Guarding Liberty, Marking Limits: The Supreme Court’s defining judgments of 2025 A year of strong interventions on arrest, dignity, and inclusion—tempered by missed opportunities on free speech doctrine and structural constitutional questions

21, Apr 2026 | Tanya Arora

Across 2025, the Supreme Court of India has delivered a series of judgments that, taken together, reflect a marked reassertion of constitutional values in the face of expanding state power, procedural rigidity, and systemic exclusion. These decisions do not merely resolve individual disputes; they collectively illuminate a judicial approach that is increasingly attentive to the lived realities of rights violations—whether in the context of criminal procedure, free speech, federal governance, or the rights of historically marginalised communities. What emerges from this body of work is a consistent effort to restore the primacy of the Constitution as a living document, one that must actively shape institutional behaviour rather than remain confined to abstract guarantees.

A defining thread running through these judgments is the Court’s insistence that procedural safeguards are substantive rights, particularly in the criminal justice system. In cases involving arrest and detention, the Court has unequivocally rejected attempts by investigative agencies to dilute constitutional protections through technicalities or statutory rigidity. Whether by holding that failure to produce an arrested person within 24 hours vitiates custody, or by mandating that the grounds of arrest must be meaningfully communicated under Article 22(1), the Court has reaffirmed that liberty cannot be compromised by procedural manipulation. This approach is further strengthened by its recognition that violations of Articles 21 and 22 override even stringent statutory frameworks such as the Prevention of Money Laundering Act, 2002 and the Narcotic Drugs and Psychotropic Substances Act, 1985. By holding that bail must follow where constitutional violations are established, and by relaxing statutory barriers in cases of prolonged incarceration, the Court has sought to rebalance a system increasingly tilted in favour of the prosecution.

Closely linked to this is the Court’s renewed emphasis on fair trial as a non-negotiable constitutional guarantee. In expanding the disclosure obligations of the prosecution under the PMLA to include even un-relied upon documents, the Court recognised that equality before law cannot exist in conditions of informational asymmetry. Particularly in regimes that impose a reverse burden on the accused, the right to defend oneself becomes meaningful only when the accused is granted access to the full evidentiary landscape. This insistence on transparency signals a broader judicial commitment to ensuring that procedural law does not become an instrument of injustice.

At the same time, the Court has demonstrated a clear sensitivity to the dangers of over criminalisation and the misuse of law to stifle dissent and expression. In Imran Pratapgarhi v. State of Gujarat, the Court intervened to quash an FIR arising from a poem shared on social media, characterising the police action as mechanical and legally untenable. By clarifying the scope of preliminary inquiry under the Bharatiya Nagarik Suraksha Sanhita, 2023 and insisting on careful scrutiny in speech-related cases, the Court introduced an important procedural safeguard against the routine criminalisation of artistic and political expression. In doing so, it reaffirmed that the vitality of a democratic society depends on the protection of dissent, even when such expression is uncomfortable or unpopular.

Another notable feature of this year’s jurisprudence is the Court’s effort to translate formal equality into substantive inclusion, particularly for persons with disabilities and gender minorities. In expanding access to scribes for all disabled candidates—irrespective of benchmark disability—the Court dismantled arbitrary thresholds that had long excluded individuals from equal participation in competitive examinations. Similarly, in In Re- Recruitment of Judicial Services v. Registrar General of MP, it struck down exclusionary recruitment practices in the judiciary itself, recognising that structural barriers often operate through facially neutral rules. These decisions are grounded in the transformative mandate of the Rights of Persons with Disabilities Act, 2016 and aligned with international human rights standards, marking a decisive shift towards a rights-based, rather than medicalised, understanding of disability.

The Court’s engagement with gender justice this year has been equally expansive. By recognising maternity leave as an integral component of reproductive rights, it moved beyond a narrow service-law framework to situate women’s entitlements within the broader domain of dignity, autonomy, and equality. In parallel, its judgment affirming the right of nursing mothers to breastfeed in public and workplaces—while directing the creation of supportive infrastructure—reflects a holistic understanding of rights that encompasses both legal recognition and social acceptance. These rulings underscore that constitutional guarantees must respond to everyday realities, including caregiving, bodily autonomy, and entrenched social stigma.

Perhaps most significantly, the Court has also turned its attention to institutional accountability and constitutional governance. In its ruling on governor’s delay in assenting to state legislation, it firmly rejected the notion that constitutional authorities can exercise a “pocket veto” by inaction. By prescribing timelines, affirming the binding nature of ministerial advice, and even deeming Bills to have received assent, the Court intervened decisively to prevent constitutional paralysis. This judgment not only strengthens federal balance but also reinforces the principle that unelected authorities cannot frustrate the democratic will of elected legislatures.

Finally, the Court’s jurisprudence reflects a growing recognition of systemic discrimination and the need for enforceable equality. Its ruling on the denial of employment to a transwoman moves beyond individual relief to identify “omissive discrimination” by the State, thereby expanding the conceptual framework of equality law. By mandating institutional reforms and holding both public and private actors accountable, the Court has sought to bridge the gap between formal rights and their actual implementation—an approach that is critical for marginalised communities whose rights are often recognised in law but denied in practice.

Taken together, these judgments represent more than isolated affirmations of rights; they signal a broader judicial trajectory that seeks to reclaim constitutionalism in both spirit and practice. In an environment marked by executive overreach, procedural excess, and persistent inequalities, the Court’s interventions this year stand out for their clarity, coherence, and commitment to first principles. They reaffirm that the Constitution is not merely a constraint on power but a framework for justice—one that demands vigilance, empathy, and, above all, the courage to hold institutions accountable.

• Reasserting Liberty: Supreme Court curtails procedural evasion in PMLA arrests

On January 21, 2025, in a significant reaffirmation of procedural safeguards against coercive state power, the Supreme Court underscored that the constitutional mandate of producing an arrested person before a magistrate within 24 hours is non-negotiable—even in cases under the Prevention of Money Laundering Act, 2002 (PMLA). The case arose from a contested arrest by the Enforcement Directorate (ED), where the agency sought to justify its actions through a technical interpretation of the time of arrest. Rejecting this approach, the Court restored primacy to the substance of custody over its formal documentation, reinforcing that constitutional protections cannot be bypassed through administrative manoeuvring.

The facts revealed a troubling attempt to circumvent safeguards. The individual was detained at 11:00 AM on March 5, 2022, at IGI Airport pursuant to a Look Out Circular issued by the ED. However, the agency recorded the formal time of arrest as 1:15 AM on March 6, 2022, and argued that the production before a magistrate at 3:00 PM the same day fell within the permissible 24-hour window. The Court firmly rejected this contention, holding that custody effectively began at the time of initial detention. By doing so, it prevented investigative agencies from manipulating arrest timelines to evade constitutional scrutiny.

A bench comprising Justices Abhay S. Oka and Ujjal Bhuyan held that the failure to produce the detainee within 24 hours from the actual time of custody amounted to a clear violation of Article 22(2) of the Constitution. The judgment drew a direct link between this procedural breach and the broader guarantee of personal liberty under Article 21, emphasising that unlawful detention—however brief—strikes at the heart of constitutional governance. The Court’s reasoning reflects a rights-centric approach that resists diluting safeguards in the face of stringent special laws like the PMLA.

Importantly, the Court clarified that there is no inconsistency between the PMLA and Section 57 of the Code of Criminal Procedure, 1973, thereby affirming that the 24-hour rule applies with full force to PMLA arrests. This finding is crucial in a legal landscape where special statutes are often invoked to justify departures from ordinary procedural protections. By harmonising the PMLA with general criminal procedure, the Court ensured that the extraordinary powers of enforcement agencies remain tethered to constitutional discipline.

Perhaps most significantly, the Court held that once a violation of Articles 21 and 22 is established, the arrest itself stands vitiated, and the accused becomes entitled to bail as a matter of right. In such circumstances, the stringent “twin conditions” under Section 45 of the PMLA cannot be invoked to deny relief. This aspect of the ruling carries far-reaching implications: it places constitutional rights above statutory restrictions and affirms the judiciary’s duty to act as a bulwark against illegal detention. As such, the judgment stands out as a robust defence of personal liberty and a clear message that procedural safeguards are not mere formalities, but foundational to the rule of law.

• Liberty Over Delay: Supreme Court relaxes NDPS bail bar in face of prolonged incarceration

On January 29, 2025, in a crucial intervention addressing the intersection of stringent statutory regimes and constitutional liberty, the Supreme Court held that courts may grant bail to convicts under the Narcotic Drugs and Psychotropic Substances Act, 1985 even in the face of the restrictive conditions under Section 37, where prolonged incarceration and systemic delays render continued detention unjust. The ruling recognises that procedural delays in appellate hearings cannot be allowed to defeat the fundamental right to personal liberty, particularly when a significant portion of the sentence has already been served.

The case arose from an appeal filed by the Narcotics Control Bureau challenging a High Court order that had suspended the sentence of a convict sentenced to ten years’ imprisonment. The High Court had taken into account that the convict had already undergone approximately four and a half years of incarceration, and that the appeal was unlikely to be heard in the near future. Rejecting the NCB’s contention that bail could not be granted unless half the sentence had been completed, the Supreme Court refused to adopt a rigid or formulaic approach to liberty.

A bench comprising Justices Abhay S. Oka and Ujjal Bhuyan acknowledged that Section 37 imposes stringent conditions on the grant of bail in NDPS cases. However, it clarified that these statutory constraints cannot be applied in a manner that leads to manifest injustice. Where an appellate court is faced with a situation in which the convict has already undergone a substantial portion of the sentence and the appeal is unlikely to be heard before completion of the sentence, continued incarceration would effectively render the right to appeal meaningless.

The Court’s reasoning is firmly anchored in Article 21 of the Constitution, which guarantees the right to life and personal liberty. It held that denying bail solely on the basis of Section 37, in such circumstances, would amount to a violation of this fundamental right. This articulation is significant as it places constitutional guarantees above statutory limitations, reaffirming that even in cases involving serious offences, the justice system must remain responsive to the realities of delay and deprivation.

Ultimately, the judgment reflects a pragmatic and rights-oriented approach to criminal justice. By recognising that prolonged incarceration pending appeal can itself become punitive, the Court sought to prevent the erosion of fair trial rights through systemic delay. In doing so, it reinforces a broader constitutional principle: that the legitimacy of stringent laws must be balanced against the enduring imperative to protect individual liberty, making this ruling a noteworthy addition to the year’s “good judgments.”

• Breaking Barriers: Supreme Court expands scribe access beyond benchmark disability

In a significant step towards deepening the constitutional promise of equality, the Supreme Court on February 3, 2025 held that the right to a scribe in examinations cannot be restricted only to persons with “benchmark disabilities.” Building upon its earlier ruling in Vikas Kumar v. UPSC, the Court clarified that the requirement of a minimum 40% disability cannot be used as a threshold to deny necessary accommodations. The case arose from a petition filed by a candidate suffering from focal hand dystonia, who had been repeatedly denied the facility of a scribe despite clear judicial precedent.

A bench comprising Justices J. B. Pardiwala and R. Mahadevan reaffirmed that the principle of reasonable accommodation lies at the heart of equality jurisprudence under the Rights of Persons with Disabilities Act, 2016. The Court emphasised that denying a scribe or compensatory time to a candidate who genuinely requires it amounts to discrimination. In doing so, it rejected the artificial and exclusionary distinction between persons with disabilities and those with benchmark disabilities, noting that such classifications often defeat the very objective of inclusive participation.

The judgment is particularly important for its insistence that procedural frameworks must adapt to lived realities. Despite clear directions in earlier cases, including Avni Prakash v. NTA, examination bodies continued to deny accommodations on technical grounds, reflecting systemic inertia and lack of awareness. The Court took note of this persistent non-compliance and stressed that rights under the disability framework are not merely formal entitlements but require active facilitation through responsive institutional design.

Going beyond declaratory relief, the Court issued a comprehensive set of directions to the Ministry of Social Justice and Empowerment, directing it to revisit and revise its Office Memorandum of August 10, 2022. These directions aim to institutionalise accessibility—mandating uniform compliance across examination bodies, setting up grievance redressal mechanisms, extending the validity of scribe certificates, and ensuring sensitisation and training of officials. The emphasis was not only on access but also on dignity, autonomy, and meaningful participation in competitive examinations.

Ultimately, the judgment marks a decisive move towards substantive equality. By centring the doctrine of reasonable accommodation, the Court reaffirmed that equality is not achieved through rigid classifications but through enabling conditions that allow individuals to participate on fair terms. In recognising that barriers often arise from institutional design rather than individual limitation, the ruling strengthens the constitutional vision of inclusive education and equal opportunity, making it a clear candidate for a “good judgment” in the year’s judicial landscape.

• Due Process Reinforced: Supreme Court links right to be informed with immediate liberty

On February 7, 2025, in a strong reaffirmation of procedural safeguards against arbitrary arrest, the Supreme Court held that failure to inform an arrested person of the grounds of arrest strikes at the core of constitutional protections under Article 22(1). The Court emphasised that this right is not a mere formality but a substantive guarantee designed to enable the arrested individual to effectively challenge their detention. By foregrounding the communicative aspect of arrest, the judgment reinforces that due process begins at the very moment of deprivation of liberty.

A bench comprising Justices Abhay S. Oka and N. Kotiswar Singh delivered concurring opinions, both underscoring that the grounds of arrest must be conveyed clearly, effectively, and in a language understood by the accused. The Court rejected any mechanical or symbolic compliance, holding that the information must meaningfully impart the basic facts underlying the arrest. Significantly, it placed the burden of proving compliance squarely on the investigating agency, thereby shifting the balance in favour of the detained individual in cases of dispute.

The judgment also clarified the role of magistrates as constitutional gatekeepers. When an arrested person is produced for remand, it is incumbent upon the magistrate to independently verify whether the safeguards under Article 22(1) have been complied with. The Court made it clear that any violation of this mandate vitiates the arrest itself, rendering continued detention unlawful. In such circumstances, courts are duty-bound to order release or grant bail, irrespective of statutory restrictions that might otherwise limit judicial discretion.

Importantly, the Court went a step further to hold that even non-compliance with Section 50 of the Code of Criminal Procedure, 1973—which requires that a friend, relative, or nominated person be informed of the arrest—can render the detention illegal. This expands the protective ambit of procedural rights by recognising that access to legal recourse and protection against disappearance depend not only on informing the accused but also their support networks. The judgment thus situates arrest within a broader ecosystem of accountability and transparency.

Perhaps the most consequential aspect of the ruling is its categorical assertion that constitutional violations override statutory constraints on bail. Even where stringent legal frameworks seek to limit the grant of bail, they cannot stand in the face of a breach of Articles 21 and 22. Applying this principle, the Court set aside the High Court’s decision and ordered the immediate release of the petitioner. In doing so, it reaffirmed a foundational principle: that personal liberty cannot be subordinated to procedural shortcuts, and that the Constitution remains the ultimate safeguard against unlawful state action.

• Dignity in Care: Supreme Court affirms breastfeeding as a constitutional right

In a progressive and deeply humanising judgment, the Supreme Court on February 19, 2025, addressed both structural and societal barriers faced by nursing mothers, holding that breastfeeding in public and workplaces must not be stigmatised. The Court’s intervention went beyond infrastructure, foregrounding dignity and social attitudes as integral to the realisation of rights. By invoking the fundamental duty under Article 51A(e), it called upon citizens to actively reject practices that undermine the dignity of women, thereby situating the issue within a broader constitutional culture.

A bench comprising Justices B. V. Nagarathna and P. B. Varale recognised breastfeeding as not merely a personal choice but a constitutionally protected activity linked to both maternal and child rights. The Court held that breastfeeding is integral to a child’s right to life, survival, and development, while also forming a core aspect of a woman’s reproductive autonomy. In doing so, it drew a direct connection between Article 21 and the lived realities of caregiving, expanding the contours of the right to life to include conditions necessary for nurturing and early childhood care.

Importantly, the Court located the State’s obligation within this rights framework, directing governments to create enabling environments for nursing mothers. It endorsed and reinforced an advisory issued by the Union Government mandating the establishment of feeding and childcare rooms in public buildings, particularly those employing a significant number of women. By recognising such measures as flowing from Articles 14 and 15(3), the Court affirmed that substantive equality requires proactive support systems rather than mere formal guarantees.

The judgment is also notable for acknowledging the social stigma attached to breastfeeding in public spaces. Drawing from international human rights perspectives, the Court highlighted how such stigma imposes undue stress and discourages women from exercising their rights. By explicitly calling for destigmatisation, the Court addressed an often-overlooked dimension of rights enforcement—social acceptance—thereby bridging the gap between legal recognition and lived experience.

Ultimately, the ruling advances a holistic vision of constitutional rights, where dignity, health, and equality intersect. By directing both infrastructural changes and a shift in societal attitudes, the Court reaffirmed that rights are meaningful only when they are practically accessible and socially respected. This judgment stands out as a “good judgment” for its empathetic and expansive understanding of constitutional guarantees, particularly in recognising and supporting the everyday realities of women and children.

• Inclusive Judiciary: Supreme Court dismantles structural barriers in judicial recruitment

On March 3, 2025, in In Re- Recruitment of Judicial Services v. Registrar General of MP, the Supreme Court delivered a landmark ruling that fundamentally reorients judicial recruitment towards inclusion and equality for persons with disabilities. Decided by a bench of Justices J. B. Pardiwala and R. Mahadevan, the case brought together multiple challenges arising from Madhya Pradesh and Rajasthan, exposing systemic exclusion of PwDs from judicial service. At its core, the judgment addressed how seemingly neutral recruitment rules and administrative practices effectively barred disabled candidates from meaningful participation.

The Court was particularly critical of the 2023 amendment to the Madhya Pradesh Judicial Service Rules, which excluded visually impaired candidates on the basis of medical opinions questioning their competence. Rejecting this paternalistic approach, the Court drew a crucial distinction between eligibility and suitability, holding that once a candidate meets the prescribed eligibility criteria, they cannot be subsequently declared unsuitable solely on the basis of disability. In doing so, it decisively shifted the framework from a medical model of disability to a rights-based approach grounded in dignity and equal opportunity.

Reaffirming the primacy of the Rights of Persons with Disabilities Act, 2016, the Court characterised it as a “super-statute” that must inform and override inconsistent service rules. It further aligned its reasoning with international standards under the United Nations Convention on the Rights of Persons with Disabilities, emphasising that the State’s obligation lies in providing reasonable accommodation rather than imposing rigid and exclusionary criteria. The Court also recognised that facially neutral requirements—such as mandating 70% marks in the first attempt or imposing uniform cut-offs—can result in indirect discrimination, thereby violating Article 14.

In a series of strong corrective directions, the Court struck down Rule 6A of the MP Rules for excluding visually impaired candidates and read down other provisions that imposed additional burdens on PwDs. It mandated the creation of separate cut-offs and relaxed criteria to ensure that reserved vacancies are meaningfully filled. Importantly, it rejected any artificial distinction between persons with disabilities and those with benchmark disabilities in matters of employment rights, reinforcing a broader and more inclusive understanding of equality under Articles 14, 15, 16, and 21.

The judgment’s impact is both immediate and structural. It set aside prior recruitment processes and directed authorities to reconsider excluded candidates through inclusive procedures, with time-bound compliance. More broadly, it signals a judicial push to address chronic non-implementation of disability rights across states. By centring reasonable accommodation and dismantling systemic barriers, the Court has not only opened the doors of the judiciary to PwDs but has also reaffirmed that constitutional equality demands transformation in institutional design—not mere formal inclusion.

• Shielding Speech: Supreme Court Checks Criminalisation of Dissent and Artistic Expression

In Imran Pratapgarhi v. State of Gujarat, the Supreme Court delivered a significant judgment on March 28, 2025, recalibrating the balance between free speech and police powers. The case arose from an FIR lodged against a Member of Parliament over a poem shared on social media, alleging that it promoted communal disharmony. Setting aside the High Court’s refusal to intervene, the Supreme Court quashed the FIR, holding that the allegations did not disclose any cognisable offence. In doing so, the Court sent a clear message against the growing tendency to criminalise political and artistic expression through overbroad invocation of penal law.

At the heart of the ruling lies an important clarification of Section 173 of the Bharatiya Nagarik Suraksha Sanhita, 2023. The Court harmonised the apparent tension between the mandate to register FIRs upon receipt of information disclosing a cognisable offence and the discretion to conduct a preliminary inquiry in certain cases. It held that while immediate registration remains the general rule, Section 173(3) operates as a critical exception, permitting a preliminary inquiry in cases involving offences punishable between three to seven years. This interpretive move marks a departure from a purely mechanical application of FIR registration, particularly in contexts requiring greater constitutional sensitivity.

The judgment is especially notable for its robust defence of free speech under Article 19(1)(a). The Court characterised the FIR in the present case as a “mechanical exercise” and an abuse of legal process, underscoring that law enforcement authorities must engage with the content of speech before initiating criminal proceedings. It emphasised that artistic and political expressions—including poetry, satire, and literature—occupy a vital space in democratic life and must be protected from undue state interference. By doing so, the Court reaffirmed that not all offensive or controversial speech falls within the narrow restrictions permitted under Article 19(2).

Crucially, the Court laid down that in cases involving speech-related allegations, police authorities should ordinarily invoke the safeguard of a preliminary inquiry under Section 173(3). This requirement ensures that individuals are not subjected to criminal prosecution merely for exercising their constitutional rights. It also places a responsibility on senior police officers to scrutinise such cases carefully before authorising FIR registration, thereby introducing an institutional check against arbitrary or politically motivated action.

Ultimately, the ruling represents a decisive intervention against the misuse of criminal law as a tool of censorship. By embedding constitutional safeguards within procedural law, the Court has strengthened protections for dissent and creative expression while maintaining the integrity of the criminal justice system. In an era marked by increasing criminalisation of speech, this judgment stands out as a vital reaffirmation that the State’s power to prosecute must always remain subordinate to the fundamental right to free expression.

• Guarding Federal Balance: Supreme Court rejects Governor’s delay and reinforces legislative primacy

On April 8, 2025, in a landmark ruling addressing constitutional deadlock and executive inaction, the Supreme Court firmly curtailed the practice of Governors indefinitely withholding assent to state legislation. In the challenge arising from the actions of R. N. Ravi, the Court held that the prolonged delay and subsequent reservation of Bills for Presidential consideration—after their re-enactment by the State Legislature—was unconstitutional, illegal, and liable to be set aside. By declaring the Governor’s actions “non-est,” the Court ensured that constitutional processes cannot be subverted through inaction or procedural improvisation.

A bench comprising Justices J. B. Pardiwala and R. Mahadevan clarified the scope of gubernatorial powers under Article 200 of the Constitution. Rejecting the notion of a “pocket veto” or “absolute veto,” the Court held that the Governor must act within the framework explicitly laid down—either granting assent, withholding assent and returning the Bill for reconsideration, or reserving it for the President at the first instance. Crucially, it ruled that once a Bill is reconsidered and re-enacted by the State Legislature, the Governor is constitutionally bound to grant assent, leaving no room for discretionary obstruction.

The Court’s reasoning underscores the foundational principles of parliamentary democracy and federalism. It held that the Governor, as a constitutional head, is ordinarily bound by the aid and advice of the Council of Ministers and cannot act as an independent political authority. By sending the Bills to the President after prolonged inaction—particularly following judicial pronouncements limiting such discretion—the Governor was found to have acted without bona fides. This finding is significant as it directly addresses the growing concern over Governors acting as institutional roadblocks rather than facilitators of democratic governance.

Importantly, the Court introduced enforceable timelines for gubernatorial action, ensuring that constitutional duties are performed within a reasonable period. It also recognised its power to issue a “limited mandamus” in cases of undue delay, thereby subjecting inaction to judicial review. In an extraordinary but necessary step, the Court invoked its powers to deem the Bills as having received assent, thereby restoring the legislative will of the elected assembly and preventing further constitutional paralysis.

Beyond the immediate dispute, the judgment carries far-reaching implications for Centre–State relations. By reaffirming that Governors must respect the will of the people as expressed through elected legislatures, the Court strengthened the democratic fabric of federal governance. Its sharp reminder that constitutional authorities must act with fidelity to their oath—not political expediency—positions this ruling as a vital safeguard against executive overreach and a strong endorsement of constitutional morality.

• Fair Trial Strengthened: Supreme Court expands disclosure obligations under PMLA

On May 7, 2025, in a significant ruling reinforcing procedural fairness, the Supreme Court held that an accused under the Prevention of Money Laundering Act, 2002 is entitled not only to relied-upon materials but also to a list of all documents, statements, and material objects collected during investigation—even those the prosecution chooses not to rely upon. This marks an important shift away from a restrictive disclosure regime and ensures that the accused is not kept in the dark about potentially exculpatory material in the custody of the Enforcement Directorate.

A bench comprising Justices Abhay S. Oka, Ahsanuddin Amanullah, and Augustine George Masih emphasised that access to such information is integral to the right to a fair trial under Article 21. The Court reasoned that without knowledge of unrelied-upon materials, the accused would be unable to effectively exercise their right to defence, including seeking production of documents or recalling witnesses at later stages of trial. This recognition is particularly crucial in PMLA cases, where the procedural landscape is already weighted against the accused.

The judgment is especially significant in light of the reverse burden imposed under the PMLA, which requires the accused to demonstrate their innocence. The Court noted that this onerous burden can only be constitutionally sustained if the accused is afforded a meaningful opportunity to defend themselves. Accordingly, it directed that courts should adopt a liberal approach when accused persons seek production of such documents, denying requests only in exceptional circumstances. This ensures that procedural technicalities do not undermine substantive justice.

Importantly, the Court clarified that this right is not confined to the trial stage but extends even to bail proceedings. An accused may invoke provisions such as Section 91 of the Code of Criminal Procedure, 1973 (now reflected in the BNSS) to seek production of un-relied upon documents, subject to limited exceptions where disclosure may prejudice an ongoing investigation. By doing so, the Court recognised that access to relevant material is essential even at preliminary stages where liberty is at stake.

By setting aside the narrower view adopted by the High Court, the Supreme Court reaffirmed that fairness in criminal proceedings requires transparency from the prosecution. This judgment strengthens the procedural rights of the accused in complex financial crime cases and ensures that the balance between state power and individual liberty is not distorted by asymmetry of information. In a regime often criticised for its stringent provisions, this ruling stands out as a vital safeguard for due process and fair trial rights. 

• Reproductive Autonomy Affirmed: Supreme Court recognises maternity leave as a fundamental right

In a significant judgment advancing gender justice and bodily autonomy, the Supreme Court on May 23, 2025, held that maternity leave is not merely a statutory entitlement but an integral component of reproductive rights. Setting aside the decision of the Madras High Court, the Court ruled that denying maternity leave to a woman for the birth of her third child—based on a rigid two-child policy—was constitutionally untenable. By framing maternity benefits within the broader ambit of fundamental rights, the Court elevated the discourse from service rules to constitutional guarantees.

A bench comprising Justices Abhay S. Oka and Ujjal Bhuyan emphasised that reproductive rights intersect with core constitutional values, including dignity, privacy, equality, and health under Article 21. The Court clarified that maternity leave is inseparable from maternity benefits and that these, in turn, form an essential facet of a woman’s reproductive autonomy. This recognition marks an important doctrinal shift, rejecting the narrow view that such entitlements flow only from statutory or contractual frameworks.

The judgment also carefully navigates the tension between population control policies and individual rights. While acknowledging that the State’s objective of regulating population growth is legitimate, the Court held that such policies cannot override or disproportionately burden women’s reproductive choices. Instead, it called for a harmonised and purposive interpretation that balances social objectives with constitutional protections, ensuring that welfare measures are not undermined by rigid administrative rules.

Importantly, the Court engaged with the specific facts of the case to underscore the inequity of the denial. The petitioner’s earlier children were born prior to her entry into service and were not in her custody, making the denial of maternity leave for her first child within service particularly unjust. By rejecting a mechanical application of the two-child norm, the Court reaffirmed that rights-based adjudication must be sensitive to lived realities rather than confined to formal classifications.

Ultimately, the ruling strengthens the constitutional foundation of maternity benefits in India. By recognising maternity leave as part of reproductive rights, the Court has reinforced the principle that workplace entitlements must align with dignity and equality. This judgment stands out as a “good judgment” for its expansive and humane interpretation of fundamental rights, ensuring that state policies do not erode the autonomy and well-being of women.

From Recognition to Enforcement: Supreme Court holds state accountable for transgender discrimination

In a significant step towards enforcing transgender rights beyond formal recognition, on October 17, 2025, the Supreme Court awarded compensation to a transwoman who was denied employment after her gender identity was disclosed. The case exposed how both private institutions and State authorities failed to uphold statutory and constitutional protections, resulting in direct and systemic discrimination. By holding not just the schools but also the Union and State governments accountable, the Court underscored that the protection of transgender rights requires active enforcement, not mere legislative existence.

A bench comprising Justices J. B. Pardiwala and R. Mahadevan grounded its reasoning in the Transgender Persons (Protection of Rights) Act, 2019 and its accompanying Rules. The Court found that the failure to implement key provisions—such as appointing complaint officers for grievance redressal—amounted to “omissive discrimination.” This articulation is particularly important, as it expands the understanding of discrimination to include not only direct acts but also failures of institutional responsibility that prevent individuals from accessing remedies.

The judgment also addressed the role of private actors, noting that while they are bound by statutory obligations, their compliance is often contingent on effective state oversight. In this case, the absence of enforcement mechanisms created an environment where discriminatory practices could persist unchecked. The Court thus placed primary responsibility on the State and its instrumentalities, including education departments and regulatory bodies, for failing to ensure adherence to the law.

Importantly, the Court moved beyond individual relief and initiated structural reform. It constituted a committee headed by Justice Asha Menon to formulate comprehensive policies on equal opportunity, reasonable accommodation, and grievance redressal for transgender persons. These directions aim to bridge the gap between legal recognition—first affirmed in National Legal Services Authority v. Union of India—and its practical implementation across institutions.

Ultimately, the judgment reflects a shift from symbolic inclusion to enforceable equality. By recognising both direct and systemic forms of discrimination and mandating institutional accountability, the Court reaffirmed that dignity, non-discrimination, and equal opportunity must be meaningfully realised for transgender persons. This ruling stands out as a “good judgment” for its emphasis on implementation, accountability, and the lived realities of marginalised communities.

Conclusion: Gains, silences, and the road ahead

Taken together, the Supreme Court’s decisions this year reflect a judiciary that has, in crucial moments, stepped in to recalibrate the balance between state power and individual rights. Across domains—criminal procedure, free speech, disability rights, gender justice, and federal governance—the Court has reaffirmed that constitutional guarantees are not ornamental but enforceable limits on authority. Its insistence on procedural fairness, transparency, and accountability has pushed back against a growing culture of overreach, while its rights-expansive approach in cases involving persons with disabilities, transgender persons, and women signals a deeper commitment to substantive equality. These are not minor course corrections; they are structural interventions that restore faith in constitutional governance.

Yet, a year-end reflection must also confront what remains conspicuously absent. Despite these strong pronouncements, there has been no significant constitutional ruling directly addressing hate speech or incitement, an area that remains doctrinally underdeveloped and inconsistently applied. In a socio-political climate marked by polarisation and targeted speech, the absence of judicial clarity on thresholds of harm, intent, and accountability is striking. Similarly, while the Court has intervened in individual cases of misuse of criminal law, there has been no comprehensive judgment revisiting the architecture of preventive detention, sedition-like provisions, or broad public order laws, which continue to be invoked in ways that chill dissent.

Equally notable is the limited engagement with digital free speech and platform regulation. While the Court has protected artistic expression in traditional contexts, the evolving challenges of online speech—algorithmic amplification, platform liability, and state takedown powers—remain largely unaddressed at a doctrinal level. This gap is particularly significant given the increasing centrality of digital spaces to democratic participation. The absence of authoritative guidance in this area leaves both rights and regulatory frameworks in a state of uncertainty.

Further, while the Court has advanced disability and transgender rights through targeted interventions, there is still no sweeping judgment addressing the broader failures in implementation of anti-discrimination law across sectors—including housing, healthcare, and private employment. The promise of horizontal rights enforcement remains uneven, and much of the burden continues to fall on individuals to litigate piecemeal injustices. Similarly, although the Court has strengthened procedural safeguards in criminal law, there has been no systemic intervention on issues such as custodial violence, prison reform, or undertrial incarceration at scale, beyond individual relief.

In this sense, the year reflects both assertion and restraint. The Court has been willing to act decisively where violations are clear and immediate, but has been more cautious in undertaking large-scale doctrinal or structural overhauls in politically sensitive or institutionally complex areas. This duality is not unusual, but it does shape the limits of constitutional progress. Rights are strengthened in fragments, while foundational questions remain open.

Ultimately, the “good judgments” of this year demonstrate the enduring capacity of the judiciary to act as a counter-majoritarian institution—one that protects liberty, ensures fairness, and gives meaning to equality. But they also underscore an unfinished project. The Constitution’s transformative potential lies not only in correcting excesses but in anticipating and addressing emerging forms of injustice. As these judgments show, the Court has taken important steps forward. The challenge ahead lies in whether it will extend this momentum to the silences that continue to define the constitutional landscape.

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