Motor Accident Claim – Enhancement of Compensation – Delay in Filing Appeal – Appeal Allowed - The Supreme Court set aside the High Court’s judgment which had enhanced the compensation awarded by the Tribunal – Held: The MAC appeal filed by the minors (after attaining majority) was grossly delayed by nearly 8 years and not maintainable under law – Exemption under Section 6 of the Limitation Act applies only to suits and applications for execution of decrees, not appeals [Paras 4, 8-9, 13-14].

Limitation Act – Section 6 – Legal Disability and Appeals – No Relief for Minors Filing Late Appeal - The Court clarified that provisions granting extension of limitation on account of minority (Section 6) do not apply to appeals – Held: There can be no inferred or extended disability when the guardian actively chose not to appeal; delay not condonable under Section 5 either [Paras 9-12].

Doctrine of Procedural Autonomy – Guardian’s Strategic Decision Binding – Finality of Award Upheld - The father, who was natural guardian and party in earlier proceedings, chose not to appeal against the Tribunal’s award – The Supreme Court held that this conscious decision bound the minors – No ground to reopen the case after years of delay [Paras 13-14].

Decision – High Court Judgment Set Aside – Appeal by Insurance Company Allowed - The Supreme Court allowed the insurer’s appeal and held the MAC appeal filed by the children was not maintainable – High Court’s enhanced compensation award was set aside [Paras 13-14].

Motor Accident Compensation – Insurer’s Liability – Vehicle Identification Disputed – MACT Award Restored - Deceased died in accident involving a speeding Verna car – MACT awarded ₹33.63 lakhs against owner and insurer jointly – High Court exonerated insurer based on delayed witness statement and alleged unreliability – Supreme Court held that evidence including police investigation, charge sheet, and owner’s admission supported finding of insurer liability – MACT order restored [Paras 3–6, 16–24].

Witness Credibility – Delay in Disclosure – Not Fatal per se – PW2 disclosed vehicle registration after two and a half months, but was corroborated by police investigation – Supreme Court held delay not fatal if otherwise supported by evidence – Testimony not discredited merely due to late disclosure [Paras 7, 17–18].

Negligence in Civil Proceedings – Standard of Proof – Based on Preponderance – Reliance placed on Mangla Ram v. Oriental Insurance Co., (2018) 5 SCC 656 – Held: Civil liability in motor claims is determined by preponderance of probabilities, not criminal standard of proof – Acquittal or delay in criminal trial not decisive [Paras 9, 19].

Owner’s Non-Appearance – Presumption Against – Respondent No.2 failed to appear in MACT, High Court, and Supreme Court despite service – Supreme Court held that owner’s silence and absence signified no viable defence – Presumption of liability valid [Paras 20–22].

Decision – Appeal Allowed – High Court Judgment Set Aside – MACT Award Restored – Insurer held jointly liable along with vehicle owner – Directions passed based on peculiar facts; no bearing on pending criminal proceedings [Paras 24–25].

Civil Law - SEBI Disgorgement Powers – Fraudulent Advertisement - Principle of Res Judicata – Later Order Invalid - SEBI issued a second order in 2018 imposing disgorgement and restraints on VCL and others based on same facts and notices addressed in final 2014 order – Held: Subsequent exercise was barred by res judicata, being on the same cause and parties – Fresh directions unsustainable after first order attained finality [Paras 19–27, 31].

Investor Compensation – SEBI Not Liable for Damages – Appeal Allowed - SEBI was wrongly directed by SAT to compensate investors who suffered losses from fraudulent ads – Tribunal’s 2013 order had already rejected SEBI's liability – Held: Re-litigation by complainants barred; SEBI not liable to compensate for investment loss absent statutory mandate [Paras 7, 12, 25, 31–33].

Tribunal’s Discretion – Costs Imposed on SEBI Set Aside – Excessive - Tribunal erred in awarding ₹2 lakhs costs per appellant despite their involvement in fraudulent schemes – Held: Costs award against SEBI was unjustified in the circumstances and stood quashed [Paras 32–33].

Constructive Res Judicata – Successive Proceedings Not Permissible – SEBI’s Powers Not Exempt - SEBI argued Section 15U(1) insulated it from CPC rules – Held: Even quasi-judicial authorities like SEBI are bound by public policy and res judicata – Doctrine applies despite nature of regulatory proceedings [Paras 27–28].

Decision – Civil Appeal by SEBI Allowed – SAT’s 2019 judgment directing SEBI to compensate investor set aside – Respondents' appeal seeking additional interest dismissed – SEBI's challenge to 2021 disgorgement quash order dismissed, but costs order reversed – All parties to bear own costs [Paras 31–33].

Civil Law – Refusal of Registration of Documents – Power to Refuse on Title Grounds – Rule 55A(i) Declared Ultra Vires – Sub-Registrar refused to register sale deed under Rule 55A(i) for want of vendor’s title proof – Supreme Court held that under the Registration Act, 1908, Sub-Registrar has no authority to verify title – Rule 55A(i) inconsistent with the parent Act – Held: Rule 55A(i) is ultra vires and invalid [Paras 1–2, 14–16].

Registration Act – Role of Sub-Registrar – Title Verification Not Required – Registrar’s role is administrative, not adjudicatory – Registration cannot be refused solely for lack of vendor’s title proof if procedural compliance is satisfied – Executant’s title is not relevant to registration under the Act [Paras 15–16].

Rule-Making Power – Section 69 of the Registration Act – Scope and Limits – Section 69 does not empower rule-making authority to introduce title-verification requirements – Held: Rule 55A(i) exceeds the statutory scope and conflicts with scheme of the Act – Hence struck down [Paras 10–13, 16].

State Amendment – Sections 22-A and 22-B – Limited Grounds for Refusal – These sections cover specific categories like government lands, encroached properties, and forgery – Held: These do not extend to requiring production of title deeds by vendors in all cases [Paras 8–9].

Decision – Appeal Allowed – Rule 55A(i) declared ultra vires – High Court orders relying on the Rule set aside – Appellant allowed to resubmit sale deed for registration within one month, subject to procedural compliance [Paras 17–19].

Consumer Law - Insurance Claim – Fire and Special Perils Policy – Liability Not Disputed – Appellant acknowledged liability for damage caused to respondent’s premises under insurance policy due to collapse following heavy rainfall – However, dispute arose regarding quantum of compensation awarded by the NCDRC – Held: Appeal limited to reconsideration of compensation amount [Paras 1, 7].

Quantum of Compensation – Improper Evaluation by NCDRC – NCDRC relied solely on assessment of respondent's surveyor introduced for the first time in rejoinder – Appellant had no opportunity to contest or respond to such assessment – Held: NCDRC erred in accepting such assessment without independent evaluation or giving appellant opportunity to lead evidence [Paras 5, 8-10].

Remand for Reassessment – Fresh Consideration Directed – Supreme Court held that compensation must be determined afresh after allowing both parties to adduce evidence – Matter remanded to NCDRC for reevaluation – Ordered that deposited amount remain in fixed deposit until final adjudication [Paras 10-12].

Decision – Appeal Partially Allowed – Quantum of compensation set aside – Matter remanded to NCDRC for fresh determination of payable compensation under insurance policy – Parties to bear their own costs [Para 11-12].

Consumer Law  - Marine Insurance – Repudiation Of Insurance Claim - Interpretation of “Voyage to Commence and Complete Before Monsoon Sets In” – No Breach Found – Insurance policy required voyage to start and complete before onset of monsoon – Appellant commenced voyage on 06.06.2013, vessel was damaged due to bad weather – Held: Clause was not a material condition precedent, was vague and incapable of strict compliance for voyage from west to east coast – Repudiation not justified [Paras 1–3, 12–15, 18].

Contra Proferentem – Applicability Rejected – Phrase “before monsoon sets in” interpreted literally – Supreme Court held clause was clear and not ambiguous on its own terms – Hence, principle of contra proferentem (against insurer) not applicable – However, clause was found to be waived or immaterial in context [Paras 13–15].

Implied Waiver – Awareness of Monsoon Timing – Policy Covered Foul Weather Period – Court held insurer was aware the voyage would run into monsoon window – Condition could not be enforced in a manner that nullified the policy’s core purpose – Term likely a boilerplate clause – Deemed waived by conduct [Paras 17–18].

Absurdity in Enforcement – Clause Rendered Policy Illusory – Treating condition as mandatory would leave assured without remedy if voyage interrupted by insured peril – Held: Clause could not be treated as a condition precedent – Would result in defeating intent of insurance itself [Paras 18–19].

Decision – Appeal Allowed – NCDRC order set aside – Matter remanded to NCDRC to determine quantum payable to appellant under policy – Parties to appear on 29.04.2025 – Expeditious disposal directed [Paras 20–21].

Criminal Law - Murder  – Appeal Against Reversal of Acquittal – Section 302 IPC – Conviction Set Aside - Trial Court acquitted accused husband citing insufficient evidence of homicide – High Court reversed based only on failure to prove alibi and presumption under Section 106 – Held: Presumption under Section 106 cannot solely justify reversal where prosecution failed to prove death as homicide – Acquittal restored [Paras 1–6, 9–10, 14].

Presumption under Evidence Act – Section 106 – Not Sufficient Alone – Husband’s Duty to Explain Death – Held: Section 106 cannot be the sole basis for conviction without evidence of homicidal death – Husband's explanation was plausible, noted in initial police intimation, not disproved by investigation [Paras 5, 9–10].

Medical Evidence – Cause of Death Unclear – No Evidence of Strangulation or Homicide - Postmortem showed ligature mark only on front of neck, no signs of throttling or ante mortem injuries – Expert did not clarify whether death was homicidal or suicidal – Held: Cause of death remains indeterminate, suspicion alone insufficient [Paras 4, 11].

Alibi – Failure to Prove Not Enough – No Burden to Establish Innocence – Accused’s claim of being on duty was not proven false by police – Initial report supported his version – Held: Failure to establish alibi does not amount to proof of guilt where prosecution evidence is lacking [Paras 7–8].

Dowry Cruelty and Suicide – Section 498A & 306 IPC – No Evidence of Harassment – Relatives’ Testimony Insufficient - No history of physical violence or cruelty found, no injuries on body – Mere complaints of laziness not enough to sustain charges – Held: No evidence to sustain conviction under 498A or 306 IPC [Paras 12–13].

Decision – Appeal Allowed – High Court Conviction Set Aside – Acquittal by Trial Court Restored – Accused to be released forthwith if not required in other cases – Bail bonds cancelled [Paras 14–15].

Criminal Law – Appeal Against Conviction - Sections 3(1)(r), 3(1)(s) of the SC/ST Act – Abuse Not in Public View –Acquittal Granted - Accused allegedly abused complainants using caste slurs during land dispute – Witnesses all related, and evidence showed no member of public was present at time of alleged incident – Held: Requirement of “public view” under clauses (r) and (s) not satisfied, thus no offence under SC/ST Act made out [Paras 7–9, 11].

House Trespass – Contradiction Between Complaint and Oral Evidence – Section 447 IPC – Charge Fails - Original complaint alleged house trespass, but all prosecution witnesses spoke of incident occurring in a field – Held: Contradiction fatal to prosecution case; no evidence of house breaking or unlawful entry into residence [Paras 8–11].

Land Dispute – No Evidence of Illegal Occupation or Forceful Eviction – Section 3(1)(f) SC/ST Act – Not Attracted - Accused allegedly entered disputed land but no proof they forcibly evicted complainants or retained unlawful possession – Held: Clause (f) not applicable, conviction unsustainable [Paras 7, 11].

Witness Credibility – All Prosecution Witnesses Related – No Independent Corroboration - Testimonies inconsistent regarding location, language used, and events – Held: Evidence unreliable and insufficient for conviction [Paras 6–9].

Decision – Conviction Set Aside – Accused Acquitted – High Court and Trial Court orders set aside – Bail bonds cancelled – Appeal allowed [Para 11–13].

Criminal Law - Discharge in Rape Case – Consent Given in Relationship – Section 376 IPC – Discharge Restored - FIR was filed after the appellant allegedly refused to marry the complainant following years of consensual relationship – Sessions Court discharged the accused on the ground that consent was not vitiated by deception – Held: FIR and charge-sheet show relationship was consensual and not induced by false promise [Paras 6–10, 15].

False Promise to Marry – Distinction Between Breach and False Promise – No Offence Made Out – Supreme Court reiterated distinction between breach of promise and false promise – Held: There is no material to suggest that the appellant never intended to marry from the outset – Relationship sustained for years and included shared domestic moments, thus excluding deceit [Paras 13–14].

Criminal Intimidation – Section 506 IPC – Lack of Prima Facie Evidence – The complaint about threats lacked supporting material – Held: No case of criminal intimidation made out on facts presented in FIR or charge-sheet [Para 15(ii)].

Scope of Revisional Jurisdiction – Improper Interference by High Court – Section 397 CrPC – High Court reversed well-reasoned discharge order despite lack of error or perversity – Held: Revisional jurisdiction must be exercised sparingly and not for re-evaluation of evidence at charging stage [Paras 16–17].

Decision – Appeal Allowed – High Court's reversal of discharge set aside – Sessions Court's order discharging the appellant from offences under Sections 376 and 506 IPC restored – FIR and all criminal proceedings quashed [Para 18].