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Delhi Municipal Corporation Act, 1957 — Section 59(d), 92 and 95(1) — Delhi Municipal Corporation Service (Control and Appeal) Regulations, 1959 — Regn. 7, Schedule — Disciplinary Authority — Competency of Commissioner to dismiss Group ‘A’ Officer — Substitution of Section 59(d) by Delhi Municipal Corporation (Amendment) Act, 1993, w.e.f. 01.10.1993 — Legislative Intent — Post-1993 amendment, the Commissioner is put in complete control both as the appointing authority and the disciplinary authority — Phrase “subject to any regulation that may be made in this behalf” used in Section 59(d) refers to regulations that may be made in future and not the existing 1959 Regulations — Commissioner held fully competent to pass dismissal orders against Group ‘A’ officers despite old regulations naming the ‘Corporation’ as the disciplinary authority. Constitution of India, 1950 — Art. 16 and 226 — Public Employment — Direct Recruitment — Eligibility Criteria — Workshop Experience — Pendency of workshop renewal applications — Effect on candidates — Where a recruitment notification mandates a minimum of one year of experience in a Government-approved workshop, candidates cannot be prejudiced or disqualified merely because the workshop’s application for renewal of approval was pending with the State authorities during the period they gained experience — Depriving an otherwise eligible candidate of employment due to an administrative “period of eclipse” or delay on the part of state machinery is arbitrary and discriminatory–Ashok Kumar Yadav v. State of Haryana, 1985 INSC 137, relied on; State of Uttar Pradesh v. Atul Kumar Dwivedi, 2022 INSC 24, Distinguished. Right to Information Act, 2005 — S. 24(4) — Madhya Pradesh Special Police Establishment Act, 1947 — S. 2(1), S. 3 — “Intelligence and Security Organisation” — Scope and Applicability of Exemption — Jurisdiction of Special Police Establishment (SPE) — The expression “intelligence and security organisations” under Section 24 of the RTI Act implies that the concerned entity must be statutory or institutionally empowered to handle matters of intelligence and national/state security — The Special Police Establishment (SPE) of Madhya Pradesh, established under Section 2(1) of the Act of 1947, is clothed with a limited jurisdiction restricted strictly to investigating offences punishable under the Prevention of Corruption Act, 1988, and select economic/fraud offenses under Sections 409, 420, and Chapter XVIII of the Indian Penal Code — Because neither the Lokayukt nor the SPE handles matters connected to general ‘intelligence’ and ‘security’, the SPE cannot be deemed an “intelligence and security organisation” under Section 24(4) of the RTI Act — Principle of institutional parity cannot be invoked to grant blanket exemptions to a anti-corruption investigation agency. Civil Procedure Code, 1908 (CPC) — Section 11, Explanation IV — Constructive Res Judicata — Application of the principle depends on the facts and circumstances of each case, considering the ambit of earlier proceedings and the nexus of the matter to the controversy — It is founded on public policy to prevent multiplicity of proceedings and avoid parties being vexed twice over for the same litigation — Parties are expected to exercise reasonable diligence and bring forward every point that properly belonged to the subject of litigation and which they might and ought to have brought forward — Negligence, inadvertence, or accident in omitting a part of the case does not exempt from its application. Motor Vehicles Act, 1988 — Section 165 and 166 — Liability for injuries sustained due to falling tree branch — Injuries caused by falling tree branch while vehicle was stationary under the tree during rain — Held, not an accident “arising out of the use of a motor vehicle” as the motor vehicle did not play an active role. [

Delhi Municipal Corporation Act, 1957 — Section 59(d), 92 and 95(1) — Delhi Municipal Corporation Service (Control and Appeal) Regulations, 1959 — Regn. 7, Schedule — Disciplinary Authority — Competency of Commissioner to dismiss Group ‘A’ Officer — Substitution of Section 59(d) by Delhi Municipal Corporation (Amendment) Act, 1993, w.e.f. 01.10.1993 — Legislative Intent — Post-1993 amendment, the Commissioner is put in complete control both as the appointing authority and the disciplinary authority — Phrase “subject to any regulation that may be made in this behalf” used in Section 59(d) refers to regulations that may be made in future and not the existing 1959 Regulations — Commissioner held fully competent to pass dismissal orders against Group ‘A’ officers despite old regulations naming the ‘Corporation’ as the disciplinary authority.

Constitution of India, 1950 — Art. 16 and 226 — Public Employment — Direct Recruitment — Eligibility Criteria — Workshop Experience — Pendency of workshop renewal applications — Effect on candidates — Where a recruitment notification mandates a minimum of one year of experience in a Government-approved workshop, candidates cannot be prejudiced or disqualified merely because the workshop’s application for renewal of approval was pending with the State authorities during the period they gained experience — Depriving an otherwise eligible candidate of employment due to an administrative “period of eclipse” or delay on the part of state machinery is arbitrary and discriminatory–Ashok Kumar Yadav v. State of Haryana, 1985 INSC 137, relied on; State of Uttar Pradesh v. Atul Kumar Dwivedi, 2022 INSC 24, Distinguished.

Arbitration and Conciliation Act, 1996 — Section 34 & 37 — Scope of Interference — Court’s jurisdiction under Section 34 is narrowly circumscribed and confined to specific grounds enumerated — Court cannot act as an appellate forum to correct factual errors or review merits — Arbitral Tribunal is master of evidence and interpretation of contracts — Interference is not warranted merely because an alternative view is possible, if the tribunal’s conclusion is plausible and can be arrived at by a reasonable person.

2026 INSC 590 SUPREME COURT OF INDIA DIVISION BENCH MADHYA PRADESH ROAD DEVELOPMENT CORPORATION LTD. THROUGH ITS MANAGING DIRECTOR Vs. M/S JABALPUR CORRIDOR PVT. LTD. THROUGH ITS MANAGING DIRECTOR (…

Arbitration Act, 1940 — Section 21 — Arbitration in suits — Mandatory requirement of court order of reference — For arbitration proceedings to be validly initiated or continued during pendency of a suit, parties must obtain an order of reference from the court under Section 21 — Failure to comply renders the award legally ineffective as a bar to the suit.

2026 INSC 591 SUPREME COURT OF INDIA DIVISION BENCH ASHOK AND OTHERS Vs. PADAM CHAND AND OTHERS ( Before : J.K. Maheshwari and Atul S. Chandurkar, JJ. ) Civil Appeal…

Land Acquisition Act, 1894 — Section 4 and 6 — Compensation for acquired land — Challenge to compensation awarded by High Court — Supreme Court upholds High Court’s decision based on a previous judgment dealing with the same acquisition and village — Appellant denied further enhancement.

2026 INSC 593 SUPREME COURT OF INDIA DIVISION BENCH GOPALA AGRI FARMS PVT. LTD. Vs. THE STATE OF HARYANA AND OTHERS ( Before : Surya Kant, CJI. and Nongmeikapam Kotiswar…

Service Matters

Right of Children to Free and Compulsory Education Act, 2009 (RTE Act) — Section 23 — Applicability to in-service teachers — Sub-section (1) governs eligibility for future appointments (prospective), while the first proviso to sub-section (2) specifically addresses teachers already in service, allowing them time to acquire qualifications — The second proviso, added by the 2017 Amendment Act, further extends this window for teachers appointed or in service as of March 31, 2015 — The legislative intent is to recognize existing appointments while providing a time-bound mechanism for qualification, not to invalidate past appointments retrospectively or impose immediate disqualification

2026 INSC 597 SUPREME COURT OF INDIA DIVISION BENCH STATE OF U.P. Vs. ANJUMAN ISHAAT-E-TALEEM TRUST AND OTHERS ( Before : Dipankar Datta and Manmohan, JJ. ) Review Petition (Civil)…

Evidence Act, 1872 — Section 133 and Illustration (b) to Section 114 — Accomplice Testimony — Testimony of an approver/accomplice is not illegal merely because it is uncorroborated, but as a rule of prudence, it is unsafe to convict solely on the basis of uncorroborated testimony — Corroboration must be in material particulars and should come from independent sources.

  2026 INSC 598 SUPREME COURT OF INDIA DIVISION BENCH GOPI CHAND @ PAPPU Vs. STATE (NCT OF DELHI) ( Before : Pamidighantam Sri Narasimha and Manoj Misra, JJ. )…

Succession Act, 1925 — Section 263 — Revocation of probate — Limitation — No specific period of limitation prescribed for application for revocation of probate — Article 137 of Limitation Act, 1963 applies — Right to apply accrues when applicant has knowledge of the facts justifying revocation.

2026 INSC 602 SUPREME COURT OF INDIA DIVISION BENCH DHIRAJ DUTTA Vs. ANIRBAN SEN AND OTHERS ( Before : Sanjay Karol and Vipul M. Pancholi, JJ. ) Civil Appeal No.…

Evidence Act, 1872 — Section 112 — Presumption of legitimacy — DNA test can be directed to determine paternity only when there is sufficient prima facie material to dislodge the presumption under Section 112.– Section 114(h) — Adverse inference — Not applicable at the stage where the Court is considering the need for a DNA test.

2026 INSC 600 SUPREME COURT OF INDIA DIVISION BENCH CHATURBHUJ PRADHAN Vs. AMAR PRADHAN AND ANOTHER ( Before : Sanjay Karol and Nongmeikapam Kotiswar Singh, JJ. ) Civil Appeal No…..of…

Constitution of India, 1950 — Articles 21, 32, 226 — Illegal detention — Definition — Illegal detention may be defined as the deprivation of liberty by the State without lawful authority or in violation of provisions of the Constitution — It involves actual custody such that the individual is not free to leave — The detention must lack a valid legal basis, including situations where authority is void or expired — Even where a law permits detention, it becomes illegal if the procedure followed is not just, fair and reasonable, including failure to observe essential safeguards — Also covers situations where the power to detain is exercised arbitrarily, for an improper purpose, or in bad faith.

2026 INSC 599 SUPREME COURT OF INDIA DIVISION BENCH DAUDAYAL Vs. THE STATE OF RAJASTHAN AND OTHERS ( Before : Sanjay Karol and Augustine George Masih, JJ. ) Criminal Appeal…

Service Matters

Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987 (1987 Act) — Section 51(2) — Principles of Natural Justice — Failure to supply charge memo and supporting documents to the appellant — Enquiry conducted ex-parte — Order of removal vitiated — High Court erred in holding that opportunity at show cause stage cured the defects — Supreme Court set aside the removal order, confirmation order, and enquiry report.

  2026 INSC 592 SUPREME COURT OF INDIA DIVISION BENCH ARJUN DASS Vs. THE STATE OF ANDHRA PRADESH AND OTHERS ( Before : J.K. Maheshwari and Atul S. Chandurkar, JJ.…

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