D.Y.CHANDRACHUD, VIKRAM NATH, B.V.NAGARATHNA
Pradeep S. Wodeyar – Appellant
Versus
State of Karnataka – Respondent
Based on the provided legal document, here are the key points:
JUDGMENT :
DHANANJAYA Y. CHANDRACHUD, J.
| Contents | ||
| (A) | The Facts | 3 |
| (B) | The Submissions | 13 |
| (C) | The Analysis | 17 |
| (C.1) | The power to take cognizance | 17 |
| (C.2) | Special Courts power to take cognizance | 19 |
| (C.2.1) | Section 465 Cr.P.C. and interlocutory orders | 30 |
| (C 2.2) | Section 465 Cr.P.C. and failure of Justice | 35 |
| (C.3) | Cognizance of the offence and not the offender | 41 |
| (C.4) | Cognizance by the Special Court of offences under the IPC | 47 |
| (C.4.1) | Joint trial and express repeal | 51 |
| (C.4.2) | Joint trial and implied repeal | 54 |
| (C.5) | Cognizance order and non-application of mind | 58 |
| (C.6) | Authorised person and Section 22 of MMDR Act | 67 |
| (C.7) | Vicarious liability and Section 23 of MMDR Act | 74 |
| (D) | The Conclusion | 78 |
(A) The Facts
1. A Single Judge of the High Court of Karnataka dismissed two petitions instituted by the appellants for quashing the criminal proceedings initiated against them in Special C.C. No. 599/2015 (arising out of Crime No. 21/2014) for offences punishable under
None of the cases in the provided list explicitly indicate that they have been overruled, reversed, or explicitly treated as bad law based solely on the language and references provided. There are no clear markers such as "overruled," "reversed," or "criticized" in the summaries or citations that suggest a case has been invalidated or discredited in subsequent rulings. Most references seem to reaffirm or follow the principles established in the case of Pradeep S. Wodeyar v. State of Karnataka (2021) 19 SCC 62.
Several entries (e.g., Mahesh Kariman Tirki VS State of Maharashtra - 2022 0 Supreme(Bom) 2106, Sumit VS State of U. P. - 2024 0 Supreme(All) 49, Sunita Devi VS State of Bihar - 2024 5 Supreme 138, Nimmagadda Prasad VS State through Central Bureau of Investigation ACB - 2024 0 Supreme(Telangana) 1037, Chandra Raj @ Chandra VS State Of U. P Thru. Prin. Secy. Home Lko. - 2024 0 Supreme(All) 1554, Arjun Anjaneya Reddy VS State Of Karnataka - 2024 0 Supreme(Kar) 547, Nishant Surendra Thadani VS State Of Gujarat - 2024 0 Supreme(Guj) 1781, SRI PRANAV S KODGI vs THE STATE BY GEOLOGIST, MINES AND MINERALS DEPARTMENT - 2025 Supreme(Online)(KAR) 7558, Garima Shaw @ Guddi Shaw vs Umesh Kumar Shaw - 2025 0 Supreme(Cal) 198, Avik Bid, S/o. Maloy Kumar Bid vs State By Jalahalli Police Station, Represented By Its Inspector Of Police - 2025 0 Supreme(Kar) 531, Arjun Anjaneya Reddy, S/o. Sri P. Anjaneyareddy vs State Of Karnataka, Through The Anekal Police Station, Represented By The Station House Officer, Represented By The Ld. Public Prosecutor - 2025 0 Supreme(Kar) 230, Santosh Karwade, S/o Late Mr.Sitaram Karwade vs Union Of India - 2025 0 Supreme(Ker) 2386, Nishant Roadlines, represented through it's sole proprietor namely Sri. Umlesh Ojha, son of Sri.Gupteshwar Ojha vs Union of India, through the Principal Secretary, Ministry of Environment - 2025 0 Supreme(Jhk) 1727) explicitly or implicitly reference the case of Pradeep S. Wodeyar v. State of Karnataka (2021) SCC 62 as being followed, reaffirmed, or reiterated. This indicates a treatment pattern of adherence and affirmation.
Phrases like “the decision was followed and reiterated,” “affirmed in subsequent decision,” and “the Court has elaborately noted upon” suggest these cases are consistent with or supportive of the principles in the Wodeyar case.
Several entries (e.g., Subhash Desai VS Principal Secretary, Governor of Maharashtra - 2023 0 Supreme(SC) 500, Mahender Kumar Khandelwal VS Directorate of Enforcement - 2024 0 Supreme(Del) 201, SUNITA DEVI vs THE STATE OF BIHAR - 2024 Supreme(Online)(SC) 3957, Gowri vs State rep. - 2024 Supreme(Online)(Mad) 54325) reference the case in the context of clarifications or discussions of principles such as due process, cognizance, jurisdiction, etc., indicating these cases are treated as consistent authority.
Some references (e.g., Ajit Kumar Sinha VS State of West Bengal - 2025 0 Supreme(Cal) 149, B. S. Yeddyurappa VS Criminal Investigating Department (CID) - Crimes (2025), Mr. T. Nagarjuna Reddy vs Central Bureau of Investigation - 2024 Supreme(Online)(Tel) 34019, Ajit Kumar Sinha VS State of West Bengal - 2025 0 Supreme(Cal) 149) mention reliance on Wodeyar or principles derived from it but do not specify whether the treatment is affirming or critical. They seem to use Wodeyar as a supporting authority rather than a case that has been overruled or criticized.
The list does not contain explicit indications of cases being overruled, reversed, or criticized, which limits the ability to identify bad law definitively. All references appear to treat the Wodeyar decision as good law or authoritative.
Cases where the treatment is not explicitly stated or where the references are generic (e.g., Ajit Kumar Sinha VS State of West Bengal - 2025 0 Supreme(Cal) 149, B. S. Yeddyurappa VS Criminal Investigating Department (CID) - Crimes (2025), Mr. T. Nagarjuna Reddy vs Central Bureau of Investigation - 2024 Supreme(Online)(Tel) 34019) are placed here due to lack of explicit affirmation or criticism. The absence of negative language or markers of overruling suggests treatment is at least neutral or supportive, but certainty is limited.
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