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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.

Civil Procedure Code, 1908 (CPC) — Order 41 Rule 27 — Additional evidence in appeal — Appellate court can allow additional evidence only in exceptional circumstances as laid down in the rule, such as where the court needs it to pronounce judgment or for any other substantial cause — Parties do not have a right to produce additional evidence and it cannot be introduced at their convenience — The provision is not meant to fill gaps in evidence or to pronounce judgment in a particular way — If the appellate court can pronounce a satisfactory judgment based on existing evidence, additional evidence is not required — The High Court rightly rejected the application for additional evidence as it was without merit and did not satisfy the conditions under Order 41 Rule 27 CPC

2026 INSC 211 SUPREME COURT OF INDIA DIVISION BENCH GOBIND SINGH AND OTHERS Vs. UNION OF INDIA AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Civil…

Constitution of India, 1950 — Article 14 — Manifest Arbitrariness — Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 — Held, the Act is manifestly arbitrary and violative of Article 14 as it involves complete vesting of property, dissolution of trust, absence of necessity or mismanagement, illusory compensation, and lack of guiding principles — State’s action was excessive, unreasoned and disproportionate to the stated object of better management and development.

2026 INSC 219 SUPREME COURT OF INDIA DIVISION BENCH ANURAG KRISHNA SINHA Vs. STATE OF BIHAR AND ANOTHER ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Civil Appeal…

Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act) — Section 50 — Compliance with search provisions — Accused must be apprised of legal right to be searched before a Magistrate or Gazetted Officer, not a Police Officer — Offering a third option to be searched before a Police Officer contravenes Section 50 and vitiates the entire trial — High Court correctly set aside conviction based on non-compliance with Section 50

2026 INSC 240 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF HIMACHAL PRADESH Vs. SURAT SINGH ( Before : Pankaj Mithal and Prasanna B. Varale, JJ. ) Criminal Appeal…

Motor Vehicles Act, 1988 — Section 166 — Compensation — Deduction of group insurance benefits — Whether amounts received by claimants under employer-provided group insurance or other contractual/social security benefits can be deducted from compensation awarded under the Motor Vehicles Act, 1988 — Held, such benefits arise from independent contractual relationships and lack nexus with statutory compensation for death in a motor vehicle accident — Principle of balancing loss and gain cannot diminish statutory entitlement to just compensation — High Court rightly set aside deductions made by the Tribunal towards group insurance amounts.

2026 INSC 241 SUPREME COURT OF INDIA DIVISION BENCH THE MANAGING DIRECTOR, KSRTC Vs. P. CHANDRAMOULI AND OTHERS ( Before : Pankaj Mithal and Prasanna B. Varale, JJ. ) Civil…

Service Matters

Recruitment Rules — Interpretation of — Anganwadi Workers applying for Supervisor posts — Eligibility and quota for graduates vs. SSLC holders — Amendment to rules increasing quota for Anganwadi Workers and earmarking a portion for graduates — Whether graduates are excluded from the general quota for Anganwadi Workers with SSLC and 10 years’ experience — Supreme Court held that the amendment did not exclude graduate Anganwadi Workers from applying for the 29% vacancies available to Anganwadi Workers with SSLC and 10 years’ experience — The 11% quota for graduates was carved out from the open recruitment quota, not from the existing quota for Anganwadi Workers with SSLC and experience — The selection process did not give any weightage to graduates, and the number of non-graduates selected indicated a level playing field.

2026 INSC 242 SUPREME COURT OF INDIA DIVISION BENCH SHINY C.J. AND OTHERS Vs. SHALINI SREENIVASAN AND OHTERS ( Before : Sanjay Kumar and K. Vinod Chandran, JJ. ) Civil…

Service Matters

Jammu and Kashmir Civil Services (Special Provisions) Act, 2010 — Section 3(b) — Exclusion of employees appointed on academic arrangement basis from regularization — Classification held unconstitutional — Section 3(b) lacks intelligible differentia and rational nexus to the object of the Act — Denial of regularization solely based on nomenclature is impermissible under Article 14 of the Constitution where duties, tenure, and conditions of service are similar to ad hoc or contractual appointees.

2026 INSC 220 SUPREME COURT OF INDIA DIVISION BENCH ABHISHEK SHARMA Vs. THE STATE OF JAMMU AND KASHMIR AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. )…

Criminal Procedure Code, 1973 (CrPC) — Section 482 — Quashing of criminal proceedings — High Court quashed proceedings against sister-in-law on ground of general and omnibus allegations, but declined relief to father-in-law and mother-in-law (appellants) — Allegations against appellants were similarly general and omnibus, with no specific role or overt act attributed to them — Delay in lodging FIR, coupled with lack of specific allegations, suggested possibility of FIR being a counter-blast to divorce petition filed by husband — High Court erred in applying different standards to similarly situated accused — Proceedings against appellants quashed.

2026 INSC 212 SUPREME COURT OF INDIA DIVISION BENCH DR. SUSHIL KUMAR PURBEY AND ANOTHER Vs. THE STATE OF BIHAR AND OTHERS ( Before : Vikram Nath and Sandeep Mehta,…

Companies Act, 2013 — Section 66 — Reduction of Share Capital — Procedural Fairness — Minority Shareholders — Valuation of Shares — Non-disclosure of valuation report and fairness report in notice for general meeting — Held, not a “tricky notice” as statutory requirement for valuation report not mandated under Section 66 — Valuation by a related agency — Held, not a conflict of interest where internal auditor is independent and valuation agency follows accepted norms — Discount for Lack of Marketability (DLOM) — Held, applicable to illiquid shares, especially in absence of oppression — Share price fixation — Held reasonable based on market value of subsidiary, past offers, and rights issue.

2026 INSC 213 SUPREME COURT OF INDIA DIVISION BENCH PANNALAL BHANSALI Vs. BHARTI TELECOM LIMITED AND OTHERS ( Before : Sanjay Kumar and K. Vinod Chandran, JJ. ) Civil Appeal…

Specific Performance of Agreement to Sell — Trial Court decreed suit for specific performance of sale agreement — High Court set aside Trial Court’s decree — Held, Memorandum of Understanding (MoU) executed on the same day as sale agreement established that sale agreement was sham and nominal, executed as security for loan — Plaintiff’s failure to disclose MoU in plaint indicated withholding of material facts and lack of bonafides — Equitable relief of specific performance denied — Appeal dismissed.

2026 INSC 214 SUPREME COURT OF INDIA DIVISION BENCH MUDDAM RAJU YADAV Vs. B. RAJA SHANKER (D) THROUGH LRS. AND OTHERS ( Before : Prashant Kumar Mishra and Prasanna B.…

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