Supreme Court Weekly Digest March 1 - 13, 2026

Advocates Act, 1961 - The Supreme Court disposed of a plea seeking reservation for advocates belonging to Other Backward Classes in appointments of government pleaders in Madhya Pradesh. While declining to issue binding directions in the absence of a statutory mandate, the Court through its order urged the Advocate General to ensure representation of lawyers from marginalised communities and women. OBC Advocates Welfare Association v. State of M.P., 2026 LiveLaw (SC) 217

Anticipatory Bail — Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 — Section 18 — Cancellation of Anticipatory Bail - The Supreme Court allowed the appeals and cancelled the anticipatory bail granted to the respondents, observing that a prima facie case under the SC/ST Act was established - noted that while the High Court relied on the absence of casteist slurs in the initial FIR (lodged by a police official based on a social media video), it failed to exercise sufficient caution in examining other records - an affidavit filed by the Deputy Superintendent of Police and statements of various persons clearly alleged the use of casteist slurs and violence by the upper-caste respondents against marginalized community members over a drainage dispute – noted that the bar under Section 18 of the SC/ST Act, which precludes the grant of anticipatory bail, is applicable when the ingredients of the offence are prima facie disclosed - In this case, investigation reports indicated offences under the SC/ST Act, the Bharatiya Nyaya Sanhita, 2023, and the Arms Act - noted that mere attempts at reconciliation by the police cannot prevent the taking of cognizance for criminal acts - Supreme Court found that the High Court erred in concluding there was no prima facie culpability, as subsequent investigation reports and affidavits by high-ranking police officials corroborated allegations of caste-based abuse and firearm discharge – Appeals allowed. [Relied on Shajan Skaria v. State of Kerala, 2024 SCC OnLine SC 2249; Paras 8-15] Kuldeep Singh v. State of Punjab, 2026 LiveLaw (SC) 239

Arbitration and Conciliation Act, 1996; Section 31(7)(a) and 31(7)(b) — General Conditions of Contract (GCC); Clause 16(3) and 64(5) — Pre-award/Pendente lite Interest — Post-award Interest — The Arbitral Tribunal cannot award pre-award or pendente lite interest, even in the form of "compensation," if the contract expressly prohibits interest on amounts payable to the contractor - a contractual bar on pre-award interest does not automatically extend to post-award interest - Post-award interest is a statutory mandate under Section 31(7)(b) and is not subject to "contracting out" by parties unless the exclusion is explicit and unambiguous - The Court retains the power to modify the rate of post-award interest if it is deemed excessive or lacks justification - Key Findings and Relied-on Decisions: i. Contractual Supremacy in Pre-award Interest: Under Section 31(7)(a), the arbitrator's power to award pre-award interest is subordinate to the terms of the agreement. If a contract (like Clause 16(3) of the GCC) bars interest on "amounts payable to the contractor," the arbitrator lacks jurisdiction to grant it. Ii. Rejection of Ejusdem Generis: The phrase "amounts payable to the contractor under the contract" in Clause 16(3) is independent and distinct from "earnest money" or "security deposits." It cannot be read down to only include deposits; iii. Statutory Mandate of Post-award Interest: Section 31(7)(b) is not subject to party autonomy. The expression "unless the award otherwise directs" refers to the rate of interest, not the entitlement to it; iv. Power to Modify Interest Rate: Courts can modify post-award interest rates to avoid excessive financial burdens and ensure "just compensation" based on contemporary economic scenarios – Appeal partly allowed. [Relied on Union of India v. Manraj Enterprises (2022) 2 SCC 331; RP Garg v. Chief General Manager, Telecom Department 2024 SCC OnLine SC 2928; Gayatri Balasamy v. M/s ISG Novasoft Technologies Limited (2025) 7 SCC 1; Union of India v. Bright Power Projects (India) (P) Limited (2015) 9 SCC 695; Union of India v. Manraj Enterprises (2022) 2 SCC 331; Paras 30-60] Union of India v. Larsen & Tubro, 2026 LiveLaw (SC) 214 : 2026 INSC 203

Arbitration and Conciliation Act, 1996 – Section 16, Section 4, and Section 34 – Appointment of Presiding Arbitrator – Improper Constitution of Tribunal – Waiver and Conduct – The Appellant challenged the arbitral award on the ground that the Presiding Arbitrator was appointed by the two nominee arbitrators beyond the 30-day period prescribed in Clause 8.3(b) of the Agreement - The Appellant contended that after 30 days, the power of the nominee arbitrators was extinguished, and only the Secretary General of ICSID could make the appointment - Held: Clause 8.3(b) is an enabling provision, not a restrictive one - It provides a "fail-safe" by permitting parties to approach ICSID if the nominee arbitrators reach an impasse, but it does not denude the nominee arbitrators of their power to appoint after the 30-day period unless a request is actually made to ICSID - Since neither party approached ICSID, the appointment by the nominee arbitrators was valid. [Paras 30-34] Municipal Corporation of Greater Mumbai v. R.V. Anderson Associates, 2026 LiveLaw (SC) 235 : 2026 INSC 228

Arbitration and Conciliation Act, 1996 – Section 4 and Section 16(2) – Timelines for Objection vs. Past Conduct – Held that while an objection under Section 16(2) raised before the statement of defence is technically "timely" to prevent statutory waiver under Section 4, the prior conduct and acquiescence of the party remain relevant in adjudicating the merits of the jurisdictional challenge - A party cannot participate in the process, allow multiple appointments of presiding arbitrators without protest, and then "keep a jurisdictional ace up their sleeve" to challenge the final constitution - Supreme Court must respect arbitral autonomy and ensure minimum judicial interference - If the arbitrator's interpretation of a contractual clause is a plausible view, the Court cannot substitute it with another view merely because it is possible – Appeal dismissed. [Relied on Hindustan Construction Co. Ltd. v. Bihar Rajya Pul Nirman Nigam Ltd. (2025 SCC OnLine SC 2578; Consolidated Construction Consortium Limited v. Software Technology Parks of India (2025 INSC 574); Paras 36, 40-45, 51-54, 61, 66, 67] Municipal Corporation of Greater Mumbai v. R.V. Anderson Associates, 2026 LiveLaw (SC) 235 : 2026 INSC 228

Cinema Law - The Supreme Court dismissed a writ petition seeking a stay on release of the film “Yadav Ji ki Love Story”, holding that the title of the movie does not portray the Yadav community in a negative manner. A bench of Justice BV Nagarathna and Justice Ujjal Bhuyan noted that the title did not contain any adjective or word that attached any negative meaning to the community. Awdesh Kumar Yadav v. Union of India, 2026 LiveLaw (SC) 215

Code of Civil Procedure, 1908 — Order XLI Rule 27 — Exercise of Judicial Discretion — Noted that power to allow additional evidence is discretionary and must be used sparingly to remove a lacuna in the evidence, not to allow a party to fill gaps in their case at their "leisure or sweet will." - If the Appellate Court can pronounce a satisfactory and reasoned judgment based on the existing record, the provision has no application. [Para 11] Gobind Singh v. Union of India, 2026 LiveLaw (SC) 221 : 2026 INSC 211

Code of Civil Procedure, 1908 — Order XLI Rule 27 — Production of Additional Evidence in Appellate Court — Scope and Conditions Precedent — The Supreme Court reaffirmed that parties to an appeal are not entitled to produce additional evidence as a matter of right - The provision is couched in negative terms and applies only in three specific contingencies: (a) refusal by the trial court to admit evidence that ought to have been admitted; (aa) the party establishing that despite due diligence, such evidence was not within their knowledge or could not be produced at the trial stage; or (b) the Appellate Court itself requiring the evidence to enable it to pronounce judgment or for any other substantial cause. Gobind Singh v. Union of India, 2026 LiveLaw (SC) 221 : 2026 INSC 211

Code of Civil Procedure, 1908 – Possession of Auction Purchaser – Supreme Court observed that while Order 21 Rule 95 CPC provides a procedure for an auction purchaser to take possession, if the purchaser actually gains possession and maintains it on the date of the suit's institution, they cannot be denied an injunction against a party with no title who seeks to interfere - Even if a specific issue on possession was not formally framed by the Trial Court, since the parties went to trial fully aware that the issue was central and led evidence accordingly, they cannot later claim prejudice - Held – The High Court erred by not considering the extensive documentary evidence (e.g., revenue records, factory registrations, tax payments) relied upon by the First Appellate Court to establish the appellant's possession - The matter was remanded to the High Court for fresh consideration within the scope of Section 100 CPC. [Relied on Nagubai Ammal and Others v. B. Shama Rao & Ors., (1956) 1 SCC 698; B. Arvind Kumar v. Govt. of India & Ors., (2007) 5 SCC 745; Paras 19-25] P. Elaiyappan v. Natarajan, 2026 LiveLaw (SC) 219

Code of Civil Procedure, 1908 – Section 100 – Second Appeal – Scope of Interference with Concurrent Findings of Fact – Possession and Injunction – The Supreme Court set aside a High Court judgment that had dismissed a suit for permanent prohibitory injunction despite concurrent findings of possession in favor of the appellant by the Trial Court and First Appellate Court – Noted that the High Court failed to frame a specific substantial question of law regarding the correctness or validity of the findings on possession returned by the lower courts - The Supreme Court held that interference with concurrent findings of fact under Section 100 CPC is permissible only on limited grounds, such as perversity, misreading of evidence, or consideration of inadmissible evidence. P. Elaiyappan v. Natarajan, 2026 LiveLaw (SC) 219

Code of Criminal Procedure, 1973 – Section 157 – Procedural Lapses – Alleged non-compliance with the requirement of sending the FIR to the Magistrate under Section 157 CrPC is not, by itself, fatal to the prosecution case - Such procedural lapses are insufficient to overturn a conviction when the overall evidence establishes the guilt of the accused - The movement of multiple accused persons, arriving together armed with firearms and chasing the deceased into a private residence to execute the killing, is sufficient to draw an inference of a common object - The recovery of 40 pellets from the body and multiple entry/exit wounds corroborated the involvement of multiple shooters. [Paras 13, 17 - 20] Dablu v. State of Madhya Pradesh, 2026 LiveLaw (SC) 238 : 2026 INSC 224

Code of Criminal Procedure, 1973 – Section 313 - Examination of Accused – Duty of Court and Prosecutor – Impact of Inadequate Questioning - Held: It is the solemn duty of both the Trial Court and the Prosecutor to ensure all incriminating circumstances (motive, dying declarations, medical evidence) are put to the accused during their Section 313 examination - A casual or "scanty" examination that omits material circumstances falls short of the legal standard and can lead to the failure of the entire prosecution. Sanjay Kumar Sharma v. State of Bihar, 2026 LiveLaw (SC) 230 : 2026 INSC 223

Code of Criminal Procedure – Quashing of Proceedings – Section 482 of CrPC / Section 528 of BNSS – Offences under Sections 341, 323, 498A, and 34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act – General and Omnibus Allegations – Parity in Relief – The High Court quashed proceedings against the sister-in-law but refused to extend the same relief to the father-in-law and mother-in-law (appellants) despite identical allegations. Held: The Supreme Court found that the allegations against the appellants were general and omnibus, lacking specific dates, places, or overt acts – Held that Relatives of the husband cannot be prosecuted based on vague and general allegations without any specific overt act attributed to them - Supreme Court observed that since the allegations against the appellants and the sister-in-law were identical in substance, the High Court erred in applying different standards. Quashing the proceedings against the appellants - noted that criminal proceedings should not be used as a tool for harassment through improved and supplemental versions of events – Appeal allowed. [Relied on Preeti Gupta & Anr. v. State of Jharkhand & Anr., (2010) 7 SCC 667; Geeta Mehrotra & Anr. v. State of Uttar Pradesh & Anr., (2012) 10 SCC 741; Kahkashan Kausar @ Sonam & Ors. v. State of Bihar & Ors., (2022) 6 SCC 599; Paras 7 - 11] Dr. Sushil Kumar Purbey v. State of Bihar, 2026 LiveLaw (SC) 220 : 2026 INSC 212

Companies Act, 2013 – Section 418A & 419 – Composition of NCLAT Benches – Validity of Technical Member Majority - Supreme Court rejected the challenge to a three-member NCLAT Bench comprising two Technical Members and one Judicial Member - held that while a Bench must have at least one Judicial Member, the current law does not mandate a majority of Judicial Members in larger Benches - Technical and administrative members are not to be treated with "disdain" or labeled lower in status, as their expertise aids in holistic adjudication - A notice is "tricky" if it is artfully framed to mislead or conceal material facts from shareholders - the disclosure of the exit price and the availability of valuation reports at the registered office satisfied the requirements of Section 102. [Relied on: Kaye v. Croydon Tramways & Co. Ltd.; Baillie v. Oriental Telephone and Electric Co. Ltd.; In Re: Cadbury India Limited; Mihir H. Mafatlal v. Mafatlal Industries Ltd. 2014 SCC Online Bom 4934; Paras 18-22, 23-37, 48, 50] Pannalal Bhansali v. Bharti Telecom, 2026 LiveLaw (SC) 222 : 2026 INSC 213

Companies Act, 2013 – Section 66 – Reduction of Share Capital – Validity of Selective Reduction and Forced Exit of Minority Shareholders - The Supreme Court upheld the reduction of share capital under Section 66, even if selective and resulting in an involuntary exit of minority shareholders – Held that reduction of share capital is a domestic concern of the company decided by the majority - As long as the procedure is followed and the transaction is not unfair, inequitable, or against public interest, the majority has the right to decide how to carry out the reduction, including extinguishing certain shares while retaining others. [Relied on: Re: Reckitt Benckiser (India) Ltd.; British and American Trustee and Finance Corporation v. Couper 2005 SCC Online Del 674; Paras 42-47] Pannalal Bhansali v. Bharti Telecom, 2026 LiveLaw (SC) 222 : 2026 INSC 213

Companies Act, 2013 – Section 66 – Requirement of Valuation Report – Statutory Interpretation – Held that unlike Sections 62, 230, and 232, Section 66 does not statutorily mandate a valuation report from a registered valuer for the reduction of share capital - The primary safeguards are a special resolution and confirmation by the Tribunal - The absence of a valuation report being sent with the notice does not constitute a "tricky notice" if the fair value and methodology are disclosed or made available for inspection. [Paras 24-37] Pannalal Bhansali v. Bharti Telecom, 2026 LiveLaw (SC) 222 : 2026 INSC 213

Companies Act, 2013 – Valuation – Discount for Lack of Marketability (DLOM) – Applicability in Unlisted Companies - held that the application of a Discount for Lack of Marketability (DLOM) is a valid accounting principle for valuing shares of unlisted or delisted companies - While DLOM may be declined in court-ordered buyouts involving "oppression," it is applicable in a standard Section 66 reduction where no oppression is proved and the shares lack liquidity - noted that "Fair Value" under Indian Accounting Standards (Ind AS 113) is a market-based measurement that accounts for restrictions on sale. [Relied on: Liew Kit Fah v. Koh Keng Chew [2020] 1 SLR 275; Paras 39-45] Pannalal Bhansali v. Bharti Telecom, 2026 LiveLaw (SC) 222 : 2026 INSC 213

Constitution of India – Article 139A(1) – Withdrawal of cases from High Court – Substantial questions of general importance – Stagnation of Trial – Failure to pronounce judgment after reserving it – The Supreme Court exercised its extraordinary power under Article 139A(1) to withdraw three criminal revision petitions pending before the Allahabad High Court to itself – Noted that the revisions had been heard and judgment reserved on 05.02.2020, but no judgment had been pronounced for several years - The continuing stay on trial proceedings arising from a 1994 incident resulted in a "standstill" of the criminal process for decades, infringing upon the right to speedy justice. Jaideep Kumar Srivastava v. State of U.P., 2026 LiveLaw (SC) 211

Constitution of India – Article 14 – Manifest Arbitrariness – Srimati Radhika Sinha Institute and Sachchidanand Sinha Library (Requisition & Management) Act, 2015 – Unconstitutionality – Held: The impugned Act, which provides for the complete takeover of the management and assets of a private trust-run institution (Sinha Library) without a principled framework for compensation or a demonstration of mismanagement, is "manifestly arbitrary" - The State cannot use its legislative power to single out a specific institution for takeover without an intelligible basis or fair process - The Act fails the test of reasonableness and non-confiscatory nature required under Article 300A. Anurag Krishna Sinha v. State of Bihar, 2026 LiveLaw (SC) 226 : 2026 INSC 219

Constitution of India – Article 21 – Right to Die with Dignity – Passive Euthanasia – Withdrawal of Life-Sustaining Treatment – Clinically Assisted Nutrition and Hydration (CANH) – Supreme Court allowed the withdrawal of life-sustaining treatment, specifically CANH administered through a PEG tube, for a patient in an irreversible Permanent Vegetative State (PVS) for over 12 years - Held: The right to live with dignity under Article 21 includes the right to die with dignity - In cases where medical treatment is futile and serves no therapeutic purpose other than artificially prolonging a mindless biological existence, its withdrawal is constitutionally permissible. [Paras 29, 52, 72, 91] Harish Rana v Union of India, 2026 LiveLaw (SC) 229 : 2026 INSC 222

Constitution of India – Article 21 – Right to Life and Health – COVID-19 Vaccination – Adverse Events Following Immunization (AEFI) – Compensation Policy – The Supreme Court directed the Union of India to formulate a "no-fault" compensation framework for serious adverse events or deaths resulting from COVID-19 vaccinations - held that while the state-led vaccination program was a vital public health intervention, the State bears a positive obligation under Article 21 to ensure that families suffering grave harm are not left without an accessible mechanism for redress. Rachana Gangu v. Union of India, 2026 LiveLaw (SC) 225 : 2026 INSC 218

Constitution of India – Article 311(2)(b) – Dismissal from service without departmental inquiry – Scope of "Reasonably Practicable" – Requirement of Objective Satisfaction – The Supreme Court set aside the dismissal of a Delhi Police Constable, holding that the power to dispense with a regular departmental inquiry under Article 311(2)(b) cannot be exercised based on mere "assumptions and conjectures" - Supreme Court noted that the disciplinary authority must record satisfaction based on independent material showing that holding an inquiry is not "reasonably practicable" - Key Observations held – i. Judicial Review and Satisfaction - The finality given to the disciplinary authority's decision under Article 311(3) is not binding on the Courts - The scope of judicial review is open to strike down orders dispensing with an inquiry if the reasons are irrelevant, arbitrary, or lack a factual basis – Held that court must consider whether a "reasonable man acting in a reasonable way" would have reached the same conclusion in the prevailing situation; ii. Absence of Material Evidence: In the present case, the Preliminary Inquiry (PE) report failed to record any specific instances of the appellant who was in custody at the time—threatening or intimidating witnesses - The Deputy Commissioner of Police (DCP) relied on the ACP's "presumption" of potential witness tampering without any supporting material, which the Court deemed a failure of application of mind; iii. Custody as a Factor: It was incumbent upon the authority to demonstrate how the appellant, while in jail, posed a threat that made an inquiry "not reasonably practicable"; iv. Adherence to Circulars: noted that the Delhi Police's own circulars (dated 31.12.1998 and 11.09.2007) mandate that Article 311(2)(b) should not be used as a "short cut" and requires "cogent and legally tenable reasons". [Relied on Union of India v. Tulsiram Patel (1985) 3 SCC 398; Jaswant Singh v. State of Punjab (1991) 1 SCC 36; Paras 23-40] Manohar Lal v. Commissioner of Police, 2026 LiveLaw (SC) 236 : 2026 INSC 234

Constitution of India – Article 32 – Writ Jurisdiction vs. High Court Administration – While the Supreme Court does not ordinarily function as a supervisory forum over the day-to-day administration or rosters of High Courts, it may intervene in "rare and exceptional situations" where continuing inaction results in a demonstrable infringement of fundamental rights under Articles 14 and 21 – Supreme Court noted that pending revisions must be decided by giving full effect to the legal and constitutional observations of the Supreme Court - The failure to implement specific directions regarding the re-evaluation of withdrawal of prosecution (Section 321 CrPC) implicated the credibility of the criminal process. [Paras 3-9] Jaideep Kumar Srivastava v. State of U.P., 2026 LiveLaw (SC) 211

Constitution of India – Articles 14 and 21 – Judicial Review of Executive Policy – Separation of Powers – While acknowledging the executive's competence in drafting health policies, Supreme Court maintained that the separation of powers cannot prevent judicial intervention when fundamental rights are violated due to the absence of a structured relief framework in exceptional circumstances. Rachana Gangu v. Union of India, 2026 LiveLaw (SC) 225 : 2026 INSC 218

Constitution of India – Doctrine of Manifest Arbitrariness – Evolution and Application – Held: Manifest arbitrariness is a well-settled ground for striking down plenary legislation under Article 14. A law is manifestly arbitrary when it is "capricious, irrational, or not guided by any principle" or is "excessive and disproportionate" - A legislative enactment that targets a specific entity for total deprivation of management and property rights without following due process, providing adequate compensation, or establishing a clear public necessity (beyond mere "better management") is hit by Article 14 of the Constitution – Appeal allowed. [Relied on Shayara Bano v. Union of India (2017) 9 SCC 1; E.P. Royappa v. State of Tamil Nadu (1974) 4 SCC 3; Maneka Gandhi v. Union of India (1978) 1 SCC 248; Paras 35-50] Anurag Krishna Sinha v. State of Bihar, 2026 LiveLaw (SC) 226 : 2026 INSC 219

Constitution of India – No-Fault Liability – Principle and International Precedent – Supreme Court emphasized that requiring proof of negligence through civil courts or consumer fora imposes an "onerous burden" on families in complex scientific matters - Relying on the principle of no-fault liability (similar to Section 164 of the Motor Vehicles Act, 1988), Supreme Court noted that global jurisdictions, including Australia, the UK, and Japan, have implemented dedicated COVID-19 vaccine injury compensation schemes - Supreme Court declined to appoint an independent medical board, finding the existing National and State AEFI Committees adequate for scientific assessment - it reaffirmed the state's duty to maintain transparent surveillance and ensure AEFI data is accessible in the public domain. [Relied on Jacob Puliyel v. Union of India (2022 SCC OnLine SC 533); In re: Distribution of Essential Supplies and Services During Pandemic (2021 SCC OnLine SC 372); Gaurav Kumar Bansal v. Union of India (W.P.(C) No. 539/2021); Paras 27-37] Rachana Gangu v. Union of India, 2026 LiveLaw (SC) 225 : 2026 INSC 218

Contempt of Courts Act, 1971 – Civil Contempt – Intentional Delays and Administrative Hurdles – The Supreme Court deprecated the practice of government departments seeking "guidance" or citing "administrative hurdles" and "internal correspondence" as excuses for the non-compliance of clear court orders - Supreme Court noted that such actions are often a "calculated strategy" to delay or defeat the implementation of judicial directions. Israr Ahmed Khan v. Amarnath Prasad, 2026 LiveLaw (SC) 209 : 2026 INSC 209

Contempt of Courts Act, 1971 – Liability of Non-Parties – Reiterated that even a third party or an officer not originally impleaded in the main proceedings can be held liable for contempt if they have knowledge of the court's order and act in a manner that willfully prevents its compliance or aids and abets its violation - Supreme Court emphasized that in contempt proceedings, the court cannot traverse beyond the original order or supplement its directions - The focus remains strictly on whether the specific directions issued in the judgment have been willfully disobeyed. [Relied on Sita Ram v. Balbir, (2014) 13 SCC 489; J.S. Parihar v. Ganpat Duggar, (1996) 6 SCC 291; Snehasis Giri v. Subhasis Mitra, (2023) 18 SCC 529; Paras 9-29] Israr Ahmed Khan v. Amarnath Prasad, 2026 LiveLaw (SC) 209 : 2026 INSC 209

Contract Act, 1872; Section 133 - Discharge of surety by variance in terms of contract - The Supreme Court held that any variance made in the terms of the contract between the principal debtor and the creditor without the surety's consent discharges the surety only as to transactions subsequent to the variance - The discharge of the surety is not absolute; they remain liable for the original amount for which they stood as guarantee before the unauthorized variance occurred. Bhagyalaxmi Co-Operative Bank Ltd. v. Babaldas Amtharam Patel, 2026 LiveLaw (SC) 210 : 2026 INSC 205

Contract Act, 1872 - Liability of Guarantors - Bifurcation of Liability - Supreme Court set aside the High Court's finding that guarantors are either liable for the entire amount or not at all. It held that liability can be bifurcated; sureties are liable to the extent of their original engagement (plus applicable interest) but are not liable for excess amounts permitted to be withdrawn by the creditor in connivance with the principal debtor without the sureties' intimation or consent - The cardinal rule is that a guarantor must not be liable beyond the terms of his engagement – noted that unless there is bad faith, misrepresentation, or a material variation to the prejudice of the surety, the creditor's actions within the contract terms do not automatically discharge the surety – Appeal allowed. [Relied on State of Maharashtra vs. Dr. MN Kaul (D) by his LRs, AIR 1967 SC 1634; Syndicate Bank vs. Channaveerappa Beleri & Ors., (2006) 11 SCC 506; Paras 4-7] Bhagyalaxmi Co-Operative Bank Ltd. v. Babaldas Amtharam Patel, 2026 LiveLaw (SC) 210 : 2026 INSC 205

Contract Law - Interpretation of Contracts – Admissibility of Extrinsic Evidence – Sections 92 and 94 of the Indian Evidence Act, 1872 – Supreme Court emphasized that when the language of a contract is plain and applies accurately to existing facts, evidence cannot be given to show it was not meant to apply to such facts - under Section 92, factual context and correspondences between parties can be used to make ambiguous terms certain. [Paras 21-22] WB State Electricity Distribution v. Adhunik Power & Natural Resource, 2026 LiveLaw (SC) 213 : 2026 INSC 202

Contract Law - Shortfall in Tapering Linkage – Indemnity Clauses – Supreme Court set aside the compensation awarded for the period prior to the coal block cancellation (pre-25.08.2014) - It held that Article 2.5 of the PPA/PSA acted as an indemnity clause, stipulating that if coal was procured from alternative sources (e-auction/import) to meet shortfalls in tapering linkage before the captive source became operational, such coal would be deemed to be from the captive source with no separate cost escalation allowed. [Paras 19-23, 25-26] WB State Electricity Distribution v. Adhunik Power & Natural Resource, 2026 LiveLaw (SC) 213 : 2026 INSC 202

Cooperative Societies — Interplay between Reorganisation Act and 2002 Act — Legislative Continuity — Section 87 of the Uttar Pradesh Reorganisation Act, 2000, embodies the doctrine of legislative continuity, allowing for the adaptation of laws for two years following bifurcation - Actions taken during this transitional period to reorganize societies to fit single-state boundaries are valid and cannot be retrospectively invalidated by Section 103 of the 2002 Act. Registrar Cane Cooperative Societies v. Gurdeep Singh Narval, 2026 LiveLaw (SC) 224 : 2026 INSC 216

Cooperative Societies — Non-obstante Clause — Section 93 of the Reorganisation Act provides that its provisions shall have effect notwithstanding anything inconsistent in any other law - The deeming fiction of Section 103 of the 2002 Act cannot override the express statutory scheme of the Reorganisation Act where reorganisation actions were already completed – Appeal allowed. [Relied on State of Uttar Pradesh through Principal Secretary and Others v. Milkiyat Singh and Others; 2025 SCC OnLine SC 2802; Paras 13-24] Registrar Cane Cooperative Societies v. Gurdeep Singh Narval, 2026 LiveLaw (SC) 224 : 2026 INSC 216

Cooperative Societies — Uttar Pradesh Reorganisation Act, 2000 — Multi-State Cooperative Societies Act, 2002 — Section 103 — Status of Sugarcane Cooperative Societies upon State Bifurcation — The Supreme Court held that the Sugarcane Growers Cooperative Societies of Bajpur and Gadarpur are not Multi-State Cooperative Societies – Held that the deeming fiction under Section 103 of the 2002 Act is neither automatic nor universal; it requires a factual determination of whether a society's objects (distinguished from its area of operation) extend to more than one State. Registrar Cane Cooperative Societies v. Gurdeep Singh Narval, 2026 LiveLaw (SC) 224 : 2026 INSC 216

Election - The Supreme Court urged the Election Commission of India to consider the suggestions put forth by a petitioner regarding measures to curb excessive election expenditures observing that the suggestions given by the petitioner are "worth consideration". Prabhakar Deshpande v. Chief Election Commissioner of India, 2026 LiveLaw (SC) 218

Electricity – Power Purchase Agreement (PPA) – Change in Law – Cancellation of Coal Blocks – The Supreme Court upheld the grant of compensation to the power generator (APNRL) for additional costs incurred due to "Change in Law" events resulting from the cancellation of the Ganeshpur captive coal block – Noted that the judgment in Manohar Lal Sharma v. Principal Secy. & Ors. (2014) 9 SCC 516 and the subsequent enactment of the Coal Mines (Special Provisions) Act, 2015 constituted a "Change in Law" under Article 10 of the PPA - These events altered the legal regime for coal allocation, thereby entitling the generator to be restored to the same economic position as if the Change in Law had not occurred. [Para 24] WB State Electricity Distribution v. Adhunik Power & Natural Resource, 2026 LiveLaw (SC) 213 : 2026 INSC 202

Evidence Act, 1872 – Ocular Evidence vs. Unnatural Conduct – held that the testimony of related witnesses (brother, son, and nephews of the deceased) could not be discarded merely because they failed to intervene or take the victim to the hospital after the shooting - Such "unnatural behavior" does not invalidate their evidence when consistent with other facts, such as the established political rivalry and the forensic evidence of multiple gunshot wounds. [Paras 11 - 15] Dablu v. State of Madhya Pradesh, 2026 LiveLaw (SC) 238 : 2026 INSC 224

Evidence Act, 1872 – Section 27 [Proviso to Section 23 of BSA, 2023] – Recovery of currency notes and blood-stained shirt – Reliability - Currency Notes: A discrepancy in the amount recovered (Rs. 46,000/- vs Rs. 46,145/- counted in Court) casts a "grave cloud of doubt" on the factum of recovery - Mere recovery of money, without a clear nexus to the crime, is not an incriminating circumstance – Noted that it "highly improbable and unnatural" that an accused, who was at liberty for days, would meticulously conceal a blood-stained shirt in an iron box rather than destroying it or washing it. Pooranmal v. State of Rajasthan, 2026 LiveLaw (SC) 227 : 2026 INSC 217

Evidence Act, 1872 – Section 65-B [Section 63 of BSA, 2023] – Admissibility of Electronic Evidence (Call Detail Records) – Held that the certificate required under Section 65-B(4) is a condition precedent to the admissibility of electronic records. Oral evidence cannot substitute this mandatory requirement - Since the prosecution failed to prove the Section 65-B certificate, the CDRs indicating frequent contact between the accused were rendered inadmissible. [Relied on Anvar P.V. v. P.K. Basheer (2014) 10 SCC 473; Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal (2020) 7 SCC 1; Paras 49-52] Pooranmal v. State of Rajasthan, 2026 LiveLaw (SC) 227 : 2026 INSC 217

Evidence Act - Section 32 - Dying Declaration – Conviction on the sole basis of dying declaration – Requirements and Caution - Held: While a dying declaration is a crucial piece of evidence that can form the sole basis for conviction without corroboration, it must inspire full confidence in the Court – Supreme Court must be satisfied that the deceased was in a fit state of mind, and the statement was not the result of tutoring, prompting, or imagination - If the declaration is suspicious or the deceased's physical/mental capacity is in doubt, it should not be acted upon without corroborative evidence - In the present case, multiple inconsistencies, the presence of interested relatives during recording, and the lack of medical certification regarding the victim's fit state of mind rendered the declarations unreliable. Sanjay Kumar Sharma v. State of Bihar, 2026 LiveLaw (SC) 230 : 2026 INSC 223

Evidence Law – Circumstantial Evidence – Recovery of Articles – Call Detail Records (CDR) – Section 65-B of Evidence Act – Indian Penal Code, 1860 – Sections 302/34 and 201 [Sections 103(1)/3(5) and 238 of BNS, 2023] – Conviction based on circumstantial evidence – Requirements for conviction – Held that the "Panchsheel" principles governing circumstantial evidence - To sustain a conviction, the circumstances must be fully established and form a complete chain that excludes every possible hypothesis except the guilt of the accused - The mental distance between "may be guilty" and "must be guilty" is long and divides vague conjectures from sure conclusions. [Relied on harad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116; Paras 27-28] Pooranmal v. State of Rajasthan, 2026 LiveLaw (SC) 227 : 2026 INSC 217

Evidence Law – Forensic Science Laboratory (FSL) Report – Chain of Custody – Sanctity of Samples. For an FSL report to be reliable, the prosecution must prove an unbroken chain of custody from seizure to laboratory - In this case, contradictions between the Malkhana In-charge and Carrier Constable regarding the dates the samples were sent and returned from the FSL (due to unspecified "defects") breached the chain of custody – Noted that even if blood groups match, this circumstance in isolation cannot link the accused to the crime without other cogent evidence. [Relied on Karandeep Sharma alias Razia alias Raju v. State of Uttarakhand 2025 SCC OnLine SC 773; Paras 41-44] Pooranmal v. State of Rajasthan, 2026 LiveLaw (SC) 227 : 2026 INSC 217

Evidence Law – Witness Testimony – Hostile Witnesses – The testimony of "hostile" independent witnesses cannot be discarded in toto - Supreme Court must consider parts of the testimony that are creditworthy and corroborated by other evidence, such as the Trap Laying Officer's account and the recovery of marked currency. [Relied on Neeraj Dutta v. State (Govt. of NCT of Delhi), (2023) 4 SCC 731; Prakash Chand v. State (Delhi Administration), (1979) 3 SCC 90; State of Bihar v. Basawan Singh, AIR 1958 SC 500; Himachal Pradesh Administration v. Shri Om Prakash, (1972) 1 SCC 249; Paras 15-30] Central Bureau of Investigation v. Baljeet Singh, 2026 LiveLaw (SC) 228 : 2026 INSC 221

Intervenors/Non-Parties — Right to Seek Review — Even a non-party to the proceedings can seek a review of an order if they perceive themselves to be an "aggrieved person" and satisfy the court of such a standing - Judgments in service matters often affect a class of employees beyond the immediate parties. Such judgments are not strictly in personam and can adversely affect the rights of others who were not joined in the original litigation. [Relied on Union of India v. Nareshkumar Badrikumar Jagad (2019) 18 SCC 586; Ajit Babu v. Union of India (1997) 6 SCC 473; K. Ajit Babu v. Union of India (1997) 6 SCC 473; Paras 13-20] Dr. Jiji K.S. v. Shibu K., 2026 LiveLaw (SC) 212 : 2026 INSC 207

Investigation - Lapses in Investigation – Failure to Secure Crime Scene and Independent Witnesses - Held: Overzealous or lethargic investigations are equally fatal to the prosecution - The failure of the Investigating Officer (I.O.) to draw a scene mahazar, conduct forensic examinations to rule out accidental fire (e.g., cylinder burst), or examine independent witnesses despite their presence at the scene constitutes a serious lacuna – Appeal dismissed. [Relied on Atbir v. Government of NCT of Delhi (2010) 9 SCC 1; Laxman v. State of Maharashtra (2002) 6 SCC 710; Paras 10-31] Sanjay Kumar Sharma v. State of Bihar, 2026 LiveLaw (SC) 230 : 2026 INSC 223

Medical Ethics – Best Interest Principle – Substituted Judgment Standard – For incompetent patients, the decision to withdraw treatment must be grounded in the "best interest of the patient" - Held: The inquiry is not whether it is in the patient's best interest to die, but whether it is in their best interest to prolong life artificially through futile treatment - The "Substituted Judgment" standard—ascertaining what the patient would have wanted if competent is a critical component of determining their best interest from a dignity-centric lens. [Paras 131, 228, 229] Harish Rana v Union of India, 2026 LiveLaw (SC) 229 : 2026 INSC 222

Medical Ethics – Procedural Guidelines – Minimal Judicial Intervention – Supreme Court emphasized that judicial intervention under Article 226 is only a fallback mechanism when medical boards disagree or hospitals fail to act. In the ordinary course, hospitals must constitute Primary and Secondary Medical Boards as per the Common Cause framework - Implementation of the boards' decision must follow a mandatory "Reconsideration Period" of 30 days to allow aggrieved parties to seek legal recourse. [Relied on Common Cause v. Union of India, (2018) 5 SCC 1; Paras 23, 109, 274, 322] Harish Rana v Union of India, 2026 LiveLaw (SC) 229 : 2026 INSC 222

Medical Law – Clinically Assisted Nutrition and Hydration (CANH) – Definition of "Medical Treatment" – Supreme Court clarified that CANH (enteral or parenteral nutrition via tubes) is a technologically mediated medical intervention, not mere basic care or sustenance - Held: Since CANH involves specialized medical protocols, risks of complications, and clinical assessment, it constitutes "medical treatment" amenable to withdrawal or withholding under the Common Cause guidelines. [Paras 118, 125, 128, 130] Harish Rana v Union of India, 2026 LiveLaw (SC) 229 : 2026 INSC 222

Other Backward Classes (OBC) – Reservation – Creamy Layer Exclusion – Validity of Clarificatory Letter dated 14.10.2004 vs. Office Memorandum dated 08.09.1993 – Equality Doctrine - Key Principles Held – i. Primacy of the 1993 Office Memorandum (OM): A mere executive letter of clarification (dated 14.10.2004) cannot override or alter the substantive framework of a parent policy like the 1993 OM - If a clarification introduces new conditions that alter rights, it ceases to be clarificatory and becomes an impermissible amendment; ii. Exclusion of Salary and Agricultural Income: Under the 1993 OM, income from salaries and agricultural land must be excluded from the "Income/Wealth Test" (Category VI) - Supreme Court affirmed that income from salaries alone cannot be the sole criterion for Creamy Layer status; parental status and category of post are essential factors; iii. Hostile Discrimination: Denying OBC-Non-Creamy Layer (NCL) status to children of PSU/private employees based on salary while granting it to similarly placed Government servants (Group C and D) who reach similar income levels is "hostile discrimination." - It treats equals as unequals; iv. Constitutional Imperative: The exclusion of the creamy layer is a constitutional necessity to ensure benefits reach the truly backward - this exercise must be rational and non-arbitrary - directed the Union of India/DoPT to consider the claims of respondent candidates and intervenors based on these principles and to create supernumerary posts as required to accommodate those who satisfy the NCL criteria. [Relied on Indra Sawhney v. Union of India, 1992 Supp (3) SCC 217; State of Kerala v. N.M. Thomas, (1976) 2 SCC 310; Ashok Kumar Thakur v. Union of India, (2008) 6 SCC 1; Paras 24 33, 37-43] Union of India v. Rohith Nathan, 2026 LiveLaw (SC) 232 : 2026 INSC 230

Other Backward Classes (OBC) – Reservation – Creamy Layer Exclusion – Validity of Clarificatory Letter dated 14.10.2004 vs. Office Memorandum dated 08.09.1993 – Equality Doctrine - The Supreme Court dismissed a batch of appeals filed by the Union of India against various High Court judgments which had ruled in favor of candidates from the OBC category - The central controversy was whether the salary of parents employed in Public Sector Undertakings (PSUs) or private sectors could be the sole basis for "Creamy Layer" exclusion in the absence of established "equivalence" with government posts - held that treating PSU/private employees differently from Government servants (where salary is excluded from the income test) constitutes hostile discrimination and violates Articles 14 and 16 of the Constitution of India. Union of India v. Rohith Nathan, 2026 LiveLaw (SC) 232 : 2026 INSC 230

Penal Code, 1860 – Section 149 – Unlawful Assembly and Vicarious Liability – Murder – The Supreme Court upheld the conviction of four appellants sentenced to life imprisonment for the murder of a Watershed Committee Chairman - Noted that to attract Section 149 IPC, two essential elements must be established: an "unlawful assembly" and a "common object" - Even in the absence of a specific overt act attributed to each member, the mere presence of the accused as part of an armed unlawful assembly is sufficient for conviction - noted that all accused alighting together from a bus while armed with firearms clearly established their common motive and participation in the unlawful assembly. [Paras 12, 13] Dablu v. State of Madhya Pradesh, 2026 LiveLaw (SC) 238 : 2026 INSC 224

Prevention of Corruption Act, 1988 – Section 7 – Indian Penal Code, 1860 – Section 120B – Criminal Conspiracy – Demand and Acceptance of Bribe – Individual Liability vs. Collective Culpability – The Supreme Court held that even if a charge of criminal conspiracy (Section 120B IPC) fails due to lack of evidence regarding a prior meeting of minds or demand by one of the accused, the other accused can still be independently convicted for demand and acceptance under Section 7 of the PC Act if the evidence specifically establishes their individual role - The conduct of an accused person—such as turning pale, remaining "mum," or attempting to escape/dispose of the bribe money when challenged by the Trap Laying Officer—is admissible as relevant conduct under Section 8 of the Evidence Act. Central Bureau of Investigation v. Baljeet Singh, 2026 LiveLaw (SC) 228 : 2026 INSC 221

Property Law — Declaration of Title — Adverse Possession — A claim for perfection of title by adverse possession cannot be sustained against the State/Union regardless of the duration of possession if the claimant fails to prove the specific point of time and basis upon which their predecessors entered possession - a decree obtained in an earlier suit where the true owner (Union of India) was not impleaded is non-est and not binding upon the Union – Appeals dismissed. [Relied on Union of India v. Ibrahim Uddin, (2012) 8 SCC 148; State of Karnataka v. K.C. Subramanya, (2014) 13 SCC 468; Paras 7- 11] Gobind Singh v. Union of India, 2026 LiveLaw (SC) 221 : 2026 INSC 211

Railway - Passengers purchasing railway tickets over the counter cannot be denied the benefit of travel insurance when the same facility is available to those booking tickets online. Union of India v. Radha Yadav, 2026 LiveLaw (SC) 231

Recovery of Debts Due to Banks and Financial Institutions Act, 1993 – Auction Sale – Finality of Sale vs. Adequacy of Valuation – Limited Remand – The Supreme Court upheld the High Court's direction to remit the matter to the Debts Recovery Tribunal (DRT) for the limited purpose of reconsidering the valuation of properties, even after the auction sale was confirmed - While the rights of a bona fide auction purchaser deserve protection, this protection is not absolute - If credible issues regarding the adequacy of valuation or the fairness of the reserve price fixation arise, the court may invoke its supervisory jurisdiction to ensure the recovery process realized the maximum possible value for the secured asset. Om Sakthi Sekar v. V. Sukumar, 2026 LiveLaw (SC) 240 : 2026 INSC 237

Recovery Proceedings – Objective of Auction – The primary goal of an auction is to obtain the most remunerative price for a property through competitive bidding, ensuring transparency and fairness - A process that compromises competitive bidding increases the risk of underbidding or inadequate pricing - The principle of finality in judicial sales does not shield the process from examination regarding valuation or reserve price fixation - Recovery processes must be fair, transparent, and based on proper value assessments to balance the interests of both creditors and borrowers – Appeal dismissed. [Relied on Rajiv Kumar Jindal v. BCI Staff Welfare Association (2023) 238 Comp Cas 227: 2023 SCC OnLine SC 507; Paras 15-19] Om Sakthi Sekar v. V. Sukumar, 2026 LiveLaw (SC) 240 : 2026 INSC 237

Rights of Persons with Disabilities Act, 2016 – Appointment to Public Posts – Suitability of Posts for Mental Illness and Specific Learning Disabilities (SLD) – Change in Rule Position during Pendency of Litigation – The Supreme Court directed the Comptroller and Auditor General (CAG) to accommodate candidates suffering from 'mental illness' and 'Specific Learning Disability' (SLD) in Group 'C' posts - Although the posts of 'Auditor' were initially identified as unsuitable for these specific benchmark disabilities in 2018, a subsequent Gazette Notification dated 04.01.2021 by the Ministry of Social Justice and Empowerment expressly identified Group 'C' posts as suitable for such categories – Supreme Court directed the Staff Selection Commission (SSC) to forward the dossiers of the candidates within two weeks - It further ordered that if the posts advertised in 2018 are already filled, the respondents must create supernumerary posts to accommodate the candidates. [Paras 17-21] Sudhanshu Kardam v. Comptroller and Auditor General of India, 2026 LiveLaw (SC) 237 : 2026 INSC 232

Service Law – Character and Suitability for Disciplined Force – Held that a candidate for the police force must possess impeccable character, rectitude, and integrity - The employer, through a screening committee, has a wide realm of discretion to assess the suitability of a candidate based on their criminal antecedents, even if an acquittal has been recorded - An acquittal based on technical grounds or "benefit of doubt" does not automatically entitle a candidate to appointment. State of Madhya Pradesh v. Rajkumar Yadav, 2026 LiveLaw (SC) 234 : 2026 INSC 225

Service Law – Distinction between "Honourable Acquittal" and "Acquittal on Benefit of Doubt" – An honourable acquittal occurs when the court definitively concludes that the accused did not commit the offence - In contrast, an acquittal based on a "benefit of doubt" due to a weak prosecution case or lack of credible evidence is a technical consideration and does not constitute a "clean chit". [Para 5] State of Madhya Pradesh v. Rajkumar Yadav, 2026 LiveLaw (SC) 234 : 2026 INSC 225

Service Law – Inter-se Seniority – Direct Recruits vs. Internally Selected Candidates – Reckoning of Seniority from Date of Appointment/Training vs. Date of Commencement of Probation - Tamil Nadu Electricity Board (Service Regulations), 1967 – Regulations 10(9), 87(1), and 97 – Determination of Seniority: The Supreme Court set aside the High Court Division Bench's judgment which had ruled that seniority for direct recruits should only commence from the date their probation started (after completion of training) - held that according to the plain language of the Regulations, a person is considered to be "on duty" and "appointed to a class of service" from the moment they perform duties or commence prescribed training/instruction. [Relied on Govt. of A.P. v. P. Bhaskar (2008) 11 SCC 687; 2008 INSC 267; Paras 19-24] M. Thanigivelu v. Tamil Nadu Electricity Board, 2026 LiveLaw (SC) 233 : 2026 INSC 229

Service Law – Limited Scope of Judicial Review – Held that courts should not override the wisdom of the employer or substitute their own view regarding a candidate's suitability unless the decision is demonstrably mala fide, arbitrary, or whimsical - The Division Bench erred by intruding into the functional realm of the screening committee – Appeals allowed. [Relied on Commissioner of Police, New Delhi & Anr. Vs. Mehar Singh (2013) 7 SCC 685; Union Territory, Chandigarh Administration & Ors. Vs. Pradeep Kumar & Anr. (2018) 1 SCC 797; State of Madhya Pradesh & Ors. Vs. Parvez Khan (2015) 2 SCC 591; Para 7-9] State of Madhya Pradesh v. Rajkumar Yadav, 2026 LiveLaw (SC) 234 : 2026 INSC 225

Service Law – Recruitment to Police Force – Criminal Antecedents and "Honourable Acquittal" – Scope of Judicial Review – The Supreme Court set aside the High Court Division Bench's order which had directed the State to treat a candidate's acquittal as "honourable" and reconsider him for the post of constable (driver) - The respondent was previously charged with serious offences involving moral turpitude, including kidnapping and rape (Sections 363, 366, 376(2)(c) IPC), but was acquitted by the trial court by being given the "benefit of doubt". State of Madhya Pradesh v. Rajkumar Yadav, 2026 LiveLaw (SC) 234 : 2026 INSC 225

Service Law – Seniority from Initial Joining - Administrative Instructions vs. Statutory Regulations - Supreme Court clarified that the period of training is an integral part of service and must be counted for seniority - Regulation 97 specifies that seniority is determined by the rank in the list of approved candidates, and the date of joining duty marks the commencement of the relationship with the service, regardless of whether the candidate is on a consolidated pay during training or a regular scale during probation - rejected the application of the "cyclic order" (Proviso to Regulation 97) because the direct recruits were selected/appointed in 2000 and 2001, while the internal candidates were promoted in May 2002 - Since they were not recruited in the same calendar year, the direct recruits appointed earlier maintain their seniority over those appointed later - noted that any Board Proceedings (BPs) or terms in appointment letters that run contrary to the statutory Regulations (10(9) and 87) cannot override the legal position that seniority counts from the first date of joining for training. M. Thanigivelu v. Tamil Nadu Electricity Board, 2026 LiveLaw (SC) 233 : 2026 INSC 229

Specific Relief Act, 1963 – Sham and Nominal Documents – Loan Transaction vs. Sale Agreement – Probative Value of Contemporaneous Documents – Held that where a registered sale agreement and a separate MoU are executed on the same day, purchased from the same stamp vendor, and witnessed by the same individuals, such facts strongly probablize the defense that the sale agreement was merely security for a loan transaction rather than a genuine sale. [Paras 10-12] Muddam Raju Yadav v. B. Raja Shanker, 2026 LiveLaw (SC) 223 : 2026 INSC 214

Specific Relief Act, 1963 – Specific Performance – Discretionary Relief – Bona Fides of Plaintiff – Suppression of Material Facts – The Supreme Court upheld the High Court's decision to dismiss a suit for specific performance where the plaintiff suppressed the existence of a Memorandum of Understanding (MoU) executed on the same day as the sale agreement - held that specific performance is an equitable and discretionary relief that must be denied if there is even a slight doubt regarding the plaintiff's bona fides or if material facts have been withheld from the Court - A plaintiff approaching the Court with "unclean hands" by failing to mention a contemporaneous document that characterizes the sale agreement as a sham/nominal document for a loan transaction is not entitled to relief. Muddam Raju Yadav v. B. Raja Shanker, 2026 LiveLaw (SC) 223 : 2026 INSC 214