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Constitution of India, 1950 — Article 226 — Writ jurisdiction — Maintainability — Inclusion of advocate’s name in IBA “Caution List” — High Court dismissing writ petition on ground that Indian Banks’ Association (IBA) is not “State” under Art. 12 — Held, focus of maintainability has shifted from formal character of respondent body to nature of function performed and effect of impugned action on legally protected rights — Caution List operates as sector-wide adverse accreditation mechanism with public law element, having direct bearing on advocate’s right to practise profession under Art. 19(1)(g) — Writ petition against IBA held maintainable notwithstanding IBA not being “State” — Kishor S. Bhat v. Indian Banks’ Association, 2018 SCC OnLine Bom 2857, distinguished — Andi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691; Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649; S. Shobha v. Muthoot Finance Ltd., 2025 SCC OnLine SC 177, relied on. Civil Procedure Code, 1908 (CPC) — Section 100 — Second appeal — Scope of interference with concurrent findings on genuineness of a Will — Whether suspicious circumstances surrounding execution of a Will exist, and stand explained, is essentially a question of fact; a second appellate court cannot re-appreciate evidence and substitute its own view merely because another view is possible — Interference is permissible only where the finding is perverse, based on circumstances that are mere “figments of a doubting mind,” or is vitiated by an erroneous placement of onus — High Court exceeded its jurisdiction under S. 100 CPC in reversing well-reasoned concurrent findings of the Trial Court and First Appellate Court discarding the Will. Criminal Procedure Code, 1973 — Sections 209, 244 — Commitment of case exclusively triable by Court of Session — Whether Magistrate is required to record prosecution evidence under Section 244 CrPC before committing such a case, where the complaint is one instituted otherwise than on a police report — Held, no — Section 244 CrPC, which mandates the Magistrate to hear the prosecution and take evidence, occurs in Chapter XIX (Part B — “Cases instituted otherwise than on a police report”) and governs warrant-case trials before a Magistrate; it has no application where the offence (here, under Section 302 IPC) is exclusively triable by the Court of Session, which is governed instead by Section 209 CrPC — Under the scheme of the 1973 Code (unlike the erstwhile 1898 Code, which mandated a full committal inquiry with recording of evidence under Section 207-A), the Magistrate’s role at the pre-commitment stage is confined to ascertaining whether the offence is exclusively triable by the Sessions Court, and no evidence need be taken or evaluated by the Magistrate at that stage — Requiring witnesses to depose twice, once before the Magistrate and again before the Sessions Court, would serve no purpose and is not the mandate of law — High Court’s contrary view, requiring compliance with Section 244 CrPC even in a Sessions-triable case, proceeds on an erroneous reading of law and is unsustainable. Motor Vehicles Act, 1988 — Sections166, 168 — Compensation — Assessment of annual income of a self-employed deceased (wholesale grocery business) — Two ITRs filed after the death of the deceased excluded by the High Court altogether from the assessment of income — Held, following the principles in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], ITRs filed post-death call for closer scrutiny with reference to surrounding financial statements, since income may be inflated in such returns, but such returns are not to be excluded outright merely for being filed post-death — In the absence of the benefit of such surrounding financial statements on record, and it being inexpedient at this stage to remand the matter, annual income fixed with reference to the nature of the deceased’s wholesale grocery business at Rs.3,25,000 — Compensation recomputed applying 40% addition for future prospects (age 28 years), 1/4th deduction for personal expenses, and a multiplier of 17, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.60,79,550 (as against Rs.15,36,560 awarded by the Tribunal and Rs.38,40,850 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed. Motor Vehicles Act, 1988 — Sections 166, 168 — Compensation — Assessment of annual income of a self-employed deceased (Insurance Agent) from Income Tax Returns — High Court had averaged the last four ITRs on record — Held, erroneous — Following the principles laid down in Rashmirekha Tripathy and Anr. v. The Branch Manager (Legal Claims), Sriram General Insurance Company Limited and Ors. [C.A. @ SLP(C) No.27220 of 2024, 2026 INSC 661], for a self-employed person the average of up to the previous three years’ ITRs, not four, is the appropriate reference point — A performance-linked spike in the income of an Insurance Agent in a particular year does not justify reaching back to an additional, earlier ITR to dilute that spike — On the facts, taking the average of the income for AY 2015-16 (Rs.4,03,180), AY 2016-17 (Rs.9,59,665) and AY 2017-18 (Rs.7,00,559), annual income assessed at Rs.6,87,802 — Compensation recomputed applying 25% addition for future prospects (age 49 years), 1/4th deduction for personal expenses, and a multiplier of 13, together with conventional heads (loss of estate, funeral expenses, consortium) — Total compensation enhanced to Rs.87,09,282 (as against Rs.49,77,000 awarded by the Tribunal and Rs.76,09,500 awarded by the High Court), with interest as awarded by the Tribunal — Appeal allowed.

Constitution of India, 1950 — Article 226 — Writ jurisdiction — Maintainability — Inclusion of advocate’s name in IBA “Caution List” — High Court dismissing writ petition on ground that Indian Banks’ Association (IBA) is not “State” under Art. 12 — Held, focus of maintainability has shifted from formal character of respondent body to nature of function performed and effect of impugned action on legally protected rights — Caution List operates as sector-wide adverse accreditation mechanism with public law element, having direct bearing on advocate’s right to practise profession under Art. 19(1)(g) — Writ petition against IBA held maintainable notwithstanding IBA not being “State” — Kishor S. Bhat v. Indian Banks’ Association, 2018 SCC OnLine Bom 2857, distinguished — Andi Mukta Sadguru Shree Muktajee Vandas Swami Suvarna Jayanti Mahotsav Smarak Trust v. V.R. Rudani, (1989) 2 SCC 691; Zee Telefilms Ltd. v. Union of India, (2005) 4 SCC 649; S. Shobha v. Muthoot Finance Ltd., 2025 SCC OnLine SC 177, relied on.

Civil Procedure Code, 1908 (CPC) — Section 100 — Second appeal — Scope of interference with concurrent findings on genuineness of a Will — Whether suspicious circumstances surrounding execution of a Will exist, and stand explained, is essentially a question of fact; a second appellate court cannot re-appreciate evidence and substitute its own view merely because another view is possible — Interference is permissible only where the finding is perverse, based on circumstances that are mere “figments of a doubting mind,” or is vitiated by an erroneous placement of onus — High Court exceeded its jurisdiction under S. 100 CPC in reversing well-reasoned concurrent findings of the Trial Court and First Appellate Court discarding the Will.

Competition Act, 2002 — Sections 3(1), 3(3)(b), 27, 48 — Anti-competitive agreements — Penalty on office-bearers — Principles of natural justice — Show cause notice — Opportunity of hearing — Commission’s power to differ with DG — Competent to impose penalties and behavioural remedies on individuals responsible for contravention after due process.

2025 INSC 1167 SUPREME COURT OF INDIA DIVISION BENCH COMPETITION COMMISSION OF INDIA Vs. KERALA FILM EXHIBITORS FEDERATION AND OTHERS ( Before : Manoj Misra and K. V. Viswanathan, JJ.…

Criminal Procedure Code, 1973 (CrPC) — Section 482 — Quashing of FIR — Essential conditions — If allegations in FIR or complaint, even if taken at face value, do not prima facie constitute an offence or make out a case against the accused, quashing is justified — Vague and general allegations are insufficient to establish a prima facie case.

2025 INSC 1168 SUPREME COURT OF INDIA FULL BENCH SANJAY D. JAIN AND OTHERS Vs. STATE OF MAHARASHTRA AND OTHERS ( Before : B.R. Gavai, CJI., K. Vinod Chandran and…

Criminal Procedure Code, 1973 (CrPC) — Section 482 — Quashing of FIR — High Court’s power to quash — While High Court should not conduct a mini-trial at the stage of quashing proceedings, an order of quashing based on justifiable reasons cannot be set aside simply due to its length or detailed reasoning.

2025 INSC 1173 SUPREME COURT OF INDIA DIVISION BENCH THE STATE OF TELANGANA Vs. JERUSALEM MATHAI AND ANOTHER ( Before : B.R. Gavai, CJI. and K. Vinod Chandran, JJ. )…

Motor Vehicles Act, 1988 — Sections 166, 173 — Award of Tribunal reversed by High Court — Claimant appealing — Death in hit and run accident alleged — Victim’s family claiming compensation — Husband of first appellant died in alleged accident — Accident witnessed by neighbour — High Court found accident and vehicle involvement not proved — Appeal dismissed.

2025 INSC 1176 SUPREME COURT OF INDIA DIVISION BENCH RAJAMMA AND OTHERS Vs. M/S. RELIANCE GENERAL INSURANCE CO. LTD. AND ANOTHER ( Before : K. Vinod Chandran and N. V.…

. Insolvency and Bankruptcy Code, 2016 — Section 62 — Appeal to Supreme Court — Limited to questions of law — Concurrent findings of fact by NCLT and NCLAT ordinarily not to be interfered with — Unless view taken in ignorance of statutory provisions, based on extraneous consideration or ex-facie arbitrary/illegal.

2025 INSC 1165 SUPREME COURT OF INDIA FULL BENCH KALYANI TRANSCO Vs. M/S BHUSHAN POWER AND STEEL LIMITED AND OTHERS ( Before : B.R. Gavai, CJI, Satish Chandra Sharma and…

Motor Vehicles Act, 1988 — Sections 166, 173 — Motor Vehicle Accident Claim — Quantum of Compensation — Medical Expenses — Insurance company unable to verify medical bills from hospitals in places other than victim’s hometown is not a valid contention. Explanation for treatment in other locations due to victim’s medical condition (paraplegia and pneumonia) and climatic conditions is accepted.

2025 INSC 1164 SUPREME COURT OF INDIA DIVISION BENCH SHARAD SINGH (DEAD) THROUGH LR. Vs. H. D. NARANG AND ANOTHER ( Before : K. Vinod Chandran and N.V. Anjaria, JJ.…

Service Matters

Telangana State Judicial Rules, 2023 — Rule 5(5.1)(a) and Rule 2(k) — Interpretation of “practicing as an Advocate in the High Court” — Rejection of candidature for District Judge post — High Court’s dismissal of writ petitions based on interpretation that “High Court” refers solely to the Telangana High Court — Supreme Court’s decision to permit appointment as a special case without unsettling the rules — Orders for declaration of results and appointment of qualified candidates — Clarification that the order is not a precedent and does not grant arrears of monetary benefits or claim to pre-existing seniority.

2025 INSC 1169 SUPREME COURT OF INDIA DIVISION BENCH USHA KIRAN KSHATRI AND OTHERS Vs. THE STATE OF TELANGANA AND OTHERS ( Before : Dipankar Datta and Augustine George Masih,…

Punjab Village Common Lands (Regulation) Act, 1961, as amended by Haryana Act No. 9 of 1992 — Section 2(g)(6) — Validity — Land reserved for common purposes under East Punjab Holdings (Consolidation and Prevention of Fragmentation) Act, 1948, vesting with Gram Panchayat — Held valid — Amendment did not suffer from constitutional infirmity — Land reserved for common purposes cannot be re-partitioned amongst proprietors.

2025 INSC 1122 SUPREME COURT OF INDIA FULL BENCH THE STATE OF HARYANA Vs. JAI SINGH AND OTHERS ( Before : B.R. Gavai, CJI, Prashant Kumar Mishra and K.V. Viswanathan,…

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