Civil Law - Commercial Suit - Commercial Courts Act 2015 - Section 15 - Order XI Rules 1 and 5 CPC - Filing of additional documents at trial stage - Dispute arose from a Professional Services Agreement dated 19th February 2013 for mobile application development - Suit originally filed in 2015 and renumbered as CS(Comm.) 169 of 2018 - Appellant filed IA No. 24359 of 2023 to bring on record additional e-mails and backend data after completion of evidence of witness PW-1 - Single Judge of High Court rejected the application applying the reasonable cause test finding no explanation for the delay - Supreme Court noted that documents were in possession of the appellant at the time of filing the suit and during a previous round of additional evidence - Held - Statutory intent of the CCA is to ensure speedy resolution and ease of doing business - Evidence however voluminous cannot water down the rigours of the statute - Piecemeal approach or stop and go method in commercial suits cannot be countenanced - Appeal dismissed - [Paras 1-17].

Civil Law - Procedure - Commercial Courts Act 2015 - Order XI Rule 1(4) and (5) CPC - Reasonable Cause vs Sufficient Cause - Appellant contended that the High Court erroneously applied the sufficient cause standard instead of reasonable cause - Supreme Court clarified that while Sudhir Kumar v. Vinay Kumar G.B. mandates the reasonable cause standard for non-disclosure of documents at the time of filing - the appellant failed to meet even the lower threshold - Held - No justification emerges when the plaintiff fails to anticipate questions for witnesses or produce documents already in its possession - Reasonable cause for non-disclosure must be well-established for subsequent discovery - [Paras 10-12].

Civil Law - Interpretation of Statute - Commercial Courts Act 2015 - Section 15 - Application to pending suits - Appellant argued against the strict application of CCA to suits initiated prior to its full notification for the relevant court - Supreme Court rejected the argument citing Section 15(3) which mandates that procedures of the CCA apply upon transfer of a suit to a Commercial Division - Held - Only exception is where judgment has been reserved - Intent of the legislature to expedite commercial disputes applies to all pending matters of specified value - [Paras 14.2-15].

Decision: Appeal dismissed – No costs – Direction issued for the trial court to decide the suit as expeditiously as possible.

Tenancy Law - Rent Control and Eviction - Delhi Rent Control Act 1958 - Section 14(1)(b) - Sub-letting and Parting with Possession - Appellant landlord leased commercial premises to Hindustan Commercial Bank HCB in 1947 - HCB amalgamated with Punjab National Bank PNB in 1986 through a scheme framed by RBI under Section 45 of Banking Regulation Act 1949 - Landlord filed eviction petition on grounds of unauthorized sub-letting - Additional Rent Controller dismissed the petition holding the statutory amalgamation binding on the landlord - Additional Rent Control Tribunal reversed this and granted eviction holding that special rent legislation requiring written consent prevails over general banking laws - High Court set aside the eviction decree by treating the merger as an involuntary statutory act outside the scope of Section 14(1)(b) - Supreme Court analyzed the statutory framework and precedent - Held - Section 14(1)(b) of the DRC Act is wide enough to encompass every mode by which possession or tenancy rights are transferred including involuntary acts - Amalgamation under Section 45 of BR Act results in the transferor entity losing identity and control of possession - Occurrence of such factual situation without written consent of landlord automatically attracts eviction grounds - High Court reliance on precedents involving legislative vesting under different statutes was erroneous as the present scheme is administrative - Impugned judgment set aside and eviction decree restored - [Paras 1-22].

Civil Law - Statutory Interpretation - Banking Regulation Act 1949 - Section 45 - Nature of Amalgamation Scheme - Comparison between schemes under Section 45 of BR Act and Section 9 of the Acquisition Act 1980 - Respondents contended transfer was by statutory operation exempt from landlord consent requirements - Court reviewed tests for legislative versus administrative functions - Held - A legislative act creates general rules while an administrative act applies specific directions to particular cases - Scheme under BR Act merely requires laying before Parliament and lacks the parliamentary modification powers found in the Acquisition Act - Amalgamation scheme under Section 45 of BR Act is administrative and cannot override the mandatory protections for landlords under Section 14(1)(b) of the DRC Act - [Paras 16-20].

Civil Law - Sub-letting - Delhi Rent Control Act 1958 - Section 14(1)(b) - Parting with Possession - Definition - Meaning of parting with possession involves the tenant divesting themselves of both physical possession and the right to possession - Held - Once the original tenant ceases to exist due to amalgamation and a new entity occupies the premises without the written consent of the landlord the ingredients of Section 14(1)(b) are fully satisfied - Reasons for transfer or its voluntary nature are wholly irrelevant - [Paras 8-15].

Decision: Appeal allowed - High Court judgment and order dated 12.03.2012 set aside - Order of Additional Rent Control Tribunal dated 21.05.2001 restored - Respondents granted time until 31.01.2027 to deliver vacant possession subject to filing a written undertaking and continued rent payment.

Criminal Law - Child Sexual Abuse - Prevention of Children from Sexual Offences Act 2012 - Sections 19 and 21 - Mandatory duty to report - Minor girl aged 8 years allegedly sexually assaulted by a senior student in a school classroom - Victim reported the incident to the Headmistress Respondent No 1 who conducted a verification exercise in a teachers room and allegedly noticed redness and sticky substance on victims undergarments - School management held a meeting and decided not to report the matter to parents or police after concluding that children behaved normally and no eyewitness existed - FIR was lodged five months later when victims mother overheard the conversation - Trial Court and High Court discharged the school staff holding that criminal culpability for non-reporting depends on knowledge which was missing as officials found no signs of assault during their own inquiry - Supreme Court held that the expression has knowledge as used in Section 19 of POCSO Act includes awareness based on receipt of credible information from the victim - School authorities have no legal mandate to conduct independent investigations or verification exercises to decide whether an offence has occurred before reporting - Subjective satisfaction or belief of the school official that the complaint is false cannot override the statutory obligation to report - Prompt reporting is a sine qua non for the implementation of the Act to prevent disappearance of evidence - Held - Discharge of Respondent No 1 set aside as she received direct information from the victim - Discharge of other respondents who had no direct communication with the victim and only attended the meeting was upheld in absence of evidence of conspiracy - [Paras 1-66].

Criminal Law - Framing of Charge - Code of Criminal Procedure 1973 - Sections 227 and 228 - Scope of inquiry - At the stage of framing charge the Court is concerned with strong suspicion and not proof - Trial Court cannot act as a post office of the prosecution but must sift evidence only to find if the allegations are groundless - Court must proceed on the assumption that materials brought on record by the prosecution are true - Law does not permit a mini-trial at this stage - Held - The Trial Court erred in weighing the evidence for conviction instead of checking for a prima-facie case - [Paras 20-25].

Evidence Law - Interpretation of Knowledge - Indian Penal Code 1860 - Section 26 - Knowledge vs Reason to Believe - Knowledge is an awareness on the part of the person indicating his state of mind - It is on a higher plane than reason to believe - In POCSO cases knowledge is not limited to direct sensory perception of the crime but extends to awareness through credible communication - Information received directly from a child capable of reporting is deemed credible - Held - To hold otherwise would defeat the purpose of the Act - [Paras 31-56].

Decision: Appeal partly allowed – Discharge order of Respondent No. 1 set aside – Trial Court directed to proceed against Respondent No. 1 under Section 21 of POCSO Act and Section 176 IPC – Discharge of other Respondents affirmed.

Civil Law - Testamentary Proceedings - Civil Procedure Code 1908 - Order XIII Rule 3 - Admissibility of Evidence - Appellant filed an application in a pending probate suit to eschew a proof affidavit and certain documents filed by the respondent, contending irrelevance - Single Judge of High Court dismissed application, allowing all documents except un-explained xerox copies - High Court affirmed, emphasizing that mere filing of affidavit does not prove contents and evidence should not be shut down prematurely - Supreme Court upheld the High Court's reasoning - held that documents not prima facie inadmissible or irrelevant to the properties involved should not be rejected at the threshold under Order XIII Rule 3 CPC - contents of such documents are still required to be proved in accordance with law - Held - Appeal dismissed - [Paras 2-12].

Evidence Law - Admissibility of Documents - Indian Evidence Act 1872 - Civil Procedure Code 1908 - Order XIII Rule 3 - Objections to admissibility - During evidence-collecting stage, objections regarding admissibility of material should generally be noted and decided at the final judgment stage to avoid unnecessary prolongation of trial - Exception being objections relating to deficiency of stamp duty - Held - Mere marking of a document as an exhibit does not amount to its proof and does not dispense with the requirement of proof in accordance with law - [Paras 10-12].

Decision: Appeal dismissed – Impugned judgment and order of the High Court dated 21.08.2024 upheld – Testamentary proceedings in T.O.S. No. 12 of 2021 to proceed uninfluenced by observations made herein – Stay of proceedings granted by this Court on 11.11.2024 stands vacated.

Writ Law - Maintainability - Constitution of India - Articles 12 and 226 - Appellant advocate challenged inclusion in IBA Caution List - High Court dismissed writ holding IBA is not State under Article 12 - Supreme Court reversed holding maintainability under Article 226 depends on public law element and nature of function rather than formal character of body - Inclusion in Caution List affects fundamental right to practice under Article 19(1)(g) and professional reputation - Focus shifted from formal character of the body to the nature of duties performed and source of power - Held - Writ petition under Article 226 is maintainable against IBA as the action possesses sufficient public law character - [Paras 10-19].

Banking Law - RBI Guidelines - Caution List - Banking Regulation Act 1949 - Section 35-A - Appellant included in Caution List for alleged negligence in title verification - IBA list titled Third Party Entities Involved in Fraud - Supreme Court examined RBI Circulars and Master Directions regarding fraud risk management - Caution List intended to alert banks against unscrupulous borrowers and third parties facilitating fraud - Held - Caution List mechanism designed only for fraud - dishonesty - criminality - or serious misconduct - Mere negligence or error of professional judgment absent mens rea cannot be elevated to the level of fraud - Inclusion of advocate in list solely for negligence is unsustainable - [Paras 20-28].

Professional Ethics - Self-Regulation - Advocates Act 1961 - Exclusive Jurisdiction - Independence of the Bar - Bank included advocate in Caution List effectively blacklisting him across banking sector - Supreme Court emphasized legal profession as sui generis and a service-oriented noble profession - Independence of legal profession secured by principle of peer-led self-regulation - Held - Matters of professional conduct - competence - or negligence fall within exclusive domain of disciplinary mechanism under the Advocates Act - Banks cannot unilaterally adjudicate upon professional conduct or bypass statutory disciplinary processes - Action declared illegal and set aside - [Paras 29-36].

Legal Reform - Directions to BCI - Performance Audit and Continuing Legal Education - Accountability of Bar - Supreme Court noted need for robust disciplinary mechanisms to maintain public confidence - Professional autonomy must withstand scrutiny on touchstones of transparency and effectiveness - Court directed BCI to undertake comprehensive performance audit of disciplinary jurisdiction administered by it and State Bar Councils - Direction to institutionalize Continuing Legal Education - CLE - for advocates post-enrolment - Suggestion for establishing National Legal Academy - NLA - for lawyers similar to National Judicial Academy - Held - BCI to constitute committee for objective assessment and file affidavit of action proposed - [Paras 37-60].

Decision: Appeal allowed – Inclusion of appellant’s name in Caution List declared impermissible and without jurisdiction – Respondents directed to remove the name with immediate effect – Matter listed on 31.08.2026 for directions on institutionalising CLE and NLA.

Civil Law - Will - Indian Succession Act 1925 - Section 63 - Suspicious circumstances - Validity of Will - Appellant-plaintiff filed suit for declaration as sole owner of property left by her husband Chhajju Ram - Defendants set up a registered Will dated 06.11.1974 - Trial Court and First Appellate Court discarded the Will finding it shrouded in suspicious circumstances - Suspicious features included illiteracy of testator - complete disinheritance of caring wife - incorrect recitals in Will regarding relationship and service rendered by beneficiaries - and uninitialed cuttings on the registration endorsement changing the name of the presenter - High Court in second appeal reversed findings and upheld the Will - Supreme Court held that the propounder failed to discharge the heavy burden of explaining suspicious circumstances to satisfy the judicial conscience - Incorrect statements in a document allegedly drafted on testator's instructions raise serious doubts about free will and understanding - Held - High Court erred in reversing well-reasoned concurrent findings of fact - appeal allowed - [Paras 1-71].

Civil Law - Second Appeal - Code of Civil Procedure 1908 - Section 100 - Scope of interference - High Court reversed concurrent findings of the courts below regarding the suspicious nature of the Will - Held - Existence of suspicious circumstances and their explanation are essentially questions of fact - Use of phrases like judicial conscience being satisfied does not convert a question of fact into one of law - High Court exceeded its jurisdiction by overturning findings of fact that were neither perverse nor irrational - [Paras 67-71].

Civil Law - Pleadings - Code of Civil Procedure 1908 - Order VIII Rule 5 - Doctrine of Non-Traverse - Non-examination of plaintiff - Respondents contended suit must fail as plaintiff did not enter the witness box to prove fraud or undue influence - Held - Plaintiff's status as legally wedded wife and husband's ownership were not specifically traversed in the written statement and stood admitted - Facts admitted need not be proved under Section 58 of the Evidence Act - Failure to lead evidence on alternative pleas of fraud does not defeat the suit because the primary burden to prove valid execution and dispel suspicion lies solely on the propounder of the Will - [Paras 34-40 and 46-48].

Civil Law - Registration of Will - Registration Act 1908 - Sections 34 35 58 59 and 60 - Presumption of validity - Registration of a Will is optional - Cuttings on the back of the Will changed the name of the presenter from Laxmi Kant Bassi to the testator Chhajju - Cuttings were not initialed by the Sub-Registrar - Held - Benefit of presumption under the Registration Act is unavailable where the endorsement itself is suspect and lacks initials on material alterations - Uninitialed cuttings deprive the propounder of the presumption that the contents were read over to and admitted by the executant - [Paras 63-66].

Civil Law - Disinheritance of Spouse - Indian Succession Act 1925 - Section 63 - Unnatural disposition - Testator was an illiterate agriculturist whose wife cared for him until his death - Will disinherited the wife in favor of distant non-relatives citing incorrect reasons such as she having sufficient jewellery and beneficiaries serving the testator - Held - Complete deprivation of the sole Class I heir in favor of non-relatives without truthful or cogent reasons is an unnatural disposition that pinches the Court's conscience and requires strict proof of testamentary capacity and understanding - [Paras 41-45 and 50-53].

Decision: Appeal allowed - Judgment and order of the High Court set aside - Decree passed by the Trial Court as affirmed by the First Appellate Court restored - No order as to costs.

Civil Law - Insolvency and Bankruptcy - Insolvency and Bankruptcy Code 2016 - Section 7 - Adjudication based on fake AI-generated material - Appellant a suspended director of corporate debtor challenged NCLT order admitting insolvency proceedings - Tribunal relied on non-existent and hallucinated material generated through Artificial Intelligence as precedents to reject the contention that liabilities were transferred due to demerger and amalgamation - NCLAT failed to detect these fake citations and affirmed the order - Supreme Court independent examination revealed that multiple cited cases were either non-existent or contained fabricated paragraphs wrongly attributed to genuine citations - Court equated the use of hallucinated AI material in law to a catastrophic release of toxic substances that contaminates the lifeblood of judicial determination - Held - Any decision of a court or adjudicating authority based on material which is fake or hallucinated is no decision in the eyes of law and amounts to subversion of the rule of law - Judgments of NCLT and NCLAT set aside - [Paras 1-17].

Civil Law - Artificial Intelligence - Information Technology - Judicial Process - Regulation of AI usage - Integrity of Adjudication - Court addressed the tendency of Artificial Intelligence to generate hallucinated results when replying to prompts - Emphasized the necessity of absolute human control over the adjudication process and a human in the loop at every stage - Declared that citing AI-generated precedents without verification constitutes professional misconduct for advocates and a serious lapse for judges - Directed the Bar Council of India to constitute a committee to deliberate on members submitting fake material and to prescribe guiding principles and disciplinary norms - Held - Zero-tolerance approach adopted for citing AI-generated precedents without verification to maintain the sanctity of adjudication - [Paras 1-9].

Decision: Appeal allowed – Judgments and orders passed by NCLT dated 28.08.2024 and NCLAT dated 11.09.2025 set aside – Section 7 application RCP (IB) 6/MB/2023 restored to its original number – NCLT directed to dispose of the application expeditiously preferably within two weeks – Parties directed to maintain status quo.

Criminal Law - Committal Proceedings - Code of Criminal Procedure 1973 - Section 209 - Recording of evidence by Magistrate before commitment - Altercation led to death of appellant father - Allegations under Section 302 IPC - Case committed to Sessions Court - Sessions Court framed charges against one respondent and discharged others - Complainant and one respondent filed revisions in High Court - High Court remanded matter to Magistrate to comply with Section 244 CrPC requiring recording of prosecution evidence before commitment - Supreme Court observed that the 1973 Code consciously did away with lengthy committal inquiries existing under the 1898 Code - Held - Magistrate is not required to record evidence when the offence is exclusively triable by the Court of Session - High Court order set aside - [Paras 1-15].

Criminal Law - Warrant Cases - Code of Criminal Procedure 1973 - Section 244 - Applicability - High Court relied on precedents involving offences triable by Magistrate to mandate pre-charge evidence for Sessions-triable cases - Supreme Court distinguished cited cases noting they pertained to Magistrate jurisdiction or Section 319 proceedings - Held - Section 244 applies to warrant cases instituted otherwise than on a police report which are triable by the Magistrate and does not apply to cases falling under Section 209 commitment - [Paras 8-9].

Criminal Law - Judicial Duty - Code of Criminal Procedure 1973 - Section 209 - Nature of committal order - Comparison with 1898 Code - Legislative intent for expeditious disposal - Power of Magistrate described as a narrow inspection hole - Magistrate role restricted to ensuring compliance with Sections 207 and 208 and determining if the case is exclusively triable by Sessions - Held - Applying mind to merits or taking evidence at pre-committal stage would frustrate the legislative purpose of the 1973 Code - [Paras 10-12].

Decision: Appeal allowed – Impugned judgment of the High Court set aside – High Court directed to hear the revisions filed by the appellant and respondent no.2 afresh and decide them independently within nine months.

Criminal Law - Territorial Jurisdiction - Negotiable Instruments Act 1881 - Section 138 - Appellant filed complaints under Section 138 NI Act at Bhilwara where he maintains a bank account at Kotak Mahindra Bank - High Court of Rajasthan at Jodhpur transferred these complaints to Ajmer because a charge sheet was filed against the appellant in Ajmer under Sections 403 and 417 IPC involving the same subject-matter cheques - Appellant contended that trial had already commenced in 2019 and the transfer petition was filed belatedly in 2022 - Supreme Court noted that the respondent failed to appear despite service - Court observed that it is settled law that jurisdiction for cheques delivered for collection through an account vests in the Court where the payee's home branch is situated - Held - Courts in Bhilwara have exclusive jurisdiction to try the offences - High Court order set aside - appeals allowed - [Paras 2-7].

Criminal Law - Dishonour of Cheque - Negotiable Instruments Act 1881 - Section 138 - Territorial Jurisdiction - Ratio Decidendi - Jurisdiction to try a complaint filed under Section 138 of the NI Act in respect of a cheque delivered for collection through an account is vested in the Court within whose local jurisdiction the branch of the bank in which the payee maintains the account is situated - Supreme Court reaffirmed the principle laid down by the coordinate Bench in Jai Balaji Industries Ltd. v. M/s HEG Ltd. 2025 SCC OnLine SC 2581 - Held - Since the appellant maintains his account in Bhilwara the jurisdiction vests exclusively in the Bhilwara Courts - [Paras 4-6].

Decision: Appeals allowed – Order dated 06th March 2024 passed by the High Court of Judicature for Rajasthan at Jodhpur is set aside – Jurisdiction for the Section 138 NI Act complaints remains with the Courts in Bhilwara.