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1. Bombay HC: Section 311 CrPC cannot be used to fill evidentiary gaps at final stage of Section 138 NI Act trial

Bombay HC: Section 311 CrPC cannot be used to fill evidentiary gaps at final stage of Section 138 NI Act trial

The Bombay High Court, in a writ petition filed by an accused, set aside a Sessions Court order that had allowed a complainant in a Section 138 Negotiable Instruments Act, 1881 cheque dishonour case to be recalled under Section 311 CrPC at the final arguments stage to prove the original cheque. Justice Abhay J. Mantri restored the trial court's refusal of the recall application. The complainant's evidence had concluded in 2017, the accused's statement under Section 313 CrPC had been recorded, and the matter was posted for final arguments when the accused contended that the cheque had not been proved. The complainant then sought recall to prove the original cheque. The trial court rejected the application as an attempt to fill a lacuna. The Sessions Court allowed the revision to permit evidence limited to proving the cheque, and the accused challenged that order before the High Court. The petitioner argued that the recall application gave no cogent reason and was moved at the final stage. The respondents submitted that the complainant was uneducated, did not know English, and should not suffer for his advocate's negligence. The High Court found that the recall application gave no reason and did not explain why the original cheque had not been produced, and that the respondent could not point to any ground in the application. It rejected the explanation that he was unaware of the contents of his Marathi affidavit of evidence. The Court held that proof of the cheque is essential because a Section 138 NI Act complaint rests on the cheque, and that the complainant could not fill the lacuna by recalling himself after evidence closed, particularly as the accused had already filed written arguments. It held the revisional order contrary to the material on record, as the Sessions Court had merely referred to the photocopy of the original cheque annexed to the complaint.

2. Supreme Court in Sai Maghalakshmi Traders Says Territorial Jurisdiction Cannot Justify Forum Shopping

The Supreme Court in Sai Maghalakshmi Traders v Sri Lakshmi Srinivasa Agro Foods on 28th October 2026 stated that any perception of a High Court being better suited for a particular type of dispute is

3. Delhi High Court returns 17 plaints to plaintiffs for lack of territorial jurisdiction

Part II of a two-part series discusses a recent judgment delivered by Justice Purushaindra Kumar Kaurav of the Delhi High Court. Justice Kaurav returned a batch of 17 plaints to the plaintiffs after f

4. Supreme Court: non-parties may challenge consent decree on showing prejudice under Section 96(3) CPC

The Supreme Court has held that a non-party to a compromise decree is not barred under Section 96(3) read with Order XXIII Rules 3 and 3A of the Code of Civil Procedure, 1908 from challenging it, but

Supreme Court: non-parties may challenge consent decree on showing prejudice under Section 96(3) CPC

The Supreme Court has held that a non-party to a compromise decree is not barred under Section 96(3) read with Order XXIII Rules 3 and 3A of the Code of Civil Procedure, 1908 from challenging it, but must prima facie establish that the decree prejudicially affects independent rights or interests and obtain leave of the appellate court. A Bench of Justices J B Pardiwala and K Vinod Chandran said the statutory bar applies to parties to the compromise and cannot be mechanically extended to a stranger asserting an affected independent legal interest. It held that limitation for a non-party cannot be calculated mechanically from the date of the decree and that the court must consider when the aggrieved person acquired, or could reasonably have acquired, knowledge of the decree and the prejudice. The Court also said an appellate court can grant interim protection pending adjudication of an appeal. It dismissed the appeal filed by Girishbhai Natwarlal Patel against the high court's decision granting leave to appeal to respondent Nos. 1-9, condoning an 11-year delay and continuing an interim injunction. The appellant had contended that an appeal under Section 96 CPC is not maintainable against a consent decree and that a non-party could not acquire a cause of action; the Court rejected that contention. It found serious questions over the land transaction and whether the legal heirs of Purshottam Punjabhai had a subsisting right or title capable of being conveyed, noted the appellant's alleged power of attorney and links to Geetagram Society, and said the respondents' asserted interest was not so tenuous as to foreclose appellate access at the threshold, without establishing fraud or collusion. It upheld the interim injunction, noting the high court had heard the appellant and respondent Nos. 1-9 after its ex parte order.

5. Patna High Court quashes Arms Act proceedings against four accused over lack of Section 39 sanction

Patna High Court quashes Arms Act proceedings against four accused over lack of Section 39 sanction

The Patna High Court, in a Single Judge Bench decision by Justice Rana Vikram Singh, quashed criminal proceedings against four accused arising from an FIR lodged by Abdul Halim alleging that on December 9, 2013, the accused intercepted him and his companion while they were carrying ₹80,000 for labourers' wages, threatened them with firearms, and that petitioner Md. Moajjam snatched the cash and a pistol fell from his possession. The police submitted a final report dated March 31, 2015, treating the occurrence as false and recommending prosecution of the informant under Sections 182 and 211 IPC, but the Judicial Magistrate, First Class, Begusarai, took cognizance on October 28, 2015, under Sections 143, 341, 323, 504 and 379 IPC and Sections 25(1-B)(a) and 26 of the Arms Act. The accused's revision was dismissed by the Additional Sessions Judge-I, Begusarai, on March 21, 2017; the Revisional Court held that the materials disclosed a prima facie case and that the sanction objection could be raised at the framing-of-charge stage. The petitioners then moved the High Court under Section 482 CrPC, objecting that the Arms Act prosecution lacked the mandatory previous sanction under Section 39. The High Court held that Section 39 requires previous sanction of the District Magistrate for prosecution under Section 3 and is statutory and cannot be dispensed with where attracted; a statutory bar demonstrated from the record cannot be treated as an inconsequential objection or invariably postponed without examining its legal effect, and its applicability must be considered with reference to the precise offence alleged and the sanction record. It also held that while a Magistrate is not bound by the investigating officer's opinion, the power to take cognizance must be exercised on due application of judicial mind, merely filing an application seeking cognizance does not establish the truthfulness of the informant's allegations, and the materials must disclose sufficient grounds. The Court noted connected proceedings in Bakhari P.S. Case No. 232 of 2014 in which Abdul Halim was accused regarding the same firearm, and that an earlier High Court order dated April 13, 2018 in Criminal Miscellaneous No. 11048 of 2017 had quashed the cognizance order in the connected case and directed consideration of its records and charge-sheet.

1. State of Himachal Pradesh vs. Union of India (UOI) and Ors. (06.11.2026 - SC)(MANU/SC/1285/2026)

The Supreme Court of India addressed the dispute between the State of Himachal Pradesh and the Union of India, along with the States of Punjab, Haryana, and Rajasthan, regarding Himachal Pradesh's ent

2. Yusuf vs. Vigyapan Loke Delhi Advertising CGHS Ltd. (06.11.2026 - SC)(MANU/SC/1284/2026)

The Supreme Court of India addressed whether the suit filed by Wazir Hussain against Vigyapan Loke Delhi Advertising CGHS Ltd. was barred by limitation due to entries in the defendant's balance sheets

3. A. John Kennedy and Ors. vs. State of Tamil Nadu and Ors. (06.11.2026 - SC)(MANU/SC/1283/2026)

The Supreme Court of India addressed the issue of eviction, rehabilitation, and ecological restoration in forest areas, focusing on the applicability of the Scheduled Tribes and Other Traditional Fore

4. Union of India and Ors. vs. Rohith Nathan and Ors. (06.11.2026 - SC)(MANU/SC/1282/2026)

The Supreme Court of India addressed the Union of India's request to clarify the retrospective application of a judgment dated 11.03.2026 concerning OBC creamy-layer status in civil service allocation

5. J. Rajesh (Minor) thr. his Mother and Natural Guardian J. Gomathi vs. M. Kumaran (Dead) thr. L.Rs. and Ors. (06.11.2026 - SC)(MANU/SC/1281/2026)

The Supreme Court of India addressed whether J. Rajesh, represented by his mother J. Gomathi, could claim a half share in his grandfather N. Ramakrishnan's property, which was inherited by his father,

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