Supreme Court of India Judgements

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Constitution of India, 1950 — Article 226 — Writ jurisdiction — Maintainability — Inclusion of advocate’s name in IBA “Caution List” — High Court dismissing writ petition on ground that Indian Banks’ Association (IBA) is not “State” under Art. 12 — Held, focus of maintainability has shifted from formal character of respondent body to nature of function performed and effect of impugned action on legally protected rights — Caution List operates as sector-wide adverse accreditation mechanism with public law element, having direct bearing on advocate’s right to practise profession under Art. 19(1)(g) — Writ petition against IBA held maintainable notwithstanding IBA not being “State” — Kishor S. Bhat v. Indian Banks’ Association, 2018 SCC OnLine Bom 2857, distinguished — Andi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691; Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649; S. Shobha v. Muthoot Finance Ltd., 2025 SCC OnLine SC 177, relied on. Civil Procedure Code, 1908 (CPC) — Section 100 — Second appeal — Scope of interference with concurrent findings on genuineness of a Will — Whether suspicious circumstances surrounding execution of a Will exist, and stand explained, is essentially a question of fact; a second appellate court cannot re-appreciate evidence and substitute its own view merely because another view is possible — Interference is permissible only where the finding is perverse, based on circumstances that are mere “figments of a doubting mind,” or is vitiated by an erroneous placement of onus — High Court exceeded its jurisdiction under S. 100 CPC in reversing well-reasoned concurrent findings of the Trial Court and First Appellate Court discarding the Will. Criminal Procedure Code, 1973 — Sections 209, 244 — Commitment of case exclusively triable by Court of Session — Whether Magistrate is required to record prosecution evidence under Section 244 CrPC before committing such a case, where the complaint is one instituted otherwise than on a police report — Held, no — Section 244 CrPC, which mandates the Magistrate to hear the prosecution and take evidence, occurs in Chapter XIX (Part B — “Cases instituted otherwise than on a police report”) and governs warrant-case trials before a Magistrate; it has no application where the offence (here, under Section 302 IPC) is exclusively triable by the Court of Session, which is governed instead by Section 209 CrPC — Under the scheme of the 1973 Code (unlike the erstwhile 1898 Code, which mandated a full committal inquiry with recording of evidence under Section 207-A), the Magistrate’s role at the pre-commitment stage is confined to ascertaining whether the offence is exclusively triable by the Sessions Court, and no evidence need be taken or evaluated by the Magistrate at that stage — Requiring witnesses to depose twice, once before the Magistrate and again before the Sessions Court, would serve no purpose and is not the mandate of law — High Court’s contrary view, requiring compliance with Section 244 CrPC even in a Sessions-triable case, proceeds on an erroneous reading of law and is unsustainable. Motor Vehicles Act, 1988 — Sections166, 168 — Compensation — Assessment of annual income of a self-employed deceased (wholesale grocery business) — Two ITRs filed after the death of the deceased excluded by the High Court altogether from the assessment of income — Held, following the principles in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], ITRs filed post-death call for closer scrutiny with reference to surrounding financial statements, since income may be inflated in such returns, but such returns are not to be excluded outright merely for being filed post-death — In the absence of the benefit of such surrounding financial statements on record, and it being inexpedient at this stage to remand the matter, annual income fixed with reference to the nature of the deceased’s wholesale grocery business at Rs.3,25,000 — Compensation recomputed applying 40% addition for future prospects (age 28 years), 1/4th deduction for personal expenses, and a multiplier of 17, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.60,79,550 (as against Rs.15,36,560 awarded by the Tribunal and Rs.38,40,850 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed. Motor Vehicles Act, 1988 — Sections 166, 168 — Compensation — Assessment of annual income of a self-employed deceased (Insurance Agent) from Income Tax Returns — High Court had averaged the last four ITRs on record — Held, erroneous — Following the principles laid down in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], for a self-employed person the average of up to the previous three years’ ITRs, not four, is the appropriate reference point — A performance-linked spike in the income of an Insurance Agent in a particular year does not justify reaching back to an additional, earlier ITR to dilute that spike — On the facts, taking the average of the income for AY 2015-16 (Rs.4,03,180), AY 2016-17 (Rs.9,59,665) and AY 2017-18 (Rs.7,00,559), annual income assessed at Rs.6,87,802 — Compensation recomputed applying 25% addition for future prospects (age 49 years), 1/4th deduction for personal expenses, and a multiplier of 13, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.87,09,282 (as against Rs.49,77,000 awarded by the Tribunal and Rs.76,09,500 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed.
Constitution

Constitution of India, 1950 — Article 226 — Writ jurisdiction — Maintainability — Inclusion of advocate’s name in IBA “Caution List” — High Court dismissing writ petition on ground that Indian Banks’ Association (IBA) is not “State” under Art. 12 — Held, focus of maintainability has shifted from formal character of respondent body to nature of function performed and effect of impugned action on legally protected rights — Caution List operates as sector-wide adverse accreditation mechanism with public law element, having direct bearing on advocate’s right to practise profession under Art. 19(1)(g) — Writ petition against IBA held maintainable notwithstanding IBA not being “State” — Kishor S. Bhat v. Indian Banks’ Association, 2018 SCC OnLine Bom 2857, distinguished — Andi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691; Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649; S. Shobha v. Muthoot Finance Ltd., 2025 SCC OnLine SC 177, relied on.

Jul 9, 2026 sclaw
C P C

Civil Procedure Code, 1908 (CPC) — Section 100 — Second appeal — Scope of interference with concurrent findings on genuineness of a Will — Whether suspicious circumstances surrounding execution of a Will exist, and stand explained, is essentially a question of fact; a second appellate court cannot re-appreciate evidence and substitute its own view merely because another view is possible — Interference is permissible only where the finding is perverse, based on circumstances that are mere “figments of a doubting mind,” or is vitiated by an erroneous placement of onus — High Court exceeded its jurisdiction under S. 100 CPC in reversing well-reasoned concurrent findings of the Trial Court and First Appellate Court discarding the Will.

Jul 7, 2026 sclaw
Constitution of India, 1950 — Article 226 — Writ jurisdiction — Maintainability — Inclusion of advocate’s name in IBA “Caution List” — High Court dismissing writ petition on ground that Indian Banks’ Association (IBA) is not “State” under Art. 12 — Held, focus of maintainability has shifted from formal character of respondent body to nature of function performed and effect of impugned action on legally protected rights — Caution List operates as sector-wide adverse accreditation mechanism with public law element, having direct bearing on advocate’s right to practise profession under Art. 19(1)(g) — Writ petition against IBA held maintainable notwithstanding IBA not being “State” — Kishor S. Bhat v. Indian Banks’ Association, 2018 SCC OnLine Bom 2857, distinguished — Andi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691; Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649; S. Shobha v. Muthoot Finance Ltd., 2025 SCC OnLine SC 177, relied on.
Constitution
Constitution of India, 1950 — Article 226 — Writ jurisdiction — Maintainability — Inclusion of advocate’s name in IBA “Caution List” — High Court dismissing writ petition on ground that Indian Banks’ Association (IBA) is not “State” under Art. 12 — Held, focus of maintainability has shifted from formal character of respondent body to nature of function performed and effect of impugned action on legally protected rights — Caution List operates as sector-wide adverse accreditation mechanism with public law element, having direct bearing on advocate’s right to practise profession under Art. 19(1)(g) — Writ petition against IBA held maintainable notwithstanding IBA not being “State” — Kishor S. Bhat v. Indian Banks’ Association, 2018 SCC OnLine Bom 2857, distinguished — Andi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691; Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649; S. Shobha v. Muthoot Finance Ltd., 2025 SCC OnLine SC 177, relied on.
Civil Procedure Code, 1908 (CPC) — Section 100 — Second appeal — Scope of interference with concurrent findings on genuineness of a Will — Whether suspicious circumstances surrounding execution of a Will exist, and stand explained, is essentially a question of fact; a second appellate court cannot re-appreciate evidence and substitute its own view merely because another view is possible — Interference is permissible only where the finding is perverse, based on circumstances that are mere “figments of a doubting mind,” or is vitiated by an erroneous placement of onus — High Court exceeded its jurisdiction under S. 100 CPC in reversing well-reasoned concurrent findings of the Trial Court and First Appellate Court discarding the Will.
C P C
Civil Procedure Code, 1908 (CPC) — Section 100 — Second appeal — Scope of interference with concurrent findings on genuineness of a Will — Whether suspicious circumstances surrounding execution of a Will exist, and stand explained, is essentially a question of fact; a second appellate court cannot re-appreciate evidence and substitute its own view merely because another view is possible — Interference is permissible only where the finding is perverse, based on circumstances that are mere “figments of a doubting mind,” or is vitiated by an erroneous placement of onus — High Court exceeded its jurisdiction under S. 100 CPC in reversing well-reasoned concurrent findings of the Trial Court and First Appellate Court discarding the Will.
Criminal Procedure Code, 1973 — Sections 209, 244 — Commitment of case exclusively triable by Court of Session — Whether Magistrate is required to record prosecution evidence under Section 244 CrPC before committing such a case, where the complaint is one instituted otherwise than on a police report — Held, no — Section 244 CrPC, which mandates the Magistrate to hear the prosecution and take evidence, occurs in Chapter XIX (Part B — “Cases instituted otherwise than on a police report”) and governs warrant-case trials before a Magistrate; it has no application where the offence (here, under Section 302 IPC) is exclusively triable by the Court of Session, which is governed instead by Section 209 CrPC — Under the scheme of the 1973 Code (unlike the erstwhile 1898 Code, which mandated a full committal inquiry with recording of evidence under Section 207-A), the Magistrate’s role at the pre-commitment stage is confined to ascertaining whether the offence is exclusively triable by the Sessions Court, and no evidence need be taken or evaluated by the Magistrate at that stage — Requiring witnesses to depose twice, once before the Magistrate and again before the Sessions Court, would serve no purpose and is not the mandate of law — High Court’s contrary view, requiring compliance with Section 244 CrPC even in a Sessions-triable case, proceeds on an erroneous reading of law and is unsustainable.
Cr P C
Criminal Procedure Code, 1973 — Sections 209, 244 — Commitment of case exclusively triable by Court of Session — Whether Magistrate is required to record prosecution evidence under Section 244 CrPC before committing such a case, where the complaint is one instituted otherwise than on a police report — Held, no — Section 244 CrPC, which mandates the Magistrate to hear the prosecution and take evidence, occurs in Chapter XIX (Part B — “Cases instituted otherwise than on a police report”) and governs warrant-case trials before a Magistrate; it has no application where the offence (here, under Section 302 IPC) is exclusively triable by the Court of Session, which is governed instead by Section 209 CrPC — Under the scheme of the 1973 Code (unlike the erstwhile 1898 Code, which mandated a full committal inquiry with recording of evidence under Section 207-A), the Magistrate’s role at the pre-commitment stage is confined to ascertaining whether the offence is exclusively triable by the Sessions Court, and no evidence need be taken or evaluated by the Magistrate at that stage — Requiring witnesses to depose twice, once before the Magistrate and again before the Sessions Court, would serve no purpose and is not the mandate of law — High Court’s contrary view, requiring compliance with Section 244 CrPC even in a Sessions-triable case, proceeds on an erroneous reading of law and is unsustainable.
Motor Vehicles Act, 1988 — Sections166, 168 — Compensation — Assessment of annual income of a self-employed deceased (wholesale grocery business) — Two ITRs filed after the death of the deceased excluded by the High Court altogether from the assessment of income — Held, following the principles in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], ITRs filed post-death call for closer scrutiny with reference to surrounding financial statements, since income may be inflated in such returns, but such returns are not to be excluded outright merely for being filed post-death — In the absence of the benefit of such surrounding financial statements on record, and it being inexpedient at this stage to remand the matter, annual income fixed with reference to the nature of the deceased’s wholesale grocery business at Rs.3,25,000 — Compensation recomputed applying 40% addition for future prospects (age 28 years), 1/4th deduction for personal expenses, and a multiplier of 17, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.60,79,550 (as against Rs.15,36,560 awarded by the Tribunal and Rs.38,40,850 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed.
Accident
Motor Vehicles Act, 1988 — Sections166, 168 — Compensation — Assessment of annual income of a self-employed deceased (wholesale grocery business) — Two ITRs filed after the death of the deceased excluded by the High Court altogether from the assessment of income — Held, following the principles in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], ITRs filed post-death call for closer scrutiny with reference to surrounding financial statements, since income may be inflated in such returns, but such returns are not to be excluded outright merely for being filed post-death — In the absence of the benefit of such surrounding financial statements on record, and it being inexpedient at this stage to remand the matter, annual income fixed with reference to the nature of the deceased’s wholesale grocery business at Rs.3,25,000 — Compensation recomputed applying 40% addition for future prospects (age 28 years), 1/4th deduction for personal expenses, and a multiplier of 17, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.60,79,550 (as against Rs.15,36,560 awarded by the Tribunal and Rs.38,40,850 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed.
Constitution Service

Contitution of India — Articles 14 & 16 — Equality in employment — Denial of promotion on discriminatory grounds — Appellant denied promotion despite long service, experience, and possessing a qualification that was accepted for similarly situated employees — High Court Division Bench erroneously set aside Single Judge’s order granting relief, creating contradiction in reasoning by first stating discretion lies with Board of Directors and then upholding Registrar’s refusal — Supreme Court allowed appeal, finding non-acceptance of promotion unsustainable and a violation of equality principles.

Apr 12, 2026 sclaw

2026 INSC 353 SUPREME COURT OF INDIA DIVISION BENCH KAMAL PRASAD DUBEY Vs. THE STATE OF MADHYA PRADESH AND OTHERS ( Before : Prashant Kumar Mishra and N.V. Anjaria, JJ.…

Constitution

Constitution of India, 1950 — Article 14 — Equality before law — Dearness Allowance (DA) and Dearness Relief (DR) — Sanctioning different rates of enhancement for DA for serving employees and DR for pensioners, when both are intended to mitigate inflation, is discriminatory and violates Article 14.

Apr 12, 2026 sclaw

2026 INSC 352 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF KERALA Vs. M. VIJAYAKUMAR AND OTHERS ( Before : Manoj Misra and Prasanna B. Varale, JJ. ) Civil…

Cr P C

Criminal Procedure Code, 1973 (CrPC) — Section 389 — Suspension of sentence pending appeal — Suspension of sentence in serious offences should not be granted routinely — Appellate court must apply its mind to the nature of the offence, manner of commission, and gravity of trial court’s findings — Reasons must be recorded in writing, reflecting due consideration of relevant factors — Order granting suspension of sentence should not be passed mechanically — This principle applies even at the stage of considering interlocutory orders.

Apr 12, 2026 sclaw

2026 INSC 349 SUPREME COURT OF INDIA DIVISION BENCH DHAN JEE PANDEY Vs. THE STATE OF BIHAR AND ANOTHER ( Before : Ahsanuddin Amanullah and R. Mahadevan, JJ. ) Criminal…

State Laws

Rajasthan Tenancy Act, 1955 — Section 88 — Khatedari rights — Claim for declaration of Khatedari rights and recovery of land unlawfully encroached upon — Trial Court decreed suit based on plaintiff’s inherited Khatedari rights from his father — Defendant contested case, later declared ex-parte — Appeal filed after significant delay rejected — Second appeal remanded by Board of Revenue, affirmed by High Court — Supreme Court held that original authority provided no opportunity to adduce evidence after specific date — Trial court proceeded ex-parte without proper service of summons, denying reasonable opportunity to defend — Sale deed not summoned, mutation ignored — Defendant’s unawareness of decree due to non-execution and delayed mutation change — High Court favoured defendant noticing her status as widow and illiterate.

Apr 12, 2026 sclaw

2026 INSC 350 SUPREME COURT OF INDIA DIVISION BENCH HARI RAM Vs. STATE OF RAJASTHAN AND OTHERS ( Before : Sanjay Kumar and K. Vinod Chandran, JJ. ) Civil Appeal…

Narcotics

Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act) — Sections 20(b)(ii)(C), 25 and 29 — Conviction and Sentence — Separate punishments for offences under Section 20 as well as offences under Sections 25 and 29 are permissible, as these are distinct and independent offences, even if they arise from the same transaction.

Apr 9, 2026 sclaw

2026 INSC 332 SUPREME COURT OF INDIA DIVISION BENCH HEM RAJ Vs. THE STATE OF HIMACHAL PRADESH ( Before : Prashant Kumar Mishra and N.V. Anjaria, JJ. ) Criminal Appeal…

Labour Cases

Industrial Disputes Act, 1947 — Section 33C(2) — Maintainability of claim petition — Labour Court and High Court dismissed the appellant’s case on the technical ground of non-maintainability of the petition under Section 33C(2) of the ID Act, primarily because proceedings under this section are in the nature of execution proceedings — The issue of grant of pension was disputed by the respondent-Bank and therefore could not be held to be a pre-existing right — Dismissal of the case at the threshold by both the Labour Court and High Court was upheld.

Apr 9, 2026 sclaw

2026 INSC 333 SUPREME COURT OF INDIA DIVISION BENCH K.G. SESHADRI Vs. THE TRUSTEES OF STATE BANK OF INDIA AND ANOTHER ( Before : Prashant Kumar Mishra and N.V. Anjaria,…

C P C

Civil Procedure Code, 1908 (CPC) — Order 1 Rule 10 — Impleadment of parties — Principles for impleadment — A necessary party is essential for effective order, while a proper party aids complete adjudication — In writ proceedings, a person directly affected by an interim order can be joined even if not an original party.

Apr 9, 2026 sclaw

2026 INSC 335 SUPREME COURT OF INDIA DIVISION BENCH M/S CHOPRA HOTELS PRIVATE LIMITED Vs. HARBINDER SINGH SEKHON AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. )…

Acquittal

Criminal Procedure Code, 1973 (CrPC) — Section 374 — Appeal against dismissal of criminal appeal by High Court — Conviction under Section 302 IPC and Section 27 Arms Act — Prosecution case based entirely on circumstantial evidence — No eyewitnesses — Reliability of prosecution witnesses critically examined — Admission by key witness regarding darkness and identification by voice only, materially undermining credibility — Evidence found insufficient to meet standard of proof in criminal law and exclude reasonable hypotheses of innocence — Conviction set aside and appellant acquitted.

Apr 7, 2026 sclaw

2026 INSC 317 SUPREME COURT OF INDIA DIVISION BENCH JAY PRAKASH YADAV Vs. THE STATE OF JHARKHAND ( Before : Dipankar Datta and Satish Chandra Sharma, JJ. ) Criminal Appeal…

I P C

Penal Code, 1860 (IPC) — Section 294(b) — Conviction for uttering obscene words — Held, mere use of the word “bastard” is not sufficient to constitute obscenity, especially in heated conversations during the modern era — Conviction under Section 294(b) IPC is not sustainable and is liable to be set aside.

Apr 7, 2026 sclaw

2026 INSC 318 SUPREME COURT OF INDIA DIVISION BENCH SIVAKUMAR Vs. STATE REP. BY THE INSPECTOR OF POLICE ( Before : Pamidighantam Sri Narasimha and Manoj Misra, JJ. ) Criminal…

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Constitution

Constitution of India, 1950 — Article 226 — Writ jurisdiction — Maintainability — Inclusion of advocate’s name in IBA “Caution List” — High Court dismissing writ petition on ground that Indian Banks’ Association (IBA) is not “State” under Art. 12 — Held, focus of maintainability has shifted from formal character of respondent body to nature of function performed and effect of impugned action on legally protected rights — Caution List operates as sector-wide adverse accreditation mechanism with public law element, having direct bearing on advocate’s right to practise profession under Art. 19(1)(g) — Writ petition against IBA held maintainable notwithstanding IBA not being “State” — Kishor S. Bhat v. Indian Banks’ Association, 2018 SCC OnLine Bom 2857, distinguished — Andi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691; Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649; S. Shobha v. Muthoot Finance Ltd., 2025 SCC OnLine SC 177, relied on.

Jul 9, 2026 sclaw
C P C

Civil Procedure Code, 1908 (CPC) — Section 100 — Second appeal — Scope of interference with concurrent findings on genuineness of a Will — Whether suspicious circumstances surrounding execution of a Will exist, and stand explained, is essentially a question of fact; a second appellate court cannot re-appreciate evidence and substitute its own view merely because another view is possible — Interference is permissible only where the finding is perverse, based on circumstances that are mere “figments of a doubting mind,” or is vitiated by an erroneous placement of onus — High Court exceeded its jurisdiction under S. 100 CPC in reversing well-reasoned concurrent findings of the Trial Court and First Appellate Court discarding the Will.

Jul 7, 2026 sclaw
Cr P C

Criminal Procedure Code, 1973 — Sections 209, 244 — Commitment of case exclusively triable by Court of Session — Whether Magistrate is required to record prosecution evidence under Section 244 CrPC before committing such a case, where the complaint is one instituted otherwise than on a police report — Held, no — Section 244 CrPC, which mandates the Magistrate to hear the prosecution and take evidence, occurs in Chapter XIX (Part B — “Cases instituted otherwise than on a police report”) and governs warrant-case trials before a Magistrate; it has no application where the offence (here, under Section 302 IPC) is exclusively triable by the Court of Session, which is governed instead by Section 209 CrPC — Under the scheme of the 1973 Code (unlike the erstwhile 1898 Code, which mandated a full committal inquiry with recording of evidence under Section 207-A), the Magistrate’s role at the pre-commitment stage is confined to ascertaining whether the offence is exclusively triable by the Sessions Court, and no evidence need be taken or evaluated by the Magistrate at that stage — Requiring witnesses to depose twice, once before the Magistrate and again before the Sessions Court, would serve no purpose and is not the mandate of law — High Court’s contrary view, requiring compliance with Section 244 CrPC even in a Sessions-triable case, proceeds on an erroneous reading of law and is unsustainable.

Jul 5, 2026 sclaw
Accident

Motor Vehicles Act, 1988 — Sections166, 168 — Compensation — Assessment of annual income of a self-employed deceased (wholesale grocery business) — Two ITRs filed after the death of the deceased excluded by the High Court altogether from the assessment of income — Held, following the principles in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], ITRs filed post-death call for closer scrutiny with reference to surrounding financial statements, since income may be inflated in such returns, but such returns are not to be excluded outright merely for being filed post-death — In the absence of the benefit of such surrounding financial statements on record, and it being inexpedient at this stage to remand the matter, annual income fixed with reference to the nature of the deceased’s wholesale grocery business at Rs.3,25,000 — Compensation recomputed applying 40% addition for future prospects (age 28 years), 1/4th deduction for personal expenses, and a multiplier of 17, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.60,79,550 (as against Rs.15,36,560 awarded by the Tribunal and Rs.38,40,850 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed.

Jul 5, 2026 sclaw