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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 Procedure Code, 1973 — Section 438 — Anticipatory Bail — Nature and Scope — Power to grant anticipatory bail under S. 438 is an extraordinary power to be exercised sparingly and only in exceptional cases, not as a matter of routine — Its object is to protect individuals from harassment or humiliation, but this must be balanced against the larger societal interest in maintaining law and order and ensuring the proper course of justice.

2025 INSC 477 SUPREME COURT OF INDIA DIVISION BENCH SERIOUS FRAUD INVESTIGATION OFFICE Vs. ADITYA SARDA ( Before : Bela M. Trivedi and Prasanna B. Varale, JJ. ) Criminal Appeal…

Uttar Pradesh Value Added Tax Act, 2008 — Sections 7(c), 13(1) & 13(7) — Input Tax Credit (ITC) — Entitlement — Sales exempt under S. 7(c) — Where a dealer makes sales to manufacturer-exporters against Form-E, which are exempt from tax under S. 7(c) pursuant to notifications (dated 24.02.2010 and 25.03.2010), the dealer is not entitled to claim ITC on the purchase tax paid on such goods

2025 INSC 476 SUPREME COURT OF INDIA DIVISION BENCH NEHA ENTERPRISES Vs. COMMISSIONER, COMMERCIAL TAX, LUCKNOW, UTTAR PRADESH ( Before : Pankaj Mithal and S.V.N Bhatti, JJ. ) Civil Appeal…

Service Matters

Where an advertisement was issued subsequent to the notification of the 2020 Rules providing 33% horizontal reservation for women, and specified certain posts (like DSP ‘SC Sports’) as reserved for women (‘SC Sports (Women)’), this reservation specification within the advertisement, implementing the mandate of the 2020 Rules, is valid for that recruitment process, unless the advertisement itself is successfully challenged or withdrawn.

2025 INSC 479 SUPREME COURT OF INDIA DIVISION BENCH PRABHJOT KAUR Vs. STATE OF PUNJAB AND OTHERS ( Before : Sudhanshu Dhulia and K. Vinod Chandran, JJ. ) Civil Appeal…

The interpretation of a written agreement to determine if it grants a ‘leave and license’ (potentially attracting deemed tenancy under S.15A Bombay Rent Act) or merely permits ‘conducting a business’ depends primarily on its written terms construed under Ss. 91/92 Evidence Act, excluding contradictory oral evidence.

2025 INSC 466 SUPREME COURT OF INDIA DIVISION BENCH ANNAYA KOCHA SHETTY (DEAD) THROUGH LRS Vs. LAXMIBAI NARAYAN SATOSE SINCE DECEASED THROUGH LRS AND OTHERS ( Before : Pankaj Mithal…

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