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Delhi Municipal Corporation Act, 1957 — Section 59(d), 92 and 95(1) — Delhi Municipal Corporation Service (Control and Appeal) Regulations, 1959 — Regn. 7, Schedule — Disciplinary Authority — Competency of Commissioner to dismiss Group ‘A’ Officer — Substitution of Section 59(d) by Delhi Municipal Corporation (Amendment) Act, 1993, w.e.f. 01.10.1993 — Legislative Intent — Post-1993 amendment, the Commissioner is put in complete control both as the appointing authority and the disciplinary authority — Phrase “subject to any regulation that may be made in this behalf” used in Section 59(d) refers to regulations that may be made in future and not the existing 1959 Regulations — Commissioner held fully competent to pass dismissal orders against Group ‘A’ officers despite old regulations naming the ‘Corporation’ as the disciplinary authority. Constitution of India, 1950 — Art. 16 and 226 — Public Employment — Direct Recruitment — Eligibility Criteria — Workshop Experience — Pendency of workshop renewal applications — Effect on candidates — Where a recruitment notification mandates a minimum of one year of experience in a Government-approved workshop, candidates cannot be prejudiced or disqualified merely because the workshop’s application for renewal of approval was pending with the State authorities during the period they gained experience — Depriving an otherwise eligible candidate of employment due to an administrative “period of eclipse” or delay on the part of state machinery is arbitrary and discriminatory–Ashok Kumar Yadav v. State of Haryana, 1985 INSC 137, relied on; State of Uttar Pradesh v. Atul Kumar Dwivedi, 2022 INSC 24, Distinguished. Right to Information Act, 2005 — S. 24(4) — Madhya Pradesh Special Police Establishment Act, 1947 — S. 2(1), S. 3 — “Intelligence and Security Organisation” — Scope and Applicability of Exemption — Jurisdiction of Special Police Establishment (SPE) — The expression “intelligence and security organisations” under Section 24 of the RTI Act implies that the concerned entity must be statutory or institutionally empowered to handle matters of intelligence and national/state security — The Special Police Establishment (SPE) of Madhya Pradesh, established under Section 2(1) of the Act of 1947, is clothed with a limited jurisdiction restricted strictly to investigating offences punishable under the Prevention of Corruption Act, 1988, and select economic/fraud offenses under Sections 409, 420, and Chapter XVIII of the Indian Penal Code — Because neither the Lokayukt nor the SPE handles matters connected to general ‘intelligence’ and ‘security’, the SPE cannot be deemed an “intelligence and security organisation” under Section 24(4) of the RTI Act — Principle of institutional parity cannot be invoked to grant blanket exemptions to a anti-corruption investigation agency. Civil Procedure Code, 1908 (CPC) — Section 11, Explanation IV — Constructive Res Judicata — Application of the principle depends on the facts and circumstances of each case, considering the ambit of earlier proceedings and the nexus of the matter to the controversy — It is founded on public policy to prevent multiplicity of proceedings and avoid parties being vexed twice over for the same litigation — Parties are expected to exercise reasonable diligence and bring forward every point that properly belonged to the subject of litigation and which they might and ought to have brought forward — Negligence, inadvertence, or accident in omitting a part of the case does not exempt from its application. Motor Vehicles Act, 1988 — Section 165 and 166 — Liability for injuries sustained due to falling tree branch — Injuries caused by falling tree branch while vehicle was stationary under the tree during rain — Held, not an accident “arising out of the use of a motor vehicle” as the motor vehicle did not play an active role. [

Delhi Municipal Corporation Act, 1957 — Section 59(d), 92 and 95(1) — Delhi Municipal Corporation Service (Control and Appeal) Regulations, 1959 — Regn. 7, Schedule — Disciplinary Authority — Competency of Commissioner to dismiss Group ‘A’ Officer — Substitution of Section 59(d) by Delhi Municipal Corporation (Amendment) Act, 1993, w.e.f. 01.10.1993 — Legislative Intent — Post-1993 amendment, the Commissioner is put in complete control both as the appointing authority and the disciplinary authority — Phrase “subject to any regulation that may be made in this behalf” used in Section 59(d) refers to regulations that may be made in future and not the existing 1959 Regulations — Commissioner held fully competent to pass dismissal orders against Group ‘A’ officers despite old regulations naming the ‘Corporation’ as the disciplinary authority.

Constitution of India, 1950 — Art. 16 and 226 — Public Employment — Direct Recruitment — Eligibility Criteria — Workshop Experience — Pendency of workshop renewal applications — Effect on candidates — Where a recruitment notification mandates a minimum of one year of experience in a Government-approved workshop, candidates cannot be prejudiced or disqualified merely because the workshop’s application for renewal of approval was pending with the State authorities during the period they gained experience — Depriving an otherwise eligible candidate of employment due to an administrative “period of eclipse” or delay on the part of state machinery is arbitrary and discriminatory–Ashok Kumar Yadav v. State of Haryana, 1985 INSC 137, relied on; State of Uttar Pradesh v. Atul Kumar Dwivedi, 2022 INSC 24, Distinguished.

Hindu Succession Act, 1956 — Proviso to Section 6 (erstwhile) and Section 8 — Devolution of interest on Class I heirs upon intestate death of a male — If a male Hindu dies intestate leaving a Class I female heir, his interest in coparcenary property devolves by intestate succession under Section 8 and not by survivorship — A notional partition is deemed to take place for ascertaining the deceased’s share.

2026 INSC 499 SUPREME COURT OF INDIA DIVISION BENCH B.S. LALITHA AND OTHERS Vs. BHUVANESH AND OTHERS ( Before : Sanjay Karol and Augustine George Masih, JJ. ) Civil Appeal…

Medical Education — Relocation of Students — Financial Liability — Supreme Court intervened to protect academic future of students admitted to a college (SRMCH) facing deficiencies, by directing their relocation to other recognized colleges — The primary issue became the financial liability for the education provided at the transferee colleges.

2026 INSC 488 SUPREME COURT OF INDIA DIVISION BENCH SOUMYA RANJAN PANDA AND OTHERS Vs. SUBHALAXMI DASH AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Civil…

Income Tax Act, 1961 — Section 147 and 148 — Reopening of assessment — Validity — Tangible material — Change of opinion — Assessing Officer has no power to review an assessment; reassessment must be based on tangible material, not a mere change of opinion — The discovery of fresh information during a survey, which reveals the true nature of a transaction and suggests income has escaped assessment, can form the basis for reopening an assessment, even if certain disclosures were made during the original assessment.

2026 INSC 472 SUPREME COURT OF INDIA DIVISION BENCH SANAND PROPERTIES P. LTD. Vs. JT. COMMR. OF I.T. RANGE 6 AND OTHERS ( Before : J.B. Pardiwala and K.V. Viswanathan,…

Wife’s pursuit of professional career and desire to provide safe environment for child are not grounds for cruelty or desertion. -Family Law — Divorce — Grounds — Cruelty and Desertion — Wife’s pursuit of professional career and desire to provide safe environment for child are not grounds for cruelty or desertion.

2026 INSC 475 SUPREME COURT OF INDIA DIVISION BENCH ANN SAURABH DUTT Vs. LIEUTENANT COLONEL SAURABH IQBAL BAHADUR DUTT ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Civil…

Constitution of India, 1950 — Article 19(1)(a) and Article 21A — Right to education — Medium of instruction — Freedom of speech and expression includes the right to receive information in a comprehensible manner — Education must be imparted in a language that the child understands best — Right to primary education in a language of choice is part of freedom of speech and expression — State cannot impose controls on such choice.

2026 INSC 476 SUPREME COURT OF INDIA DIVISION BENCH PADAM MEHTA AND ANOTHER Vs. STATE OF RAJASTHAN AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Civil…

Motor Vehicles Act, 1988 — Compensation — Enhancement — Deceased was an engineering student with good academic record and potential future earnings — High Court enhanced compensation but it was found to be on the lower side — The Supreme Court assessed the monthly income at Rs. 12,000/-, added 40% for future prospects, deducted half for personal expenses, and applied a multiplier of 18 — Compensation under conventional heads was also enhanced — The motorcycle damage was awarded as per the surveyor’s report.

2026 INSC 477 SUPREME COURT OF INDIA DIVISION BENCH MOHINDER KAUR (D) THROUGH L.R. Vs. BRIJ LAL ARORA AND OTHERS ( Before : S.V.N. Bhatti and Vijay Bishnoi, JJ. )…

Service Matters

. Canara Bank Officer Employees’ (Discipline and Appeal) Regulations, 1976 — Regulation 10 — Common Proceedings — The word “may” in Regulation 10, which empowers the competent authority to direct common disciplinary proceedings against multiple employees, is directory and not mandatory — This interpretation allows for discretion to be exercised by the employer based on the circumstances and the varying roles of the employees involved — The failure to hold a joint inquiry does not automatically vitiate individual disciplinary proceedings.

2026 INSC 478 SUPREME COURT OF INDIA DIVISION BENCH CANARA BANK Vs. PREM LATHA UPPAL (DEAD) THROUGH LRS. ( Before : S.V.N. Bhatti and Vijay Bishnoi, JJ. ) Civil Appeal…

Insolvency and Bankruptcy Code, 2016 — Section 61 — Appeal against NCLT order — Requirement of certified copy of impugned order — Rules for filing appeal before NCLAT — Presentation of appeals under Rule 22 of NCLAT Rules, 2016 — Appeal must be accompanied by a certified copy of impugned order — Applying for certified copy before expiry of limitation period is crucial for excluding time taken to procure it — Failure to file certified copy or obtain exemption renders appeal incompetent — NCLAT wrongly condoned delay in filing and refiling appeal without ensuring compliance with essential requirements.

2026 INSC 479 SUPREME COURT OF INDIA DIVISION BENCH ANGELWOODS APARTMENT ALLOTTEES ASSOCIATION Vs. M LALITHA AND ANOTHER ( Before : Sanjay Kumar and K. Vinod Chandran, JJ. ) Civil…

National Highways Act, 1956 — Section 3A(1) and 3G(1) — Compensation — Applicability of Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 (2013 LA Act) — Held that provisions of 2013 LA Act regarding determination of compensation apply to land acquisition under NH Act.

2026 INSC 480 SUPREME COURT OF INDIA DIVISION BENCH PROJECT DIRECTOR, NATIONAL HIGHWAYS AUTHORITY OF INDIA Vs. ALFA REMIDIS LTD. AND OTHERS ( Before : Sanjay Kumar and K. Vinod…

. Criminal Procedure Code, 1973 (CrPC) — Section 482 — Quashing of Criminal Proceedings — High Court’s power to quash — Allegations in complaint, even if taken at face value, do not prima facie constitute any offence or make out a case against the accused — High Court failed to exercise its power under Section 482 CrPC

2026 INSC 481 SUPREME COURT OF INDIA DIVISION BENCH NARAYANA HEALTH AND OTHERS Vs. THE STATE OF WEST BENGAL AND OTHERS ( Before : Pamidighantam Sri Narasimha and Alok Aradhe,…

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