SCO.LR | 2026 | Volume 4 | Issue 2

Volume 4 Issue 2 of the Supreme Court Observer Law Reports (SCO.LR) is here! 

In this issue, we bring you five important judgements from last week alongside concise summaries and well-formatted, reader friendly renditions of judgements on: 

• Article 14 as a facet of fairness in public work contracts 
• Principle of Natural Justice in classification of fraud 
• Denial of promotion of similarly situated employees 
• Criminal proceedings against medical professionals, and 
• Cancellation of lease on industrial land due to non-utilisation

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The Supreme Court Observer Law Reports 

SCO.LR | Volume 4 | Issue 2

6 April – 10 April 2026

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Criminal Proceedings Against Medical Professionals

Dr. S. Balagopal v State of Tamil Nadu

6 April 2025 

Citation: 2026 INSC 319 | 2026 SCO.LR 4(2)[6]

Bench: Justices P.S. Narasimha and Manoj Misra

The Supreme Court quashed criminal proceedings against a doctor holding that medical professionals are placed on a different pedestal from ordinary citizens. 

A boy’s father filed an FIR against a doctor alleging that the practitioner had forged his consent for an orchidectomy procedure, and claimed that consent was only given for orchidopexy. The Madras High Court rejected the doctor’s prayer for quashing the proceedings and allowed the father’s petition, directing the constitution of a three-member Medical Board. The investigation continued even after the Board opined in his favour. The doctor filed again for quashing the entire proceeding. Upon dismissal by the High Court, he appealed to the Supreme Court. 

The Supreme Court held that continuance of criminal proceedings would be nothing but an abuse of law. It relied on Jacob Mathew v State of Punjab and reiterated the importance of Medical Board reports. Finding no material on record to suggest forgery of consent, it held that courts must be loath to examine questions of fact and evidence in summary proceedings.

Key words/phrases: Alleged forgery of consent for orchidectomy surgery—Medical Board constituted—Report in favour of doctor—Proceedings continued—Supreme Court quashed proceedings—Importance of Board opinion—Question of fact to be examined in summary proceedings only in rare cases. 

Read the Judgement here.

 MIND MAP

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Equality of Opportunity in Public Contracts

Save Mon Region Federation v State of Arunachal Pradesh

6 April 2026

Citations: 2026 INSC 320 | 2026 SCO.LR 4(2)[7]

Bench: Justices Vikram Nath, Sandeep Mehta and N.V. Anjaria

The Supreme Court held that arbitrariness and favouritism in the award and execution of public work contracts violates Article 14. 

The petitioner—a civil society organisation—alleged that contracts for projects and public works in the State of Arunachal Pradesh were being illegally and arbitrarily awarded to firms and individuals closely connected to the current Chief Minister. Approaching the top court under Article 32, they demanded an investigation by a Special Investigation Team (SIT) and/or Central Bureau of Investigation (CBI), arguing that awards were executed without call for tenders.

The Supreme Court granted the petition. It held that the award of public works is subject to principles of equality and non-arbitrariness guaranteed under Article 14. Further, it held that missing comparative statements are prima facie indication of arbitriness by the State which deems independent investigation. 

Key words/phrases: Independent investigation–Special Investigation Team–Central Bureau of Investigation–Concerened departments–State of Arunachal Pradesh–Public Works–Illegality and arbitariness–Award of public works–Article 32–Arbitariness in public work violates Article 14–Petition granted. 

Read the Judgement here.

 MIND MAP

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Utilisation of Industrial Land Lease

Piaggio Vehicles v State of Uttar Pradesh 

6 April 2026

Citations: 2026 INSC 321 | 2026 SCO.LR 4(2)[8]

Bench: Justices Vikram Nath, Sandeep Mehta and N.V. Anjaria

The Supreme Court held that land allotted at a subsidised rate must serve public objectives, such as employment and economic developments. Non-utilisation of the land can result in the cancellation of an industrial lease. 

The appellant acquired lease rights for a 33-acre plot in 2001. The lease deed of the company was forfeited by the Uttar Pradesh State Industrial Development Authority (UPSIDA) due to non-utilisation and failure to complete the construction of a factory building within a stipulated time period. A writ petition was dismissed by the Allahabad High Court and the matter progressed in appeal to the Supreme Court. 

The Supreme Court upheld UPSIDA’s decision to cancel the lease. It held that the appellant failed to demonstrate its bona fide intent to establish a manufacturing unit. Further, the company did not have an approved layout plan for the said factory and had utilised only 7.68 per cent of the area. 

Key words/phrases: Industrial land lease—Subsidised rates—Public objectives—Non-utilisation of the allotted land—No bona fide intent to use—Revocation of lease deed—Upheld

Read the Judgement here. 

 MIND MAP

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Natural Justice in Fraud Classification

State Bank of India v. Amit Iron Private Limited

7 April 2026

Citations: 2026 INSC 323 | 2026 SCO.LR 4(2)[9]

Bench: Justices J.B. Pardiwala and K.V. Viswanathan

The Supreme Court held that borrowers do not have a right to a personal hearing before their account is classified as fraud. 

The State Bank of India (SBI) classified Amit Iron’s account as “fraud” in March 2024 after issuing a show cause notice and a reasoned order. SBI did not provide an opportunity for an oral hearing or supply the forensic audit report. A Single Judge of the Calcutta High Court, relying on State Bank of India v Rajesh Agarwal (2023) directed that the borrower must be given a personal hearing and supplied with the Forensic Audit Report (FAR). A Division Bench upheld the decision and a parallel Delhi matter involving Bank of India and Liliput Kidswear produced similar relief. The banks, backed by the Reserve Bank of India (RBI), appealed, contending that Rajesh Agarwal only mandated notice, reply and a reasoned order.

The Supreme Court clarified that Rajesh Agarwal did not mandate a personal hearing. It held that the RBI’s 2024 Master Directions correctly incorporate principles of natural justice. While it set aside the direction for personal hearing, it upheld mandatory disclosure of FARs.

Key words/phrases: Account classified as “fraud”—Bank issues show cause notice—Non-disclosure of Forensic Audit Report—Personal hearing of borrower—Mandated by Rajesh Agarwal (2023)—Supreme Court clarifies no personal hearing required—Mandatory to disclose Forensic Audit Reports

Read the Judgement here. 

 MIND MAP

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Discrimination in Promotion for Similarly Situated Employee

Kamal Prasad Dubey v State of Madhya Pradesh

10 April 2026

Citations: 2026 INSC 353 | 2025 SCO.LR 4(2)[10]

Bench: Justices P.K. Mishra and N.V. Anjaria

The Supreme Court held that the refusal to relax qualification requirements for promotions while granting it to other similarly situated employees is arbitrary and violative of Articles 14 and 16 of the Constitution.

The appellant, an employee of a Primary Agricultural Cooperative Society, was recommended for promotion to the post of Society Manager by the Board of Directors with relaxation in educational qualification on the basis of experience, competence and seniority. The General Body approved the recommendation. The Registrar rejected the proposal without assigning reasons. While the Single Judge of the Madhya Pradesh High Court allowed the writ petition, the Division Bench reversed the decision holding that relaxation could not be granted. The appellant approached the Supreme Court.

The Supreme Court set aside the judgement of the Division Bench. The Court held that the governing legislation permitted relaxation in educational qualification. It observed that the Registrar’s rejection of the proposal was cryptic and without reasons and noted that denial of relaxation to other employees of the same homogeneous class amounted to discrimination. 

Key words/phrases: Madhya Pradesh Cooperative Societies Act, 1960—Service Rules, 2013—Rule 19A proviso—Promotion—Relaxation in educational qualification—Board of Directors—Registrar—Cryptic rejection—Homogeneous class—Similarly situated employees—Arbitrariness—Discrimination—Articles 14 and 16—Equality in public employment—Division Bench judgement set aside

Read the Judgement here.

 MIND MAP