Motor Accident Compensation – Reversal of High Court Findings – Section 166 of the MV Act – Tribunal’s Award Restored – Supreme Court set aside High Court’s judgment which had overturned the MACT award by disbelieving the claimants' version of accident – Held: MACT correctly relied on eyewitness testimony (PW-1) and documentary evidence like FIR, MLC, death report, and chargesheet – Non-examination of additional witnesses not fatal – MACT’s findings restored [Paras 9-10].

Eyewitness Evidence – Pillion Rider's Testimony Credible – Supreme Court held that testimony of PW-1, wife of deceased who was pillion rider, was credible and sufficient to prove accident was caused by rash driving of offending vehicle – High Court erred in brushing aside direct eyewitness account [Para 9].

Contradictory Police Statements – Cross-Examination Denials Ignored – Court observed High Court wrongly relied on PW-2's police statement which he denied during cross-examination – Insurance company failed to prove contents of police statement by examining investigating officer – Held: Such contradictions insufficient to discard claim [Para 9].

Compensation Quantum – Tribunal’s Award Upheld Without Enhancement – Supreme Court declined to enhance compensation from ₹12,43,324/- awarded by Tribunal – Held: Claimants failed to prove higher income of deceased from agricultural activities – Loss of agricultural income offset by pension benefits – Tribunal’s computation just and reasonable [Para 11].

Apportionment of Compensation – Higher Share to Spouse – Supreme Court modified apportionment of compensation awarding 85% to wife of deceased and 15% equally among three adult children – Held: Apportionment adjusted considering age and dependency factors [Para 12].

Decision of the Judgment – Appeal Allowed in Part – MACT award restored, High Court order set aside, compensation quantum maintained with modified apportionment – Supreme Court upheld insurer’s liability and directed execution accordingly [Paras 11-13].

Criminal Law -  Sections 63 and 65 of the Copyright Act, 1957 - Sections 120B and 420 of the - Appeal by Victim Against Acquittal  – Corporate Entity as Victim – Section 2(wa) CrPC – Right of Appeal Upheld – In a case involving sale of counterfeit products infringing trademarks and copyrights, the Court held that the appellant company Asian Paints Limited qualifies as a ‘victim’ under Section 2(wa) CrPC, having suffered commercial and reputational injury due to the criminal acts – The Court clarified that juristic persons like companies are covered under the definition of ‘victim’ and are entitled to file appeal under Section 372 CrPC – High Court’s dismissal of appeal as non-maintainable was set aside and matter remitted for decision on merits [Paras 36-37, 51-52].

Proviso to Section 372 CrPC – Independent and Standalone Remedy – Not Constrained by Section 378 – The Supreme Court reiterated that the right conferred on a ‘victim’ under the proviso to Section 372 CrPC is a substantive and independent right, not restricted by Section 378 CrPC – Appeal by victim is maintainable against acquittal orders, including those passed by the First Appellate Court – Procedural limitations applicable to State or complainant under Section 378 do not dilute the victim’s substantive right to appeal [Paras 43-44, 47].

Appeal Against First Appellate Court Order – Next Level Appeal Permissible – Victim Can Challenge Acquittal in High Court – The Court clarified that where acquittal occurs at First Appellate Court level, the victim’s appeal lies to the next higher court i.e., the High Court – Proviso to Section 372 CrPC is applicable even in such situations – High Court’s restrictive interpretation rejected [Paras 45-47].

Victim Need Not Be Complainant – Distinction Upheld – Corporate Victim’s Right Recognized – The Court upheld the principle that a victim under Section 2(wa) need not be the original complainant or informant – Despite the FIR being lodged by an investigator, the company suffering direct injury is the victim and entitled to file appeal – Distinction between ‘victim’ and ‘complainant’ reaffirmed [Paras 23, 44].

Purpose of Victim Appeal Right – Expansive Interpretation Favoured – The Court reiterated that the 2009 amendment introducing Section 372 proviso was intended to strengthen victim rights in the justice process, granting a right of participation and remedy to victims against acquittals or inadequate outcomes – Liberal and purposive construction of the victim’s right to appeal was adopted [Paras 49-50].

Decision – Appeal Allowed – High Court Judgment Set Aside – Appeal Restored for Merits Hearing – The Supreme Court allowed the appeal, set aside the High Court’s order rejecting maintainability, restored the appeal before High Court for consideration on merits, and directed expeditious hearing in light of the prolonged pendency since 2016 [Paras 51-52].

Civil Law – Abatement of Appeal – Duty to Inform Death of Party – Order XXII Rule 10A CPC – High Court Order Set Aside - The Supreme Court set aside the High Court judgment which had dismissed the First Appellate Court’s decree on grounds of abatement for non-substitution of deceased respondents’ heirs—Held, defendants were under a legal duty under Order XXII Rule 10A CPC to inform the court and plaintiffs about the deaths during the First Appeal—Failure to disclose the death amounts to abuse of process and parties cannot derive advantage from their own omission—Remand directed for fresh hearing of the Second Appeal [Paras 1-79].

Doctrine of No Advantage from Own Wrong – Nullus Commodum Capere Potest de Injuria Sua Propria – Applicability to Civil Litigation – The Court distinguished between the legal maxims ‘ex injuria jus non oritur’ and ‘nullus commodum capere potest de injuria sua propria’—Held, Rule 10A CPC is intended to prevent parties from gaining advantage through suppression of death of a party—Observations made on ethical obligations of pleaders and equitable principles requiring courts to avoid legal technicalities defeating substantive justice—High Court failed to appreciate these principles [Paras 45-56].

Equitable Considerations – Remand for Fresh Adjudication – Importance of Rule 10A CPC – The Court observed that Rule 10A CPC, though procedural and lacking penal consequences, has substantial equitable impact—Failure to comply requires courts to assess abatement claims carefully, balancing justice over procedural lapse—Second Appeal restored to High Court for fresh adjudication—Directions issued to decide the matter on merits, considering decree’s nature (joint or divisible) and allowing opportunity to cure abatement if necessary [Paras 70-79].

Decision – Appeal Partly Allowed – Second Appeal Restored – The Supreme Court partly allowed the appeal, set aside the High Court judgment, restored Second Appeal No. 190 of 2008 to the High Court's file, and directed expeditious disposal within three months, emphasizing that courts must prevent abuse of process through suppression of material facts [Paras 73-79].

Partnership Law - Section 42 of the Indian Partnership Act - Partnership Continuation after Partner’s Death – Clause 18 of Partnership Deed – No Automatic Dissolution – Partnership Firm Continues - Upon the death of one partner in a three-partner firm, the Court held that the business did not automatically dissolve as the partnership deed specifically permitted continuation by surviving partners and induction of any competent heir – Section 42 of the Partnership Act applies only where not otherwise provided – IOCL could not treat the dealership as lapsed without formally terminating it [Paras 17-22].

Guideline Interpretation – Clause 1.5 of IOCL Guidelines – Reconstitution of Firm – Non-Mandatory Inclusion of All Heirs – Clause 1.5 does not mandate inclusion of all legal heirs after a partner’s death, it allows for reconstitution with willing heirs and surviving partners – Court held IOCL’s insistence on inclusion of all heirs or their 'No Objection Certificates' is contrary to its own guidelines and the partnership deed – IOCL misapplied its guidelines [Paras 25-26].

Statutory Corporation Conduct – Arbitrary Actions – Public Interest – Corporation Directed to Act Fairly – The Court emphasized IOCL, being a state instrumentality, must act justly and not create obstacles in legitimate business continuance – High-handed refusal to renew supply tokens without terminating dealership agreement was condemned as arbitrary [Paras 2, 27, 29].

Decision – Dismissal of SLP – High Court Judgment Upheld – The Supreme Court dismissed the Special Leave Petition, upheld High Court directions for continuance of supply to the existing firm, recognized rights under partnership deed and dealership agreement, and criticized IOCL for adopting a narrow technical approach [Paras 28-31].

Senior Advocate Designation – Suo Motu Power of High Courts – Section 16(2) of the Advocates Act – Validity of Suo Motu Designation Affirmed – Supreme Court upheld the power of the High Court to designate advocates suo motu as Senior Advocates under Section 16(2), observing that such designations were permissible under law and the Rules, 2019, as clarified in Indira Jaising (2017) 9 SCC 766 and Indira Jaising (2023) 8 SCC 1 – Held: High Court wrongly struck down Rule 6(9), which validly enables suo motu designation [Paras 2-10].

Indira Jaising Guidelines – Reconsideration and Clarification – Supreme Court noted that Indira Jaising-I guidelines are subject to periodic reconsideration and clarified in Indira Jaising-II that suo motu power remains intact for exceptional cases – Held: Guidelines for transparency apply primarily to application-based designations; suo motu designations by Full Court are preserved under constitutional scheme [Paras 10, 15-18].

Reaffirmation of Suo Motu Power – Recent Judicial Clarifications – Following Jitender @ Kalla v. State of NCT of Delhi, 2025 INSC 667, Supreme Court reiterated that suo motu designations remain valid, subject to fairness, transparency, and adherence to constitutional principles – Held: Rule 6(9) as amended aligns with these principles and requires no further interference [Paras 17-18].

Recognition of Designation as Privilege – Not a Right – Supreme Court reaffirmed that Senior Advocate designation is a discretionary privilege conferred based on merit, not seniority or popularity – Held: Courts must exercise this power fairly without arbitrariness or undue preference, with suo motu designations recognized as part of judicial discretion [Para 19].

Decision of the Judgment – High Court Order Set Aside – Designations of Respondent Nos.5 to 9 affirmed – Amended Rule 6(9) upheld to remain in force until fresh rules are framed – Special Leave Petitions allowed with no costs [Paras 20-21].

Civil Law - Order VII Rule 11 CPC – Scope of Rejection of Plaint – Rejection of Plaint on Ground of Res Judicata Set Aside – The appellant challenged the orders of the Trial Court and High Court which allowed rejection of plaint under Order VII Rule 11 CPC on the ground of res judicata due to an earlier ex parte decree – Supreme Court held that adjudication on res judicata involves an analysis of previous pleadings, judgments, and facts which cannot be undertaken merely on averments in an Order VII Rule 11 application – Held: Res judicata must be decided at trial, particularly when fraud and collusion are alleged, and plaint contains specific pleadings regarding invalidity of earlier decree – Appeal allowed, suit restored [Paras 3-12].

Fraud Allegations – Collusive Ex Parte Decree – Prima Facie Bar of Res Judicata Inapplicable – Appellant pleaded fraud and collusion in obtaining ex parte decree in prior partition suit, alleged suppression of material facts during purchase of property – Supreme Court held that whether prior decree binds appellant requires detailed inquiry into facts and circumstances, and such issues cannot be summarily decided at preliminary stage – Held: Fraud allegations require trial stage determination, not rejection under Order VII Rule 11 CPC [Paras 4-10].

Res Judicata – Principles Clarified – Examination at Trial Stage Required – Referring to Srihari Hanumandas Totala v. Hemant Vithal Kamat & Ors. and Keshav Sood v. Kirti Pradeep Sood, Supreme Court reiterated that res judicata can only be decided upon full appreciation of prior proceedings, pleadings, and judgments, not solely on plaint averments – Held: Courts below erred in rejecting plaint without trial; appeal allowed and suit restored [Paras 8-9].

Decision – Rejection of Plaint Set Aside – Suit Restored – Supreme Court set aside the orders of the Trial Court and High Court, restored the suit to original number and directed expeditious disposal considering pendency since 2009 – Clarified no opinion on merits; all defences including res judicata to remain open for trial determination [Paras 13-15].

Civil Law – Fresh Suit  – Res Judicata – Section 11 CPC – Relief Barred – Earlier findings upheld - The plaintiff’s challenge based on coercion and misrepresentation regarding the execution of Power of Attorney and subsequent sale deeds was earlier rejected by three courts – The issue now raised was identical and held barred by res judicata under Section 11 CPC – Held: Liberty granted by High Court in second appeal did not revive adjudicated claims or create new cause of action [Paras 5-6, 9-10].

Limitation – Fresh Suit Filed Based on Liberty Reserved – Claim Time-Barred – Agreements Executed in 1998 - The second suit filed by plaintiff for declaration and possession was barred by limitation, as the cause of action dated back to the execution of agreements in 1998 – The liberty granted in second appeal cannot override statutory limitation periods – Held: No application of Section 14 of Limitation Act; suit not before wrong forum but improperly framed [Paras 7, 10].

Civil Procedure – Order 23 CPC – Leave to File Fresh Suit – No Immunity from Limitation – Order 23 Rule 1 and Rule 2 CPC Considered - Though liberty to file a comprehensive suit was granted, it does not extend to revive barred or decided claims – The High Court rightly observed that Order 23 CPC does not exempt parties from adhering to limitation laws [Para 7].

Non-Joinder of Necessary Parties – Suit Deficient – Important Stakeholders Not Impleaded – Belgaum Urban Development Authority and Badminton Association were necessary parties to the dispute concerning civic amenities and property layout – Held: Suit rightly found defective for non-joinder [Para 11].

Final Decision – Special Leave Petition Dismissed – Findings of High Court Affirmed – Supreme Court upheld the High Court’s view that the second suit was barred by limitation and res judicata and that liberty granted earlier did not override legal bars – Held: No interference warranted – SLP dismissed [Paras 10, 12].

Cheque Dishonour – Liability under Section 138 of Negotiable Instruments Act – Quashing of Complaint Set Aside – The High Court had quashed the complaint filed by the appellant on grounds of non-issuance of statutory notice to the partnership firm and failure to arraign the firm as an accused – Supreme Court held that under Section 141 of the Act, a firm is merely a compendious expression for its partners, who are personally, jointly, and severally liable for its acts – Held: Complaint maintainable even without arraigning the firm as accused or serving statutory notice to the firm, provided partners are issued notice and made parties – Permission granted to implead partnership firm as an accused – Impugned order quashing complaint set aside and matter restored to trial court for disposal on merits [Paras 2-12].

Company vs. Partnership Firm – Distinction in Liability – Partnership Firm Not a Separate Juristic Entity – Unlike a company which enjoys distinct legal personality and creates vicarious liability for directors, a partnership firm lacks separate legal existence from its partners – Held: Partners of a firm are personally liable and bound by joint and several liability for actions done in the firm’s name – Notice to partners equals notice to firm – Omission to implead firm is curable and does not invalidate proceedings under Section 138 of the Act [Paras 6.1-7.24].

Interpretation of Section 141 – Legal Fiction of ‘Company’ includes Firm – The term ‘company’ under Section 141 includes a partnership firm by legal fiction – Held: While in company matters directors can be liable vicariously, in partnership the partners are directly, jointly, and severally liable along with the firm – Even absent arraignment of firm as accused, complaint can proceed against partners under joint liability principle – Distinction in treatment of firms and companies upheld to prevent misuse of Section 141 by rigid procedural technicalities [Paras 9.1-9.11].

Decision – Complaint Restored – High Court Judgment Reversed – Supreme Court allowed the appeal, set aside the order of the Madras High Court which had quashed the complaint under Section 138 of the Act, permitted the appellant to implead the partnership firm as an accused, restored the complaint before the Judicial Magistrate and directed disposal in accordance with law [Paras 10-12].

Criminal Law – Appeal Against Quashing - Criminal Conspiracy and Cheating – Prima Facie Offence Established – Quashing of Criminal Proceedings Set Aside – Appellant, a daughter deprived of share in ancestral property, alleged fraudulent exclusion from compensation awarded on land acquisition – High Court quashed criminal proceedings based on Sub-Registrar’s statement and pending civil suit – Supreme Court held prima facie case exists under Sections 120B, 415, 420 IPC – Held: Quashing unjustified; fraudulent family tree and partition deed used to siphon public compensation warrants criminal trial [Paras 2-18].

Bar of Civil Suit – No Bar on Criminal Prosecution – Distinct Remedies – Supreme Court reiterated that pendency of civil suits for partition and declaration does not preclude criminal proceedings – Referring to K. Jagadish v. Udaya Kumar G.S. and Pratibha Rani v. Suraj Kumar, Court clarified that civil and criminal remedies are coextensive and prosecution is maintainable where criminal intent is alleged – Held: Coexistence of civil proceedings does not shield accused from criminal liability when ingredients of cheating and criminal conspiracy are satisfied [Paras 19-23].

Fraudulent Family Tree and Partition Deed – Material Disputes Require Trial – High Court erred in relying solely on Sub-Registrar’s untested statements – Supreme Court observed that fabrication of family tree excluding daughters and forged partition deed involving huge compensation amount are serious allegations needing thorough trial – Held: Genuineness of documents cannot be concluded in writ jurisdiction; criminal prosecution to proceed [Paras 17-18].

Decision – Criminal Proceedings Restored – Appeal Allowed – Supreme Court allowed the appeal, set aside High Court order quashing proceedings, and directed continuation of criminal trial against respondent Nos. 1 and 2 as per law – Emphasized necessity of trial for adjudication of serious allegations involving property rights and criminal misconduct [Paras 24-25].