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 Claim – Assessment of Income for Minor Victim – High Court and Tribunal Orders Modified – The appellant, an 8-year-old child, suffered 90% permanent disability due to a motor accident – Tribunal awarded Rs.3.9 lakhs, High Court enhanced to Rs.8.65 lakhs – Supreme Court held that minor victims cannot be treated as non-earning individuals – Income must be assessed at least on the basis of prevailing minimum wages for skilled workers – Compensation enhanced to Rs.35,90,489 with 9% interest – Appeal allowed [Paras 9-13, 17].

Disability Assessment – Functional Disability at 90% – Loss of Earning Capacity – Held: High Court correctly fixed permanent functional disability at 90% – Supreme Court affirmed this finding based on medical evidence and impact on future prospects [Para 11].

Compensation Principles – Pecuniary and Non-Pecuniary Damages – Enhanced Compensation – Held: Courts failed to apply principles laid down in Kajal v. Jagdish Chand and Pranay Sethi – Supreme Court recalculated under heads including loss of income, medical expenses, future treatment, pain and suffering, amenities, loss of marriage prospects, and artificial limb cost – Total compensation fixed at Rs.35,90,489 [Paras 12-13].

Judicial Responsibility – Error by Tribunal and High Court – Need to Apply Settled Law – Held: Tribunal and High Court erred in ignoring binding precedents, forcing avoidable appeals – Directions issued that insurance companies must furnish prevailing minimum wage data in absence of proof of income – Order to be circulated to all Motor Accident Claims Tribunals by High Courts [Paras 14-16, 18].

Final Decision – Appeal Allowed – Supreme Court modified award, enhancing compensation from Rs.8.65 lakhs to Rs.35.90 lakhs with 9% interest from date of claim petition – Amount to be remitted directly to claimant’s bank account by 30th September 2025 [Paras 17, 19].

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].

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].

Civil Suit – Adverse Possession – Necessity of Pleadings – First Appellate Court’s Finding Set Aside – Plaintiffs sought declaration that sale deed was bogus and for injunction—Trial court dismissed suit; first appellate court decreed suit partly by accepting plea of adverse possession, holding title matured during pendency of suit—High Court found no such plea in plaint or written statement; held appellate court erred in framing additional issue absent foundational pleading—Supreme Court reaffirmed that adverse possession must be specifically pleaded, put in issue, and proved; cannot be raised for first time in appeal as a surprise to defendant—Petition dismissed; trial court’s dismissal of suit restored [Paras 19-31].

Criminal Law - Dowry Demand – Quashing of FIR – Sections 3 & 4 Dowry Prohibition Act – High Court’s Finding of “Vague and Omnibus” Allegations Set Aside – The appellants lodged FIR alleging specific dowry demands by the in-laws of the prospective bridegroom, including Rs. 10 lakh, a vehicle, and cash with articles on tilak ceremony—Marriage negotiations were later called off after refusal to meet further demands—High Court quashed FIR against the father, mother, and brother of the bridegroom holding allegations vague—Held: FIR contained specific details with dates and amounts; prima facie ingredients of offences made out—High Court erred in exercising Section 482 powers to quash—Whether allegations are true is matter for trial—Order quashing proceedings set aside; trial to proceed against all accused [Paras 8-14].

Motor Accident Compensation – Cancelled Insurance Policy – Pay and Recovery – Appeal Disposed – Offending vehicle’s insurance policy cancelled over three months before accident due to dishonoured premium cheque; insurer intimated owner and RTO—Tribunal and High Court still directed insurer to pay claimants and recover from owner—Supreme Court applied Deddappa and United India Insurance principles: insurer absolved in law upon cancellation before accident with intimation, yet, in exercise of Article 142 powers, pay-and-recover direction sustained in part—No recovery from claimants for 50% already paid; insurer may recover that amount from owner—Remaining 50% recoverable by claimants from owner [Paras 3.1-6].

Cancellation of Policy – Effect on Third Party Claims – While cancellation before accident generally negates liability, Court balanced equities by protecting amounts already disbursed to claimants—Avoided reopening settled part-payments to prevent hardship [Paras 5.3-5.7].

Decision – Appeal partly allowed; insurer permitted to recover 50% already paid from vehicle owner; claimants to recover remaining 50% from owner—No recovery from claimants for amounts withdrawn [Para 6].

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].