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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.

. Civil Procedure Code, 1908 (CPC) — Order 37 — Summary Suits — Procedure — Filing of reply/defence without leave to defend — High Court allowing filing of reply to Summons for Judgment without defendant first applying for leave to defend amounts to procedural deviation from Order 37 Rule 3(4) and 3(5) CPC.

2025 INSC 1157 SUPREME COURT OF INDIA DIVISION BENCH EXECUTIVE TRADING COMPANY PRIVATE LIMITED Vs. GROW WELL MERCANTILE PRIVATE LIMITED ( Before : Ahsanuddin Amanullah and S.V.N. Bhatti, JJ. )…

Recovery of Debts Due to Banks and Financial Institutions Act, 1993 (DRT Act) — Income Tax Act, 1961 — Application of Second and Third Schedules to Income Tax Act and Income Tax (Certificate Proceedings) Rules, 1962 for immovable property sales — Rule 53 of Second Schedule requires proclamation of sale to contain Material information for the purchaser, including any encumbrances or claims affecting the property’s value.

2025 INSC 1161 SUPREME COURT OF INDIA DIVISION BENCH DELHI DEVELOPMENT AUTHORITY Vs. CORPORATION BANK AND OTHERS ( Before : Sanjay Kumar and Alok Aradhe, JJ. ) Civil Appeal No.…

Provincial Insolvency Act, 1920 — Section 37 — Proceedings on annulment — The validity of acts done by a court or receiver before annulment of adjudication of insolvency depends on whether the sales and dispositions of property and payments made were “duly made.” If these acts are found to be not duly made, Section 37 will not protect them.

2025 INSC 1159 SUPREME COURT OF INDIA DIVISION BENCH SINGAMASETTY BHAGAVATH GUPTHA AND ANOTHER Vs. ALLAM KARIBASAPPA (D) BY LRS./ALLAM DODDABASAPPA (D) BY LRS. AND OTHERS ( Before : Pamidighantam…

Negotiable Instruments Act, 1881 — Sections 138, 139, 118 — Dishonour of cheque — Presumptions — Scope — Once execution/signature admitted, presumption arises that cheque was for consideration and discharge of legally enforceable debt — Burden initially on accused to rebut by raising probable defence — Mere plea of complainant’s financial incapacity, without documentary or independent evidence, not sufficient — Failure to reply to statutory notice, an adverse inference against accused — Defence that blank signed cheque given for obtaining bank loan, held unbelievable.

2025 INSC 1158 SUPREME COURT OF INDIA DIVISION BENCH SANJABIJ TARI Vs. KISHORE S. BORCAR AND ANOTHER ( Before : Manmohan and N.V. Anjaria, JJ. ) Criminal Appeal No. 1755…

Arbitration and Conciliation Act, 1996 — Sections 34 and 37 — Setting aside of arbitral award — Scope of interference — Courts are prohibited from rewriting contracts and should not interfere with arbitral awards unless grounds under Section 34 are met, such as violation of public policy or patent illegality. Interference is justified when an award shocks the conscience or is contrary to basic notions of justice. The scope of appeal under Section 37 is narrower than Section 34.

2025 INSC 1171 SUPREME COURT OF INDIA DIVISION BENCH SEPCO ELECTRIC POWER CONSTRUCTION CORPORATION Vs. GMR KAMALANGA ENERGY LTD. ( Before : B. R. Gavai, CJI. and Augustine George Masih,…

Penal Code, 1860 (IPC) — Section 302 — Murder — Conversion of conviction — Where evidence shows that though accused had knowledge that injuries would cause death, there is no material to prove intention to kill, conviction under Section 302 IPC is not tenable and should be converted to Section 304 Part I IPC.

2025 INSC 1172 SUPREME COURT OF INDIA DIVISION BENCH RAGHAV PRASHAD AND OTHERS Vs. STATE OF U.P. ( Before : B.R.Gavai, CJI. and K. Vinod Chandran, J. ) Criminal Appeal…

Criminal Procedure Code, 1973 (CrPC) — Section 374(2) — Appeals against conviction — High Court’s power to acquit — High Court, after considering evidence and finding patent infirmities and insufficiency of evidence in the prosecution case, rightly acquitted the accused giving them the benefit of doubt.- Evidence Act, 1872 — Section 65-B — Electronic records — Call detail records — Non-production of certificate under Section 65-B along with call detail records renders them inadmissible — Handwritten notes of call details without examining the scribe are not proved according to law.

2025 INSC 1166 SUPREME COURT OF INDIA DIVISION BENCH STATE OF RAJASTHAN Vs. BHANWAR SINGH ETC. ETC ( Before : Sandeep Mehta and Joymalya Bagchi, JJ. ) Criminal Appeal No(s).…

Criminal Procedure Code, 1973 (CrPC) — Clubbing of FIRs — Multiple FIRs registered across different states for same cause of action — Generally, it is illegal and overambitious to club FIRs from various states and future FIRs — Prayer for clubbing future FIRs cannot be granted by any court — This power may be exercised under Article 142 of the Constitution with consent of states.

2025 INSC 1174 SUPREME COURT OF INDIA DIVISION BENCH ODELA SATYAM AND ANOTHER Vs. THE STATE OF TELANGANA AND OTHERS ( Before : B. R. Gavai, CJI. and K. Vinod…

Indian Succession Act, 1925 — Section 306 — Abatement of suits — Claim for compensation for personal injury under Motor Vehicles Act, 1988 — Right to claim compensation survives to legal representatives upon death of injured claimant, irrespective of cause of death — Amendment to Section 167 of Motor Vehicles Act, 1988 by Act 32 of 2019 with effect from 01.04.2022 is retrospective and applicable to pending appeals — Preliminary objection by insurance company regarding abatement of appeal on death of claimant rejected

2025 INSC 1177 SUPREME COURT OF INDIA DIVISION BENCH DHANNALAL ALIAS DHANRAJ (DEAD) THR. LRS. Vs. NASIR KHAN AND OTHERS ( Before : K. Vinod Chandran and N. V. Anjaria,…

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