4. Pushpa & Ors. Vs. Dayawati & Ors.: 2026 INSC 603- Facts of the Case • Family background: o Shis Ram (Defendant No.1) and Chameli (Defendant No.2) had five children:  Dayawati (Plaintiff/Respondent No.1)  Daya Ram (Defendant No.3, now deceased)  Har Prasad (Defendant No.4)  Ramrati (Defendant No.5)  Leelawati (Defendant No.6) o Appellants Pushpa, Saroj Kumari, and Sudesh are daughters/legal heirs of Daya Ram. • Property transaction: o In August 2007, ancestral agricultural land measuring 31 bighas 9 biswas was sold for ₹15.31 crore. o Sale proceeds were received by Shis Ram in his personal account. • Suit filed (2009): o Dayawati sought partition, recovery of ₹45 lakh with interest, and injunction against her parents and siblings. o Claimed entitlement to her share in the sale proceeds. • Written statement (2010): o Daya Ram admitted receipt of ₹3 crores from the sale proceeds. o This admission became the basis for recovery proceedings. Facts in Issue a. Whether Dayawati was entitled to a share in the ancestral property sale proceeds. b. Whether the High Court was correct in decreeing recovery against Daya Ram based on his admission in written statement. c. Whether the appellants (legal heirs of Daya Ram) could avoid liability after his death. Court’s Reasoning • The High Court had already passed a preliminary decree (2011) granting equal shares to all parties. • Later modified to 1/6th share each after Leelawati relinquished her rights. • Daya Ram’s written admission of receiving ₹3 crores was binding and formed the basis of liability. • The Supreme Court held that the High Court rightly exercised revisional jurisdiction under Article 227 to decree recovery. • The appellants, being legal heirs of Daya Ram, were liable to satisfy the decree. Final Holding • Appeal dismissed. • Supreme Court upheld the Delhi High Court’s decree dated 16.04.2019. • Directed recovery of ₹44,79,167 with interest against Daya Ram’s estate/legal heirs.

9. Gopi Chand @ Pappu v. State (NCT of Delhi): 2026 INSC 598 Facts in Issue 1. Whether the recovery of the firearm was proven beyond reasonable doubt. 2. Whether the prosecution complied with mandatory procedural safeguards under the Arms Act. 3. Whether the conviction could be sustained solely on police testimony without independent corroboration. Court’s Reasoning • The Supreme Court examined the chain of custody and the manner in which the firearm was allegedly recovered. • It noted inconsistencies in the prosecution’s case, including lack of independent witnesses at the time of recovery. • The Court reiterated that in criminal law, suspicion cannot substitute proof. • Procedural lapses in seizure and documentation weakened the prosecution’s case. • Benefit of doubt must go to the accused when recovery evidence is shaky. Final Holding • Appeal allowed. • Conviction under the Arms Act and IPC set aside. • The appellant was acquitted, as prosecution failed to prove guilt beyond reasonable doubt.

10. Ishwar Chand Sharma v. State of Uttar Pradesh: 2026 INSC 5 Facts of the Case • Appellant: Ishwar Chand Sharma. • Respondent: State of Uttar Pradesh. • Background: o The appellant was prosecuted for offences under the Indian Penal Code (IPC) relating to murder and unlawful assembly. o The case arose from a violent incident in which one person was killed and others injured. o The Trial Court convicted the appellant along with co accused, sentencing them to life imprisonment. o The conviction was upheld by the Allahabad High Court. o The appellant challenged the conviction before the Supreme Court, arguing that his role was not established and that he was falsely implicated. Facts in Issue 1. Whether the prosecution proved the appellant’s active participation in the crime beyond reasonable doubt. 2. Whether the conviction could be sustained based on eyewitness testimony despite alleged inconsistencies. 3. Whether the High Court rightly upheld the Trial Court’s findings. Court’s Reasoning • The Supreme Court examined the eyewitness accounts, which consistently implicated the appellant. • Minor discrepancies in witness statements were held to be natural and not sufficient to discredit the core evidence. • The medical evidence corroborated the prosecution’s version of events. • The appellant’s defense of false implication was rejected, as no motive for fabrication was shown. • The Court reiterated that in cases of unlawful assembly and murder, individual roles may vary, but collective liability under Sections 302/149 IPC applies when participation is proven. Final Holding • Appeal dismissed. • Conviction and life sentence under Section 302 read with Section 149 IPC upheld. • The Supreme Court confirmed that the appellant was rightly convicted based on credible eyewitness and corroborative evidence.

Shahul Hameed Vs. N. Malligarjuna and Ors.:2026 INSC Facts of the Case • On 19 March 2010, the plaintiff (Shahul Hameed) entered into a sale agreement with the defendants for property in Survey No. 75/12. • Sale consideration: ₹9,30,000. o ₹9,00,000 paid upfront as earnest money. o Balance ₹30,000 payable at the time of registration. • Plaintiff claimed he was ready and willing to perform his part and issued a legal notice on 1 February 2011 demanding execution of the sale deed. • Defendants denied the claim, arguing: o The agreement was nominal, executed only as a security document. o It was linked to an earlier transaction with “Bangalore Buyers” in 2009. • Plaintiff filed OS No. 35 of 2011 seeking specific performance of the agreement. Facts in Issue a. Whether the sale agreement dated 19.03.2010 was a genuine enforceable contract or merely a security/nominal document. b. Whether the plaintiff had established readiness and willingness to perform his obligations under the agreement. c. Whether the plaintiff was entitled to specific performance or only to a refund of the money paid. What the Court Held • Trial Court: Dismissed the suit for specific performance, finding inconsistencies in plaintiff’s conduct. • First Appellate Court: Ordered refund of ₹9,30,000 with 12% interest per annum from 2011. • Madras High Court: Affirmed appellate court’s decree, denying specific performance but upholding refund with interest. • Supreme Court (Justice Sanjay Karol, 2026): o Plaintiff failed to prove continuous readiness and willingness beyond initial payment. o Delay in issuing notice and lack of evidence of arranging balance amount weakened his case. o Circumstances supported defendants’ claim that the agreement was nominal/security, not a genuine sale contract. o Equity required refund of money with interest, not enforcement of sale. Final Holding • Specific performance denied. • Defendants directed to refund ₹9,30,000 with 12% interest per annum from 10 March 2011 until realization. • Supreme Court upheld the High Court’s decree and dismissed the appeal.

3. Mondira Ghosh v. Chaitali Ghosh: 2026 INSC 545. Facts in Issue 1. Whether the defendant could be permitted to file an additional written statement after trial had commenced. 2. Whether the defendant could change her stand from being a co-sharer to claiming tenancy. 3. Whether the High Court was justified in allowing such a pleading under Article 227 of the Constitution. Court’s Reasoning • Order 8 Rule 9 CPC: No pleading shall ordinarily be presented after filing of a written statement unless it is in response to a set-off or counterclaim. • Order 6 Rule 7 CPC: No pleading shall raise a new ground of claim or contain allegations inconsistent with earlier pleadings, except by way of amendment. • The defendant’s attempt to change her stand from co-sharer to tenant was contradictory and inconsistent. • The High Court erred in permitting the additional written statement despite acknowledging that the proviso to Order 6 Rule 17 CPC bars amendments after commencement of trial. • The Supreme Court held that the defendant’s application was an abuse of process, aimed at bypassing procedural safeguards. Final Holding • Appeal allowed. • Supreme Court set aside the Calcutta High Court’s order dated 03.09.2025. • Restored the Trial Court’s order dated 17.06.2025, rejecting the defendant’s application. • Defendant cannot be allowed to change her stand and file an additional written statement at an advanced stage of trial.

1. Supriya Kumari M.C. v. State of Kerala: 2026 INSC 537-

Facts

• Patient K.P. Muralidhar admitted for piles surgery at Dhanalakshmi Hospital, Kannur (28 May 2002).
• Surgery conducted on 29 May 2002; patient collapsed early morning 30 May 2002.
• Post‑mortem: 80% blockage in left coronary artery; cause of death – acute coronary insufficiency.
• Allegations:
  • Appellant (senior anaesthetist) failed to administer anesthesia personally.
  • Instructed nurse Rosamma Varghese to administer analgesic Sensorcaine.
  • Patient lost consciousness and collapsed thereafter.
• FIR initially against surgeon Dr. Mujeeb Rahiman; later chargesheet filed against surgeon, anaesthetist (appellant), and nurse under Section 304‑A & 34 IPC.

Legal Issues

1. Section 482 CrPC – Quashing of Proceedings
   • Whether allegations of negligence justified quashing at threshold.
2. Medical Negligence Standard
   • Whether failure to personally administer anesthesia and delegation to nurse amounted to culpable negligence.
3. Role of Expert Evidence
   • Whether expert panel findings and medical testimony required trial evaluation.

Outcome

• Appeal dismissed.
• Criminal proceedings against appellant under Section 304‑A IPC to continue.
• Court emphasized that doctors cannot escape trial merely by invoking Section 482 CrPC when allegations of negligence exist.

Significance

• Medical negligence law: Reinforces that criminal liability may arise when doctors delegate critical tasks improperly.
• Procedural law: Clarifies limits of Section 482 CrPC; quashing not allowed if prima facie negligence is alleged.
• Healthcare accountability: Strengthens patient rights and ensures medical professionals face trial where negligence is claimed.

Vijaya kumar v. State of Tamil Nadu: 2026 INSC 525 Key Legal Issues

1. Whether acquittal on rape and related charges nullifies intimidation conviction.
   • Court held intimidation was a distinct offence; acquittal on other charges did not affect it.
2. Absence of recovery of mobile phone/video.
   • Defence argued conviction unsustainable without physical evidence.
   • Court ruled prosecutrix’s testimony was credible and sufficient.
3. Scope of Section 506 Part II IPC.
   • Threats to damage dignity and reputation by uploading private videos fall squarely within “criminal intimidation.”

Outcome

• Appeal dismissed.
• Conviction under Section 506 Part II IPC upheld.
• Sentence confirmed.

1. Mallika v. R. Nallathambi & Ors: 2026 INSC 529 Facts of the Case • Properties in dispute: o Agricultural land at Kalapatty Village, Coimbatore Taluk. o Purchased by appellant Mallika in 1996 through registered sale deeds. • Appellant’s claim: o Executed two GPAs in 1997 and 1998 only as collateral security for loans of ₹2 lakhs and ₹5 lakhs at 18% interest. o Original title deeds were handed over merely as security. o Alleged that respondents misused GPAs to execute sale deeds in favor of their relatives. • Respondents’ defense: o Asserted that the GPAs and subsequent sale deeds were genuine transactions with full consideration paid. o Claimed possession and subsequent transfers were valid. Legal Issues • Whether the GPAs executed by the appellant were collateral securities for loans or genuine sale transactions. • Whether the High Court correctly dismissed the appellant’s second appeal under Order XLI Rule 31 CPC. Court’s Reasoning • The First Appellate Court had reappreciated oral and documentary evidence and reversed the Trial Court’s decree. • The appellant failed to produce documentary proof of loan repayment or interest payments. • The appellant did not enter the witness box despite alleging fraud and forgery, leading to an adverse inference. • The sale deeds and mutation entries supported the respondents’ claim of genuine transactions. • Delay in filing suit (instituted in 2008, years after alleged misuse) weakened the appellant’s case. Final Holding • The Supreme Court dismissed the appeal. • It held that the appellant failed to establish that the GPAs were executed merely as loan security. • The transactions were upheld as valid sale deeds, confirming the High Court and First Appellate Court’s judgments.

1. Chetan Dashrath Gade v. State of Maharashtra: 2026 INSC 522-

Key Legal Issues

1. Suicide vs. Homicide
   • Defence claimed Rupali committed suicide.
   • Medical evidence (injury marks inconsistent with hanging) suggested homicide.
2. Credibility of Witnesses
   • Testimony of PW‑1 (father) and relatives supported prosecution case.
   • Doctor’s evidence confirmed injuries inconsistent with suicide.
3. Section 201 IPC (Destruction of Evidence)
   • Appellant’s conduct in reporting suicide and attempting to mislead police amounted to concealment of offence.

Outcome

• Appeal dismissed.
• Conviction under Sections 302 & 201 r/w 34 IPC confirmed.
• Life imprisonment + fine sustained.

PARVATHI NAIRTHI (DEAD) AND ORS. VERSUS LAXMI NAIRTHY (DEAD) THROUGH LRS. AND ORS.: 2026 INSC 521 Facts:

• Testator: B. Sheena Nairi, Chartered Accountant, resident of Bombay, owned properties in Karnataka (Brahmavar & Chanthar villages, Udupi Taluk).
• Family: Wife Parvathi Nairthi (Appellant No.1), five children (Appellants & Respondents), and sister Laxmi Nairthy (Respondent No.1).
• Will dated 15 May 1983: Bequeathed all plaint schedule properties to his sister Laxmi Nairthy.
• Death: 30 November 1983, Delhi.
• Widow sought mutation of properties in her name (1984).
• Sister Laxmi filed suit in 1990 claiming ownership under the Will.

Key Legal Issues

1. Validity of Will (1983)
   • Whether the Will executed in favor of Laxmi Nairthy was genuine and enforceable.
2. Effect of Mutation Orders (1984)
   • Whether mutation in widow’s name could override testamentary succession.
3. Succession Rights
   • Whether heirs of widow could claim ownership despite existence of Will.

Outcome

• Appeal dismissed.
• High Court’s judgment (2012) affirmed.
• Will of 1983 in favor of Laxmi Nairthy upheld.
• Mutation entries in widow’s name declared ineffective.

Significance

• Succession Law: Testamentary succession overrides mutation entries under land revenue laws.
• Property Law: Mutation is only for fiscal purposes; does not confer title.
• Judicial Principle: Courts must give primacy to valid Wills over administrative orders.

1. Parvinder Singh v. Directorate of Enforcement: 2026 INSC 519-

Legal Issues

1. Applicability of BNSS Section 223(1) proviso
   • Does it apply when complaint filed before BNSS but cognizance taken after BNSS commencement?
2. Saving clause under Section 531(2)(a) BNSS
   • Whether ministerial steps before 1 July 2024 amounted to “inquiry” under CrPC, thus saving proceedings.
3. Nature of defect
   • Is failure to hear accused at cognizance a curable irregularity or illegality vitiating cognizance?

Outcome

• High Court judgment set aside.
• Matter remanded to Special Court for compliance with Section 223(1) BNSS.
• Supreme Court reinforced accused’s right to be heard before cognizance in complaint cases under BNSS.

DHARMENDRA KALRA & ORS. VERSUS KULVINDER SINGH BHATIA: 2026 INSC 492-1. Key Legal Issues

1. Order XV Rule 5 CPC – Mandatory Deposit of Rent
   • Whether tenant’s defence could be struck off for non‑deposit of arrears.
2. Extension of Time
   • Whether courts can grant additional time to deposit arrears despite mandatory wording of Rule 5.
3. Balance of Rights
   • How to balance landlord’s right to timely rent with tenant’s right to defend eviction suit.

Outcome

• Appeal dismissed.
• High Court’s order allowing tenant’s revision petition upheld.
• Tenant’s defence restored; eviction suit to proceed on merits.

Significance

• Civil Procedure: Clarifies that Order XV Rule 5 CPC is not an absolute bar; courts retain discretion.
• Tenancy Law: Protects tenants from harsh consequences of procedural defaults.
• Judicial Principle: Reinforces fair trial rights; striking off defence is a drastic step to be used sparingly.

1. Gunjan @ Girija Kumari v. State (NCT of Delhi): 2026 INSC 468-

Legal Issues

1. SC/ST Act – Sections 3(1)(r) & 3(1)(s):
   • Requires insult or intimidation to occur “in any place within public view.”
   • Question: Does abuse inside a private home with only friends present qualify?
2. IPC – Section 506 read with Section 34 (Criminal Intimidation):
   • Whether threats alleged in FIR disclosed ingredients of intimidation.
3. Framing of Charges:
   • Whether trial court and High Court orders framing charges were legally sustainable.

Significance

• Clarifies “public view” requirement under SC/ST Act: abuse inside private homes, even with friends present, does not qualify.
• Protects against misuse of SC/ST Act in family/property disputes.
• Reinforces principle that criminal charges must strictly satisfy statutory ingredients before framing.

1. Mitesh @ T.V. Vaghela v. State of Gujarat: 2026 INSC 469-

Key Legal Issues

1. Reliability of Oral Dying Declaration
   • Defence argued it was unsafe to convict solely on oral statements.
   • Court held dying declarations, if credible, can form sole basis of conviction.
2. Hostile Witnesses
   • Majority of witnesses turned hostile.
   • Court emphasized quality over quantity of evidence.
3. Single Eyewitness Testimony
   • Defence challenged credibility of sole eyewitness.
   • Court found testimony consistent and corroborated by dying declaration.

Outcome

• Appeal dismissed.
• Conviction under Section 302 IPC and Section 135 Bombay Police Act upheld.
• Liberty granted to appellant to seek remission considering long incarceration.

MANJULA AND OTHERS VERSUS D.A. SRINIVAS: 2026 INSC 465 Facts:

• Plaintiff (D.A. Srinivas) sought declaration of ownership of properties based on a Will dated 20 April 2018 allegedly executed by K. Raghunath (deceased 4 May 2019).
• Defendants (Manjula & others) relied on an earlier registered Will dated 28 January 2016 in favor of Manjula (wife).
• Trial Court (Oct 2023): Rejected plaint under Order VII Rule 11(a) & (d) CPC, holding suit barred under Sections 4 & 6 of Benami Act, 1988.
• High Court (Feb 2024): Reversed, restored suit for trial.
• Supreme Court: Set aside High Court order, upheld rejection of plaint.

Key Legal Issues

1. Order VII Rule 11 CPC
   • Whether plaint disclosed cause of action or was barred by law.
2. Benami Transactions Act (1988, amended 2016)
   • Whether claim based on alleged Will amounted to benami transaction.
   • Scope of Sections 4 & 6 prohibiting suits to enforce benami rights.
3. Fiduciary Capacity Exemption
   • Whether plaintiff could claim exemption under fiduciary relationship provisions.
4. Prospective vs. Retrospective Application of 2016 Amendment
   • Court analyzed whether amendments applied to transactions predating 2016.

  Court’s Findings

Issue	Supreme Court’s Holding
Cause of action	Suit barred under Benami Act; plaint rightly rejected.
Benami prohibition	Sections 4 & 6 bar enforcement of benami claims.
Fiduciary exemption	Not applicable; plaintiff failed to establish fiduciary relationship.
2016 amendment	Operates prospectively but bars suits filed after commencement.

  Outcome

• Appeal allowed.
• High Court judgment set aside.
• Trial Court’s rejection of plaint restored.

Significance

• Benami Law: Reinforces strict bar on suits enforcing benami transactions.
• Civil Procedure: Clarifies scope of Order VII Rule 11 CPC in rejecting plaints barred by law.
• Succession & Property Law: Fiduciary exemption under Benami Act narrowly construed; cannot be used to bypass statutory bar.

SHEIKH ABEDIN VERSUS IQBAL AHMED & ANR.: Special Leave to Appeal (C) No(s).19868/2022- Legal Issues

1. Scope of Order XII Rule 6 CPC
   • Whether admissions outside pleadings (like complaints in criminal proceedings) can be relied upon.
2. Possession Rights
   • Whether plaintiffs were entitled to decree of possession based on defendant’s admissions.
3. Validity of Defendant’s Claim
   • Defendant relied on documents dated 9 July 1996 (GPA, Will, etc.) in his favor.

Outcome

• Supreme Court upheld decree of possession in favor of plaintiffs.
• Defendant’s appeal dismissed.
• Reinforced principle that unequivocal admissions can shortcut litigation under Order XII Rule 6 CPC.

Significance

• Civil Procedure: Expands scope of Order XII Rule 6 CPC to admissions outside pleadings.
• Property Law: Caretaker status cannot evolve into ownership rights.
• Judicial Efficiency: Encourages speedy justice where admissions are clear.