SARAFAT ALI (DEAD) THROUGH LRS & ORS. V. DEPUTY DIRECTOR OF CONSOLIDATION, HARIDWAR & ORS: 2026 INSC 652 Facts

• Appellants’ predecessors purchased land via a registered sale deed (04.06.1957).
• Mutation was allowed in their favour in 1984.
• During 1991 consolidation proceedings, their names were omitted from records.
• They relied on the sale deed to claim ownership.
• Consolidation authorities, appellate authority, revisional authority, and High Court all rejected their claim, holding the sale deed was not properly proved.
• Appellants approached the Supreme Court.

Issue Whether minor discrepancies regarding the attesting witness were sufficient to rebut the presumption of genuineness attached to a registered sale deed? Held

• A registered sale deed carries a strong presumption of genuineness and due execution.
• The burden of proof lies heavily on the challenger to establish fraud, coercion, or illegality.
• Unlike Wills or gifts, attestation is not a statutory requirement for sale deeds.
• Minor variations in witness details decades later cannot dislodge the statutory presumption.

Ratio Decidendi

• Presumption of genuineness attached to registered sale deeds is robust.
• Attestation discrepancies are immaterial unless they strike at the root of the transaction.
• Courts must distinguish between documents requiring attestation (like Wills) and those where it is not mandatory (like sale deeds).

Outcome

• Appeal allowed.
• Judgments of High Court and consolidation authorities set aside.
• Appellants’ names directed to be entered in revenue records as tenure holders.

MOHAMMED KHALEEL (D) THROUGH LRS & ORS. V. JAYAMMA (2026 INSC 651): Facts of the Case

• Agreement to Sell: Executed in December 1990 for immovable property.
• Consideration: Part payment made as earnest money; balance payable within four months at execution of sale deed.
• Disputes: Several legal notices exchanged between parties.
• Suit: Purchaser filed suit for specific performance in December 1993.
• Trial Court: Decreed in favour of purchaser.
• High Court: Reversed decree, dismissed suit holding purchaser failed to prove readiness and willingness.
• Supreme Court: Appeal filed challenging High Court’s judgment.

Issues

1. Did the appellant prove continuous readiness and willingness under Section 16(c) of the Specific Relief Act, 1963?
2. Did the delay of nearly three years in filing the suit, though within limitation, disentitle him to equitable relief of specific performance?

Ratio Decidendi

• A plaintiff seeking specific performance must continuously prove readiness (financial capacity) and willingness (conduct) from the date of agreement until decree.
• Financial documents created long after filing the suit cannot establish readiness at the relevant time.
• Unexplained delay in approaching the court, even within limitation, is a valid ground to refuse discretionary equitable relief.
• Since the appellant failed to show sufficient funds at the relevant time, did not actively pursue permissions, and delayed filing the suit, he did not satisfy Section 16(c) requirements.

Outcome

• Supreme Court dismissed the appeal.
• High Court’s judgment refusing specific performance was upheld.

7. Dr. Ramesh v. State of Maharashtra: 2026 INSC 635- Facts in Issue 1. Whether the District Civil Surgeon was legally competent to act as the “Appropriate Authority” under the PCPNDT Act. 2. Whether omissions in Form ‘F’ records were minor clerical errors or serious statutory violations. 3. Whether the criminal proceedings initiated against Dr. Ramesh should be quashed. Court’s Reasoning • Authority: The Court held that pursuant to a valid state notification, the District Civil Surgeon was duly empowered to act as the Appropriate Authority. • Form ‘F’ Compliance: o The Court relied on FOGSI v. Union of India (2019), which established that Form ‘F’ maintenance is a mandatory statutory obligation. o Incomplete records are not trivial slips but a “springboard” for female foeticide, undermining the Act’s purpose. • Public Interest: The Court emphasized that strict enforcement of the PCPNDT Act is essential to combat patriarchal bias and safeguard the right to life of the girl child. • Outcome: The appeal was dismissed, clearing the way for Dr. Ramesh to face trial. Final Holding • Appeal dismissed. • Criminal proceedings under Section 23 of the PCPNDT Act to continue. • Incomplete Form ‘F’ records treated as serious violations, not clerical errors. • District Civil Surgeon confirmed as valid Appropriate Authority.

In the landmark Shishu Pal @ Shish Ram & Ors. v. Surjeet & Ors. judgment delivered on June 11, 2026, the Supreme Court of India officially recognized homemakers as "Nation Builders". The Court fixed a minimum notional benchmark of ₹30,000 per month for unpaid domestic labour and introduced a new distinct compensation head called “Loss of Domestic Care” in motor accident claims Economic Value of Unpaid Work: The Division Bench (Justices Sanjay Karol and N.K. Singh) ruled that domestic work has real economic value. It cannot be treated as valueless simply because it does not generate formal monetary income

6. Shephali Chakraborty vs. The State Of West Bengal: 2026 INSC 621 Facts in Issue 1. Whether the petitioner had a legal right to regularization/appointment under service law principles. 2. Whether the State of West Bengal acted arbitrarily in denying her claim. 3. Whether the High Court was justified in dismissing her writ petition. Court’s Reasoning • The Supreme Court examined precedents on regularization of temporary/contractual employees. • Reiterated that long service alone does not create a right to regularization unless statutory rules or schemes provide for it. • The petitioner failed to establish any statutory entitlement or violation of equality principles under Article 14. • The High Court’s dismissal was found to be correct, as the claim was not supported by law. Final Holding • Appeal dismissed. • Supreme Court upheld the High Court’s order, confirming that the petitioner had no enforceable right to regularization or appointment. • The State’s action was not arbitrary, as her engagement was contractual in nature.

8. Sonu Jaysawal v. State of Uttar Pradesh: 2026 INSC 6 Facts of the Case • Appellant: Sonu Jaysawal. • Respondent: State of Uttar Pradesh. • Background: o The appellant was prosecuted under the Protection of Children from Sexual Offences Act, 2012 (POCSO Act). o Allegations involved sexual assault on a minor girl. o The Trial Court convicted the appellant and sentenced him under relevant provisions of the POCSO Act. o The conviction was upheld by the High Court. o The appellant challenged the conviction before the Supreme Court, arguing inconsistencies in the victim’s testimony and lack of corroborative evidence. Facts in Issue 1. Whether the testimony of the minor victim was credible and sufficient to sustain conviction under the POCSO Act. 2. Whether absence of corroborative medical or independent evidence weakened the prosecution’s case. 3. Whether the Trial Court and High Court rightly convicted the appellant. Court’s Reasoning • The Supreme Court reiterated that in sexual offence cases, the testimony of the victim, if found credible and trustworthy, is sufficient for conviction even without corroboration. • Minor inconsistencies in the victim’s statement do not affect the core truth of the allegations. • The Court emphasized the protective intent of the POCSO Act, which requires courts to adopt a sensitive approach in evaluating evidence. • The appellant’s defense was found weak and unable to dislodge the prosecution’s case. Final Holding • Appeal dismissed. • Conviction and sentence under the POCSO Act upheld. • The Court confirmed that the victim’s testimony was reliable and sufficient to sustain conviction.

5. Darubai & Anr. Vs. Kamalabai & Ors.:2026 INSC 613 Facts in Issue 1. Whether the daughters (respondents) were entitled to equal share in ancestral property under the Hindu Succession Act. 2. Whether the appellants could deny succession rights by relying on customary law or prior partition claims. 3. Whether the High Court was justified in affirming the decree of partition in favor of the daughters. Court’s Reasoning • The Supreme Court emphasized the 2005 amendment to the Hindu Succession Act, which grants daughters equal coparcenary rights in ancestral property. • The appellants failed to prove any valid partition prior to the amendment. • Customary law arguments were rejected, as statutory law overrides customs in matters of succession. • The Court reiterated that gender equality in succession is the legislative intent, and daughters cannot be deprived of their rightful share. Final Holding • Appeal dismissed. • The Supreme Court upheld the High Court’s decree granting the daughters (respondents) their equal share in the property. • Confirmed that Darubai & another (appellants) cannot claim exclusive ownership.