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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.

Prohibition of Benami Property Transactions Act, 1988 vs. Insolvency and Bankruptcy Code, 2016 — Jurisdiction — Orders passed under Benami Act cannot be questioned before authorities under IBC — NCLT lacks jurisdiction to entertain challenges to provisional attachment orders under Benami Act — Remedy lies exclusively before competent forum under Benami Act — IBC cannot be converted into a parallel appellate forum to review validity of attachment orders under specialised enactment — Doing so would render appellate machinery of Benami Act otiose.

2026 INSC 187 SUPREME COURT OF INDIA DIVISION BENCH S. RAJENDRAN Vs. THE DEPUTY COMMISSIONER OF INCOME TAX (BENAMI PROHIBITION) AND OTHERS ( Before : Pamidighantam Sri Narasimha and Atul…

Maharashtra Co-operative Societies Act, 1960 — Section 98 — Recovery Certificate — Sale under Section 98 — Mandatory Deposit — Rule 107(11)(h) of Maharashtra Co-operative Societies Rules, 1961 — Deposit of entire auction amount within 15 days of auction date is a mandatory condition — Failure amounts to void sale — Bank did not raise objection and accepted deposit after 15 days — Such acceptance does not waive the mandatory condition — Sale was void as the entire amount was not deposited within the stipulated period.

2026 INSC 197 SUPREME COURT OF INDIA DIVISION BENCH M/S. ADISHAKTI DEVELOPERS AND OTHERS Vs. THE STATE OF MAHARASTRA AND OTHERS ( Before : Pamidighantam Sri Narasimha and Manoj Misra,…

Prisoner Rights — Human Dignity and Rights — The strength of a constitutional democracy is tested not merely by the liberties it guarantees abstractly, but by the manner in which it treats those at its margins — Prisons, though instruments of lawful confinement, are not spaces where constitutional values cease to operate — The guarantee of life and personal dignity under Article 21 of the Constitution of India extends beyond prison gates, obliging the State to ensure that incarceration does not degenerate into inhumanity — Overcrowded prisons, bereft of humane living conditions and rehabilitative avenues, strike at the very core of this constitutional promise and call for sustained institutional response rather than sporadic remedial measures.

2026 INSC 198 SUPREME COURT OF INDIA DIVISION BENCH SUHAS CHAKMA Vs. UNION OF INDIA AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Writ Petition (C)…

Insolvency and Bankruptcy Code (IBC), 2016 — Sections 7 and 60(2) — Corporate Insolvency Resolution Process (CIRP) — Initiation against principal debtor and guarantor — Co-extensive liability — Creditor can initiate CIRP against both the principal debtor and guarantor simultaneously, and also file claims in the CIRP of both.

2026 INSC 201 SUPREME COURT OF INDIA DIVISION BENCH ICICI BANK LIMITED AND OTHERS Vs. ERA INFRASTRUCTURE (INDIA) LIMITED AND OTHERS ( Before : Dipankar Datta and Augustine George Masih,…

Criminal Procedure Code, 1973 (CrPC) — Section 468, 469, 473 — Limitation bars taking cognizance — Offence punishable with imprisonment for a term exceeding one year (Section 27(d) of Act) falls under Section 468(2)(c) of Cr.P.C. with limitation expiring after 3 years from the date the identity of the offender becomes known to the aggrieved party or police officer.

2026 INSC 200 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF KERALA AND ANOTHER Vs. M/S. PANACEA BIOTEC LTD. AND ANOTHER ( Before : Ahsanuddin Amanullah and S.V.N. Bhatti,…

Transfer of Property Act, 1882 — Section 105 — Lease vs. License — Determining the nature of a document is based on the substance and intention of the parties, not just its wording — A lease transfers an interest in land, while a license merely permits use without transferring ownership or interest.

2026 INSC 199 SUPREME COURT OF INDIA DIVISION BENCH THE GENERAL SECRETARY, VIVEKANANDA KENDRA Vs. PRADEEP KUMAR AGARWALLA AND OTHERS ( Before : Pankaj Mithal and S.V.N. Bhatti, JJ. )…

Penal Code, 1860 (IPC) — Sections 406, 420, 467, 468, 471 — Criminal Breach of Trust, Cheating, Forgery, Using Forged Document — Joint Venture Agreement — Dispute arising from JVA — FIR quashed — Allegations primarily civil in nature, with a criminal cloak — Dishonest intention not evident from the inception — Delay in lodging FIR indicates civil dispute — Security deposit not refundable, adjustable against share in sale proceeds — No false representation regarding title or litigation in JVA — Allegation of forgery of a tracing document unsubstantiated — Recourse to civil remedies should be taken for contractual disputes.

2026 INSC 192 SUPREME COURT OF INDIA DIVISION BENCH VANDANA JAIN AND OTHERS Vs. THE STATE OF UTTAR PRADESH AND OTHERS ( Before : Pamidighantam Sri Narasimha and Manoj Misra,…

Uttar Pradesh Zamindari Abolition and Land Reforms Act, 1950 — Section 123 — Regularisation of unauthorised occupation — Legal fiction created by Section 123(2) deems land settled with house owners in possession by a specific cut-off date, overriding Section 143 declaration — Regularisation is a socio-economic measure and is applicable even if houses were built forcefully or without consent.

2026 INSC 193 SUPREME COURT OF INDIA DIVISION BENCH RAM NARAIN (D) BY LRS. AND OTHERS Vs. THE SUB DIVISIONAL OFFICER AND OTHERS ( Before : S.V.N. Bhatti and R.…

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