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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.

Income Tax Act, 1961 — Section 276C(1) — Wilful attempt to evade tax — Prosecution for wilful attempt to evade tax requires proof of mens rea — Settlement Commission granted immunity from penalty after full disclosure, finding no suppression of facts or wilful evasion — Continuation of prosecution despite settlement order and lack of mens rea amounts to abuse of process of law.

025 INSC 1048 SUPREME COURT OF INDIA DIVISION BENCH VIJAY KRISHNASWAMI @ KRISHNASWAMI VIJAYAKUMAR Vs. THE DEPUTY DIRECTOR OF INCOME TAX (INVESTIGATION) ( Before : J.K. Maheshwari and Vijay Bishnoi,…

Andhra Pradesh Motor Vehicles Taxation Act, 1963 — Section 3 — Levy of tax — Requirement of motor vehicle being used or kept for use in a ‘public place’ — ‘Public place’ defined under Section 2(34) of Motor Vehicles Act, 1988 as a road, street, way or other place to which public has a right of access — Visakhapatnam Steel Plant premises, being a restricted area with controlled access, not a public place — Tax not leviable on vehicles used exclusively within such premises.

025 INSC 1052 SUPREME COURT OF INDIA DIVISION BENCH M/S. TARACHAND LOGISTIC SOLUTIONS LIMITED Vs. STATE OF ANDHRA PRADESH AND OTHERS ( Before : Manoj Misra and Ujjal Bhuyan, JJ.…

Service Matters

Disciplinary Proceedings — Charges — Proof — Constable found 12 kms from camp when permitted to visit hospital — Detained by civilians due to unwarranted activities affecting reputation of Force — Charge of leaving camp without permission not proved, but being found at distant residential colony instead of hospital and subsequent detention sufficiently proved conduct unbecoming of member of Armed Forces.

2025 INSC 1055 SUPREME COURT OF INDIA DIVISION BENCH CONST. AMAR SINGH Vs. UNION OF INDIA AND OTHER ( Before : Pamidighantam Sri Narasimha and Atul S. Chandurkar, JJ. )…

Evidence Act, 1872 — Appreciation of Evidence — Testimony of victim’s family witnesses admitted no dowry demand until examination-in-chief in court — Neighbour’s testimony stating no dowry demand, although brushed aside by lower courts, is relevant and gains credibility when other evidence is lacking — Reason for discarding neighbour’s testimony as speculative was erroneous, as information about dowry harassment can spread widely.

2025 INSC 1051 SUPREME COURT OF INDIA DIVISION BENCH SMT. BHAGWATI DEVI Vs. STATE OF UTTARAKHAND ( Before : Aravind Kumar and N.V. Anjaria, JJ. ) Criminal Appeal No. 2616…

Service Matters

Police Service — Discipline — Unauthorized Absence — Dismissal justified — Unauthorized absence from duty, especially in a disciplined force, constitutes gross indiscipline. When a member of a disciplined force remains absent without permission or intimation for a considerable period, dismissal from service is justified, provided due procedure is followed.

2025 INSC 1056 SUPREME COURT OF INDIA DIVISION BENCH STATE OF PUNJAB AND OTHERS Vs. EX. C. SATPAL SINGH ( Before : J.K. Maheshwari and Vijay Bishnoi, JJ. ) Civil…

Electricity Regulatory Commissions Act, 1998 — Electricity Act, 2003 —Tariff Determination — Supplementary PPA — Execution of Supplementary PPA and Stipulation of Enhanced Tariff without Seeking Commission’s Approval and Review is Unlawful — Parties are Bound to Approach Commission for Approval.

2025 INSC 1057 SUPREME COURT OF INDIA DIVISION BENCH M/S. KKK HYDRO POWER LIMITED Vs. HIMACHAL PRADESH STATE ELECTRICITY BOARD LIMITED AND OTHERS ( Before : Sanjay Kumar and N.V.…

Service Matters

Service Law — Employee’s Plea for Mercy — An employee’s statement pleading innocence and seeking forgiveness for any mistake indirectly admits guilt and warrants mercy. Evidence in Departmental Inquiry — Findings in a departmental inquiry are based on preponderance of probabilities, not strict proof beyond reasonable doubt, and the High Court’s view that findings were based on conjecture and surmises was legally unsustainable if evidence supported the findings

2025 INSC 1010 SUPREME COURT OF INDIA DIVISION BENCH STATE BANK OF INDIA AND OTHERS Vs. RAMADHAR SAO ( Before : Rajesh Bindal and Manmohan, JJ. ) Civil Appeal No.…

Haryana School Education Act, 1995, Section 22 — Civil Court Jurisdiction — Ouster of jurisdiction by statute must be express or implied — Section 22 only ousts jurisdiction where Government or its officers have power to adjudicate — Recovery of fees by a school is not a power conferred on Government/authorities — Civil court jurisdiction not ousted in matters of reasonable fee recovery.

2025 INSC 925 SUPREME COURT OF INDIA FULL BENCH APEEJAY SCHOOL Vs. DHRITI DUGGAL AND OTHERS ( Before : B.R. Gavai, CJI., K. Vinod Chandran and N. V. Anjaria, JJ.…

Penal Code, 1860 — Section 498A — Cruelty by husband or relatives of husband — Allegations in FIR were vague, general, and filed one year after admitted separation of the parties — No specific instances of cruelty were mentioned — Criminal proceedings are liable to be quashed. Criminal Procedure Code, 1973 — Section 482 — Quashing of FIR — Court can quash FIR if allegations, taken at face value, do not constitute any offence — Vague and general allegations of marital discord, without specific instances, do not prima facie constitute an offence under Section 498A IPC.

2025 INSC 926 SUPREME COURT OF INDIA FULL BENCH ANURAG VIJAYKUMAR GOEL Vs. STATE OF MAHARASHTRA AND ANOTHER ( Before : B.R. Gavai, CJI., K. Vinod Chandran and N. V.…

Penal Code, 1860 — Sections 376(2), 450 — Protection of Children from Sexual Offences Act, 2012 — Section 4 — Sexual assault on a minor — Evidence of prosecutrix — Conviction can be based solely on the prosecutrix’s testimony if it inspires confidence — Corroboration of testimony of prosecutrix is not a requirement of law, but a guidance of prudence — Minor contractions or small discrepancies should not be a ground for throwing out the evidence of the prosecutrix.

2025 INSC 929 SUPREME COURT OF INDIA DIVISION BENCH DEEPAK KUMAR SAHU Vs. STATE OF CHHATTISGARH ( Before : Sudhanshu Dhulia and N.V. Anjaria, JJ. ) Criminal Appeal No. …..of…

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