Motor Accident Claim – Death of Minor – Tribunal’s award restored – Appeal by parents against High Court’s reduction of compensation from Rs.8,55,000/- to Rs.5,80,000/- – Supreme Court held that Tribunal’s assessment of Rs.5,000/- monthly income for a 10-year-old child under Section 166 MV Act was proper, no deduction for personal expenses applicable, multiplier of 15 justified, and certain heads of compensation wrongly deleted by the High Court – Order of Tribunal reinstated [Paras 5-7].

Quantum of Income – Schedule II in Section 163A vs. Section 166 – High Court erred in applying Schedule II (Rs.30,000/- p.a.) meant for ‘no-fault’ claims under Section 163A – Tribunal’s reliance on Division Bench precedent adopting Rs.5,000/- monthly income for minor upheld – No deduction for personal expenses in case of minor’s death – Multiplier of 15 correct considering mother’s age [Paras 5-6].

Non-Pecuniary Damages – Filial Consortium and Funeral Expenses – As per Pranay Sethi, Rs.40,000/- each for both parents allowed – Funeral expenses Rs.15,000/- maintained – High Court’s deletion of transportation expenses and loss of dress/ornaments/cycle set aside – Loss of estate Rs.15,000/- upheld – Recomputed total Rs.8,70,000/- [Paras 6-7].

Decision – Appeal Allowed – High Court judgment set aside – Tribunal’s award of Rs.8,55,000/- restored – Amount to be paid within one month after deducting sums already deposited, with interest as directed by Tribunal/High Court [Para 7].

Motor Accident Liability – Insurer’s Obligation – Appeal Allowed – Appellant, ostensible owner/driver, challenged High Court’s absolution of insurer from liability for compensation in three claim petitions—Supreme Court held that deceased/injured were owners of goods accompanying their goods in a goods vehicle, hence covered as third parties under Section 147(1)(b)(i) MV Act—Finding of gratuitous passengers by High Court set aside—Ownership remained with registered owner at accident time; insurer bound to indemnify [Paras 7-11].

Gratuitous Passengers – Evidence – Tribunal’s factual finding that victims were accompanying goods for security, hence not gratuitous passengers, upheld—Insurer’s assertion lacked substantiation; no seizure mahazar or criminal case records produced—High Court erred in reversing finding without material [Paras 7-8].

Transfer of Ownership – Possession vs. Ownership – Agreement showed only possession with balance consideration unpaid; registration not transferred as per Section 50 MV Act—Registered owner continued to be ‘owner’ for liability purposes—Naveen Kumar applied; liability falls on registered owner and indemnifiable by insurer [Paras 9-10].

Selective Appeals by Insurer – High Court failed to address claimants’ contention that insurer challenged only three of eleven awards—No rebuttal by insurer—Irrelevant in light of insurer’s liability being upheld [Para 11].

Decision – C.A. Nos. 6338-6339/2024 and 6340/2024 allowed; C.A. Nos. 6341/2024 and 6342/2024 dismissed as settled in Lok Adalat—Awards to be satisfied by insurer with interest as per Tribunal/High Court directions [Paras 6, 12].

Judicial Discipline – Directions to High Court Judge – Modification on Request of CJI – Supreme Court had earlier set aside an Allahabad High Court order and remanded matter for fresh hearing, while issuing directions restraining the concerned judge from handling criminal matters till demitting office – On written request from CJI, SC deleted paras 25 and 26 of earlier order, leaving matter to the Chief Justice of the High Court – Court reiterated that directions were issued to protect institutional dignity and public faith in judiciary, not to cast aspersions on the judge [Paras 1-8].

Institutional Integrity – Role of Supreme Court and High Courts – SC clarified it does not intend to interfere with administrative powers of High Court CJ as ‘master of the roster’ – However, in cases raising institutional concerns affecting rule of law, SC may intervene – Emphasised that High Courts must uphold rule of law, avoid perverse/unjust orders, and maintain credibility – Judges expected to discharge duties diligently and honour constitutional oath [Paras 4, 6, 9, 11-12].

Reference to Precedent – Rikhab Birani v. State of Uttar Pradesh, 2025 INSC 512 – Noted past concern over misuse of criminal proceedings for civil disputes – Stressed the need to avoid recurrence of such cases [Para 10].

Decision – Special Leave Petition disposed – Paras 25 and 26 of order dated 04/08/2025 deleted – Registry to forward copy of present order to Chief Justice of Allahabad High Court [Paras 7, 13-14].

Criminal Law - Bail – Sections 302, 307, 333, 353 of the IPC - Non-Reasoned Order – High Court’s Grant of Bail Without Recording Reasons – Set Aside – The respondent-accused was granted bail by the High Court in a serious offence involving the murder of a project coordinator and his bodyguard – Supreme Court found that the High Court failed to assign any reasons for granting bail despite the respondent having over twenty prior criminal cases and being named by co-accused – Held: The High Court’s order granting bail without justification is legally unsustainable and is liable to be set aside [Paras 10, 13, 16, 18].

Criminal Law – Seriousness of Allegations and Criminal Antecedents – Consideration at Bail Stage – Respondent was accused under Sections 302, 307, 333, 353 read with Section 34 IPC and Section 27 of the Arms Act – His name surfaced during investigation through co-accused disclosures – The Supreme Court held that the serious nature of allegations, combined with the accused's criminal antecedents, warranted denial of bail – Directions issued to treat respondent as in judicial custody [Paras 4-6, 15, 18].

Judicial Discipline – Requirement of Reasoned Bail Orders – Reiterated that grant of bail in serious offences must reflect judicial reasoning and application of mind – Absence of reasons leads to arbitrary exercise of discretion – Court emphasised that bail orders must record relevant considerations to enable judicial scrutiny [Paras 13-14, 18].

Decision: Held: High Court’s order granting bail without reasons is set aside – Respondent deemed to be in custody in the present case – Appeal allowed [Para 18].

Motor Accident Compensation – Self-Employed Person Abroad – Appeal Partly Allowed – Claimants challenged High Court’s award of ₹1,17,20,200/- for accidental death of 31-year-old U.S. national, contending omission of “future prospects” – Supreme Court upheld High Court’s income assessment of ₹78,300/- per month but applied 40% addition towards future prospects as per Pranay Sethi, revised conventional heads, and recalculated total compensation to ₹1,60,15,280/- – Additional sum of ₹42,95,080/- with 6% interest awarded [Paras 3.7, 5.3-5.8].

Assessment of Income – High Court Correct in Relying on Foreign Earnings Evidence – Salary certificate, tax records with social security number, and U.S. minimum wage data properly considered – Tribunal’s finding of ₹5,000/- per month rejected – No cross-objections from insurer; SC maintained High Court’s income computation [Paras 3.5, 3.7].

Future Prospects – Self-Employed – 40% Addition Applicable – Constitution Bench in Pranay Sethi clarified benefit applies to self-employed persons below 40 years – Applied despite complexities of assessing prospects abroad; lack of contrary evidence justified standard addition – Multiplier of 16 upheld [Paras 4, 5.1-5.5].

Conventional Heads – Figures Aligned with Pranay Sethi – Loss of estate ₹15,000/-, funeral expenses ₹15,000/-, loss of consortium ₹40,000/- per dependent (four dependents: ₹1,60,000/-) – Medical/transportation expenses not allowed [Paras 5.5-5.7].

Decision – Appeal partly allowed – Additional ₹42,95,080/- with 6% interest to be deposited by insurer within four weeks before Tribunal; claimants to withdraw upon verification [Paras 6-7].

Criminal Law - Murder  – Benefit of Doubt – Appeal Allowed – Acquittal -  Appellant convicted with husband under Section 302 IPC for beating victim with sticks following land dispute—Supreme Court noted contradictions between medical evidence and prosecution’s timeline, unexplained injuries on victim’s parents, admitted family enmity over partition, and improbabilities in alleged dying declaration—Body found at victim’s house despite alleged assault at temple—Only PW-7, victim’s father with strained relations, claimed to witness attack; other witnesses only saw accused fleeing—Held: Reasonable doubt exists; conviction set aside; appellant acquitted [Paras 1-11].

Medical Evidence vs. Eyewitness Testimony – Doctor opined death occurred between 10-12 p.m., inconsistent with claim that victim died before 9 p.m.—Weapon (danda) allegedly recovered from appellant not chemically examined nor linked to fatal injury—Lack of clarity on cause and time of death undermined prosecution case [Paras 2-7].

Unexplained Injuries on Witnesses – PW-7 and victim’s mother had incised wounds possibly self-inflicted; prosecution failed to explain—Supports defence of intra-family dispute and alternative narrative [Paras 8-9].

Decision – Conviction and sentence under Section 302 IPC set aside—Appellant acquitted; to be released forthwith if not wanted in any other case; bail bonds cancelled [Paras 11-13].

Judicial Service Law - In-House Procedure – Constitutional Validity – Challenge by Sitting Judge – Petition Dismissed – A sitting High Court judge filed a writ petition under Article 32 challenging the validity of paragraphs 5(b) and 7(ii) of the In-House Procedure adopted by the Supreme Court in 1999, contending that it violates Articles 14, 21, 124(4), and the Judges (Inquiry) Act, 1968, by enabling a fact-finding committee and the Chief Justice of India (CJI) to forward recommendations on judicial misconduct directly to the President and Prime Minister – The Court held that the In-House Procedure is not unconstitutional, does not result in punitive action, and merely initiates a constitutionally permissible process without infringing on judicial independence or procedural safeguards – Petition was dismissed with observations on the need to protect judicial integrity and independence through internal mechanisms – The recommendation of the CJI is not binding on Parliament, and thus does not amount to extra-constitutional action [Paras 1, 26, 47, 55, 82, 84-86].

Judicial Conduct – Constitutionality of In-House Procedure – Articles 124 and 218 – Procedure Upheld - Petitioner, a High Court judge, challenged the In-House Procedure allowing a fact-finding Committee to recommend initiation of removal proceedings and enabling the CJI to forward such recommendation to the President and Prime Minister – Held: In-House Procedure is a legally sanctioned mechanism evolved through judicial precedent and Full Court Resolution, and does not violate the Constitution – Forwarding of recommendation by CJI to constitutional authorities does not amount to parallel or extra-constitutional process – Petition dismissed [Paras 26, 47, 55, 82].

Judicial Discipline – Internal Fact-Finding – Not Ultra Vires – Validity of Preliminary Inquiry – The internal process under the In-House Procedure is a preliminary and non-punitive mechanism aimed at preserving institutional integrity and credibility – It fills the gap between judicial misconduct not warranting immediate impeachment and the absence of disciplinary control – The process is fact-finding, not determinative of removal, and compliant with principles of natural justice [Paras 27, 40, 44-46].

Role of Chief Justice of India – Power to Recommend – Not Unconstitutional – The CJI’s action in forwarding the Committee’s report and making observations is within the scope of the Procedure and necessary for explaining withdrawal of judicial work – Such recommendation is not binding on Parliament and cannot be considered prejudicial or unconstitutional – No deviation from Procedure established [Paras 63-69].

Protection of Judges – Judges (Protection) Act, 1985 – Applicability Confirmed – Section 3(2) permits the Supreme Court, among other authorities, to initiate in-house inquiries under existing law – The In-House Procedure, being sanctioned through precedent and Full Court resolution, falls within the scope of “otherwise” mentioned in the Act – Hence, the Supreme Court has lawful authority to initiate such inquiries [Paras 70-83].

Public Disclosure – Confidentiality of Inquiry Reports – Uploading of Photographs/Videos – Not Justified – While procedural safeguards were generally followed, premature publication of material may affect judicial fairness and violate Article 21 rights of the petitioner – Court expressed concern, though no relief was granted on this point [Para 15].

Decision – Writ Petition Dismissed – The Supreme Court held that the Petitioner had not established that paragraphs 5(b) and 7(ii) of the In-House Procedure were ultra vires or violative of constitutional safeguards – The internal mechanism was upheld as a necessary, constitutionally compliant system to ensure judicial accountability without compromising independence [Paras 84-86].

Civil Law - Challenge Ordinance - Temple Management – Constitutionality of Ordinance – Prior Judicial Directions Modified – Interim Committee Constituted – Status Quo Restored – The Supreme Court dealt with a batch of writ petitions challenging the Uttar Pradesh Shri Bankey Bihari Ji Temple Trust Ordinance, 2025, and seeking modification of earlier directions allowing use of Temple funds for land acquisition – The Court found that critical stakeholders (Shebait Goswamis) were not heard before passing directions in Ishwar Chanda Sharma allowing the use of Temple funds, despite the High Court's earlier contrary order having attained finality – Held: Directions in Ishwar Chanda Sharma modifying the High Court’s order dated 08.11.2023 are set aside; petitioners relegated to High Court to challenge the Ordinance – In the interim, operation of the Trust-creating provisions of the Ordinance stayed – To avoid management vacuum, a High-Powered Committee is constituted to supervise the Temple’s day-to-day functioning and public amenities [Paras 1–5, 16–20, 21–23, 28–30, 33–36].

Temple Fund Utilisation – Modification of Prior SC Directions – High Court Order Restored – Directions in Ishwar Chanda Sharma permitting use of Temple funds for acquiring 5 acres of land were passed without hearing affected stakeholders – Held: Such directions cannot override the High Court’s judgment dated 08.11.2023 that barred use of Temple funds – Supreme Court restored status quo ante and directed that redevelopment expenses must be borne by the State, not the Temple trust [Paras 16–20].

Writ Jurisdiction – Constitutional Challenge to Ordinance – Petitioners Relegated to High Court – Petitioners invoked Article 32 to challenge the 2025 Ordinance – Court held that more appropriate remedy lies under Article 226 – Given past and ongoing proceedings in High Court over Temple management, writ petitions under Article 32 not entertained – Petitioners directed to approach High Court [Paras 21–23].

Procedural Fairness – Stakeholders Not Heard – Earlier Directions Invalidated – Court noted that Shebait Goswamis were not heard before authorising Temple fund usage – Directions in Ishwar Chanda Sharma were passed in collateral proceedings unrelated to Bankey Bihari Temple – Held: Judicial fairness and best practices require affording hearing to affected parties – Directions passed in breach thereof were unsustainable [Paras 16–17].

Interim Relief – Trust Formation Stayed – Committee Constituted to Avoid Management Vacuum – Till the High Court adjudicates the constitutional validity of the Ordinance, provisions enabling formation of Trust under Section 3 and 5 of the Ordinance stayed – To prevent a vacuum in temple administration, a High-Powered Temple Management Committee constituted to oversee operations and ensure amenities for devotees – Goswami participation limited to religious rituals [Paras 28–30, 33–36].

Committee Functioning – Roles, Powers and Honorariums Defined – Final Authority with Chairperson – Chairperson (Retd. Justice Ashok Kumar) and Member (Retd. Judge Mukesh Mishra) to be paid monthly honorarium from Temple funds – Committee to operate from Mathura; Chairperson to be final authority on procedures – Petitioners and public permitted to submit suggestions to the Committee for consideration [Paras 35–36].

Decision – Supreme Court allowed modification applications – Portions of Ishwar Chanda Sharma judgment authorising use of Temple funds expunged – High Court’s order dated 08.11.2023 restored – Petitioners relegated to High Court for challenging the Ordinance – Interim stay on formation of Trust – High-Powered Committee constituted to administer Temple operations pending final adjudication [Paras 19–20, 23, 28–30, 35].

Electricity Law -  Tariff – Challenge to Regulatory Asset Practice – Supreme Court Issues Mandate for Time-Bound Liquidation – The petitioners, Delhi-based electricity distribution companies, challenged the Delhi Electricity Regulatory Commission’s continued creation of regulatory assets without structured recovery – Supreme Court held that this violated statutory provisions under the Electricity Act and Policy directives under the National Tariff Policy – Creation of regulatory assets is permissible only in exceptional circumstances with a clear amortisation plan – Indefinite deferment impacts financial viability and transparency in tariff setting – Held: DERC’s conduct unjustified – Court issued binding directions for time-bound liquidation, prohibited further creation without strict conditions, and ordered monitoring through an independent committee [Paras 1–4, 15, 32–38, 75–80].

Tariff Determination – Regulatory Mandate of SERCs – Sections 61, 62, 64 and 86 of the Electricity Act – SERCs must determine tariffs that ensure recovery of the cost of electricity in a reasonable time – Held: Cost-reflective tariffs are essential for DISCOM sustainability – Failure by DERC to ensure timely recovery led to accumulation of regulatory assets and severe financial strain – Non-compliance with statutory provisions warrants judicial intervention [Paras 40–46, 49–54].

Regulatory Assets – Clause 8.2.2 of National Tariff Policy – To be Created Only in Exceptional Situations – The Policy permits regulatory assets where tariffs cannot be increased due to unavoidable reasons – Held: DERC’s prolonged and recurring creation of such assets contravened the mandate of exceptionality – Absence of a clear amortisation plan and structured recovery roadmap is illegal and unsustainable – Recovery must occur within three years as per policy [Paras 34–38, 55–61].

Maintainability – Writ Jurisdiction Despite Alternative Remedy – DERC contended that petitions were not maintainable due to alternate appellate remedies before APTEL – Held: Petitions concern persistent failure of statutory duties by a regulator with widespread consequences for public interest and power sector – Judicial review under Article 32 and 136 maintainable in such exceptional circumstances [Paras 48–49].

Consumer Interest vs. Financial Sustainability – Balancing Mandate under Electricity Act – Regulatory Commissions must balance consumer protection with financial viability of licensees – Held: While protecting tariff affordability, commissions must not allow indefinite postponement of recovery – Sustained under-recovery affects power supply reliability, investor confidence, and overall energy infrastructure [Paras 51–54, 68–70].

Regulatory Accountability – DERC’s Disregard of Directions – Despite specific orders from APTEL and the Supreme Court in earlier matters, DERC failed to implement amortisation plans or comply with mandates – Held: This constitutes systemic regulatory failure – DERC must be held accountable – Monitoring of compliance is essential to ensure transparency and discipline in future tariff processes [Paras 55–61, 68–74].

Final Directions – Supreme Court Mandates Time-bound Liquidation – DERC directed to publish and implement a phased amortisation roadmap – Tariff Orders to reflect realistic cost recovery – Creation of new regulatory assets not permitted unless strict conditions of Clause 8.2.2 are satisfied – Independent Monitoring Committee to oversee and report on progress every six months – Next tariff determination process to account for legacy gaps and recovery charges [Paras 75–80].