Weekly Overview| Supreme Court Judgments: June 22 – June 26, 2026
1) "Readiness" in specific performance suits must be proved with reference to relevant period; subsequent FDRs insufficient
The Court dismissed a suit for specific performance, ruling that the plaintiff failed to demonstrate continuous readiness and willingness to fulfil his obligations under the agreement to sell. The Court observed that financial documents generated years after the institution of the suit cannot be relied upon to prove the availability of funds during the relevant period for performance of the contract.
The Court reiterated that readiness under Section 16(c) of the Specific Relief Act, 1963, relates to the financial capacity of the plaintiff, while willingness is reflected through his conduct. Both requirements, the Court held, must be continuously satisfied from the date of the agreement until adjudication of the suit.
Cause Title- Mohammed Khaleel (D) Through LRs & Ors. v. Jayamma (Neutral Citation: 2026 INSC 651)
Date of Judgment- June 23, 2026
Coram- Justice Prashant Kumar Mishra and Justice N.V. Anjaria
2) Posture & dexterity indispensable to artisan trades: Supreme Court grants 10 lakh for prosthetic leg to carpenter as motor accident compensation
The Court held that posture and manual dexterity are indispensable to artisan trades, and amputation affecting these essential skills can amount to 100% functional disability despite a lower medical impairment assessment.
Holding that a carpenter’s lower-limb amputation completely impaired his ability to perform essential work postures like squatting and sitting cross-legged, the Court awarded ₹10 lakh for prosthetic limb replacement and maintenance, emphasizing that functional loss must be assessed from the perspective of actual earning capacity.
Cause Title- Shankar Dutt v. United India Insurance Co. Ltd. And Others (Neutral Citation: 2026 INSC 656)
Date of Judgment- June 24, 2026
Coram- Justice Ujjal Bhuyan and Justice N.V. Anjaria
3) Registered sale deed u/s 154 of unamended UPZA not void ab initio for ceiling violations; consolidation authorities cannot disregard it
The Court clarified that a registered sale deed executed in contravention of the land ceiling limits under Section 154 of the unamended U.P. Zamindari Abolition and Land Reforms Act, 1950, is merely voidable at the instance of the Gaon Sabha and cannot be treated as void ab initio. It noted that consolidation authorities lack the statutory competence to disregard or brush aside registered instruments of conveyance unless they are formally cancelled by a competent civil court.
Furthermore, the court held that the 1981 legislative amendments rendering such contraventions void with automatic state vesting apply strictly prospectively and cannot impair vested rights under a 1957 deed. Additionally, the court said that because attestation is not a statutory prerequisite for a sale deed, minor discrepancies in the residence description of an attesting witness examined decades later cannot dislodge the formidable presumption of validity attached to registered documents.
Cause Title- Sarafat Ali (Deceased) through LRs and Others v. Deputy Director of Consolidation Haridwar and Others (Neutral Citation: 2026 INSC 652)
Date of Judgment- June 23, 2026
Coram- Justice Prashant Kumar Mishra and Justice N.V. Anjaria
4) Sentencing must be proportionate to factual matrix & degree of criminality: Supreme Court reduces sentence in revenue document forgery case
The Court reduced the sentence imposed upon a convict to the period of incarceration already undergone by him in a case of using forged revenue documents for furnishing surety in judicial proceedings. The Apex Court noted that the alleged misuse did not ultimately culminate in any irreversible pecuniary or proprietary consequence and further observed that sentencing must remain proportionate to the overall factual matrix and the degree of criminality reflected in the case.
The Court was considering a criminal appeal arising out of the judgment passed by the Madhya Pradesh High Court affirming the judgment of conviction and sentence of the accused under Sections 420, 467, 468 and 471 of the Indian Penal Code, 1860. The accused was sentenced to imprisonment for five years on each count along with fine of Rs.1,000 under each head, with the substantive sentences directed to run concurrently. The proceedings before the Court were confined only to the issue relating to the sentence imposed upon the appellant.
Cause Title- Israfil @ Pappu @ Naimuddin Khan v. State of Madhya Pradesh (Neutral Citation: 2026 INSC 654)
Date of Judgment- June 23, 2026
Coram- Justice Prashant Kumar Mishra and Justice N.V. Anjaria
5) Motor accident compensation can't be founded on assumptions of assured professional success
The Court held that compensation under the Motor Vehicles Act cannot be founded on assumptions of assured professional success or on salary benchmarks of unrelated successful professionals. The Court affirmed the concurrent findings of negligence against a truck driver who left his punctured vehicle hazardously stationed on the road without indicators or warning signs in the dead of night.
While dealing with the quantum of compensation for the parents of a twenty-year-old Chartered Accountancy student who died in the ensuing collision, the Court acknowledged that the Motor Accident Claims Tribunal had adopted an exceptionally liberal methodology by projecting entry-level professional earnings as the base income and simultaneously adding a fifty percent increment for future prospects.
Cause Title- The Oriental Insurance Company Limited v. Kalu Ram and Ors. (Neutral Citation: 2026 INSC 653)
Date of Judgment- June 23, 2026
Coram- Justice Prashant Kumar Mishra and Justice N.V. Anjaria
6) Functional disability affecting earning capacity may be assessed at higher percentage including 100%: Supreme Court enhances mason’s motor accident compensation
While awarding enhanced motor accident compensation to a mason whose right leg came to be amputated, the Court held that the physical disability may be assessed at a particular percentage, but the functional disability affecting earning capacity may, depending upon the nature of the avocation carried on by the injured, be assessed at a higher percentage, including 100%.
The Appeal before the Apex Court arose out of the judgment passed by the Madras High Court partly allowing the appeal preferred by the appellant-claimant and enhancing the compensation awarded by the Motor Accident Claims Tribunal/Sub Court from Rs 10,84,330 to Rs 23,86,320 together with interest.
Cause Title- M Paramesh v. VRL Logistics Ltd. (Neutral Citation: 2026 INSC 655)
Date of Judgment- June 23, 2026
Coram- Justice Prashant Kumar Mishra and Justice N.V. Anjaria