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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.

Petition by High Court Judge challenging ‘In-House Procedure’ for judicial misconduct inquiry — Petitioner sought declaration of certain paragraphs of the Procedure as unconstitutional and ultra vires — Held, the ‘In-House Procedure’ is legally sanctioned and fills a constitutional gap in disciplining judges for misconduct not amounting to impeachment — Procedure is not an extra-constitutional mechanism — Petitioner’s conduct in participating without demur and challenging post-adverse findings dis-entitled him to relief on grounds of tardiness and lack of bona fides, although Constitutional challenge itself is not waivable

2025 INSC 943 SUPREME COURT OF INDIA DIVISION BENCH XXX Vs. THE UNION OF INDIA AND OTHERS ( Before : Dipankar Datta and Augustine George Masih, JJ. ) Writ Petition…

Constitution of India, 1950 — Tenth Schedule, Para 6(1) — Disqualification of Members — Speaker’s authority to decide — Judicial review of Speaker’s decision — Scope of — Decision of Speaker is amenable to judicial review on grounds of jurisdictional errors, mala fides, non-compliance with natural justice, and perversity.

2025 INSC 912 SUPREME COURT OF INDIA DIVISION BENCH PADI KAUSHIK REDDY ETC. Vs. STATE OF TELANGANA AND OTHERS ETC. ( Before : B.R. Gavai, CJI. and Augustine George Masih,…

Evidence Act, 1872 — Section 35 — Relevancy of entries in public records — Entries made by public servants in discharge of official duty or by other persons in performance of a duty enjoined by law are relevant facts. — Family Register maintained under the U.P. Panchayat Raj Act, 1947, and Voters’ List are considered public records and public documents. — School records from a private, though government-recognized, school are not public documents, and the headmaster is not a public servant for the purposes of Section 35.

2025 INSC 918 SUPREME COURT OF INDIA DIVISION BENCH SURESH Vs. STATE OF UTTAR PRADESH AND ANOTHER ( Before : Pankaj Mithal and Ahsanuddin Amanullah, JJ. ) Criminal Appeal No.…

Industrial Disputes Act, 1947 — Section 12(3) — Memorandum of Settlement — Binding nature — Clause 14 of 1979 settlement providing alternate employment for colour blind drivers held valid and enforceable despite subsequent 1986 settlement and policy circulars — 1986 settlement did not expressly supersede 1979 settlement and was general in nature, while 1979 settlement was specific to colour blindness and did not contain a termination clause, thus operating harmoniously.

2025 INSC 920 SUPREME COURT OF INDIA DIVISION BENCH CH. JOSEPH Vs. THE TELANGANA STATE ROAD TRANSPORT CORPORATION AND OTHER ( Before : J.K. Maheshwari and Aravind Kumar, JJ. )…

Criminal proceedings can be quashed if a civil dispute is disguised as a criminal offense, indicating an abuse of process. Penal Code, 1860 (IPC) — Sections 419, 420, 467, 468, 471 — Cheating, Forgery, Using Forged Document — Abuse of process of law — Civil dispute disguised as criminal offence — Complaint filed after significant delay following dismissal of objections and failure to pursue civil remedies — Allegations of fabrication of will and circumvention of sale deed not prima facie made out — Continuation of proceedings would be an abuse of process and not serve ends of justice — High Court erred in refusing to quash — Order set aside and proceedings quashed.

2025 INSC 915 SUPREME COURT OF INDIA DIVISION BENCH URMILA DEVI AND OTHERS Vs. BALRAM AND ANOTHER ( Before : B.V. Nagarathna and K.V. Viswanathan, JJ. ) Criminal Appeal No.…

Criminal proceedings may be quashed if cheating or criminal breach of trust elements are absent, or if civil disputes are wrongly criminalized, amounting to abuse of process.- Section 420 — Cheating — Ingredients not made out — Agreement to Sell for property was executed, but possession was not handed over as stipulated in the ATS — No fraudulent or dishonest inducement found — Criminal proceedings quashed.

2025 INSC 917 SUPREME COURT OF INDIA DIVISION BENCH S.N. VIJAYALAKSHMI AND OTHERS Vs. STATE OF KARNATAKA AND ANOTHER ( Before : Sudhanshu Dhulia and Ahsanuddin Amanullah, JJ. ) Criminal…

Constitution of India, 1950 — Tenth Schedule, Para 6(1) — Disqualification of Members — Speaker’s authority to decide — Judicial review of Speaker’s decision — Scope of — Decision of Speaker is amenable to judicial review on grounds of jurisdictional errors, mala fides, non-compliance with natural justice, and perversity. Delay in deciding disqualification petitions — Speaker’s duty to decide expeditiously — Held, Speaker is bound to decide disqualification petitions within a reasonable period.

2025 INSC 912 SUPREME COURT OF INDIA DIVISION BENCH PADI KAUSHIK REDDY ETC. Vs. STATE OF TELANGANA AND OTHERS ETC. ( Before : B.R. Gavai, CJI. and Augustine George Masih,…

Arbitration and Conciliation Act, 1996 vs. Madhya Pradesh Madhyastham Adhikaran Adhiniyam, 1983 — Works Contract — Concession Agreement for development of State Highway falls under ‘works contract’ as defined in MP Act, 1983 — MP Act, 1983 has overriding effect on Arbitration and Conciliation Act, 1996 for such contracts — Private arbitration under 1996 Act is inoperative and void ab initio where MP Act, 1983 mandates adjudication by Madhya Pradesh Arbitration Tribunal.

2025 INSC 907 SUPREME COURT OF INDIA DIVISION BENCH UMRI POOPH PRATAPPUR (UPP) TOLLWAYS PVT. LTD. Vs. M.P. ROAD DEVELOPMENT CORPORATION AND ANOTHER ( Before : J.B. Pardiwala and R.…

Service Matters

Interpretation of Statute and Notifications — ‘Any’ University does not mean only within the State — The phrase “in any State-aided University or College” in a notification extending retirement age was interpreted to include experience from universities or colleges outside the State of West Bengal. The court found that confining the benefit to experience within West Bengal had no rational nexus or object, making it artificial, discriminatory, and violative of equality principles.

2025 INSC 910 SUPREME COURT OF INDIA DIVISION BENCH SUBHA PRASAD NANDI MAJUMDAR Vs. THE STATE OF WEST BENGAL SERVICE AND OTHERS ( Before : Pamidighantam Sri Narasimha and Manoj…

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