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Motor Vehicles Act, 1988 — Section 166 — Claim Petition for death of bachelor — Selection of Multiplier — Multiplier to be determined based on age of deceased and not age of dependents/parents — Deceased was 33 years old at the time of accident — Correct multiplier applicable according to standardized matrix in Sarla Verma and Pranay Sethi is 16 — Argument of insurer that multiplier should correspond to age of parents rejected — MACT and High Court rightly applied multiplier of 16. Legal Representatives Can Claim Motor Accident Compensation Even Without Financial Dependency On Deceased Execution Of Unregistered Agreement To Sell Does Not Terminate Subsisting Landlord-Tenant Relationship Nor Entitle Tenant To Section 53A TP Act Protection A. Transfer of Property Act, 1882 — Section 111(e) & (f) — Landlord and Tenant — Determination of lease by express or implied surrender — Execution of agreement to sell by landlord in favour of tenant — Effect on jural relationship — Held, mere execution of an agreement to sell between landlord and tenant does not ipso facto determine the subsisting tenancy — Tenancy is determined only when terms of agreement or unequivocal conduct of parties disclose express or implied surrender — Where agreement to sell contained clause for cancellation and restoration of possession in case loan was not sanctioned, existing possession was referable to tenancy and not to agreement to sell — Landlord-tenant relationship continued to subsist. Appellate Courts Should Not Remand Cases Under Order 41 Rule 23 CPC As A Matter Of Course When Sufficient Evidence Is Available On Record. A. Civil Procedure Code, 1908 (CPC) — Order 41 Rules 23 and 24 — Power of Appellate Court to remand — Remand of case to Trial Court for framing of additional issues and fresh evidence — Permissibility — High Court remitted suit regarding one item of property for framing issues on whether sale deed was sham, limitation, and possession — Held, remand is not to be adopted as a matter of ordinary course and reflects incorrect exercise of discretion when sufficient evidence is available on record — Issues already framed by Trial Court were comprehensive enough to cover core disputes — Appellate Court is fully empowered to decide issues on merits or admit additional evidence if warranted, rather than remitting matter to cause unnecessary delay — Remand set aside and appeals restored to High Court for fresh disposal on merits. Extended Period Of Limitation Under Proviso To Section 11A, Central Excise Act Cannot Be Invoked When Facts Are Known To Department Without Wilful Suppression A. Central Excise Act, 1944 — Section 35L — Maintainability of appeal before Supreme Court — Preliminary objection raised by Department that appeal does not come under Section 35L as issue had no relation to rate of duty or valuation — Held, issue raised regarding extended period of limitation on ground of non-inclusion of certain costs in assessable value has an inextricable link with valuation of goods for purposes of assessment — Issue raised in show cause notice fundamentally dealt with valuation of goods — Supreme Court declined to relegate matter to High Court after almost a decade of pendency — Preliminary objection rejected.

Motor Vehicles Act, 1988 — Section 166 — Claim for compensation — Deduction of Mediclaim benefits — Motor Accidents Claims Tribunal — Award of compensation — Mediclaim policy is a contract of insurance purchased by an individual to cover uncertainties of life, with no specific accidental coverage — Compensation under Motor Vehicles Act is a statutory remedy arising from negligence and injury — Mediclaim reimbursement is a contractual benefit independent of the Motor Vehicles Act claim — Deduction of Mediclaim benefits would denude claimant of benefits from premiums paid and unduly benefit insurer of offending vehicle — Compensation awarded under Motor Vehicles Act is a beneficial legislation intended to put the injured in the position as if the accident had not occurred — Medical expenses claimed and paid under Mediclaim are not deductible from compensation awarded by the Tribunal under the Motor Vehicles Act — These two stand on different footing; one is statutory, the other is contractual.

2026 INSC 498 SUPREME COURT OF INDIA DIVISION BENCH NEW INDIA ASSURANCE COMPANY LIMITED Vs. DOLLY SATISH GANDHI AND ANOTHER ( Before : Sanjay Karol and Vipul M. Pancholi, JJ.…

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…

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