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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.

Companies Act, 1956 — Sections 397, 398, 41 and 2(27) — Member of a company — Locus standi to file petition for oppression and mismanagement — Essential requirement is not just formal entry in register of members, but also equitable consideration of proprietary interest and conduct of the company treating the person as a member

2026 INSC 447 SUPREME COURT OF INDIA DIVISION BENCH DR. BAIS SURGICAL AND MEDICAL INSTITUTE PVT. LTD. AND OTHERS Vs. DHANANJAY PANDE ( Before : Pamidighantam Sri Narasimha and Alok…

Corporate Veil — Lifting of — May be lifted where associated companies are inextricably connected, forming part of one concern, or to prevent evasion of obligations or protect public interest. In this case, subsidiary companies were found to be mere fronts for the holding company’s development activities, justifying lifting the corporate veil.

2026 INSC 449 SUPREME COURT OF INDIA DIVISION BENCH ALPHA CORP DEVELOPMENT PRIVATE LIMITED Vs. GREATER NOIDA INDUSTRIAL DEVELOPMENT AUTHORITY (GNIDA) AND OTHERS ( Before : Sanjay Kumar and Alok…

Contempt of Courts Act, 1971 — Section 2(c) — Criminal Contempt — Publication of scandalous matter or doing any act that scandalises or tends to scandalise, lowers or tends to lower the authority of any court, prejudices or interferes with judicial proceedings, or obstructs justice — Appellant, President of the Gujarat High Court Advocates’ Association and a senior advocate, made unwarranted and disreputable allegations in a press conference against the High Court and its Registry, calling it a ‘gambling den’ and alleging preferential treatment — The High Court initiated suo motu criminal contempt proceedings against the Appellant. Judicial Magnanimity and Reform — The Supreme Court demonstrated exceptional magnanimity and a desire for reform by suspending the conviction and sentence, emphasizing that while accountability is paramount, it must be balanced with patience to guide and elevate, rather than resorting to punitive destruction.

2026 INSC 470 SUPREME COURT OF INDIA DIVISION BENCH YATIN NARENDRA OZA Vs. SUO MOTU, HIGH COURT OF GUJARATAND ANOTHER ( Before : J.K. Maheshwari and Atul S. Chandurkar, JJ.…

Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) — Sections 3(1)(r) and 3(1)(s) — Essential ingredient — “in any place within public view” — Both sections require the act of insult, intimidation, or abuse to occur in a place visible to the public — This is a mandatory condition for constituting the offence.

2026 INSC 468 SUPREME COURT OF INDIA DIVISION BENCH GUNJAN @ GIRIJA KUMARI AND OTHERS Vs. STATE (NCT OF DELHI) AND ANOTHER ( Before : Prashant Kumar Mishra and N.V.…

Uttar Pradesh Panchayat Raj Act, 1947 — Section 12C — Election Dispute — Candidate challenging election results — Prescribed Authority passed an order allowing the election petition and directing recounting of votes — Later, after recounting, the authority declared the appellant as the returned candidate — The High Court set aside this order — The Supreme Court held that once the Prescribed Authority passes a final order allowing the election petition, it becomes functus officio and loses jurisdiction to pass further orders — The initial order directing recounting was deemed final, not interim, as it allowed the petition and rejected the respondent’s statement, leaving no scope for further orders after recounting — The High Court was correct in quashing the subsequent proceedings and the declaration of the appellant as elected — Appeal dismissed.

2026 INSC 471 SUPREME COURT OF INDIA DIVISION BENCH URMILA DEVI Vs. THE STATE OF UTTAR PRADESH AND OTHERS ( Before : Aravind Kumar and Prasanna B. Varale, JJ. )…

Criminal Law — Dying Declarations — Legal position is that a truthful and voluntary dying declaration, if reliable, can be the sole basis for conviction — In this case, dying declarations were found reliable and corroborated by surrounding circumstances and other witnesses — Defence argument about deceased’s unconsciousness rejected.

2026 INSC 469 SUPREME COURT OF INDIA DIVISION BENCH MITESH @ T.V. VAGHELA Vs. THE STATE OF GUJARAT ( Before : Aravind Kumar and Prasanna B. Varale, JJ. ) Criminal…

Specific Relief Act, 1963 — Section 28(1) and 28(4) — Decree for specific performance — Executability — Non-deposit of balance sale consideration within stipulated time — Plaintiff’s failure to deposit balance sale consideration within three months as stipulated in the decree — No application for extension of time filed within the stipulated period — Contract deemed rescinded and decree rendered inexecutable

2026 INSC 451 SUPREME COURT OF INDIA DIVISION BENCH HABBAN SHAH Vs. SHERUDDIN ( Before : Pankaj Mithal and S. V. N. Bhatti, JJ. ) Civil Appeal No…..of 2026 (Arising…

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