Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Criminal LawSupreme Court of India

XYZ vs State of Madhya Pradesh & Ors

Criminal AppealDecided 5 Aug 2022
Criminal Appeal No. 1184 of 2022

Background

The appellant, a yoga instructor at a Gwalior institute, alleged that the institute's Vice-Chancellor touched her inappropriately in March 2019. Despite multiple complaints to the police over several months, no FIR was registered, and an internal committee separately found her allegations established. When she approached the Magistrate under Section 156(3) CrPC seeking a police investigation (including CCTV footage the institute said had been handed to the Vice-Chancellor but never returned), the Magistrate instead converted her plea into a private complaint case requiring her to lead evidence herself, and the Madhya Pradesh High Court upheld this.

Decision Breakdown

The Supreme Court held that once a complaint discloses a cognizable offence, the police must register an FIR, this is settled by the Constitution Bench in Lalita Kumari, and a Magistrate's "discretion" under Section 156(3) CrPC is not unfettered but must be exercised judicially. Since the Magistrate himself found a prima facie case, and since key evidence (the CCTV DVRs) was outside the complainant's control and only the police could retrieve it, the Court held the Magistrate was duty-bound to order a police investigation rather than push the complainant into proving her case privately. It set aside the High Court's judgment and directed the JMFC to order an investigation, to be supervised by a woman officer of at least Superintendent of Police rank, while reiterating that courts must handle sexual harassment complainants with sensitivity throughout the process.

Lesson Learnt

When a complaint of sexual harassment or assault discloses a cognizable offence and important evidence is not in the complainant's own possession, a Magistrate should direct the police to investigate rather than relegate the complainant to proving the case herself, and courts at every stage must treat such complainants with sensitivity, not added procedural burden.

XYZ vs State of Madhya Pradesh & Ors – Legal Case Shots | LegalAware