April 2025 Indian Court Judgments: Important Rulings from the Supreme Court of India and Bombay High Court

1. Accelerate Productx Ventures Pvt Ltd Vs State of Maharashtra and Ors

 Citation: Accelerate Productx Ventures Pvt Ltd Vs State of Maharashtra and Ors (01.04.2025 – Bombay High Court); Writ Petition No 1169 of 2025; Decided by Hon’ble Justices G.S Kulkarni and Advait M Sethna

 Ratio: The Bombay High Court held that law does not prohibit convenience stores from remaining open 24×7 as Maharashtra Shops and Establishments Act 2017 imposes no operating hours restrictions on such establishments beyond those specified for liquor-serving venues bars and formerly theatres now deregulated. Petitioner’s “The New Shop” convenience store registered under 2017 Act qualifies for unrestricted 24×7 operations absent specific notification under Section 11 regulating its class with State notification dated 19 December 2017 limiting hours solely for permit rooms beer bars dance bars hookah parlours discotheques liquor shops and 31 January 2020 amendment freeing theatres cinemas. Police lacked jurisdiction to orally coerce closure post 10-11pm mistaking food sales for eating house restrictions constituting arbitrary action absent statutory basis. State reply affirmed no additional permissions or prohibitions apply to convenience stores facilitating public convenience economic growth employment without law and order disruption. Petition allowed mandating non-interference with the petitioner’s Hadapsar Pune store operations post 10-11pm.

 2. P Kumarakurubaran Vs P Narayanan and Ors

 Citation: P Kumarakurubaran Vs P Narayanan and Ors (29.04.2025 – Supreme Court of India); Civil Appeal No 5622 of 2025 arising out of SLP (C) No 2549 of 2021; Decided by Hon’ble Justices J B Pardiwala and R Mahadevan

 Ratio: The Supreme Court said no to the Madras High Court decision that threw out the lawsuit early, saying it came too late. The court explained that you cannot reject a case at the start when there is a real fight about when the plaintiff first learned of the problem with the sale deed. Plaintiff got land from the government in 1974, built a house, gave dad a power of attorney on 6 January 1978, only for building work and deals, not for selling. Dad sold to granddaughter (defendant 1) on 10 Oct 1988 without permission, plaintiff found out much later, complained to police about land grab on 9 Dec 2011, asked for land papers in his name on 24 Feb 2012, objected to registry and building permit, then filed suit on 3 Dec 2014 to declare himself owner, cancel sale gift power deeds, and stop defendants. The trial court said let it go to a full hearing to check facts like when he really knew and what power dad had. The High Court was incorrect to assume that time began from the sale date, disregarding the claim of late discovery. Court said time limit under Article 59 is 3 years from when you know not from sale date if fraud or no notice, and its mix of fact and law so take plaint story as true no proof yet (cited Daliben Chhotanben Shakti Bhog Salim cases, if when knew is argued then full trial needed read whole plaint do not pick lines only reject if time bar clear from plaint alone). Dad misused power, and fraud claims also need a hearing. Suit value is fine since it declares rights, plus prevents others from declaring alone. Appeal allowed, High Court 3 Sep 2020 order in CRP NPD 131/2018 set aside, trial court 4 Oct 2017 order bringing back suit OS 310/2014 for full hearing, no High Court ideas affect it, no costs, other requests closed​.

 3. Angadi Chandranna Vs Shankar and Ors

 Citation: Angadi Chandranna Vs Shankar and Ors (22.04.2025 – Supreme Court of India); Civil Appeal No 5401 of 2025 arising out of SLP (C) No 6799 of 2022; Decided by Hon’ble Justices J B Pardiwala and R Mahadevan

 Ratio: The Supreme Court held that shares allotted in HUF partition become self-acquired property of the recipient, thereby losing their joint family character, enabling absolute disposal without the consent of coparceners, absent proof of a nucleus, blending of intention, or legal necessity. Karnataka High Court erred re-appreciating evidence under Section 100 CPC restoring trial court decree granting plaintiffs partition of suit Sy No 93 despite First Appellate Court reversal as post 09.05.1986 partition among Defendant 1 C Thippeswamy C Eshwarappa Thippeswamy’s A-schedule share sold to Defendant 1 vide 16.10.1989 sale deed, Rs15000 using personal loan from DW3 repaid via 4-acre sale with no blending evidence, will recitals irrelevant to suit property. Plaintiffs failed to prove the nucleus from Defendant 1’s C-schedule income of Rs 10,000 in cash, as grandmother funds, merely existing, with insufficient strict proof required. The presumption shifts only on the nucleus yielding acquisition aid, as per Deivanai Ammal Mulla Yudhishter Govindbhai Rohit Chauhan. Sale to Defendant 2  on 11.03.1993, Rs 20000 valid family benefit marriage expenses necessity no fraud inconsistencies in PW1, PW2 partition deed prevails over oral claims doctrine of blending inapplicable absent voluntary abandonment clear intention waiver. Appeal allowed, restoring the First Appellate Court decree, parties bear costs.

 4.Jharkhand Urja Utpadan Nigam Ltd and Anr Vs Bharat Heavy Electricals Ltd

 Citation: Jharkhand Urja Utpadan Nigam Ltd and Anr Vs Bharat Heavy Electricals Ltd (15.04.2025 – Supreme Court of India); Petition for Special Leave to Appeal (C) No 9580 of 2025; Decided by Hon’ble Justices J B Pardiwala and R Mahadevan

 Ratio: The Supreme Court held that Order XX Rule 1 CPC provision mandating Commercial Courts issue judgment copies via email or otherwise within 90 days post-arguments is directory not mandatory with limitation for Section 13(1A) Commercial Courts Act 60-day appeal commencing from open court pronouncement date parties duty-bound diligently apply for certified copies absent active procurement efforts during limitation defeating Act’s speedy high-value dispute resolution object. Jharkhand High Court correctly rejected 301-day delay condonation IA in Commercial Appeal No 1 of 2025 against Commercial Court Ranchi decree awarding BHEL Rs26.59 Cr recovery MSME award basis as petitioners neglected applying certified copy post-09.10.2023 pronouncement until 30.08.2024 despite counsel’s presence, Legal Department monitoring duty, negligence, inaction, unlike Housing Board Sagufa Ahmed consumer/special statute contexts. Government instrumentalities are ineligible, with a relaxed yardstick as per the Government of Maharashtra. Long delays beyond 60+60 days are exceptional, only in bona fide, non-negligent cases, as per Section 5 of the Limitation Act. Strict timelines prevail, with no automatic extension; mere non-communication results in SLP dismissal.