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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.
Service Matters

Public Employment — Recruitment — Medical Unfitness — Suppression of Material Facts — A candidate found medically unfit for a post, specifically for knock knees, cannot retain an appointment if this vital fact was suppressed, especially when the initial appointment and subsequent reinstatement were based on either flawed processes or non-disclosure of disqualifying conditions — The principle of “fraud unravels everything” applies, and an appointment vitiated by the suppression of a disqualifying medical condition cannot be sustained.

2026 INSC 394 SUPREME COURT OF INDIA DIVISION BENCH STATE OF UTTAR PRADESH AND OTHERS Vs. AJAY KUMAR MALIK ( Before : Ahsanuddin Amanullah and N. V. Anjaria, JJ. )…

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…

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