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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.

Negotiable Instruments Act, 1881 — Section 138 — Dishonour of cheque — Quashing of proceedings — Cheques issued as security and not for consideration — Memorandum of Understanding (MOU) clearly stated cheques were for security purposes to show banks and not for deposit — Complainant failed to read the complete terms of MOU in isolation and misinterpreted it to claim cheques were converted into debt — Court empowered to consider unimpeachable documents at pre-trial stage to prevent injustice — Complaints under Section 138 NI Act liable to be quashed.

2025 INSC 1270 SUPREME COURT OF INDIA DIVISION BENCH K. NAGENDRA Vs. THE NEW INDIA INSURANCE CO. LTD. AND OTHERS ( Before : Sanjay Karol and Prashant Kumar Mishra, JJ.…

Tender Conditions — Interpretation — Ambiguity — The terms of a tender must be clear and unambiguous — If a tendering authority intends for a specific document to be issued by a particular authority, it must be clearly stated in the tender conditions — Failure to do so may lead to rejection of the bid being deemed arbitrary and dehors the tender terms.

2025 INSC 1276 SUPREME COURT OF INDIA 2 JUDGES BENCH KIMBERLEY CLUB PVT. LTD. Vs. KRISHI UTPADAN MANDI PARISHAD AND OTHERS ( Before : Surya Kant and Joymalya Bagchi, JJ.…

Public Interest Litigation (PIL) — Environmental Protection — Monitoring Committee — Powers and Scope — A PIL was filed concerning environmental issues in Delhi, leading to the appointment of a Monitoring Committee. The Supreme Court clarified that the committee was appointed to prevent misuse of residential premises for commercial purposes and not to interfere with residential premises used as such. Their power was limited to making suggestions to a Special Task Force regarding encroachments on public land, not to summarily seal premises.

2025 INSC 1274 SUPREME COURT OF INDIA 2 JUDGES BENCH M.C. MEHTA Vs. UNION OF INDIA AND OTHERS ( Before : B. R. Gavai, CJI. and K. Vinod Chandran, J.…

Service Matters

Right of Children to Free and Compulsory Education Act, 2009 — Section 23 — Minimum qualifications for teachers — Teacher Eligibility Test (TET) — Amendment extending deadline for unqualified teachers to acquire minimum qualifications — Termination of teachers appointed before amendment for not possessing TET at the time of appointment — Held: Termination erroneous as teachers acquired TET within extended deadline.

2025 INSC 1273 SUPREME COURT OF INDIA 2 JUDGES BENCH UMA KANT AND ANOTHER Vs. STATE OF U.P. AND OTHERS ( Before : B.R. Gavai, CJI. and K. Vinod Chandran,…

Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 — Section 179 — Summoning of Advocate by Investigating Agency — Advocate representing accused cannot be summoned directly to elicit case details as it violates advocate-client privilege and constitutional rights of the accused, unless specific exceptions under Section 132 of the Bharatiya Sakshya Adhiniyam (BSA) apply.

2025 INSC 1275 SUPREME COURT OF INDIA 3 JUDGES BENCH IN RE: SUMMONING ADVOCATES WHO GIVE LEGAL OPINION OR REPRESENT PARTIES DURING INVESTIGATION OF CASES AND RELATED ISSUES. ( Before…

Arbitration and Conciliation Act, 1996 — Section 34 — Setting aside of arbitral award — Delay in pronouncement — While undue and unexplained delay in pronouncing an arbitral award is not a ground, in itself, to set it aside, it can lead to the award being vitiated if the delay adversely affects the final decision and reflects on the findings, making it conflict with public policy or be patently illegal.

2025 INSC 1277 SUPREME COURT OF INDIA 2 JUDGES BENCH M/S. LANCOR HOLDINGS LIMITED Vs. PREM KUMAR MENON AND OTHERS ( Before : Sanjay Kumar and Satish Chandra Sharma, JJ.…

Transfer of Property Act, 1882 — Sections 54, 55 — Agreement to Sell vs. Sale Deed — An agreement to sell by itself does not create any interest or charge on the property. Ownership passes only upon execution of a conveyance (sale deed). An agreement to sell, even with possession, is not a conveyance and does not confer title or transfer interest, except for the limited right under Section 53-A for protection against the transferor.

2025 INSC 1245 SUPREME COURT OF INDIA DIVISION BENCH ZOHARBEE AND ANOTHER Vs. IMAM KHAN (D) THR. LRS. AND OTHERS ( Before : Sanjay Karol and Prashant Kumar Mishra, JJ.…

Criminal Procedure Code, 1973 (CrPC) — Suspension of Sentence — Bail Pending Appeal — Appellant incarcerated for over seven and a half years, appeal pending before High Court for years — Sufficient grounds exist for suspension of sentence and release on bail during appeal pendency — Order of High Court declining to suspend sentence set aside

SUPREME COURT OF INDIA DIVISION BENCH MUNCHUN KHAN Vs. THE STATE OF BIHAR ( Before : Dipankar Datta and Augustine George Masih, JJ. ) Criminal Appeal No….of 2025 [Arising out…

Bharatiya Nyaya Sanhita, 2023 — Sections 298, 299, 296, 115(2), 351(2) & Chhattisgarh Religion Act, 1968 — Section 4 — Bail in anticipation of arrest — Appellant joined investigation as directed by the court — High Court rejected bail application — Supreme Court considered materials on record and found appeal deserving acceptance — Appellant admitted to bail in anticipation of arrest.

SUPREME COURT OF INDIA DIVISION BENCH RAJESH SHARMA Vs. THE STATE OF CHHATTISGARH ( Before : Dipankar Datta and Augustine George Masih, JJ. ) Criminal Appeal No.4561/2025 [Arising out of…

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