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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 10(2)(d) & 2(21) — Driving Licence for Light Motor Vehicle (LMV) — Validity for driving commercial vehicle with Gross Vehicle Weight not exceeding 7500 kg — Driver possessing LMV license can drive transport vehicle up to 7500 kg without additional endorsement — Constitutional Bench decision in Bajaj Alliance General Insurance Co. Ltd. v. Rambha Devi affirmed Mukund Dewangan v. Oriental Insurance Co. Ltd.

2025 INSC 867 SUPREME COURT OF INDIA DIVISION BENCH SUNITA AND OTHERS Vs. UNITED INDIA INSURANCE CO. LTD. AND OTHERS ( Before : Sanjay Karol and Joymalya Bagchi, JJ. )…

Prevention of Corruption Act, 1988 — Sections 7, 13(1)(d), 13(2) read with Section 120B of Indian Penal Code, 1860 — Demand and acceptance of bribe — Essential to prove demand and acceptance by public servant — Mere acceptance of illegal gratification without demand is not an offence — Prosecution must prove foundational facts through oral or documentary evidence — Presumption under Section 20 is mandatory and subject to rebuttal; presumption of fact is discretionary — High Court erred in reversing acquittal based on inferences and conjectures, ignoring glaring contradictions in prosecution evidence.

2025 INSC 868 SUPREME COURT OF INDIA DIVISION BENCH M SAMBASIVA RAO Vs. THE STATE OF ANDHRA PRADESH ( Before : Pankaj Mithal and Ahsanuddin Amanullah, JJ. ) Criminal Appeal…

Penal Code, 1860 — Sections 406 and 420 — Cheating and Criminal Breach of Trust — FIR registered based on a property dispute, with conflicting allegations between FIR and civil suit pleadings — Discrepancies in alleged sale consideration and property descriptions indicate manipulation to create a criminal case out of a civil transaction.

2025 INSC 870 SUPREME COURT OF INDIA DIVISION BENCH MALA CHOUDHARY AND ANOTHER Vs. STATE OF TELANGANA AND ANOTHER ( Before : Vikram Nath and Sandeep Mehta, JJ. ) Criminal…

Constitution of India, 1950 — Article 227 — Penal Code, 1860 — Sections 147, 323, 341, 325, 307, 427, 149 — Criminal Procedure Code, 1973 — Sections 439, 439(2) — Supreme Court’s Role and Judicial Restraint — High Courts should generally refrain from passing strictures against judicial officers. Strictures should only be passed in exceptional circumstances and after providing an opportunity to the officer to explain — The proper procedure is to report such matters to the Chief Justice for administrative action — Supreme Court expunged strictures against a judicial officer due to lack of opportunity and reversal of a key judgment cited by the High Court.

2025 INSC 871 SUPREME COURT OF INDIA FULL BENCH KAUSHAL SINGH Vs. THE STATE OF RAJASHTAN ( Before : Vikram Nath, Sanjay Karol and Sandeep Mehta, JJ. ) Criminal Appeal…

Arbitration and Conciliation Act, 1996 — Section 11 — Appointment of Arbitrator — Existence of arbitration agreement — High Court dismissed appellant’s application under Section 11 on the ground that no arbitration agreement existed — Clause 13 of contract relied upon as arbitration agreement — Clause stated that for parties other than Govt. Agencies, redressal of disputes “may be sought” through arbitration — Supreme Court held that use of “may be sought” indicates no subsisting agreement to use arbitration — Clause was an enabling provision if parties agreed, not a binding agreement.

2025 INSC 874 SUPREME COURT OF INDIA DIVISION BENCH BGM AND M-RPL-JMCT (JV) Vs. EASTERN COALFIELDS LIMITED ( Before : Pamidighantam Sri Narasimha and Manoj Misra, JJ. ) Civil Appeal…

Civil Procedure Code, 1908 — Order 22 Rules 3 & 4 — Abatement of appeal — Joint and indivisible decree — Non-substitution of LRs of deceased co-appellant — Fatal to the entire appeal — Possibility of conflicting and contradictory decrees — Defence based on common ground — joint claim.

2025 INSC 873 SUPREME COURT OF INDIA DIVISION BENCH SURESH CHANDRA (DECEASED) THR. LRS. AND OTHERS Vs. PARASRAM AND OTHERS ( Before : Pamidighantam Sri Narasimha and Manoj Misra, JJ.…

Protection of Children from Sexual Offences Act, 2012 — Section 4 — Section 376 (3) IPC — Rape — Conviction upheld — Evidence of victim’s mother and medical evidence — Reliability of victim’s mother’s testimony confirmed despite lengthy cross-examination, finding it natural and trustworthy and corroborated by other witnesses and medical evidence — Medical evidence, though partially presented by defense, conclusively supported sexual assault, citing perineal tear and abrasions around anus

SUPREME COURT OF INDIA DIVISION BENCH SHAMBHU YADAV Vs. THE STATE OF BIHAR ( Before : Sandeep Mehta and Prasanna B. Varale, JJ. ) Special Leave Petition (Criminal) No. 9155…

Hindu Succession Act, 1956 — Section 6 (as amended by Amendment Act, 2005) — Retrospective application — Validity of pre-amendment sale deeds — The prohibition contained in the amended Section 6 of the Hindu Succession Act, 1956, does not affect registered sale deeds executed prior to December 20, 2004 (date of introduction of the amending provision) — This principle aligns with the judgment in Vineeta Sharma v. Rakesh Sharma, (2020) 9 SCC 1.

SUPREME COURT OF INDIA DIVISION BENCH RENAVVA @ LAKSHMI AND OTHERS Vs. SHANTILKUMARSWAMY R. SUBRAMANYA AND OTHERS ( Before : Sandeep Mehta and Prasanna B. Varale, JJ. ) Special Leave…

Judicial Process — Misuse of process — Challenging bail conditions previously offered voluntarily — Accused offering substantial deposits to secure bail and subsequently challenging the onerous nature of conditions or the counsel’s authority to make such offers — This practice is condemned for undermining the judicial process and preventing consideration of bail applications on their merits — Such conduct leads to setting aside of bail orders and remittal for fresh consideration.

SUPREME COURT OF INDIA DIVISION BENCH KUNDAN SINGH Vs. THE SUPERINTENDENT OF CGST AND CENTRAL EXCISE ( Before : K.V. Viswanathan and Nongmeikapam Kotiswar Singh, JJ. ) Petition(s) for Special…

Social Media Posts — Content-Related Offenses — Retaliatory Action — Quashing of Proceedings — While the court made no final determination on the nature of the petitioner’s social media posts, it acknowledged the petitioner’s counsel’s submission that the tweets were ‘retaliatory’ and were made in response to an incident involving a social media influencer. This assertion formed part of the petitioner’s argument for quashing or consolidating the numerous FIRs, suggesting a motive beyond simple offensive content.

SUPREME COURT OF INDIA DIVISION BENCH WAZAHAT KHAN Vs. UNION OF INDIA AND OTHERS ( Before : K.V. Viswanathan and Nongmeikapam Kotiswar Singh, JJ. ) Writ Petition (Criminal) No. 247…

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