Supreme Court's September Rulings: From NGT's Powers to Bail Jurisprudence and Minority Rights

New Delhi – September 2025 marked a period of significant judicial activity, with the Supreme Court of India delivering a series of impactful judgments spanning constitutional law, criminal jurisprudence, arbitration, and environmental regulation. The month's rulings provided crucial clarifications on the powers of specialized tribunals, addressed systemic delays in bail matters, and cast doubt on a key precedent concerning minority educational institutions. These decisions are set to reshape legal discourse and practice across various sectors.

In a month characterized by incisive judicial oversight, the Court notably rebuked the National Green Tribunal (NGT) for its procedural conduct, criticized High Courts for mechanical and delayed handling of bail applications, and referred a critical question on the applicability of the Right to Education (RTE) Act to minority schools to a larger bench.

Constitutional and Educational Rights: Re-examining Minority Institutions

In one of the month's most consequential developments, the Supreme Court in Anjuman Ishaat E Taleem Trust v. State of Maharashtra expressed "respectful doubt" over the correctness of the 2014 five-judge Constitution Bench ruling in Pramati Educational & Cultural Trust . The Pramati judgment had exempted both aided and unaided minority schools from the purview of the Right of Children to Free and Compulsory Education (RTE) Act, 2009.

A bench of Justice Dipankar Datta and Justice Manmohan observed, “we respectfully express our doubt as to whether Pramati insofar as it exempts application of the RTE Act to minority schools, whether aided or unaided... has been correctly decided.” The matter has now been referred to the Chief Justice of India for consideration by a larger bench, signaling a potential re-evaluation of the delicate balance between minority rights under Article 30 and the fundamental right to education under Article 21A.

Simultaneously, the Court affirmed that qualifying the Teachers' Eligibility Test (TET) is mandatory for both aspiring and in-service teachers seeking promotions. However, it carved out a temporary exception for minority institutions pending the larger bench's decision.

Scrutiny of Judicial and Quasi-Judicial Bodies

The judiciary's role in holding other institutions accountable was a prominent theme. In M/S. Triveni Engineering and Industries Ltd. v. State of Uttar Pradesh & Ors. , the Supreme Court delivered a sharp critique of the National Green Tribunal (NGT), stating it was functioning like a "mere rubber stamp" by outsourcing its core judicial responsibilities to external committees. The Court set aside an ₹18 crore compensation order imposed by the NGT, highlighting that the tribunal had blindly relied on a Joint Committee report without independent application of mind, thereby violating principles of natural justice.

The functioning of High Courts also came under the Supreme Court's scanner, particularly concerning bail matters. In Phireram v. State of Uttar Pradesh & Anr. , the apex court strongly criticized the Allahabad High Court for issuing "cyclostyled template orders" in bail cancellation matters. The Court noted a disturbing trend where, instead of deciding on allegations of witness tampering, the High Court directed complainants to the Witness Protection Scheme as an alternative remedy.

“We are at pains to note that we came across at least forty recent orders, that have been passed in the last one year alone… All of the above orders are a verbatim copy of each other,” the bench of Justice JB Pardiwala and Justice Sandeep Mehta observed.

This concern over judicial efficiency culminated in a directive in Anna Waman Bhalerao v. State of Maharashtra , where the Court mandated that all High Courts and trial courts must dispose of bail and anticipatory bail applications preferably within two months. "Applications concerning personal liberty cannot be kept pending for years," the Court remarked, underscoring the constitutional ethos of Articles 14 and 21.

Developments in Criminal Law and Procedure

September saw several key rulings clarifying principles of criminal law and evidence. The Court, in Sushil Kumar Tiwari v. Hare Ram Sah & Ors. , cautioned against the mechanical invocation of 'proof beyond reasonable doubt'. It emphasized that "minor contradictions in evidence cannot be elevated to the level of reasonable doubt to justify an acquittal," warning that a misapplication of this principle allows culprits to walk free.

In a significant decision on anticipatory bail, Mohammed Rasal & Anr. v. State of Kerala & Anr. , the Supreme Court expressed disapproval of High Courts entertaining anticipatory bail pleas directly, bypassing the Sessions Court. Acknowledging the concurrent jurisdiction, the bench opined that direct entertainment by a High Court should be reserved for "exceptional cases" with "special reasons to be recorded."

The Court also reiterated established principles of FIR registration. In Vinod Kumar Pandey & Anr. v. Seesh Ram Saini & Ors. , it upheld a Delhi High Court directive to register an FIR against former senior police officers. The Court underscored the principle from Lalita Kumari , stating, "It is the duty of the police to register an FIR if a prima facie cognizable offence is made out, the police is not required to go into the genuineness and credibility of the said information."

Rulings on Commercial and Arbitration Law

The commercial and arbitration landscape received important clarifications. In M/S. KKK Hydro Power Limited v. Himachal Pradesh State Electricity Board Limited , the Court held that electricity tariffs cannot be fixed unilaterally through private Power Purchase Agreements (PPAs) and require prior approval from the State Electricity Regulatory Commission under the Electricity Act, 2003.

On the arbitration front, in Oil and Natural Gas Corporation Ltd. v. M/S G & T Beckfield Drilling Services Pvt. Ltd. , the Court ruled that an Arbitral Tribunal can grant pendente lite interest unless expressly or impliedly barred by the contract. It clarified that a clause merely barring interest on delayed payments does not automatically preclude the award of interest for the period during which arbitration is pending.

The Court also addressed a common issue in insolvency proceedings in Amit Nehra & Anr. v. Pawan Kumar Garg & Ors. , observing that once a claim is verified and admitted by a Resolution Professional, it cannot be subsequently treated as "belated" to deny substantive relief under an approved resolution plan. This ruling provides greater certainty for creditors, particularly homebuyers, whose claims are part of the record.

Other Notable Judgments

• Motor Accident Compensation: In Hitesh Nagjibhai Patel v. Bababhai Nagjibhai Rabari & Anr. , the Court ruled that for calculating compensation, a minor with permanent disability cannot be treated as a non-earning individual. Their notional income should be pegged to that of a skilled worker. It also placed an obligation on insurance companies to furnish the prevailing minimum wage schedules.

• Property Law: Reaffirming a fundamental principle in Ramesh Chand (D) Thr. Lrs. v. Suresh Chand and Anr. , the Court held that title to immovable property cannot be transferred without a registered sale deed. Instruments like an Agreement to Sell or General Power of Attorney do not suffice.

• NI Act: The Court held in Gian Chand Garg v. Harpal Singh & Anr. that once a complainant signs a compromise deed acknowledging full and final settlement, a conviction under Section 138 of the Negotiable Instruments Act cannot be sustained.

• Service Law: In two separate but related rulings ( Union of India & Ors. v. Sajib Roy and Uma Shankar Gurjar v. Union of India ), the Court clarified rules on reservation. It held that reserved category candidates availing age relaxation cannot migrate to the general category if rules prohibit it. However, availing relaxation in physical standards does not bar a meritorious reserved candidate from being appointed to an unreserved post, unless expressly prohibited.

This expansive set of rulings from September underscores the Supreme Court's active role in shaping legal standards, ensuring procedural propriety across the judicial hierarchy, and revisiting long-standing precedents to align them with evolving constitutional interpretations. Legal practitioners will need to closely analyze these judgments as they navigate litigation and advisory roles in the months to come.