a historic shift with the Constitution Bench decision (4:1) in Gayatri Balaswamy. For decades, courts and scholars remained divided on whether Indian courts, when seized of a challenge under Section 34 of the Arbitration and Conciliation Act, 1996, possess the power to modify an arbitral award or are restricted to either upholding or setting it aside.
The majority judgment authoritatively held that Indian courts always possessed the power of modification under Sections 34 and 37, read with the overarching mandate of doing complete justice (Article 142). What the Court did in 2025 was to delineate the precise circumstances in which such power may be exercised, thereby removing uncertainty and preventing unnecessary remittal or fresh arbitration.
The permissible grounds for modification are now clearly limited to:
- Application of the doctrine of severability – where an identifiable part of the award is vitiated but the remainder can stand independently.
- Correction of clerical, typographical, or computational errors.
- Rectification of errors in the computation or award of interest (including cases where interest was erroneously omitted).
- Limited remedial alterations necessary to achieve complete justice under Article 142, provided they do not involve re-appreciation of evidence or merits.
Justice K.V. Viswanathan delivered a powerful minority opinion, arguing that conferring a general power of modification undermines the finality that is the cornerstone of arbitration and deviates from the UNCITRAL Model Law philosophy embedded in the 1996 Act. Nevertheless, the majority view now constitutes binding precedent.
The practical consequence is profound: parties will no longer be compelled to restart lengthy arbitration proceedings merely because of minor errors. Commercial certainty has been significantly enhanced.
No. 5. Mehnoor Fatima v. Vishwesh Infrastructure Pvt. Ltd.
Title, Registration, and the Nemo Dat Principle in Indian Property Law
In a judgment destined to be quoted in every sale deed caveat henceforth, the Supreme Court reiterated the ancient maxim nemo dat quod non habet – no one can transfer a better title than they themselves possess.
The petitioners had purchased large parcels of land that had already vested in the State decades earlier under the 1975 urban land ceiling legislation. Despite duly executed and registered sale deeds, the Court held that registration alone cannot cure a fundamental defect in title. Section 49 of the Registration Act, 1908 makes it abundantly clear that an unregistered document that is compulsorily registrable cannot affect immovable property or confer any valid title.
Key takeaways from Mehnoor Fatima:
- Registration perfects an otherwise valid transfer; it does not create title where none exists.
- Buyers bear the burden of due diligence to verify that the vendor possesses transferable title. Reliance on registration entries alone is insufficient.
- Writ jurisdiction under Article 226 cannot be invoked to protect possession founded on transactions that are void ab initio.
The judgment serves as a stark reminder to practitioners and citizens alike that the sanctity of public records and statutory vesting cannot be defeated by private agreements followed by registration.
Conclusion
The five judgments examined above represent more than isolated disputes; they reflect the Supreme Court’s continuing effort to balance competing constitutional values – individual liberty against investigative necessity, federal comity against executive autonomy, commercial efficiency against procedural rigour, and transactional certainty against statutory land reforms.
For law students and judicial services aspirants in 2025 and beyond, mastery of these decisions is non-negotiable. They are likely to feature prominently in preliminary screenings, mains answers, and interview discussions for years to come. Understanding not only what the Court held, but why it chose one interpretive path over another, will separate outstanding candidates from the merely competent.
As the judiciary navigates an increasingly complex socio-economic landscape, judgments such as these reaffirm that constitutional interpretation remains a dynamic, context-sensitive enterprise – one that demands both doctrinal rigour and practical wisdom.
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