Maintenance – Section 12 DV Act – Presumption of Legitimacy – Section 112 IEA – DNA Test – Child's Maintenance Denied – Appellant-mother, employed as domestic help, married the respondent on 2nd March 2016; child born 1st April 2016 – Respondent sought DNA test to establish paternity; report dated 8th May 2017 concluded respondent is not the biological father – Trial Court and First Appellate Court denied maintenance to the child; High Court affirmed denial of child's maintenance but remanded appellant's own maintenance claim for fresh consideration – Appeal before Supreme Court dismissed [Paras 2–5, 10].

Section 112 IEA – Presumption of Legitimacy – DNA Report – Evolution of Judicial Opinion – Section 112 creates a conclusive presumption of legitimacy for a child born during a valid marriage unless non-access is proved – DNA test not contemplated when section was enacted – Held: Where a DNA test has been conducted on court direction, its report is on record, and has attained finality without any challenge by the party in whose favour the presumption operates, the position in Nandlal Wasudeo Badwaik v. Lata Nandlal Badwaik, (2014) 2 SCC 576 applies; the DNA report prevails over the statutory presumption – Aparna Ajinkya Firodia (2024) 7 SCC 773 distinguished as it addressed the anterior question of whether a DNA test ought to be ordered at all [Paras 6–10].

Child Welfare – Directions to State – Secretary, Women and Child Development, Government of NCT of Delhi directed to depute an experienced person to visit the residence of the appellant and ascertain the wellbeing of the child in terms of education, nutrition, health and basic material needs; remedial measures to be taken wherever found lacking [Para 11].

Decision: Appeal dismissed – High Court order denying maintenance to the child upheld – Matter of appellant's own maintenance to be decided afresh by Trial Court as directed by High Court – Secretary, Women and Child Development, Delhi directed to assess child's wellbeing and take remedial measures.

Civil Law – Rejection of Plaint – Order VII Rule 11 CPC – Cause of Action – Composite Commercial Arrangement – Appellant-company sold its commercial IT building "Digital Zone-I" to respondents pursuant to negotiations culminating in a Memorandum of Agreement (MoA) dated 17.03.2023 – Eight sale deeds were executed on 03.04.2023 and registered on 19.04.2023 – Appellant filed suit for mandatory injunction to enforce MoA and recover balance consideration of Rs. 53 crores, alternatively seeking reconveyance – Respondents filed application under Order VII Rule 11 CPC for rejection of plaint – Trial court rejected the application holding plaint disclosed cause of action – High Court in revision allowed rejection on grounds that MoA was not a concluded contract and suit was undervalued – Held: Plaint read holistically discloses a triable cause of action arising from a composite commercial arrangement; High Court committed error in conducting a mini-trial at the threshold stage [Paras 2–29].

Cause of Action – Holistic Reading of Plaint – Test under Order VII Rule 11 – Court must take averments in the plaint in their entirety along with documents relied upon; it cannot isolate a sentence or passage – Whether MoA constitutes a concluded contract is a matter for trial; any finding at the threshold amounts to premature adjudication – Plaint pleaded sequence of material facts including negotiations, WhatsApp communications, incorporation of SPVs, partial implementation through sale deeds, subsistence of reciprocal obligations, and alleged breach — these facts constitute a complete and intelligible cause of action warranting a full-fledged trial [Paras 17–29].

Court Fees – Undervaluation – Mandatory Opportunity to Cure – Order VII Rule 11(b) and (c) CPC – Rejection of plaint on ground of undervaluation or deficit court fee requires a two-step process: (i) court must first form opinion that relief is undervalued or court fee is insufficient, and (ii) must afford plaintiff an opportunity to correct valuation and pay requisite fee within time fixed — only upon non-compliance can rejection ensue — High Court erred in rejecting plaint outrightly without fixing proper valuation or granting opportunity to cure — deficiency in court fee is a curable defect and does not render suit non-maintainable at threshold [Paras 32–35].

Decision: Appeal allowed — Impugned order of High Court quashed and set aside — Trial court directed to afford appellant opportunity to correct valuation and pay requisite court fees within time to be fixed — No order as to costs [Para 36–37].

Criminal Law — Quashing of Proceedings — Section 482 CrPC — Bona Fide Purchaser — Absence of Material Connecting Accused to Forgery or Conspiracy — Respondent-complainant alleged that a Will dated 12.09.1988 purportedly executed by his deceased father was forged while the father was in a comatose state, and that the legatee (A-1) in furtherance of a criminal conspiracy with A-2 to A-9 used the forged Will to execute registered sale deeds dated 18.12.1998 in favour of A-2 to A-6, one of whom is the appellant — FIR registered for offences under Sections 465, 468, 420 and 120-B IPC — Chargesheet filed under Sections 467, 468, 471, 420 read with 120-B IPC — High Court dismissed the quashing petition holding that disputed questions of fact were involved — Held on appeal: Proceedings against the appellant quashed — There is not an iota of evidence connecting the appellant with the fabrication of the Will — Appellant was approximately 14-15 years of age when the Will was allegedly forged in 1988 and was studying in Australia at the time of execution of the sale deed in 1998 — Sale deeds clearly show execution for valuable consideration — Appellant was not party to the earlier agreement to sell dated 13.07.1995 — No privity of contract between appellant and complainant — No material to show that the appellant had knowledge that the Will was forged or that he made any fraudulent inducement to the complainant — Continuation of proceedings amounts to abuse of process [Paras 20–25].

Cheating — Section 420 IPC — Purchaser Cannot Be Accused of Cheating the Original Owner — The complainant who is the original owner (or his heir) cannot allege that the purchaser under a registered sale deed cheated him — The offence of cheating under Section 420 IPC requires that the accused deceived the complainant or fraudulently induced him to part with property — In the instant case no such allegation was made against the purchasers — If the Will was indeed forged, the purchasers would themselves be the persons aggrieved, having acquired title from a vendor who used a fabricated Will — A third party who is not a purchaser under the impugned deed cannot make such a complaint of cheating against the purchaser — Ratio in Mohammed Ibrahim and Others v. State of Bihar and Another, (2009) 8 SCC 751 applied [Paras 22–24].

Handwriting Expert's Opinion — Evidentiary Value — FSL Report Based on Xerox Copy — The FSL report, heavily relied upon by the State and the complainant, was based on comparison of the disputed signatures with a xerox copy of the allegedly forged Will and not with the original document — This raises a serious issue regarding the evidentiary value and persuasive worth of such report — Handwriting expert's opinion is inherently a weak piece of evidence and cannot without independent corroboration form the sole basis of criminal prosecution [Para 21].

Decision: Appeal allowed — Impugned order of the High Court dated 11.08.2022 set aside — All criminal proceedings against the appellant in C.C. No. 419 of 2018 before the Judicial Magistrate No. II, Karur quashed — Proceedings to continue against the other accused — Pending applications disposed of.

Land Law – Reclassification of Revenue Land – Public Utility Land – Void Patta – Section 132, U.P. Zamindari Abolition and Land Reforms Act, 1950 – Subject land in District Hardoi, Uttar Pradesh, recorded as Category-6 (barren/non-agricultural land including khalihan and pasture land) in khatauni – Sub-Divisional Officer reclassified land as Category-5 (cultivable land) vide order dated 31.10.1992 and pattas granted in favour of appellant – Consolidation Officer subsequently expunged appellant's name from revenue records – High Court dismissed writ petition holding land to be public utility land under Section 132 of the Abolition Act – Held: Sub-Divisional Officer had no jurisdiction to reclassify land falling within the prohibitory ambit of Section 132; patta granted in favour of appellant void ab initio; appeal dismissed [Paras 2, 10, 18, 30, 37].

Jurisdiction – Power of Sub-Divisional Officer – Paragraph Ka-155-Ka, U.P. Land Records Manual – Appellant contended that Paragraph Ka-155-Ka, Clause (9) empowers the Assistant Collector/Sub-Divisional Officer to transfer land from one category of khata to another – Held: The provision only regulates entries pertaining to the tenure of khatedars already recorded in revenue records and does not authorise any change in the category of the land itself – Reliance on the said provision to justify re-categorisation of land from Category-6 to Category-5 is misconceived and untenable [Para 28].

Statutory Interpretation – Prohibition Cannot Be Circumvented Indirectly – Quando aliquid prohibetur ex directo, prohibetur et per obliquum – Section 132 of the Abolition Act expressly prohibits conferment of bhumidhari rights in respect of public utility land including pasture land and khalihan – Power to alter land category vests exclusively in the State Government under Section 117(6) read with Section 77(2) of the U.P. Land Revenue Code, 2006, subject to stringent safeguards – Allowing subordinate revenue officers to reclassify such land through administrative entries would render the statutory prohibition nugatory – Held: What cannot be done directly cannot be done indirectly [Para 29].

Bhumidhari Rights – Public Utility Land – Asami Patta – Section 132, 195 of the Abolition Act – Bhumidhari rights cannot accrue in respect of land falling under Section 132 – At best, such land may be temporarily settled by way of an Asami patta limited to five years under Rule 176-A of the U.P. Zamindari Abolition and Land Reforms Rules, 1952 – Even assuming a valid patta had been granted, it would stand expired upon completion of the five-year period [Para 25].

Res Judicata – Earlier Proceedings Under Section 198(4) – No Adjudication on Merits – Earlier application seeking cancellation of pattas was rejected by the Additional Collector on 19.08.1994 solely on the ground that execution of pattas was not established – No adjudication on the validity or legality of the pattas on merits – Revision also dismissed without entering into merits – Held: Since the existence and legality of the pattas were never finally adjudicated, the principle of res judicata has no application [Paras 33–36].

Protection of Community Land – Public Welfare – Consolidation Proceedings Cannot Circumvent Statutory Protections – Communal resources such as khalihan and pasture land constitute material assets of the community essential for ecological balance and public welfare – Consolidation proceedings cannot be employed as a vehicle to divert public utility land to private individuals through administrative manipulation – Held: Diversion of public utility land through administrative processes cannot be countenanced by law [Paras 31–32].

Decision: Appeal dismissed – Order of Consolidation Officer expunging appellant's name from revenue records upheld – Patta granted in favour of appellant declared void ab initio – No orders as to costs.

Motor Accident – Compensation – Prosthetic Limb – Restitutio in Integrum – Section 168 of the Motor Vehicles Act, 1988 – Appellant's right leg was crushed and amputated below the knee in a motor accident on 02.05.2007 caused by a bus of Haryana Roadways – Tribunal awarded Rs. 8,73,211/- and High Court enhanced it to Rs. 13,02,043/- — Neither Tribunal nor High Court awarded any compensation under the head of prosthetic limb — Held: Appellant is entitled to compensation for purchase and maintenance of prosthetic limb on the principle of restitutio in integrum — Compensation further enhanced; total additional amount of Rs. 36,20,350/- directed to be paid by insurance company [Paras 2–37].

Prosthetic Limb – Computation – Standard Formula – Life Span of Limb and Claimant – The Court is not bound by the abysmally low rates prescribed in the Government Notification — Claimant is entitled to choose a private centre for procuring prosthetic limb and it is no answer for the defendant to point to cheaper options — Assumed life span of claimant fixed at 70 years — Life span of one prosthetic limb taken as five years — Appellant was 32 years old at time of accident; accordingly entitled to seven prosthetic limbs — Rs. 3,00,000/- awarded per limb on a standard basis totalling Rs. 21,00,000/- — Maintenance cost awarded at Rs. 15,000/- per annum i.e. Rs. 75,000/- per five-year block; consolidated sum of Rs. 5,00,000/- awarded for maintenance till assumed life span — Henceforth, all claims under the head of prosthetic limb/artificial limb shall be accompanied by price quotations from at least two or three service providers to enable Tribunal to make informed assessment [Paras 18–33].

Just Compensation – Loss of Future Income – Functional Disability – Monthly income of appellant as a heavy vehicle driver accepted at Rs. 6,000/- per month — Medical evidence (AW-2 Dr. Ratan Lal Dayma) confirmed appellant cannot drive heavy vehicles — Functional disability assessed at 100 per cent — Applying formula of Rs. 6,000 x 40% future prospects x 12 x 16 (multiplier), loss of future income computed at Rs. 16,12,800/- — Absence of documentary evidence not fatal where claim is reasonable considering occupation and year of accident — Compensation under this head enhanced by Rs. 8,02,368/- over High Court's award [Paras 34–35].

Decision: Appeal allowed — Compensation enhanced under the following heads over and above High Court's award: loss of future income Rs. 8,02,368/-; loss of income during treatment period Rs. 18,000/-; prosthetic limb including maintenance Rs. 26,00,000/-; litigation cost Rs. 2,00,000/- — Total additional amount of Rs. 36,20,350/- (rounded off) directed to be paid by Insurance Company-Respondent No. 2 within four weeks, failing which interest at 9% per annum — No order as to costs [Paras 37–39].

Service Law – Departmental Inquiry – De Novo Inquiry – Rule 10 – "Further Inquiry" Does Not Mean De Novo Inquiry – Appellant, a Civil Judge promoted as Senior Civil Judge, placed under suspension and charge-sheeted on eight charges — Inquiry Officer found only Charge No. 1 (habitual absenteeism) proved — Disciplinary Authority, finding procedural lapses and improper appreciation of evidence, ordered de novo inquiry — Held: The expression "further inquiry" in Rule 10(1) does not mean a fresh or de novo inquiry but only a further inquiry into the existing inquiry — Disciplinary Authority's direction for de novo inquiry impermissible — High Court erred in upholding the same [Paras 11–12].

Judicial Officer – Reinstatement – Consequential Benefits – Impugned judgment of the High Court quashed and set aside — respondent directed to reinstate the appellant with all consequential benefits [Paras 13–14].

Decision: Appeal allowed — judgment of the High Court of Gujarat dated 26.09.2024 quashed and set aside — respondent directed to reinstate the appellant with all consequential benefits — no order as to costs.

Prisoners with Disabilities – Constitutional Rights – RPwD Act, 2016 – High-Powered Committee – Directions Extended to All States and UTs – Petition raising issues of rights, detention conditions, and safeguards for disabled prisoners – Court previously issued directions in L. Muruganantham (2025) 10 SCC 401 for identification, accessible infrastructure, healthcare, assistive devices, staff training, accessibility audits, and compliance reporting – Present order extends those directions to all States and UTs and issues further directions – Held: Issues more effectively addressed through High-Powered Committee constituted in Suhas Chakma v. Union of India & Ors., 2026 SCC OnLine SC 317 [Paras 1–6].

Grievance Redressal – Inclusive Education – Section 89 RPwD Act – Enhanced Visitation – Additional directions issued: (a) robust, independent and accessible grievance redressal mechanism for disabled prisoners; (b) inclusive education facilities within prison; (c) Section 89 of RPwD Act made applicable to prison establishments; (d) States/UTs to indicate structured mechanism for provision of assistive devices and mobility aids; (e) enhanced visitation rights for prisoners with benchmark disabilities [Para 3].

High-Powered Committee – Mandate Expanded – Compliance Mechanism – Issues in present proceedings entrusted to High-Powered Committee constituted in Suhas Chakma (supra) – Committee empowered to issue directions to State/UT departments, formulate action plan for assistive devices, seek expert assistance, and submit consolidated status report within four months – Expenses to be borne by Ministry of Social Justice and Empowerment – All States/UTs to file compliance affidavits within six weeks [Paras 5–7].

Decision: Matter referred to High-Powered Committee – States and UTs directed to file compliance affidavits within six weeks – Registry directed to transmit copy of order to Chairperson of High-Powered Committee – Matter listed on 1st September 2026 along with W.P. (C) No. 1082 of 2020.

Succession Law – Probate – Revocation – Section 263 of the Indian Succession Act, 1925 – Suppression of Material Facts – Necessary Parties – Respondent No. 1 obtained probate of an unregistered Will dated 09.01.1976 executed by her father Eswaramurthy Gounder, by filing a probate petition under Section 276 of the ISA on 21.04.2009, nearly 33 years after the Will's execution and 26 years after the testator's death — Only her two sisters were impleaded; her two brothers/their legal heirs and the present appellants (who had purchased the suit property from third-party vendees by registered sale deeds dated 31.12.1997) were not cited — Appellants filed application for revocation under Section 263 ISA — District Court allowed revocation finding Will unproved and probate obtained by fraud — High Court in revision set aside revocation holding testamentary jurisdiction is confined to pronouncing upon genuineness of Will — Held: High Court erred; District Court's revocation order is restored [Paras 3–26].

Probate – Judgment in Rem – Caveatable Interest – Alienees as Necessary Parties – Grant of probate is a judgment in rem binding not only parties but the entire world — Any person aggrieved thereby who had no knowledge of proceedings and was not properly cited is entitled to file application for revocation — Even a slight interest or bare possibility of interest is sufficient to entitle a party to oppose a testamentary document — A purchaser who acquires interest in the testator's estate by reason of transfer by heirs at law, prior to the filing of probate proceedings, is an interested party entitled to citation under Illustration (ii) to Section 263 ISA — In the present case, appellants purchased property by registered sale deeds prior to the filing of probate petition in 2009 and were therefore necessary parties who ought to have been cited [Paras 7–22].

Proof of Will – Attesting Witnesses – Section 63 ISA and Section 68 Indian Evidence Act – Will not proved in accordance with law where no attesting witness was examined and no satisfactory explanation offered for their absence — Custody of Will unaccounted for a period of nearly 26 years from testator's death — Original Will removed from court's custody on 23.02.2010 in contravention of Section 294 ISA — Procedure under Section 283 ISA for issuing citations was not followed [Para 3.5].

Revocation of Probate – Fraud – Concealment – Section 263(b) ISA – Respondent No. 1 was aware that her father had sold the property to third parties after executing the Will, yet suppressed this fact while filing probate petition — She filed a civil suit O.S. No. 110/2009 barely eight days after the probate petition wherein she herself averred about the transfer of property by her father — Such suppression amounts to obtaining probate by fraud by concealing material facts — Absence of citation on parties who ought to have been cited is a defect of substance constituting just cause for revocation [Paras 21–24].

Decision: Appeal allowed — Impugned order of High Court dated 26.04.2022 set aside — Order of District Court revoking grant of probate restored — Civil proceedings pending before concerned court to be decided in accordance with law uninfluenced by observations in this judgment — No order as to costs [Paras 25–29].

Foreign Judgment – Enforcement – Section 13 CPC read with Section 44A – Summary Judgment – Natural Justice – Triable Issues – English Court passed summary judgment against respondent after refusing leave to defend, arising from a share purchase and co-operation agreement and subsequent guarantee invoked under an external commercial borrowing facility – Division Bench of Delhi High Court refused enforcement holding the judgment violated Section 13 CPC – Supreme Court upheld refusal – Held: Summary disposal of a claim in the presence of bona fide triable issues supported by contemporaneous documents constitutes a judgment not rendered "on the merits" within the meaning of Section 13(b) CPC; and denial of leave to defend despite triable issues violates natural justice under Section 13(d) CPC [Paras 2, 40–53, 86].

Merits of Foreign Judgment – Summary Jurisdiction – Balance Sheets – Minutes of Board Meetings – Respondent raised three oral agreement defences, supported by balance sheets and board minutes signed by appellant's nominee director reflecting no subsisting liability – English Court refused leave to defend and proceeded summarily – Held: When assertions are supported by contemporaneous documents carrying statutory presumptive value under Sections 194, 210, 211 and 215 of the Companies Act, 1956, and oral evidence could reasonably be expected at trial, it is not open to the court to dispose of the matter summarily – Respondent was foreclosed without full opportunity [Paras 44–53].

Section 13 CPC – Principles Restated – Exceptions (a) to (f) – English Court was a court of competent jurisdiction under clauses 12.5, 31.1 and 31.2 of the Loan Agreement – No fraud made out – Judgment fails tests under Sections 13(b), 13(c), 13(d) and 13(f) – Failure to give effect to statutory permissions and conditions of Indian foreign exchange law attracts Section 13(c) – Enforcement contrary to binding RBI conditions brings decree within Section 13(f) [Para 86].

Foreign Exchange – Section 47 FERA – Distinction Between Institution of Proceedings and Enforcement – RBI Conditions – Though Section 47(3) of FERA does not bar legal proceedings to determine liability, sub-section (3)(b) imposes an absolute embargo on taking steps for enforcement of any decree without prior permission of the Central Government/RBI – Held: Permission of RBI is a sine qua non before any step in enforcement can be initiated – Conditional permission granted by RBI on 03.09.1997 stipulating "no liability whatsoever will extend to the Indian Company" does not constitute an absolute bar to enforcement for all time, but RBI's approval is a mandatory precondition before execution steps are commenced – Judgment of High Court reversed on this principle of law [Paras 54–83].

Decision: Appeal dismissed – Foreign judgment held unenforceable under Section 44A CPC as it falls foul of exceptions under Sections 13(b), 13(c), 13(d) and 13(f) of CPC – No order as to costs.