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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.

Debts Recovery Tribunal Act, 1993 — Auction Sale — Revaluation of Property — High Court’s direction to reconsider valuation after confirmation of auction sale is permissible if there are credible issues regarding adequacy of valuation or fairness of process for fixing reserve price, to ensure best possible value is realised for the secured asset.

2026 INSC 237 SUPREME COURT OF INDIA DIVISION BENCH OM SAKTHI SEKAR Vs. V. SUKUMAR AND OTHERS ( Before : J.B. Pardiwala and R. Mahadevan, JJ. ) Civil Appeal No.…

Penal Code, 1860 (IPC) — Sections 376(2)(g) and 506 — Conviction based on sole testimony of prosecutrix — Delay in lodging FIR — Lack of corroborative evidence — Court held that conviction can be based on sole testimony of prosecutrix only if it inspires confidence — In this case, the prosecutrix’s version did not inspire confidence due to unexplained delay and lack of disclosure to family, inconsistencies in statements, and absence of medical or other corroborative evidence — Defence of prior enmity also not properly considered — Conviction set aside.

2026 INSC 238 SUPREME COURT OF INDIA DIVISION BENCH RAJENDRA AND OTHERS Vs. STATE OF UTTARAKHAND ( Before : Pankaj Mithal and Prasanna B. Varale, JJ. ) Criminal Appeal No.(s)…

Prevention of Corruption Act, 1988 (PC Act) — Sections 7 and 13(2) — Appeal against conviction and sentence — Supreme Court upheld the concurrent findings of the Trial Court and High Court regarding the guilt of the appellant based on ocular evidence and corroboration from independent witnesses — No error found in appreciating the evidence or in rejecting the defence submissions regarding motive, contradictions, and the trustworthiness of witnesses — Appeal dismissed concerning conviction.

SUPREME COURT OF INDIA DIVISION BENCH RAJ BAHADUR SINGH Vs. STATE OF UTTARAKHAND ( Before : Pankaj Mithal and Prasanna B. Varale, JJ. ) Criminal Appeal No. 1105 of 2013…

Arbitration and Conciliation Act, 1996 – Section 34 and 37 – Challenge to arbitral award – Improper constitution of arbitral tribunal – Interpretation of Clause 8.3(b) of the agreement – Co-arbitrators’ power to appoint the presiding arbitrator after 30 days – High Court’s upholding of arbitral tribunal’s decision – Appeals dismissed.

2026 INSC 228 SUPREME COURT OF INDIA DIVISION BENCH MUNICIPAL CORPORATION OF GREATER MUMBAI Vs. M/S R.V. ANDERSON ASSOCIATES LIMITED ( Before : J.K. Maheshwari and Atul S. Chandurkar, JJ.…

Service Matters

Police Recruitment — Criminal Antecedents — Suitability for Appointment — A candidate with criminal antecedents, even if acquitted by giving benefit of doubt, can be deemed unsuitable for police service by the screening committee, as the employer has the right to assess character and integrity for a disciplined force.

2026 INSC 225 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF MADHYA PRADESH AND OTHERS Vs. RAJKUMAR YADAV ( Before : Ahsanuddin Amanullah and N.V. Anjaria, JJ. ) Civil…

Service Matters

Tamil Nadu Electricity Board Service Regulations, 1967 — Regulations 10(9), 87, and 97 — Seniority of direct recruits — Determination of date of appointment — A person is considered on ‘duty’ when performing duties of a post or undergoing probation or training — Appointed to a class of service when discharging duties or commencing probation or training — Seniority is determined by rank in the approved list; probation starts from joining duty — Training is part of service, not a reason to exclude it from seniority calculation. — Division Bench misinterpreted Regulations by stating seniority commences from probation start date — Appeals allowed, High Court judgment set aside.

2026 INSC 229 SUPREME COURT OF INDIA DIVISION BENCH M. THANIGIVELU AND OTHERS Vs. TAMIL NADU ELECTRICITY BOARD AND OTHERS ( Before : Rajesh Bindal and Vijay Bishnoi, JJ. )…

Companies Act, 2013 — Sections 241, 242, 244, 59 — Oppression and mismanagement — Interim protection — Supreme Court’s role is to preserve the subject matter of the dispute until the competent forum adjudicates the matter — Interim measures should ensure that the subject matter remains protected while allowing the statutory forum to proceed with adjudication.

2026 INSC 226 SUPREME COURT OF INDIA DIVISION BENCH MONIVEDA CONSULTANTS LLP AND ANOTHER Vs. SHAJAS DEVELOPERS PRIVATE LIMITED AND OTHERS ( Before : Dipankar Datta and Augustine George Masih,…

Indian Penal Code, 1860 (IPC) — Section 302/149 — Murder — Conviction and sentence for life imprisonment — Unlawful assembly and common object — Accused alighting from a bus together, armed with firearms, establishes unlawful assembly with a common object — Vicarious liability under Section 149 IPC applies to all members of the unlawful assembly — Presence in the assembly is sufficient for conviction even without overt acts by each individual.

2026 INSC 224 SUPREME COURT OF INDIA DIVISION BENCH DABLU ETC. AND OTHERS Vs. STATE OF MADHYA PRADESH ( Before : Pankaj Mithal and S.V.N. Bhatti, JJ. ) Criminal Appeal…

Criminal Law — Investigation — Overzealous or lethargic investigation can be fatal to prosecution — A proper investigation requires drawing up a scene mahazar, forensic examination, independent witnesses, and thorough examination of the cause of fire — The failure to do so, coupled with contradictory statements from the investigating officer and undue haste in recording statements, can render the investigation a sham and prejudice the accused — Acquittal upheld by the Supreme Court due to flawed investigation and lack of credible evidence.

2026 INSC 223 SUPREME COURT OF INDIA DIVISION BENCH SANJAY KUMAR SHARMA Vs. STATE OF BIHAR AND OTHERS ( Before : Sanjay Kumar and K. Vinod Chandran, JJ. ) Criminal…

Service Matters

Rights of Persons with Disabilities Act, 2016 (RPwD Act) — Disability — Mental Illness and Specific Learning Disability — Post of Auditor in CAG — Identified as not suitable for persons with benchmark disabilities suffering from mental illness, but later identified as suitable for Group C posts of Assistant (Audit) and Auditor-II through Notification dated 4th January, 2021 — Court directs accommodation in suitable Group C posts.

2026 INSC 232 SUPREME COURT OF INDIA DIVISION BENCH SUDHANSHU KARDAM Vs. COMPTROLLER AND AUDITOR GENERAL OF INDIA AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. )…

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