Madhya Pradesh High Court Monthly Digest: June 2025

Update: 2025-07-09 03:30 GMT
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Citations: 2025 LiveLaw (MP) 120 to 2025 LiveLaw (MP) 141Nominal Index:Piyush Patidar Versus The State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 120Roopansh Khatri And Others Versus The State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 121Shankar Singh Dawar Versus The State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 122The State Of Madhya Pradesh And Others Versus Rajendra...

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Citations: 2025 LiveLaw (MP) 120 to 2025 LiveLaw (MP) 141

Nominal Index:

  • Piyush Patidar Versus The State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 120
  • Roopansh Khatri And Others Versus The State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 121
  • Shankar Singh Dawar Versus The State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 122
  • The State Of Madhya Pradesh And Others Versus Rajendra Kumar Sharma 2025 LiveLaw (MP) 123
  • Parimal Singh Gurjar Versus The State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 124
  • Dr. Rakesh Kumar Verma Vs. State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 125
  • Smt Anjali Sharma Versus Raman Upadhyay 2025 LiveLaw (MP) 126
  • Dr. Nasheem Bano Versus The State Of Madhya Pradesh 2025 LiveLaw (MP) 127
  • Kamlesh Chaturvedi v Saksham Adhikari Dwitiya Vyavhar Nyayadheesh 2025 LiveLaw (MP) 128
  • M/S Tricon Energy Uk Limited Through Its Authorized Signatory Mr. Santosh Koli Vs M/S Kriti Industries (India) Limited 2025 LiveLaw (MP) 129
  • Rajaram @ Rajkumar v The State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 130
  • Narendra Kumar Sharma v The State Of Madhya Pradesh 2025 LiveLaw (MP) 131
  • Nand Kishore Choudhary v High Court of Madhya Pradesh 2025 LiveLaw (MP) 132
  • Vishnu Gupta Vs. State Of Madhya Pradesh And Others 2025 LiveLaw (MP) 133
  • Sabla Hasan Vs. The Union Of India & Ors. 2025 LiveLaw (MP) 134
  • 2025 LiveLaw (MP) 135
  • Arvind Kumar Shukla v Neeraj Nigam 2025 LiveLaw (MP) 136
  • In Reference vs. VA 2025 LiveLaw (MP) 137
  • Shrankhala v Bar Council of India and Others 2025 LiveLaw (MP) 138
  • Mohit Sadana v Vijay Kumar Goyal 2025 LiveLaw (MP) 139
  • MPMKVV Co. Ltd. & Others Vs. Surendra Kumar Gupta 2025 LiveLaw (MP) 140
  • Laxmi Devi Versus National Testing Agency And Others 2025 LiveLaw (MP) 141

Final Orders/Judgements:

MP High Court Quashes Condition In Job Advert By Agriculture Dept Mandating Degree From ICAR Accredited Institute

Case Title: Piyush Patidar Versus The State Of Madhya Pradesh And Others

Citation: 2025 LiveLaw (MP) 120

The Madhya Pradesh High Court has quashed a condition in a job advertisement issued by Department of Farmers Welfare and Agricultural Development which mandated Graduation or Post-Graduation from ICAR (Indian Council for Agricultural Research) Accredited Institute.

'Gross Misuse Of Powers By Police': MP High Court Quashes FIR In Fake Motor Accident Case, Directs DGP To Conduct Inquiry Against Officers

Case Title: Roopansh Khatri And Others Versus The State Of Madhya Pradesh And Others

Citation: 2025 LiveLaw (MP) 121

While quashing a FIR in a fake motor accident case, the Madhya Pradesh High Court condemned the act of police officials for misleading the case and fabricating evidences against the litigant to incriminate him in a 'non-existent' case.

In doing so, the Court also directed the Director General of Police to inquire whether the activities of various police officials in the matter lead to any criminal offence or misconduct on their part and to proceed accordingly.

Sole Official's Absence Can't Hamper Entire Mandi Board's Work: Madhya Pradesh High Court Upholds Suspension

Case Title: Shankar Singh Dawar Versus The State Of Madhya Pradesh And Others

Citation: 2025 LiveLaw (MP) 122

The Madhya Pradesh High Court upheld the suspension of an official by the Managing Director of Krishi Mandi Board, who was acting in place of the Additional Director who had been recently transferred, ruling that an officer's absence cannot hamper the working of the entire board.

MP High Court Slams State For 'Sleeping Over' Execution Of Revenue Notice After Labour Court Granted Relief To Diploma Holder Supervisor

Case Title: The State Of Madhya Pradesh And Others Versus Rajendra Kumar Sharma

Citation: 2025 LiveLaw (MP) 123

While dismissing State's plea against a 2024 decision rejecting its request for modification of a 2013 Labour Court order, the Madhya Pradesh High Court slammed the authorities for 'sleeping' over execution of the revenue notice passed after the labour court's order and for not acting against erring officers responsible for such inaction.

MP High Court Slams Magistrate For Sending Attempt To Murder Case To Sessions Court Without Considering Merits, Says It Acted 'Passively'

Case Title: Parimal Singh Gurjar Versus The State Of Madhya Pradesh And Others

Citation: 2025 LiveLaw (MP) 124

The Madhya Pradesh High Court criticised a Magistrate for playing a 'passive role' by not taking cognizance under Section 190 CrPC in a matter where chargesheet was only filed against two out of the four accused for the offence of attempt to murder under Section 307 IPC.

The Court opined that the Magistrate failed to apply judicial mind, did not consider the merits of the case and had simply said that Section 307 is to be tried by Sessions court. Clarifying the scope of Section 193 of CrPC (Cognizance of offences by Courts of Session), the high court directed the Sessions Judge to take cognizance in the matter.

Order Passed To Save Education Dept's Face: MP High Court Quashes College Principal's Suspension For No Direct Role In Irregular Evaluation

Case Title: Dr. Rakesh Kumar Verma Vs. State Of Madhya Pradesh And Others

Citation: 2025 LiveLaw (MP) 125

While setting aside the suspension order of a Government College Principal, the Madhya Pradesh High Court said that the order was passed just to save the face of department among the public and to show that appropriate action was taken for the alleged irregularity in evaluation of answer sheets.

The Court noted that the Higher Education Department passed the order without taking into account the enquiry report, which revealed that the petitioner was not 'directly' involved in the alleged irregularity.

MP High Court Allows Husband To Produce Wife's WhatsApp Chats Obtained Without Her Consent To Prove Adultery Allegations

Case Title: Smt Anjali Sharma Versus Raman Upadhyay

Citation: 2025 LiveLaw (MP) 126

While hearing a matrimonial dispute, the Gwalior Bench of Madhya Pradesh High Court held that private WhatsApp Chat is admissible as evidence under Section 14 of the Family Courts Act even if it was obtained without consent of the partner or is not admissible under the Indian Evidence Act, 1872.

MP High Court Grants Bail To Lecturer Booked For Hurting Religious Sentiments By Forwarding Content On WhatsApp

Case Title: Dr. Nasheem Bano Versus The State Of Madhya Pradesh

Citation: 2025 LiveLaw (MP) 127

The Madhya Pradesh High Court has granted bail to a Lecturer who was accused of circulating questionable religious content on WhatsApp which allegedly hurt the sentiments of a community.

In doing so, the Court said that simply on ground of forwarding messages and videos which may hurt religious sentiments of others, a person cannot be kept in jail indefinitely.

Judicial Officers Acting In Official Capacity Cannot Be Prosecuted Unless Malafide Is Apparent: Madhya Pradesh High Court

Case Title: Kamlesh Chaturvedi v Saksham Adhikari Dwitiya Vyavhar Nyayadheesh

Citation: 2025 LiveLaw (MP) 128

The Madhya Pradesh High Court, in a recent judgment, highlighted that judicial officers, while acting in their judicial capacity, are protected from prosecution. The court reiterated that judicial officers enjoy protection under Section 197 of the CrPC (Criminal Procedure Code) and interference through Article 226 and 227 is only possible if there is clear malafide intentions or cogent evidence is available.

Ex Parte Order Can Be Recalled If Party Complies With Directions & Legal Issues Require Full Hearing For Proper Adjudication: MP High Court

Case Title: M/S Tricon Energy Uk Limited Through Its Authorized Signatory Mr. Santosh Koli Vs M/S Kriti Industries (India) Limited

Citation: 2025 LiveLaw (MP) 129

The Madhya Pradesh High Court bench of Justice Subodh Abhyankar has held that an ex parte order may be recalled when the concerned party appears later, complies with the court's directions, and the matter involves complex legal issues requiring a fair hearing from both sides for an effective adjudication.

'Act Was Brutal But Not Committed With Brutality': Madhya Pradesh High Court Commutes Death Penalty In Child Rape Case

Case Title: Rajaram @ Rajkumar v The State Of Madhya Pradesh And Others

Citation: 2025 LiveLaw (MP) 130

The Madhya Pradesh High Court commuted death penalty of a 20 year old man belonging to a scheduled tribe convicted of raping a 4 year old child. The trial court had granted capital punishment, noting that the child was left permanently disabled. The high court, while acknowledging the gravity of the offence, held that although the act was undeniably brutal, it was not executed with brutality.

'Opportunity To Be Heard Was Not Granted': Madhya Pradesh High Court Quashes Order Terminating Panchayatkarmi

Case Title: Narendra Kumar Sharma v The State Of Madhya Pradesh 

Citation: 2025 LiveLaw (MP) 131

The Madhya Pradesh High Court set aside a termination order of a Panchayatkarmi, noting that the removal/ termination order was passed in violation of the principles of natural justice. The bench noted that the petitioner was neither granted any opportunity to file written statements nor was granted an opportunity to be heard.

Madhya Pradesh High Court Upholds Penalty Against District Court Clerk For Delay In Relaying Important Information Requested By HC

Case Title: Nand Kishore Choudhary v High Court of Madhya Pradesh

Citation: 2025 LiveLaw (MP) 132

The Madhya Pradesh High Court upheld a disciplinary action initiated against an Executant Clerk, serving in the Court of Judicial Magistrate First Class, for causing undue delay in relaying essential information requested by the High Court.

Madhya Pradesh High Court Dismisses Father's Habeas Corpus Plea For Custody Of Minor Child, Suggests Alternate Remedy U/S 13 Of CPC

Case title: Vishnu Gupta Vs. State Of Madhya Pradesh And Others

Citation: 2025 LiveLaw (MP) 133

The Madhya Pradesh High Court in its Gwalior Bench dismissed a habeas corpus petition filed by a father based in USA, seeking the custody of his minor son.

The Bench comprising of Justice Anand Pathak & Justice Rajendra Kumar Vani deliberated on whether an order passed by the Foreign Court directing the mother to produce the child before it would render the custody of the minor unlawful.

The court stated that the petitioner has an alternate remedy in form of section 13 & 14 of the CPC but has to satisfy its requirements.

Madhya Pradesh High Court Rejects Appeal To Allow Urs, Namaz At Gwalior's Centrally Protected Muhammad Ghaus Dargah

Case Title: Sabla Hasan Vs. The Union Of India & Ors.

Citation: 2025 LiveLaw (MP) 134

The Madhya Pradesh High Court dismissed an intra-court appeal seeking permission to perform religious and cultural activities, including Urs (Jalsa) and Namaz, at the tomb of Hazrat Sheikh Muhammad Ghaus in Gwalior, a monument declared of national importance and protected (in 1962) under the Ancient Monuments and Archaeological Sites and Remains Act, 1958.

A Bench of Justice Anand Pathak and Justice Hirdesh noted that the monument “deserves to be protected with utmost care and caution” and no such activities, as sought by the appellant, could be permitted. Otherwise, it added, the monument "will lose its originality, sanctity, and vitality".

Madhya Pradesh HC Dismisses Plea Seeking Guidelines To Curb Allegedly Misleading News Reports Targeting Muslims

Citation: 2025 LiveLaw (MP) 135

The Madhya Pradesh High Court last week refused to entertain a writ petition seeking preventive and prohibitory action against allegedly misleading news reports and publications targeting the Muslim community and Islam.

Dealing with a writ plea filed by one Maruf Ahmad Khan, a bench of Justice Vishal Mishra said that the reliefs sought were in the nature of a Public Interest Litigation (PIL), and therefore, the same were not maintainable in the plea seeking mandamus.

MP High Court Quashes Remarks Against Ex-State CIC's Conduct For Delaying RTI Info, Says Decision Was 'Bona Fide'

Case Title: Arvind Kumar Shukla v Neeraj Nigam

Citation: 2025 LiveLaw (MP) 136

The Madhya Pradesh High Court set aside adverse observations made on the conduct of former State Chief Information Commissioner (CIC) Arvind Kumar Shukla in an order passed by a single judge bench and quashed the direction to recover a penalty of Rs. 40,000.

A division bench of Acting Chief Justice Sanjeev Sachdeva and Justice Vinay Saraf observed that the order passed by the CIC with respect to information sought by an RTI applicant was passed in bona fide discharge of his duties.

Madhya Pradesh High Court Commutes Death Penalty Imposed On Man For Committing Rape Of Minor Relative

Case Title: In Reference vs. VA

Citation: 2025 LiveLaw (MP) 137

The Madhya Pradesh High Court commuted the death penalty awarded to a man convicted for rape of a minor girl aged 12 years. The court commuted the death penalty after noting that the convict was 24 years of age and had no criminal antecedents, except one murder case, which is under appeal.

The bench, however, upheld his conviction, observing that the "chain of all the circumstances is complete to point out towards the guilt of the appellant and nobody else. Therefore, as far as conviction is concerned, that is required to be upheld and is hereby upheld".

2025 AIBE: MP High Court Rejects PIL By Candidate Seeking Reduction In Passing Marks Following Deletion Of Questions

Case Title: Shrankhala v Bar Council of India and Others

Citation: 2025 LiveLaw (MP) 138

The Madhya Pradesh High Court dismissed a PIL plea challenging the results of the 2025 All India Bar Examination (AIBE) and seeking a direction to Bar Council of India to lower the minimum passing marks in proportion to the number of valid questions and to republish the results.

Commercial Courts Act Applies On Immovable Properties 'Actually & Exclusively Used' For Trade & Commerce: MP High Court

Case Title: Mohit Sadana v Vijay Kumar Goyal

Citation: 2025 LiveLaw (MP) 139

The Madhya Pradesh High Court has clarified that for a dispute to fall within the jurisdiction of the Commercial Courts Act, 2015 the immovable property in question must be "actually used" and "exclusively used" for the purpose of trade and commerce.

Reinstatement Not Automatic Remedy For Illegal Termination, Court Awards Lumpsum Compensation; MP HC

Case Title: MPMKVV Co. Ltd. & Others Vs. Surendra Kumar Gupta

Citation: 2025 LiveLaw (MP) 140

A single judge bench consisting of Justice Milind Ramesh Phadke denied reinstatement to a contractual employee who worked for the Madhya Pradesh Madhya Kshetra Vidyut Vitaran (MPMKVV). The court explained that reinstatement is not the automatic consequence of illegal termination, especially if it involved a daily wage or contractual worker.

NEET-UG 2025: Madhya Pradesh High Court Allows Re-Test For Petitioners Affected By Power Outage At Indore & Ujjain Centres

Case Title: Laxmi Devi Versus National Testing Agency And Others

Citation: 2025 LiveLaw (MP) 141

The Madhya Pradesh High Court directed the National Testing Agency to hold a re-test of the NEET-UG 2025 exam for the candidates who were affected by a power outage at the centres in Indore and Ujjain.

Justice Subodh Abhyankar passed the order allowing a batch of writ petitions filed by the affected students. Since the petitioners were put at a disadvantage for no fault of theirs, the Court observed that a re-test was necessary.

Other Developments:

NEET UG 2025: MP High Court Stays Result Declaration For Candidates Who Complained Of Power Outage At Indore Centres

While hearing pleas by 2025 NEET-UG candidates claiming power outage at centres in Indore during the exam, the Madhya Pradesh High Court on Monday (June 9) modified its earlier order which stayed declaration of result for 11 Indore Centres, thereby giving National Testing Agency the liberty to declare results of all candidates except the petitioners.

MP High Court Permits Mountaineer Megha Parmar Who Conquered Mt Everest To Approach State For Inclusion In 2023 Vikram Award List

While hearing a plea filed by mountaineer Megha Parmar for inclusion of her name in the Vikram Award List 2023, the Madhya Pradesh High Court has permitted the mountaineer to file a representation before the State for consideration of her case.

The court also asked the State to respond to plea filed by Parmar, who is stated to be the first woman mountaineer from the state to climb Mount Everest, seeking a direction to the respondent- authorities to deliver Vikram Award 2023 to her. The interim prayer seeks an ad-interim relief directing respondents to include the name of the petitioner in Vikram Award List 2023.

MP High Court Issues Notice To Centre, State On PIL Concerning Unauthorised Use Of Govt Tribal & SC Girls Hostel By Kendriya Vidyalaya

The Madhya Pradesh High Court has issued notice to Union and State Government in a PIL concerning violation of privacy of girls residing in Government Senior Tribal Girls hostel and Government Senior Girls SC hostel, Jabalpur.

As per the plea, a government school is being run inside the premises of the girls' hostel. The Court has also issued notice to Deputy Commissioner and Assistant Commission of Kendriya Vidyalaya Sangathan.

Madhya Pradesh High Court Issues Notice To State On Plea Concerning Overpricing Of Liquor

While hearing a PIL concerning overpricing of liquor beyond MRP by vendors, the Madhya Pradesh High Court has issued notice to State and asked to file an affidavit indicating the action taken by them in this regard.

PIL In Madhya Pradesh High Court Seeks Ban On Jain Ritual Of 'Fasting Unto Death' For Minors

A PIL has been filed before the Madhya Pradesh High Court seeking to ban the ritual of 'Santhara' for children below 18 years of age and persons of unsound mind.

For context, Santhara is a Jain ritual of voluntarily fasting unto death. As per this practice, a person gradually reduces his or her intake of food and water until death as a means of achieving spiritual purification and detachment from the world. The plea states that the practice involves a conscious decision to abstain from food and water which ultimately leads to death however it should be performed by an adult Jain individual who has a clear understanding of the practice and its implications.

NEET UG 2025 | Power Outage At Exam Centers Didn't Affect Candidates' Performance, Re-Exam Not Feasible: NTA To MP High Court

The Madhya Pradesh High Court heard a batch of petitions filed by medical aspirants alleging that a power outage at the examination centres across Indore during the NEET UG 2025 examination impacted their performance.

The candidates argued that the examination centre experienced power outages due to mismanagement and a lack of power backups. The aspirant further claimed that they had to complete their exam using emergency lamps or candles.

However, Solicitor General Tushar Mehta, representing the National Testing Agency (NTA), presented a report drafted by an independent committee, which showed that despite the one-hour power outage at the 18 affected centres, the candidates had sufficient natural light to complete the exam.

MP High Court Issues Notice On Plea Questioning Vires Of Rule Mandating Convict's Prior Surrender To Challenge Conviction

The Madhya Pradesh High Court has issued notice on a writ petition challenging the constitutionality of a provision under the MP High Court Rules 2008 mandating prior surrender by a convicted person as a pre-condition to challenge the conviction order.

The plea asserts that Rule 48 is ultra vires the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which does not impose any such precondition of prior surrender before the filing of an appeal or revision. It contends that the rule infringes upon the rights of a convicted person under Articles 14, 19(1)(a) and 21 of the Constitution. 

MP High Court Issues Notice On Landowner's Appeal Under Land Acquisition Act Questioning Imposition Of Ad-Valorem Court Fees

The Madhya Pradesh High Court has issued notice on an appeal by a landowner challenging an award passed under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act 2013, wherein the landowner has also questioned the imposition of ad-valorem court fees in filing the appeal.

For context, ad valorem indicates the amount levied which is in proportion to the estimated value of the goods or transaction concerned.

MP High Court Issues Notice On PIL For Appointment Of Special Needs Teachers In Private Schools Across Jabalpur

While hearing a PIL seeking appointment of special educators for special needs children in private schools across Jabalpur, the Madhya Pradesh High Court issued notice to Centre and State authorities and has granted time to file a reply.

'Bar Is The Force That Sustains Justice Delivery System': Justice Sanjay Dwivedi Bids Farewell To MP High Court

The Bar is the force that sustains the justice delivery system, said Justice Sanjay Dwivedi of the Madhya Pradesh High Court on Monday (June 30) at his farewell ceremony.

Justice Dwivedi's remark set the tone for a deeply personal reflection on his journey through the law, beginning with the influence of his father, Late B.M. Dwivedi, a lawyer.

"Watching him work with integrity and commitment left a mark on me. It was an example that made me want to try and follow in his footsteps", he recalled, crediting both his parents for laying the foundation of his values. Their unwavering faith, he said, remained his 'guiding light' throughout his life.

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