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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.

Environmental Law — Environmental Clearance (EC) — Ex-post facto EC — The Supreme Court has held that the concept of ex-post facto Environmental Clearance is alien to Indian environmental jurisprudence and struck down notifications allowing it — However, in cases where industries were established based on Consent to Establish (CTE) and Consent to Operate (CTO) granted by Pollution Control Boards (PCBs) which were themselves unaware of the prior EC requirement, and the industries have subsequently applied for EC, the Court may allow them to operate while the EC process is pending, to avoid economic and livelihood impacts if no actual pollution is caused or norms are otherwise met.

2026 INSC 455 SUPREME COURT OF INDIA DIVISION BENCH NEETU SOLVENTS Vs. VINEET NAGAR AND OTHERS ( Before : J.K. Maheshwari and Atul S. Chandurkar, JJ. ) Civil Appeal No.…

Land Revenue Records — Evidentiary Value for Title — Revenue records like Faisal Patti, Vasool Baqi, and Pahanies are primarily for fiscal purposes and do not confer title or ownership — Mutation entries do not create or extinguish title and have no presumptive value regarding ownership — Such records cannot be the sole basis for declaring title, especially when the primary document of title (patta) is not produced.

2026 INSC 450 SUPREME COURT OF INDIA DIVISION BENCH VADIYALA PRABHAKAR RAO AND OTHERS Vs. THE GOVERNMENT OF ANDHRA PRADESH AND OTHERS ( Before : Pankaj Mithal and S.V.N. Bhatti,…

Service Matters

Recruitment Process — Advertisement and Selection — While filling vacancies, State instrumentalities must adhere to comparative merit and avoid discrimination — A candidate in a select list does not gain an indefeasible right to appointment without specific rules to that effect.

2026 INSC 459 SUPREME COURT OF INDIA DIVISION BENCH DURGAPUR STEEL PLANT AND OTHERS Vs. BIDHAN CHANDRA CHOWDHURY AND OTHERS ( Before : Pamidighantam Sri Narasimha and Alok Aradhe, JJ.…

Specific Relief Act, 1963 — Section 28 — Rescission of contract for failure to pay purchase money within time limit prescribed by decree — Court’s discretion to extend time or rescind — Dismissal of appeal for non-prosecution does not result in merger of trial court decree — Permitting deposit of balance amount does not extinguish judgment-debtor’s right to seek rescission — Court can consider extending time to balance equities and compensate judgment-debtor for delay, but not automatically — Judgment-debtor’s conduct showing willful negligence is a factor for rescission.

2026 INSC 463 SUPREME COURT OF INDIA DIVISION BENCH ANAND NARAYAN SHUKLA Vs. JAGAT DHARI ( Before : Manoj Misra and Manmohan, JJ. ) Civil Appeal No. 7355 of 2026…

Prohibition of Benami Property Transactions Act, 1988 — Section 45 — Bar of jurisdiction of civil courts — This section bars civil courts from entertaining suits or proceedings related to matters within the jurisdiction of authorities, Adjudicating Authorities, or the Appellate Tribunal under the Act — However, the question of whether a suit falls under this bar is itself a matter that can be considered in the context of Order 7 Rule 11 or Order XIV Rule 2.

2026 INSC 465 SUPREME COURT OF INDIA DIVISION BENCH MANJULA AND OTHERS Vs. D.A. SRINIVAS ( Before : J.B. Pardiwala and R. Mahadevan, JJ. ) Civil Appeal No. 7370 of…

Penal Code, 1860 (IPC) — Section 34 — Common intention — Requires proof of pre-arranged plan or prior meeting of minds, which must be clearly discernible from the material on record — Mere presence at the scene of offence without proof of participation or shared intention is insufficient to sustain conviction with the aid of Section 34 IPC — Prosecution must establish that accused shared a common intention and acted in furtherance thereof.

2026 INSC 467 SUPREME COURT OF INDIA DIVISION BENCH SANJAY SINGH Vs. STATE OF MADHYA PRADESH ( Before : Sanjay Karol and Augustine George Masih, JJ. ) Criminal Appeal No.440…

Service Matters

Police Manual, Jharkhand, Rule 828 read with Appendix 49 — Procedure for imposition of major penalties — Respondent No — 1 was provided with charge memorandum, relevant materials, afforded adequate defence opportunity, participated in enquiry, received enquiry report, and submitted representation, satisfying procedural fairness.

2026 INSC 466 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF JHARKHAND AND OTHERS Vs. RANJAN KUMAR AND OTHERS ( Before : Ahsanuddin Amanullah and R. Mahadevan, JJ. )…

Electricity Act, 2003 — Section 61(d), Section 62, Section 125 — Delhi Electricity Regulatory Commission (Terms and Conditions for Determination of Generation Tariff) Regulations, 2011 — Regulation 6.32, Regulation 4.1 — Capital Cost Recovery — Depreciation — Consumers’ Interest — The Electricity Act mandates that tariff determination must safeguard consumer interests and allow reasonable cost recovery — Depreciation recovery for a power plant cannot extend beyond the period for which electricity was actually supplied to consumers or the approved operational period under a Power Purchase Agreement (PPA), even if the plant has a longer technical useful life

2026 INSC 461 SUPREME COURT OF INDIA DIVISION BENCH DELHI ELECTRICITY REGULATORY COMMISSION Vs. TATA POWER DELHI DISTRIBUTION LIMITED ( Before : Pamidighantam Sri Narasimha and Alok Aradhe, JJ. )…

Sarva Shiksha Abhiyan (SSA) — Engagement of para-teachers on contract basis — Part of Government of India’s flagship program for universal elementary education — Aimed to address human resource gaps in employing teachers — Jharkhand Education Project Council responsible for implementation in Jharkhand — Para-teachers engaged since 2002 — Primarily vehicle for Right of Children to Free and Compulsory Education Act, 2009 (RTE Act)

2026 INSC 462 SUPREME COURT OF INDIA DIVISION BENCH SUNIL KUMAR YADAV AND OTHERS Vs. THE STATE OF JHARKHAND AND OTHERS ( Before : Pankaj Mithal and S.V.N. Bhatti, JJ.…

Karnataka Scheduled Castes and Scheduled Tribes (Prohibition of Transfer of Certain Lands) Act, 1978 — Applicability — Interpretation of delay in initiating proceedings — While delay is generally discouraged, it may not be fatal in cases of beneficial legislation aimed at protecting Scheduled Castes and Scheduled Tribes lands, especially when parties to the original transaction are privy to the proceedings.

2026 INSC 457 SUPREME COURT OF INDIA DIVISION BENCH SEETHAMMA W/O LATE SATHYAPPA Vs. THE STATE OF KARNATAKA AND OTHERS ( Before : Sanjay Kumar and K. Vinod Chandran, JJ.…

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