(381) THE STATE OF MADHYA PRADESH AND OTHERS Vs. SHYAMLAL[MADHYA PRADESH HIGH COURT (INDORE BENCH)] 09-04-2025 Prison Law — M.P. Prisoners Release on Probation Act, 1954 — Sections 2, 9 — M.P. Prisoners Release on Probation Rules, 1964, Rule 3(F) — Eligibility for Release on Licence — Bar for Conviction under Prisoners Act, 1900, Section 31(A) [related to breach leading to S.31(D) conviction] — The interplay between the M.P. Prisoners Release on Probation Act, 1954, and the M.P. Prisoners Release on Probation Rules, India Law Library Docid # 2425516
(382) LATE SHRI RAMCHANDRA SHARMA (DECEASED) / TENANT THROUGH SUSHEELA Vs. SHANTI DEVI[MADHYA PRADESH HIGH COURT (INDORE BENCH)] 09-04-2025 M.P. Accommodation Control Act, 1961 — Sections 23-A(b), 23-E, 23-J — Eviction of Tenant by Special Category Landlord — Bona Fide Requirement — Summary Procedure — The scope of a revision petition under Section 23-E against an order of eviction passed by the Rent Controlling Authority (RCA) in favour of a landlord falling under a special category defined in Section 23-J (widow, handicapped person) — The nature of summary procedure under Chapter III-A of the Act for India Law Library Docid # 2425517
(383) THE STATE OF MADHYA PRADESH Vs. DINESH KUMAR AND OTHERS[SUPREME COURT OF INDIA] 08-04-2025 Madhya Pradesh Land Revenue Code, 1959 — Sections 11 & 165(6)(ii) — Revenue Officers — Collector — Competence of Additional Collector — An Additional Collector is competent and possesses the requisite jurisdiction to grant permission for the transfer of land belonging to a member of an indigenous tribe under Section 165(6)(ii), where Section 11 includes 'Additional Collectors' within the class of 'Collector', and a specific, pre India Law Library Docid # 2424370
(384) RAKESH KUMAR VERMA Vs. HDFC BANK LTD.[SUPREME COURT OF INDIA] 08-04-2025 Contract Act, 1872 — S. 28 — Civil Procedure Code, 1908 — S. 20 — Contractual Clauses — Exclusive Jurisdiction — Validity — Parties to a contract, including an employment contract, are free to agree on conferring exclusive jurisdiction upon a specific court, thereby ousting the jurisdiction of other courts which might otherwise be competent under S. 20, CPC — Such a clause is valid and enforceable provided that: (i) it does not absolutely restrict a party from enforcing rights through usual lega India Law Library Docid # 2424371
(385) NEW INDIA ASSURANCE CO. LTD. Vs. SMT. SUNITA SHARMA AND OTHERS[SUPREME COURT OF INDIA] 08-04-2025 Motor Vehicles Act, 1988 — Compensation — Deductibility — Haryana Compassionate Assistance to the Dependents of Deceased Government Employees Rules, 2006 — Financial assistance received or receivable by dependents of a deceased government employee under the Haryana Rules of 2006, specifically under the head equivalent to ‘pay and other allowances’ last drawn by the deceased, must be deducted/excluded while computing compensation for loss of income/dependency under the Motor India Law Library Docid # 2424372
(386) HYEOKSOO SON AUTHORIZED REPRESENTATIVE FOR DAECHANG SEAT AUTOMOTIVE PVT. LTD. Vs. MOON JUNE SEOK AND ANOTHER[SUPREME COURT OF INDIA] 08-04-2025 Criminal Procedure Code, 1973 — Section 482 — Quashing of FIR/Chargesheet — Scope of Power — The inherent power of the High Court under Section 482 Cr.P.C. to quash criminal proceedings must be exercised sparingly and with caution — The court cannot embark upon an inquiry into the reliability, genuineness, or veracity of the allegations made in the FIR or chargesheet, nor conduct a ‘mini-trial’ — The allegations must be taken at face value to determine if they prima facie constitute an offence a India Law Library Docid # 2424373
(387) M/S. CHATHA SERVICE STATION Vs. LALMATI DEVI AND OTHERS[SUPREME COURT OF INDIA] 08-04-2025 Motor Vehicles Act, 1988 — S. 149 (pre-amendment 2019) — Central Motor Vehicles Rules, 1989 — R. 9 — Driving Licence — Endorsement for Hazardous Goods — Breach of Policy Condition — Pay and Recover — The absence of a specific endorsement on the driver's transport vehicle licence, certifying completion of the training course prescribed under Rule 9 of the Central Motor Vehicles Rules, 1989, for driving a goods carriage carrying dangerous or hazardous goods, constitutes a fundamental breach of the India Law Library Docid # 2424374
(388) SAKSHI ARHA Vs. THE RAJASTHAN HIGH COURT AND OTHERS[SUPREME COURT OF INDIA] 08-04-2025 Service Law — Recruitment — Rajasthan Judicial Service Rules, 2010 — Reservation — OBC-NCL/MBC-NCL/EWS — Cut-off Date for Eligibility — Certificate Validity — The eligibility of a candidate claiming reservation benefits under categories like Other Backward Classes (Non-Creamy Layer) [OBC-NCL], Most Backward Classes (Non-Creamy Layer) [MBC-NCL], or Economically Weaker Section [EWS], whose status is dynamic and dependent on current socio-economic criteria, must be established as existing on the cu India Law Library Docid # 2424375
(389) ANNAYA KOCHA SHETTY (DEAD) THROUGH LRS Vs. LAXMIBAI NARAYAN SATOSE SINCE DECEASED THROUGH LRS AND OTHERS[SUPREME COURT OF INDIA] 08-04-2025 Evidence Act, 1872 — Sections 91 & 92 — Interpretation of Written Agreements (Deeds) — Exclusion of Oral Evidence — The terms of a written contract, grant, or disposition of property must primarily be ascertained from the document itself — Oral evidence contradicting, varying, adding to, or subtracting from the terms of such a written instrument is inadmissible between the parties, unless the situation falls within the specific exceptions provided in the Provisos to S. 92 (such as fraud, mistake India Law Library Docid # 2424376
(390) STATE OF KARNATAKA Vs. SRI CHANNAKESHAVA.H.D. AND ANOTHER[SUPREME COURT OF INDIA] 08-04-2025 Prevention of Corruption Act, 1988 — Section 17 (Second Proviso) & Section 13(1)(b) — Investigation of Disproportionate Assets — Order of Superintendent of Police — Preliminary Enquiry — The second proviso to Section 17 mandates that an investigation into an offence under Section 13(1)(b) (disproportionate assets) requires an order from a police officer not below the rank of Superintendent of Police (SP) — However, this provision does not explicitly require the SP to conduct a separate prelimina India Law Library Docid # 2424377
(391) KARAN SINGH Vs. THE STATE OF HARYANA[SUPREME COURT OF INDIA] 08-04-2025 Haryana Good Conduct Prisoners (Temporary Release) Act, 1988 (as amended by Act of 2012) — Section 9 — Sentence for failure to surrender after parole — Applicability of Amendment Act, 2012 — Retrospectivity — The amendment to S. 9 by the Haryana Good Conduct Prisoners (Temporary Release) Amendment Act, 2012 (w.e.f. 01.10.2012), which introduced a minimum sentence of two years, is not applicable retrospectively — Where the offence of failing to surrender after parole was committed (17.06.2010) an India Law Library Docid # 2424447
(392) THE STATE OF TAMIL NADU Vs. THE GOVERNOR OF TAMILNADU AND ANOTHER[SUPREME COURT OF INDIA] 08-04-2025 Governor's Powers under Article 200 are Limited and Exclusive — When presented with a Bill, the Governor must choose one of only three mutually exclusive options under the substantive part of Article 200: assent, withhold assent, or reserve for Presidential consideration. India Law Library Docid # 2424501
(393) HARDYAL INDER SINGH Vs. STATE OF PUNJAB[SUPREME COURT OF INDIA] 08-04-2025 Criminal Procedure Code, 1973 — Section 438 — Anticipatory Bail — Factors Considered — Prolonged Investigation & Cooperation — Anticipatory bail may be granted where the investigation against the appellant has remained incomplete for a considerable period (over two and a half years), even after an initial closure report was rejected and further investigation ordered, particularly when coupled with the fact that the appellant has joined the investigation when called upon (thrice in this instance) India Law Library Docid # 2424552
(394) AWADHESH SINGH THAKUR Vs. STATE OF CHHATTISGARH AND OTHERS[CHHATTISGARH HIGH COURT] 08-04-2025 Chhattisgarh Minor Mineral Rules, 2015 — Rule 23-A (inserted w.e.f. 23.03.2016) — Applications for Quarry Lease filed before Amendment — Ineligibility — As per Rule 23-A(2)(a) of the Rules of 2015, all applications for the grant of a quarry lease received prior to the commencement of the Amendment Rules (i.e., before 23.03.2016) became ineligible upon the coming into force of the amendment. An application filed on 06.05.2015, therefore, became ineligible by operation of law, and its rejection ba India Law Library Docid # 2424713
(395) KAVILAS Vs. STATE OF CHHATTISGARH[CHHATTISGARH HIGH COURT] 08-04-2025 Penal Code, 1860 — Section 302 — Circumstantial Evidence — Last Seen Theory — Time Gap — In a case based on circumstantial evidence, the circumstance of ‘last seen together’ is a relevant factor, but conviction cannot be based solely on it, especially when there is a significant time gap between when the accused and deceased were last seen together and when the deceased was found dead — A substantial gap weakens the probative value of the last seen evidence, as it does not exclude the possibilit India Law Library Docid # 2424714
(396) ARJUN DEVANGAN Vs. STATE OF CHHATTISGARH[CHHATTISGARH HIGH COURT] 08-04-2025 Chhattisgarh Excise Act, 1915 — Section 34(2) — Illegal Possession of Liquor — Proof Beyond Reasonable Doubt — Independent Witnesses Turning Hostile — In a prosecution for illegal possession of liquor under the Excise Act, where independent seizure witnesses (PW-1, PW-2) do not support the prosecution case regarding the time, place, and manner of seizure from the accused, and there are material contradictions between their testimonies and that of the investigating police officer (PW-7), the pros India Law Library Docid # 2424715
(397) SANTOSH KUMAR CHOUHAN AND ANOTHER Vs. NATWAR SHARMA AND ANOTHER[CHHATTISGARH HIGH COURT] 08-04-2025 Motor Vehicles Act, 1988 — Section 166 — Compensation — Dependency — Claim by Married Siblings — Adult siblings (brother and sister) of a deceased person, who are married and maintain their own separate families, are generally not considered dependents for the purpose of awarding compensation for loss of dependency under the Motor Vehicles Act, unless specific evidence is adduced to prove their financial dependency on the deceased’s income — Mere assertion of dependency is insufficient, especial India Law Library Docid # 2424716
(398) NEW INDIA ASSURANCE CO. LTD. Vs. GOPU AND ANOTHER[SUPREME COURT OF INDIA] 08-04-2025 Limitation Act, 1963 — Sections 6 & 2(l) — Motor Vehicles Act, 1988 — Section 166 — Legal Disability (Minority) — Extension of Limitation Period — Applicability to Appeals from MACT Award — The extension of limitation period granted under Section 6 of the Limitation Act, 1963, on account of legal disability (such as minority), applies only to the institution of a ‘suit’ or the making of an ‘application for the execution of a decree’ — Given that Section 2(l) explicitly states that a ‘suit’ does India Law Library Docid # 2424739
(399) KAMANURI NARASIMHA RAO Vs. STATE OF AP[ANDHRA PRADESH HIGH COURT] 08-04-2025 Criminal Procedure Code, 1973 — Sections 397 & 401 — Revisional Jurisdiction — Scope against Conviction — The High Court’s revisional jurisdiction under Sections 397 and 401 Cr.P.C., particularly against concurrent findings of conviction upheld by the appellate court, is circumscribed — The High Court will not act as a second appellate court to re-appreciate evidence — Interference is warranted only in exceptional cases involving manifest illegality, findings based on no evidence or overlooking India Law Library Docid # 2424828
(400) PRAMOD KUMAR TIWARI Vs. PREMLAL GAUTAM AND OTHERS[SUPREME COURT OF INDIA] 08-04-2025 Motor Vehicles Act, 1988 — Compensation — Deductibility of Family Pension — The amount of family pension received by the dependents of an employee, who died in a motor vehicle accident during the subsistence of his employment, is not deductible from the deceased's income when calculating the loss of dependency for determining compensation under the Act — The High Court's view affirming such deduction is set aside. India Law Library Docid # 2424849