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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.

Uttar Pradesh Zamindari Abolition and Land Reforms Act, 1950 — Section 132 — Prohibition of Bhumidhari rights — Land originally recorded as Category-6 (barren/non-agricultural) that was later purportedly re-categorised to Category-5 (cultivable) on the basis of an order by the Sub-Divisional Officer, was found to be public utility land (khalihan and pasture) falling under Section 132, meaning no Bhumidhari rights could be conferred and any patta (lease) granted would be void ab initio.

2026 INSC 395 SUPREME COURT OF INDIA DIVISION BENCH BABU SINGH Vs. CONSOLIDATION OFFICER AND OTHERS ( Before : Prashant Kumar Mishra and N.V. Anjaria, JJ. ) Civil Appeal No.…

Evidence Act, 1872 — Section 112 — Presumption of legitimacy — Birth during marriage being conclusive proof of legitimacy — While Section 112 raises a conclusive presumption, it is rebuttable — Modern scientific advancements like DNA testing, where conclusive and undisputed, can override this presumption, especially when the child’s legitimacy is not the sole issue and the test is conducted with consent.

2026 INSC 399 SUPREME COURT OF INDIA DIVISION BENCH NIKHAT PARVEEN @ KHUSBOO KHATOON Vs. RAFIQUE@SHILLU ( Before : Sanjay Karol and Nongmeikapam Kotiswar Singh, JJ. ) Criminal Appeal No…

Rights of Persons with Disabilities Act, 2016 — Prisoners with Disabilities — This case concerns the rights and conditions of prisoners with disabilities, focusing on the effective implementation of the Rights of Persons with Disabilities Act, 2016, and constitutional guarantees of dignity, equality, and non-discrimination within prison systems.

2026 INSC 397 SUPREME COURT OF INDIA DIVISION BENCH SATHYAN NARAVOOR Vs. UNION OF INDIA AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Writ Petition (Civil)…

Succession Act, 1925 — Section 263 — Revocation of probate — Just cause — Fraudulent grant by concealing material facts or false suggestions — Failure to cite necessary parties — Grant of probate is a judgment in rem and binds the world — Persons with even a slight interest, including subsequent transferees from heirs, are entitled to citation before probate is granted — Failure to implead appellants and legal heirs of deceased sons, and to issue citations, constitutes just cause for revocation.

2026 INSC 400 SUPREME COURT OF INDIA DIVISION BENCH S. LEOREX SEBASTIAN AND ANOTHER Vs. SAROJINI AND OTHERS ( Before : Ujjal Bhuyan and Vipul M. Pancholi, JJ. ) Civil…

Civil Procedure Code, 1908 (CPC) — Section 13 — Conclusiveness of foreign judgment — Enforceability in India — Summary judgment granted by foreign court without full trial despite existence of triable issues and crucial documentary evidence like Balance Sheets and Board Minutes, particularly when the respondent was denied leave to defend — Such procedure prevents a fair adjudication and is not rendered “on the merits” as required by Section 13(b) — Foreign judgment is therefore not enforceable in India.

2026 INSC 401 SUPREME COURT OF INDIA DIVISION BENCH MESSER GRIESHEIM GMBH (NOW CALLED AIR LIQUIDE DEUTSCHLAND GMBH) Vs. GOYAL MG GASES PRIVATE LIMITED ( Before : Pamidighantam Sri Narasimha…

Civil Procedure Code, 1908 (CPC) — Order 7 Rule 11 — Rejection of Plaint — Cause of Action — Valuation and Court Fees — The Supreme Court reiterated that Order 7 Rule 11 allows rejection of a plaint if it does not disclose a cause of action, is undervalued, insufficiently stamped, or barred by law — It clarified that a plaint should not be rejected at the threshold if it contains averments that, taken at face value, set out a dispute requiring adjudication — The Court emphasized that assessing the sufficiency of evidence or the probability of success is impermissible at this stage and constitutes a premature mini-trial.

2026 INSC 402 SUPREME COURT OF INDIA DIVISION BENCH M/S. MARG LIMITED Vs. SUSHIL LALWANI AND OTHERS ( Before : Pamidighantam Sri Narasimha and Alok Aradhe, JJ. ) Civil Appeal…

Motor Vehicles Act, 1988 — Section 168 — Just Compensation — Award of compensation for prosthetic limb — No fixed guidelines for compensation amount — Courts can deviate from governmental notifications if they are too low — Emphasis on “restitutio in integrum” principle to restore the claimant as close as possible to their pre-injury state — Claimants are entitled to choose private centres for prosthetic limbs and renewal costs should be considered — Compensation can be awarded for periodic replacement and maintenance of prosthetic limbs.

2026 INSC 396 SUPREME COURT OF INDIA DIVISION BENCH PRAHLAD SAHAI Vs. HARYANA ROADWAYS AND ANOTHER ( Before : J.B. Pardiwala and K. V. Viswanathan, JJ. ) Civil Appeal No.4642…

Insurance Law — Fire Insurance Claim — Assessment of Loss — Survey Report — Admissibility and Weightage — Admissibility of Survey Report as Primary Evidence — In insurance claims, a survey report, prepared by an expert after physical inspection, is considered primary and significant evidence — It cannot be disregarded without strong contrary evidence showing arbitrariness or unreasonableness.

NATIONAL CONSUMER DISPUTES REDRESSAL COMMISSION   M/S. A.P. KNITWEARS Vs. SBI GENERAL INSURANCE CO. LTD. AND OTHERS ( Before : A.P. Sahi, President and Bharatkumar Pandya, Member ) First Appeal…

Consumer Protection Act, 2019 — Section 2(1)(d) — Consumer — A person purchasing a vehicle for business to earn livelihood is a consumer. — Deficiency in service — No deficiency in service if a vehicle model is not available and another available model is given to the buyer as per mutual understanding and agreement, and the buyer fails to make payments for the second vehicle.

NATIONAL CONSUMER DISPUTES REDRESSAL COMMISSION   PROGRESSIVE AUTOMOBILES PVT. LTD. AND OTHERS Vs. BHAJAN DEBNATH ( Before : Inder Jit Singh, Presiding Member and Sudhir Kumar Jain, Member ) Second…

Service Matters

Regularisation of contractual/ad hoc employees — Notifications dated 16.06.2014 and 18.06.2014, which sought to regularise the services of Group ‘B’, ‘C’, and ‘D’ employees were found to be valid as they aimed to provide benefits to employees left out from a previous regularisation policy and had clear criteria for eligibility such as working on sanctioned posts and possessing necessary qualifications.

2026 INSC 379 SUPREME COURT OF INDIA DIVISION BENCH MADAN SINGH AND OTHERS Vs. STATE OF HARYANA AND OTHERS ( Before : Pamidighantam Sri Narasimha and Atul S. Chandurkarm, JJ.…

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