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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.

Criminal Law — Circumstantial Evidence — Admitted Facts — Cause of death by gunshot from a specific weapon in appellant’s home undisputed — Appellant admitted removing the body and cleaning the scene — Discovery of articles linked to the incident from appellant’s disclosure relevant for Section 201 IPC.

2025 INSC 800 SUPREME COURT OF INDIA DIVISION BENCH VAIBHAV Vs. THE STATE OF MAHARASHTRA ( Before : B.V. Nagarathna and Satish Chandra Sharma, JJ. ) Criminal Appeal No. 1643…

Five golden principles for cases based on circumstantial evidence reiterated: (1) circumstances establishing conclusion of guilt must be fully established; (2) facts established consistent only with hypothesis of guilt; (3) circumstances conclusive in nature; (4) exclude every possible hypothesis except guilt; (5) complete chain of evidence leaving no reasonable ground for innocence

2025 INSC 793 SUPREME COURT OF INDIA DIVISION BENCH CHETAN Vs. THE STATE OF KARNATAKA ( Before : Surya Kant and Nongmeikapam Kotiswar Singh, JJ. ) Criminal Appeal No. 1568…

Appellant Trust’s contentions regarding non-demarcation, encroachment, and non-delivery of possession are baseless; demarcation was done and acknowledged, alleged encroachment is not proven by evidence, and delivery of possession was contingent on execution of lease deed, a condition appellant failed to meet — Respondent Corporation’s actions were in accordance with prescribed procedures and allotment terms

2025 INSC 791 SUPREME COURT OF INDIA DIVISION BENCH KAMLA NEHRU MEMORIAL TRUST AND ANOTHER Vs. U.P. STATE INDUSTRIAL DEVELOPMENT CORPORATION LIMITED AND OTHERS ( Before : Surya Kant and…

Environmental Law — Public Trust Doctrine — MCGM’s mandate to develop recreational spaces providing legal foundation for project — Prior condition of water body suggested degradation, not functional lake — Completed park providing substantial public benefit, including green space and recreational amenities utilized by community — Post facto sanction restricting land use to recreational purposes providing legal safeguard — Delay in filing petition undermining challenge — Direction to maintain park in perpetuity for public use, explore alternative water body, and restore other deteriorated water bodies by MCGM.

2025 INSC 792 SUPREME COURT OF INDIA DIVISION BENCH MUNICIPAL CORPORATION OF GREATER MUMBAI AND OTHERS Vs. PANKAJ BABULAL KOTECHA AND OTHERS ( Before : Surya Kant and Nongmeikapam Kotiswar…

Nagaland Village and Area Councils Act, 1978 — Section 3 — Recognition of villages — State’s duty to consider objections fairly — Failure appears to have occurred in present case — Objections by appellant regarding ancestral land ownership not adequately considered by State authorities before recommending recognition — Court cannot definitively decide complex factual disputes regarding land ownership and customary practices — Appropriate for State authorities to resolve such issues.

SUPREME COURT OF INDIA DIVISION BENCH OLD JALUKAI VILLAGE COUNCIL Vs. KAKIHO VILLAGE AND OTHERS ( Before : J.B. Pardiwala and R. Mahadevan, JJ. ) Civil Appeal No. ….of 2025…

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