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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.

Transfer of Property Act, 1882 – Sections 105, 106, 107 and 108 – Registration Act, 1908 – Sections 17 and 49 – Unregistered deed of lease for immovable property – In the absence of a registered instrument, the courts are not precluded from determining the factum of tenancy from other evidence on record as well as the purpose of tenancy In the present case, factum of creation of tenancy has been established – But the purpose of tenancy, so as to attract the six months’ notice period under Section 106 of the 1882 Act cannot be established by such evidence as in such a situation, registration of the deed would have been mandatory

SUPREME COURT OF INDIA DIVISION BENCH M/S PAUL RUBBER INDUSTRIES PRIVATE LIMITED — Appellant Vs. AMIT CHAND MITRA AND ANOTHER — Respondent ( Before : Aniruddha Bose and Vikram Nath,…

Constitution of India, 1950 — Article 32 — Writ jurisdiction — Violation of Fundamental Rights — A writ petition under Article 32 requires a prima facie case of violation or imminent threat of violation of a Fundamental Right, with specific pleadings and prayers for relief. Vague allegations of arbitrariness or violation of natural justice without specific impact on Fundamental Rights are insufficient to maintain the petition.

2025 INSC 884 SUPREME COURT OF INDIA FULL BENCH VISHNU VARDHAN @ VISHNU PRADHAN Vs. THE STATE OF UTTAR PRADESH AND OTHERS ( Before : Surya Kant, Dipankar Datta and…

Juvenile Justice (Care and Protection of Children) Act, 2000 — Applicability — Plea of juvenility raised for the first time before the Supreme Court — Permissible at any stage, even after disposal of the case, as held in various judgments of the Supreme Court.-— Determination of Age — Inquiry report confirmed the appellant was a juvenile (16 years, 2 months, 3 days) at the time of the commission of the offence.

2025 INSC 887 SUPREME COURT OF INDIA DIVISION BENCH SUA Vs. THE STATE OF RAJASTHAN ( Before : B.R. Gavai, CJI. and Augustine George Masih, J. ) Criminal Appeal No.2695…

Criminal Procedure Code, 1973 — Section 482 — Quashing of proceedings — High Court quashed proceedings under SC/ST Act, 1989, against respondents — Appellant contended High Court erred in exercising jurisdiction, overlooking evidence, and conducting roving inquiry — Court held High Court’s scope under Section 482 is limited to determining if allegations disclose a cognizable offence, and it should not engage in detailed evidence evaluation at pre-trial stage — However, if allegations are baseless, motivated by personal vendetta, or lack requisite ingredients for an offence, High Court can quash proceedings to prevent abuse of process.

2025 INSC 886 SUPREME COURT OF INDIA DIVISION BENCH KONDE NAGESHWAR RAO Vs. A. SRIRAMA CHANDRA MURTY AND ANOTHER ( Before : B.R. Gavai, CJI. and Augustine George Masih, J.…

Criminal Procedure Code, 1973 — Section 482 — Quashing of criminal proceedings — Second quashing petition — Maintainability — Not permissible to raise previously available grounds in a subsequent petition to effect a review of an earlier order, violating Section 362 CrPC — Exception is when there has been a change in circumstances.

2025 INSC 888 SUPREME COURT OF INDIA DIVISION BENCH M.C. RAVIKUMAR Vs. D.S. VELMURUGAN AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Criminal Appeal No(s). ….of…

DTAA, India-UAE, Article 5(1) — Permanent Establishment — Definition of “fixed place of business” — The definition of Permanent Establishment requires a fixed place of business through which the business of an enterprise is wholly or partly carried on. The key test is whether the place is “at the disposal” of the enterprise, meaning the enterprise has the right to use the premises to carry on its business. Factors like stability, productivity, and a degree of independence are also considered.

2025 INSC 891 SUPREME COURT OF INDIA DIVISION BENCH HYATT INTERNATIONAL SOUTHWEST ASIA LTD. Vs. ADDITIONAL DIRECTOR OF INCOME TAX ( Before : J.B. Pardiwala and R. Mahadevan, JJ. )…

Central Goods and Services Tax Act, 2017 — Section 129 — Detention, seizure and release of goods and conveyances in transit — Show cause notice — Payment of penalty — Obligation to pass final order — Where a show cause notice is issued under Section 129(3) of the CGST Act and the taxable person files objections against the proposed levy, the proper officer is duty-bound to pass a reasoned, speaking order under Section 129(3), even if the penalty is paid. Such an order is crucial for enabling the taxpayer to exercise their statutory right of appeal under Section 107 of the CGST Act.

2025 INSC 890 SUPREME COURT OF INDIA DIVISION BENCH M/S ASP TRADERS Vs. STATE OF UTTAR PRADESH AND OTHERS ( Before : J.B. Pardiwala and R. Mahadevan, JJ. ) Civil…

Criminal Procedure Code, 1973 (CrPC) — Section 174 — Inquiry by Police into cause of unnatural death — Requirement of fair and impartial investigation — Evidence considered — Inconsistencies in CCTV footage, suspicious medical findings, and failure to preserve crucial forensic evidence indicated failures in local investigation.

2025 INSC 893 SUPREME COURT OF INDIA DIVISION BENCH SUKDEB SAHA Vs. THE STATE OF ANDHRA PRADESH AND OTHERS ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Criminal…

Criminal Procedure Code, 1973 — Section 156(3) — FIR Registration — Application to Magistrate without approaching Police/SP — While a Magistrate ought not ordinarily entertain an application under Section 156(3) CrPC directly without the informant having availed and exhausted remedies under Section 154(3) CrPC, the Magistrate is competent to direct FIR registration if allegations disclose cognizable offence — Such an order is not without jurisdiction and not vitiated on this count, but it is a procedural irregularity.

2025 INSC 895 SUPREME COURT OF INDIA DIVISION BENCH ANURAG BHATNAGAR AND ANOTHER Vs. STATE (NCT OF DELHI) AND ANOTHER ( Before : Pankaj Mithal and S.V.N. Bhatti, JJ. )…

Constitution of India, 1950 — Article 170(3) — Proviso — Readjustment of seats in Legislative Assemblies — Constitutional bar on readjustment of seats in State Legislative Assemblies until publication of census data after 2026 — Andhra Pradesh Reorganisation Act, 2014, Section 26 — Increase in seats subject to Article 170(3) — Petitioners’ claim for delimitation in Andhra Pradesh and Telangana dismissed as it contravened constitutional mandate.

2025 INSC 894 SUPREME COURT OF INDIA DIVISION BENCH K. PURUSHOTTAM REDDY Vs. UNION OF INDIA AND OTHERS ( Before : Surya Kant and Nongmeikapam Kotiswar Singh, JJ. ) Writ…

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