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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.

Motor Vehicles Act, 1988 — Section 149 — Liability of insurer — Award of compensation — Insurance policy validity — Truck driver’s rash and negligent driving caused death of security guard — Tribunal awarded compensation to claimants — Insurance Company argued policy was not valid on accident date due to fraudulent alteration of dates by owner — This contention was raised only in review petition, not in main proceedings — Insurer failed to prove fraud — Review application dismissed for lack of power by Tribunal.

2025 INSC 1178 SUPREME COURT OF INDIA DIVISION BENCH NEW INDIA ASSURANCE CO. LTD Vs. NARAYAN SINGH AND OTHERS ( Before : K. Vinod Chandran and N.V. Anjaria, JJ. )…

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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