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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.
Service Matters

Service Law — Termination of Contractual Service — Qualifications — Interpretation of Educational Qualifications — Advertisement requiring “Postgraduate degree in Statistics” — Appellant holding M.Com. degree with Business Statistics and Indian Economic Statistics as principal subjects — Where no Government university offers a degree exclusively titled “Postgraduate degree in Statistics,” insisting solely on the title of the degree, without considering the actual curriculum, amounts to elevating form over substance — The interpretation must be contextual and purposive — Termination based solely on the title of the degree, ignoring expert opinion (Director, W.S.O., S.W.M., P.H.E.D.) that the appellant meets the requirement and the University certificate confirming inclusion of Statistics as principal subjects, is arbitrary and unreasonable. (Paras 3, 4, 31, 32, 37, 44)

2025 INSC 1385 SUPREME COURT OF INDIA DIVISION BENCH LAXMIKANT SHARMA Vs. STATE OF MADHYA PRADESH AND OTHERS ( Before : Sanjay Karol and Vipul M. Pancholi, JJ. ) Civil…

Contempt of Court — Initiating contempt proceedings — Clear and unequivocal terms of the underlying order — A Contempt Petition can be dismissed summarily only if the underlying order, the non-compliance of which is alleged, is genuinely unclear, ambiguous, or susceptible to two equally reasonable interpretations — Where the High Court dismissed a Contempt Petition holding that the underlying order was capable of two interpretations, but the Supreme Court found, upon reading the order as a whole, that there were clear and categorical directions and recorded statements regarding handing over of possession and payment of compensation, the dismissal of the Contempt Petition was erroneous. (Paras 1, 7, 8, 9, 10)

2025 INSC 1379 SUPREME COURT OF INDIA DIVISION BENCH BHASKAR GOVIND GAVATE (NOW DECEASED) THROUGH HIS LEGAL HEIRS. Vs. THE STATE OF MAHARASHTRA AND OTHERS ( Before : Pamidighantam Sri…

Goods and Services Tax (GST) — Exemption Notification — Notification No. 9/2017- Integrated Tax (Rate) dated 28.06.2017 — Entry 13 — Exemption on services by way of renting of residential dwelling for use as residence — Renting residential property as hostel to students/working professionals — Conditions for exemption: renting service, residential dwelling, and use as residence — The term “residential dwelling” is not defined under GST laws but refers to any residential accommodation for long-term stay, excluding commercial places, hotels, guesthouses for temporary stay — Property comprising 42 rooms rented out and sub-leased for use as hostel accommodation is considered a “residential dwelling” as its nature and use remain residential, not commercial accommodation like a hotel. (Paras 36, 46, 47, 50)

2025 INSC 1380 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF KARNATAKA AND ANOTHER Vs. TAGHAR VASUDEVA AMBRISH AND ANOTHER ( Before : J.B. Pardiwala and K.V. Viswanathan, JJ.…

Arbitration and Conciliation Act, 1996 — Section 31(7)(a) and (b) — Power of Arbitral Tribunal to grant interest — Party Autonomy — Pre-award (pendente lite) interest — Section 31(7)(a) mandates that the Arbitral Tribunal’s discretion to award interest on the sum awarded (from date cause of action arose till date of award) is subject to the agreement between the parties (“unless otherwise agreed by the parties”) — When parties specify a contractual rate of interest in the agreement, subject to no legal bar, this stipulation takes precedence over the Arbitrator’s discretion to deem a rate “reasonable” — Arbitral Tribunal is bound by the contractual terms regarding interest once agreed upon, and the borrower cannot later challenge the rate as unconscionable or against public policy, especially in commercial transactions between parties of equal bargaining power — Post-award interest is governed by Section 31(7)(b) (Paras 51, 53, 56, 64, 65, 70).

2025 INSC 1380 SUPREME COURT OF INDIA DIVISION BENCH BPL LIMITED Vs. MORGAN SECURITIES AND CREDITS PRIVATE LIMITED ( Before : J.B. Pardiwala and Sandeep Mehta, JJ. ) Civil Appeal…

Criminal Procedure Code, 1973 (CrPC) — Section 319 — Summoning of Additional Accused — Nature and Scope of Power — The power under Section 319 CrPC is extraordinary and discretionary, intended to be exercised sparingly, but it is an enabling provision aimed at ensuring that no guilty person escapes the process of law — The prerequisite for its exercise is that it must appear from the evidence adduced during inquiry or trial that a person not already arraigned as an accused has committed an offence — The object is to ensure a fair and complete trial and give effect to the maxim ‘judex damnatur cum nocens absolvitur’ (Judge is condemned when guilty is acquitted). (Paras 6, 7)

2025 INSC 1386 SUPREME COURT OF INDIA DIVISION BENCH NEERAJ KUMAR @ NEERAJ YADAV Vs. STATE OF U.P. AND OTHERS ( Before : Sanjay Karol and Nongmeikapam Kotiswar Singh, JJ.…

Arbitration and Conciliation Act, 1996 — Sections 34 and 37 — Arbitral Award — Excepted or Prohibited Claims — Contractual clauses barring certain claims (e.g., for idle labour, idle machinery, business loss) — Judicial review of awards involving prohibited claims — Applicability of such clauses primarily depends on the agreement between the parties, guided by the principle of party autonomy — Arbitral Tribunal and Courts must rely on the contract as the foundation of the legal relationship — High Court setting aside Civil Court order (under Section 34) and restoring award (under Section 37) solely based on precedent (Bharat Drilling) without independent contractual analysis is flawed — Reinstating claims (underutilised overheads, loss due to underutilised tools/machinery, loss of profit) barred by specific contractual provisions (Clauses 4.20.2, 4.20.4) is incorrect if based only on flawed precedent. (Paras 4, 5, 6, 8, 9)

2025 INSC 1388 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF JHARKHAND Vs. THE INDIAN BUILDERS JAMSHEDPUR ( Before : Pamidighantam Sri Narasimha and Atul S. Chandurkar, JJ. )…

Stamp Act, 1899 — Section 9A (inserted by Indian Stamp (Bihar Amendment) Act, 1988) — Exemption of Stamp Duty — Cooperative Societies — Transfer of Premises to Members — Jharkhand Self-Supporting Cooperative Societies Act, 1996 — Section 5(7) — Conclusive Evidence — Mandating recommendation from Assistant Registrar, Cooperative Society, as a prerequisite for granting stamp duty exemption under Section 9A is illegal and ultra vires because the certificate of registration issued under Section 5(7) of the 1996 Act is conclusive proof of the society’s existence, rendering the additional requirement superfluous, unnecessary, and based on irrelevant consideration. (Paras 2.2, 3, 4, 11, 12, 13, 14, 15)

2025 INSC 1389 SUPREME COURT OF INDIA DIVISION BENCH ADARSH SAHKARI GRIH NIRMAN SWAWLAMBI SOCIETY LTD. Vs. THE STATE OF JHARKHAND AND OTHERS ( Before : Pamidighantam Sri Narasimha and…

Service Matters

General Provident Fund (Central Service) Rules, 1960 — Rules 5(5), 5(6), 33 and Note 2 to Rule 476(V) of Official Manual (Part V) — Interpretation — While Rules 5(5) and 5(6) read together do not automatically cancel a nomination where the subscriber fails to send a notice of cancellation and a fresh nomination — The express condition in the original nomination form stating it invalidates upon the subscriber acquiring a family renders the nomination void the moment the condition (marriage) occurs, triggering distribution under Rule 33(i)(b) to all family members in equal shares. (Paras 5, 7, 8)

2025 INSC 1391 SUPREME COURT OF INDIA DIVISION BENCH SMT. BOLLA MALATHI Vs. B. SUGUNA AND OTHERS ( Before : Sanjay Karol and Nongmeikapam Kotiswar Singh, JJ. ) Civil Appeal…

Hindu Marriage Act, 1955 — Section 13(1)(ia) — Divorce — Cruelty — Irretrievable breakdown of marriage — Parties living separately for more than thirteen years (since 2012) without any meaningful effort at reconciliation — Relationship deeply embittered and acrimonious — High Court confirmed dissolution of marriage considering the welfare of the parties and their child — Supreme Court affirmed the decree of divorce, holding that perpetuating a legal bond long ceased to have substance would only prolong hostility and impede ability to move forward with dignity, confirming dissolution is in the interest of justice and welfare of all concerned. (Paras 4, 6, 7, 13)

2025 INSC 1390 SUPREME COURT OF INDIA DIVISION BENCH SONIA VIRK Vs. ROHIT VATS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Civil Appeal No. 14856 of 2024…

Constitution of India, 1950 — Articles 14, 21 — Rights of Persons with Disabilities Act, 2016 (RPwD Act) — Substantive Equality and Inclusion — Scope and Spirit — The measure of a just society demands the removal of barriers for all citizens to realize their potential, transforming formal equality into substantive inclusion — Constitutional vision requires every person, regardless of physical or sensory limitation, to participate with dignity — Rights guaranteed to persons with disabilities are expressions of the constitutional promise of equality, dignity, and non-discrimination, not acts of benevolence. (Paras 1, 12, 13)

2025 INSC 1376 SUPREME COURT OF INDIA DIVISION BENCH MISSION ACCESSIBILITY Vs. UNION OF INDIA AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Writ Petition (C)…

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