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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 302 read with 34, 148, and 341 — Murder —Appeal against reversal of acquittal — Appellate court’s duty in overturning acquittal — Trial court’s acquittal based on “imaginary and illusionary reasons” and misappreciation of evidence, including attributing undue significance to minor contradictions and perceived manipulation of delayed FIR submission, justifies reversal by High Court. (Paras 31, 45, 46, 52)

2025 INSC 1478 SUPREME COURT OF INDIA DIVISION BENCH PATCHAIPERUMAL @ PATCHIKUTTI AND ANOTHER Vs. STATE REP. BY INSPECTOR OF POLICE AND ANOTHER ( Before : Dipankar Datta and Augustine…

Service Matters

Service Law — Central Industrial Security Force (CISF) Rules, 2001 — Rule 18(b) — Recruitment: Disqualification — Second Marriage — Rule 18(b) disqualifies a person who, having a spouse living, has entered into or contracted a marriage with another person from appointment to the Force — Respondent, a CISF Constable, was dismissed from service for marrying a second time while his first marriage subsisted, violating Rule 18(b) — Held, the rule is a service condition intended to maintain discipline, public confidence, and integrity in the Force, and is not a moral censure — The rule is clear and mandatory, and the maxim “dura lex sed lex” (the law is hard, but it is the law) applies — The statutory rule prescribing penal consequences must be strictly construed — Dismissal upheld. (Paras 2, 3, 7, 9)

2025 INSC 1479 SUPREME COURT OF INDIA DIVISION BENCH UNION OF INDIA AND OTHERS Vs. PRANAB KUMAR NATH ( Before : Sanjay Karol and Vipul M. Pancholi, JJ. ) Civil…

Penal Code, 1860 (IPC) — Section 366A, 372, 373, 34 — Immoral Traffic (Prevention) Act, 1956 (ITPA) — Section 3, 4, 5, 6 — Child Trafficking and Commercial Sexual Exploitation — Evidence of Minor Victim — Appreciation of Evidence — Concurrent findings of fact by Trial Court and High Court regarding conviction for procuring and sexually exploiting a minor victim upheld — Prosecution case substantially corroborated by testimony of minor victim (PW-13), decoy witness (PW-8), independent witness (PW-12), and recovery of incriminating articles — Minor contradictions in testimony (e.g., about forcible sexual intercourse causing injury, or apartment topography) do not vitiate the prosecution case, as the consistent version of the victim establishes procurement for sexual exploitation. (Paras 5, 6, 8, 9, 10, 12, 13)

2025 INSC 1473 SUPREME COURT OF INDIA DIVISION BENCH K.P. KIRANKUMAR @ KIRAN Vs. STATE BY PEENYA POLICE ( Before : Manoj Misra and Joymalya Bagchi, JJ. ) Criminal Appeal…

Criminal Procedure Code, 1973 (CrPC) — Section 439(2) — Cancellation of Bail — Annulment of Bail — Distinction — Cancellation of bail is generally based on supervening circumstances and post-bail misconduct; Annulment of an order granting bail is warranted when the order is vitiated by perversity, illegality, arbitrariness, or non-application of mind — High Court granted bail ignoring prior cancellation of bail due to commission of murder by accused (while on bail) of a key witness in the first case, and failed to consider the gravity of offenses (including under SC/ST (POA) Act) and threat to fair trial — Such omissions and reliance on irrelevant considerations (existence of civil dispute) render the bail order perverse and unsustainable, justifying annulment by the Supreme Court. (Paras 12, 12.1, 12.2, 12.4, 12.5)

2025 INSC 1483 SUPREME COURT OF INDIA DIVISION BENCH LAKSHMANAN Vs. STATE THROUGH THE DEPUTY SUPERINTENDENT OF POLICE AND OTHERS ( Before : B.V. Nagarathna and R. Mahadevan, JJ. )…

Environmental Law — Wildlife Protection and Conservation — Protection of Great Indian Bustard (GIB) and Lesser Florican (LF) — Conflict between conservation goals and green energy generation (solar/wind) — Supreme Court modified earlier blanket prohibition on overhead transmission lines based on Expert Committee recommendations to balance non-negotiable preservation of GIB with sustainable development and India’s international climate change commitments — Importance of domain expert advice in policy matters concerning conservation and infrastructure development affirmed. (Paras 6, 14, 15, 60, 61)

2025 INSC 1472 SUPREME COURT OF INDIA DIVISION BENCH M.K. RANJITSINH AND OTHERS Vs. UNION OF INDIA AND OTHERS ( Before : Pamidighantam Sri Narasimha and Atul S. Chandurkar, JJ.…

Criminal Procedure Code, 1973 (CrPC) — Quashing of FIR — Protection from Arrest — Directions for time-bound investigation — High Court, while declining to quash the FIR, directed the completion of investigation within 90 days and granted protection from arrest till the court takes cognizance (following ‘Shobhit Nehra v. State of U.P.’) — ‘Legality’: Such directions granting protection from arrest while refusing to quash are contrary to the law established by the Supreme Court, particularly ‘Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra’ and ‘State of Telangana v. Habib Abdullah Jeelani’ — Granting protection from arrest in this manner amounts to an order under Section 438 CrPC (Anticipatory Bail) without satisfying the statutory conditions and is legally unsustainable and inappropriate — High Courts must scrupulously avoid passing blanket orders of “no arrest” or “no coercive steps” while dismissing or disposing of quashing petitions under Section 482 CrPC or Article 226 of the Constitution. (Paras 4, 15, 16)

2025 INSC 1480 SUPREME COURT OF INDIA DIVISION BENCH STATE OF U.P. AND ANOTHER Vs. MOHD ARSHAD KHAN AND ANOTHER ( Before : Sanjay Karol and Nongmeikapam Kotiswar Singh, JJ.…

Rajasthan Land Revenue Act, 1956 — Section 16 — Creation of Revenue Villages — Naming Convention — Circular dated 20.08.2009, Clause 4 — Policy regarding naming — Clause 4 mandates that the name of a new Revenue Village shall not be based on any person, religion, caste, or sub-caste — Names “Amargarh” and “Sagatsar” derived from names of individuals (Amarram and Sagat Singh) — Naming is in contravention of the policy circular — Policy decisions, even if executive in nature, bind the Government, and any action taken in derogation thereof (without lawful amendment or justification) is arbitrary and violative of Article 14 of the Constitution of India, 1950 — Notification dated 31.12.2020 creating ‘Amargarh’ and ‘Sagatsar’ is void to the extent it contravenes the binding policy. (Paras 15, 16, 17)

2025 INSC 1482 SUPREME COURT OF INDIA DIVISION BENCH BHIKA RAM AND ANOTHER Vs. STATE OF RAJASTHAN AND OTHERS ( Before : Sanjay Kumar and Alok Aradhe, JJ. ) Civil…

Criminal Procedure Code, 1973 (CrPC) — Section 482 — Quashing of criminal proceedings — Penal Code, 1860 (IPC) — Section 498A (Cruelty by husband or relatives) — Dowry Prohibition Act, 1961 (DP Act) — Sections 3 and 4 (Penalty for giving/taking/demanding dowry) — Allegations of matrimonial discord and cruelty — High Court refused to quash FIR and consequent complaint case against husband (appellant) for Section 498A IPC and DP Act charges, despite quashing proceedings against all other in-laws — Supreme Court held that the allegations, including financial dominance (forcing maintenance of excel sheet of expenses) or taunts about weight postpartum, reflect “daily wear and tear of marriage” and cannot be categorised as ‘cruelty’ or warrant criminal prosecution, especially where other family members have been exonerated — Criminal litigation cannot be a tool for personal vendettas. (Paras 4, 11, 23)

2025 INSC 1471 SUPREME COURT OF INDIA DIVISION BENCH BELIDE SWAGATH KUMAR Vs. STATE OF TELANGANA AND ANOTHER ( Before : B.V. Nagarathna and R. Mahadevan, JJ. ) Criminal Appeal…

M.P. Land Revenue Code, 1959 (MPLRC) — Sections 109, 110 — Mutation of Land Records — Acquisition of Right — Mutation based on a Will — The MPLRC and the Madhya Pradesh Bhu-Rajasv Sanhita (Bhu-Abhilekhon Mein Namantaran) Niyam, 2018, do not prohibit mutation based on a registered will; application for mutation based on a will must be considered on merits — Full Bench decision of the High Court confirmed that an application for mutation based on a will cannot be rejected at the threshold — Where no serious dispute is raised by the natural legal heirs of the deceased tenure holder, mutation based on a will should not be denied. (Paras 15, 18, 19, 21)

2025 INSC 1485 SUPREME COURT OF INDIA DIVISION BENCH TARACHANDRA Vs. BHAWARLAL AND ANOTHER ( Before : Sanjay Karol and Manoj Misra, JJ. ) Civil Appeal No. 15077 of 2025…

Specific Relief Act, 1963 — Section 28 (1) — Decree for specific performance — Payment of purchase money — Extension of time — Execution of decree — Where a decree for specific performance allows a period for the purchaser to pay the purchase money, the court has the power under Section 28(1) to extend this time on such terms as it deems fit — The power to extend time for performance of the conditions of the decree cannot be the end of the transaction, and adopting a hyper-technical approach that treats non-extension as final ought to be eschewed — The real test is whether the plaintiff’s conduct amounts to a positive refusal to complete their part of the contract. (Paras 5, 7)

2025 INSC 1486 SUPREME COURT OF INDIA DIVISION BENCH DR. AMIT ARYA Vs. KAMLESH KUMARI ( Before : Sanjay Karol and Manoj Misra, JJ. ) Civil Appeal No…..of 2025 (Arising…

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