Insurance Law - Insurance claim dispute – Alleged breach of insurance policy conditions – Immediate notice of theft given to the insurance company – Whether a delay in intimating the insurance company about the theft constitutes a fundamental breach of Condition No.1 of the insurance policy – Court’s interpretation of Condition No.1 and reliance on previous judgments to determine its applicability. (Para 9)

Negligence of leaving the key in the ignition during the theft – Whether such negligence amounts to a fundamental breach of Condition No.5 of the insurance policy – Court’s consideration of the facts and circumstances to assess the breach. (Para 15)

Previous judgments – Nitin Khandelwal and Amalendu Sahoo – Their application in determining the proportionate deduction from the assured amount in case of contributory factors affecting the claim – Court’s reliance on these precedents to decide the matter. (Para 19)

Guidelines issued by the New India Assurance Co. Ltd. For settling claims on a non-standard basis – Court’s acceptance of the guidelines as relevant and applicable to the present case. (Para 20)

Court’s ruling on the appeal – Setting aside the judgment of the National Commission and restoring the decision of the District Forum as affirmed by the State Commission – Awarding 75% of the admissible claim amount to the appellant. (Para 20)

Property Dispute – Sale Deed – Transfer of Title and Possession – Recitals in Sale Deed – Whether title and ownership passed to the plaintiff on the date of Sale Deed – Validity of unilateral cancellation deed executed by the first defendant – Effect of subsequent Gift Deed – Examination of recitals in Sale Deed to determine the nature of the transaction. (Para 12-17)

Interpretation of Sale Deed – Transfer of Property Act, 1882 – Section 54 – Consideration and Possession – Whether normal execution and registration of a Sale Deed transfer title in the property subject matter to the purchaser even if consideration is not fully paid – Exception to the general rule under the practice of ta khubzul badlain in Bihar. (Para 13)

Charge for Unpaid Consideration – Section 55(4)(b) of the Transfer of Property Act, 1882 – Effect of unpaid consideration on the seller’s right to have a charge over the property – Liability of the plaintiff to discharge the liabilities mentioned in the Sale Deed. (Para 16)

Unilateral Cancellation Deed – Binding on the plaintiff – Validity of the cancellation deed executed by the first defendant without the plaintiff’s consent. (Para 17)

Decree for Possession – Ownership of the plaintiff – Consequences of establishing plaintiff’s ownership over the suit property. (Para 18)

Counter-claim for Unpaid Consideration – Absence of counter-claim by the first or second defendant for the alleged unpaid consideration – Effect on the plaintiff’s ownership and right to possession. (Para 17)

Decision of High Court – Reversal of Trial Court’s decree – Examination of the reasoning adopted by the High Court and its validity – Restoration of the Trial Court’s decree in favor of the plaintiff. (Para 18)

Criminal Appeal – Dowry Harassment – Allegations of dowry harassment and cruelty against in-laws by Bhawna – Appellants, Kusum Lata, Abhishek, and Sourabh, accused of subjecting Bhawna to mental and physical harassment – Allegations pertain to the period from 2007 to 2013 – Divorce proceedings initiated by Bhawna’s husband, Nimish. [Para 18-21]

Inconsistencies and Discrepancies – Glaring inconsistencies noted in Bhawna’s allegations, particularly concerning her stridhan jewelry and her animosity towards her brother-in-law, Abhishek. [Para 18]

Timing of Complaint – Complaint filed just before divorce proceedings were initiated by her husband, Nimish. Bhawna parted ways with her in-laws in 2009 but did not file a complaint until 2013. [Para 19-21]

Lack of Specific Instances – Allegations against the appellants were vague and general in nature, lacking specific instances of harassment. [Para 19-21]

Prima Facie Case Not Made Out – The Court concluded that the allegations were insufficient and far-fetched, failing to make out a prima facie case against the appellants. [Para 22]

Decision – Given the totality of the circumstances, the Court exercised its inherent power under Section 482 Cr.P.C. to quash the FIR and the consequential proceedings against the appellants. [Para 23]

Criminal Appeal – Anticipatory Bail – Denial of anticipatory bail and direction to surrender before the Court for regular bail – Appellant aggrieved by the High Court’s order – Peculiar nature of the impugned order warranted further consideration – Special leave granted. [Para 1]

Personal Liberty – Importance of personal liberty in the context of applying discretion to grant bail – Emphasis on granting bail ordinarily, with caution in serious cases involving offences carrying long sentences or special offences. [Para 9]

Arrest – Power to arrest not mandatory in every case – Arrest to be made only when essential for custodial investigation, preventing further offences, or avoiding tampering with evidence or witnesses – Courts to consider Section 41A of the CrPC in this regard. [Para 10]

Guidelines for Granting Anticipatory Bail – Reiteration of directions in Arnesh Kumar v. State of Bihar and Another – Police officers and Magistrates to exercise discretion judiciously while granting anticipatory bail – Checklists to be used, and reasons for arrest to be recorded in writing – Non-compliance may lead to departmental action and contempt of court proceedings. [Para 11]

Importance of Upholding Personal Liberty – History of the Republic and the Freedom Movement highlights the significance of safeguarding personal liberty and preventing arbitrary arrests. [Para 12]

Conclusion – High Court’s casual approach in rejecting anticipatory bail set aside – Appellant granted anticipatory bail subject to terms and conditions imposed by the Trial Court – All courts and police authorities directed to strictly follow the law laid down in Arnesh Kumar and the directions in the judgment within the specified time frame. [Para 13]

Criminal Appeal - Quashing of opinion formed in final report - Car accident resulting in multiple deaths - Further investigation conducted and final report submitted stating accident was unavoidable and not due to negligence on part of deceased - Petition filed seeking quashing of final report - High Court quashed the report and attributed negligence to deceased - Appeal filed against quashing of report. [Para 2-7]

High Court's observations and findings - High Court made unnecessary findings beyond the scope of considering the correctness of final report - Incorrect approach adopted by High Court. [Para 8]

Effect of quashing of report on criminal proceeding - Criminal proceeding abated due to death of accused - Quashing of report does not impact criminal proceeding. [Para 7]

Compensation claim petitions - Negligence needs to be proven based on preponderance of possibilities, not beyond reasonable doubt - Claimants must establish negligence of drivers involved in accident. [Para 9-10]

Previous judgments - Culpable rashness and negligence need to be proven in claim petitions - Standard of proof beyond reasonable doubt not applicable in compensation claims. [Para 9-10]

Supreme Court's decision - High Court's order set aside - Appeal allowed - Opinion in final report does not affect compensation claim petitions - Each party to bear respective costs. [Para 11]

Civil Appeal - Valuation of Suit - Amendment of Plaint - Declaration and Cancellation of Property Documents - Dispute over Ad Valorem Court Fee - Appeal against High Court Order under Article 227 of the Constitution - Directions to Revalue Suit and Pay Court Fee - Trial Court Dismisses Applications for Amendment and Rejects Plaint - Petition before High Court - High Court allows Petition and Orders Framing of Issue on Suit Valuation - Appeal to Supreme Court Challenging High Court Order.

Trial Court's Direction for Proper Valuation of Suit - Appellant contends Substantive Right of Appeal under Section 96, CPC - High Court's Order under Article 227 of the Constitution - Substantial Questions of Law and Valuation remain Unaddressed - Nature of Amendment sought not Clearly Mentioned in High Court Order - Appellants seek Reconsideration.

Supreme Court Remands the Matter back to High Court for Fresh Consideration - High Court Directed to Address all Legally Available Contentions - Emphasizes Expeditious Disposal of the Case within Six Months - Observes No Observations on Merits made - No Order as to Costs.

Suspension of Medical Practitioner's License - Contempt of Court Proceedings - Jurisdiction of Court - Punishment under Contempt of Courts Act, 1971 - Nature of Punishment specified in the Act - Examination of whether suspension of medical practitioner's license is alien to the specified punishments under the Act. (Para 10 and 20)

National Medical Commission Act, 2019 - Governance of Medical Practitioner's Licenses - Mechanism for revoking license for professional misconduct - Distinction between contempt of court and professional misconduct as separate offenses. (Para 7, 8, 16, and 21)

Exercise of Contempt Jurisdiction - Judicious and sparing use of the power of contempt - Need for restraint, wisdom, and confidence in upholding the judicial system - Importance of protecting free speech while exercising contempt powers. (Para 13, 14, and 15)

Suspension of License in Contempt Proceedings - Contempt Proceedings arising from unauthorized construction - Suspension of medical practitioner's license as a punishment for contempt - Punishment not recognized or accepted under the Contempt of Courts Act, 1971 - Disregard for statutory text and prescribed punishment under the Act. (Para 19 and 20)

Revival of Medical Practitioner's License - Undertaking for remedial construction - Direction to complete necessary demolitions and remedial construction to safeguard the existing building - Revival of the medical practitioner's license to practice medicine. (Para 24 and 25)

Criminal Appeal – Bail – Unlawful Activities (Prevention) Act, 1967 – Indian Penal Code, 1860 – Appellants sought bail in cases relating to charges under UAPA and IPC – Examination of materials and evidence presented by prosecution  – Assessment of whether reasonable grounds exist to believe accusations against appellants are prima facie true  – Analysis of various documents, including letters and account statements allegedly recovered from co-accused's devices and residences – Evaluation of witness statements  – Absence of direct attribution of terrorist acts to appellants  – Mere possession of literature promoting violence or advocating overthrow of democratically elected government not sufficient to constitute an offense  – Insufficient evidence to implicate appellants under relevant provisions of UAPA  – Court's duty to carefully interpret stringent provisions of the law – Consideration of delay in trial  – Bail-restricting clauses in UAPA cannot deprive court of jurisdiction to examine constitutional right to liberty  – Granting bail considering factors including seriousness of charges and duration of detention  – Imposition of conditions for bail  – Right to seek cancellation of bail in case of breach or further illegal activities (Para No. 2, 20, 22, 26, 29, 36, 41, 42, 43, 45, 46).

Criminal Appeal - Summoning of Additional Accused - Scope of Section 319 Cr.P.C - The Supreme Court examines the scope and application of Section 319 Cr.P.C, which empowers the court to summon a person as an accused if evidence during the trial indicates their guilt.

Trial Court's Order - Summoning Three Accused - The appellant, who was the informant and a prosecution witness in a criminal trial, moved an application under Section 319 Cr.P.C to summon three individuals as accused who were named in the FIR but not charged in the chargesheet.

High Court's Revision - Setting Aside Summoning Order - One of the accused, Ramesh Gandhi, filed a revision before the High Court, challenging the summoning order issued by the trial court.

High Court's Error - Misinterpretation of Section 319 Cr.P.C - The High Court erred in allowing the revision and setting aside the summoning order based on incorrect reasoning. It should have only considered whether a prima facie case was made out against the accused at the stage of Section 319 Cr.P.C.

Section 149 IPC - Unlawful Assembly - No Specific Individual Roles Required - The court clarified that for the offense of being a member of an unlawful assembly under Section 149 of the IPC, specific individual roles or acts are not necessary. The presence as part of an unlawful assembly is sufficient for conviction.

Supreme Court's Decision - Setting Aside High Court's Order - The Supreme Court held that the prosecution had fully made out its case for summoning the three accused under Section 319 Cr.P.C, based on the evidence of the prosecution witness (PW-9). The court allowed the appeal, set aside the High Court's order, and directed that the trial should proceed as expeditiously as possible with all three accused facing trial for the offenses charged against them.

(Para 3, 4, 5, 6)