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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.

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.

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…

Criminal Procedure Code, 1973 (CrPC) — Section 482 — Quashing of criminal proceedings — Medical negligence — Consent for surgery — Allegation of interpolation in consent form for Orchidectomy — Medical Board’s opinion that Orchidectomy was an appropriate procedure in cases of undescended testicle and that consent should have been obtained — No evidence of interpolation in consent form (different ink or handwriting) — Consent form indicated both Orchidopexy and Orchidectomy as options. Held, continuance of criminal proceedings would be an abuse of process of court and liable to be quashed. Appeals allowed, impugned High Court judgment set aside, and proceedings quashed

2026 INSC 319 SUPREME COURT OF INDIA DIVISION BENCH DR. S. BALAGOPAL Vs. STATE OF TAMIL NADU AND ANOTHER ( Before : Pamidigantam Sri Narasimha and Manoj Misra, JJ. )…

Constitution of India, 1950 — Article 14 — Public power, allocation of public resources, award of public contracts, execution of public works — State bound to act transparently, fairly, and consistently with equality — Process must withstand objective scrutiny and be free from arbitrariness, favouritism, or undisclosed conflicts of interest — Public confidence in governance requires equality, integrity, and accountability.

2026 INSC 320 SUPREME COURT OF INDIA FULL BENCH SAVE MON REGION FEDERATION AND ANOTHER Vs. THE STATE OF ARUNACHAL PRADESH AND OTHERS ( Before : Vikram Nath, Sandeep Mehta…

Criminal Procedure Code, 1973 (CrPC) — Section 482 — Quashing of criminal proceedings — Four-step test for assessing prayer for quashing — The Supreme Court, in Pradeep Kumar Kesarwani v. State of Uttar Pradesh, outlined a four-step test: (i) Is the material relied upon by the accused of sterling quality? (ii) Does it rule out the allegations in the complaint? (iii) Has it not been refuted by the prosecution/complainant? (iv) Would proceeding with the trial be an abuse of process and not serve the ends of justice? If all answers are affirmative, High Court should quash proceedings.

2026 INSC 322 SUPREME COURT OF INDIA FULL BENCH SAJAL BOSE Vs. THE STATE OF WEST BENGAL AND OTHERS ( Before : Vikram Nath, Sandeep Mehta and N. V. Anjaria,…

Service Matters

Central Civil Services (Revised Pay) Rules, 2008; Seventh Central Pay Commission Recommendations — Non-Functional Upgradation (NFU) to Level 9 — Recommendation 7.4.13 (iv) (b) — Eligibility criteria — Completion of four years in Level 8 on seniority-cum-suitability basis — Interpretation of — Held, denial of NFU on the ground that Junior Engineers did not enter service at Grade Pay of Rs — 4,800/- amounts to adding an additional condition not contemplated by the recommendation.

2026 INSC 311 SUPREME COURT OF INDIA DIVISION BENCH UNION OF INDIA AND OTHERS Vs. SUNIL KUMAR RAI AND OTHERS ( Before : Pankaj Mithal and S.V.N. Bhatti, JJ. )…

Foreign Exchange Management Act, 1999 (FEMA) — Section 37A — Seizure of assets — Adjudication proceedings are independent of seizure proceedings — The order of the Competent Authority confirming seizure of equivalent assets continues until the disposal of adjudication proceedings — The Adjudicating Authority then passes appropriate directions regarding further action on the seizure — However, this does not apply to a situation where seizure has not been confirmed.

2026 INSC 309 SUPREME COURT OF INDIA DIVISION BENCH J. SRI NISHA Vs. THE SPECIAL DIRECTOR, ADJUDICATING AUTHORITY, DIRECTORATE OF ENFORCEMENT AND ANOTHER ( Before : Vikram Nath and Sandeep…

Arbitration and Conciliation Act, 1996 — Section 11 — Appointment of Arbitrator — Scope of jurisdiction under Section 11 is confined to existence of an arbitration agreement — Issue of res judicata not considered at Section 11 stage — Principles of Order 23 Rule 1 of CPC apply to proceedings under Section 11 — A fresh application under Section 11 is not maintainable if the earlier application was withdrawn without liberty to file a fresh one.

2026 INSC 302 SUPREME COURT OF INDIA DIVISION BENCH RAJIV GADDH Vs. SUBODH PARKASH ( Before : Pamidighantam Sri Narasimha and Alok Aradhe, JJ. ) Civil Appeal No….of 2026 (@…

Criminal Procedure Code, 1973 (CrPC) — Section 197(1) — Requirement of sanction for prosecution of public servants — Protection under Section 197(1) applies only to public servants who are not removable from office except by or with the sanction of the government — Subordinate police officers not falling under this category are not entitled to the benefit of this protection, even if the alleged offence was committed while acting or purporting to act in the discharge of official duty.

2026 INSC 304 SUPREME COURT OF INDIA DIVISION BENCH SAMARENDRA NATH KUNDU AND ANOTHER Vs. SADHANA DAS AND ANOTHER ( Before : J.B. Pardiwala and Manoj Misra, JJ. ) Criminal…

Service Matters

Service Law — Dismissal from Service — Disciplinary Proceedings — Violation of Natural Justice — Requirement of Oral Enquiry — Employer’s Burden of Proof — The Apex Court held that unless the charged employee clearly admits guilt, a disciplinary enquiry must be held — The employer must first present evidence and witnesses, allowing the employee to cross-examine — Only then should the employee be given an opportunity to present their defense — The Court emphasized that relying solely on documents without examining witnesses or making them available for cross-examination when charges are denied, vitiates the enquiry.

2026 INSC 305 SUPREME COURT OF INDIA DIVISION BENCH JAI PRAKASH SAINI Vs. MANAGING DIRECTOR, U.P. COOPERATIVE FEDERATION LTD. AND OTHERS ( Before : Sanjay Karol and Manoj Misra, JJ.…

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