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Hindu Religious Institutions and Endowments Act: Removal of Mahant – Natural Justice

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In Arjun Dass v. The State of Andhra Pradesh and Others (Civil Appeal No. [To Be Allocated] of 2026, arising out of SLP (Civil) No. 38500 of 2025, decided on May 29, 2026), the Supreme Court of India adjudicated a significant religious and administrative dispute concerning the removal of the Mathadhipathi (Mahant) of the historical Sri Swamy Hathiramji Mutt in Tirupathi under the Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987 (“1987 Act”). The appellant challenged his removal by the Dharmika Parishad (and its subsequent confirmation by the State Government), which was based on an ex-parte enquiry report containing 16 charges of financial mismanagement, nepotism, and customary violations. The High Court of Andhra Pradesh had previously dismissed the appellant’s appeal, affirming his removal.

The Supreme Court allowed the appeal and set aside the High Court’s judgment along with the removal and confirmation orders, ruling that the entire disciplinary process was severely vitiated by gross violations of the principles of natural justice (audi alteram partem). The Division Bench of Justice J.K. Maheshwari and Justice Atul S. Chandurkar found that the 27-page charge memo and 600 pages of supporting documents were never properly served upon the appellant, and his requests for documents and time to prepare his defense were ignored. Furthermore, the Court observed that a pre-decisional resolution passed by the Dharmika Parishad to simultaneously frame charges and suspend the Mahant revealed that the outcome was predetermined.

Invoking its plenary powers under Article 142 of the Constitution of India to remedy systemic vulnerabilities and structural gaps in the statutory framework, the Supreme Court fashioned a unique, case-specific mechanism. It appointed an independent, one-man enquiry committee led by a retired District Judge to conduct a fresh, fair enquiry within one year. To preserve the institutional integrity of the Mutt’s extensive properties during this transition without severing the unique, legally blended spiritual and temporal components of Mahantship, the Court reinstated the appellant as Mathadhipathi. However, his administrative functions were subjected to the oversight of a newly formed, judicially supervised six-member Administrative Committee.

1. Factual Matrix & Institutional Conflict

  • Rise to Mahantship: The appellant has been associated with the Sri Swamy Hathiramji Mutt since 1970. Starting as a Pujari in 1975, he rose through the ranks to be confirmed as the permanent Mahant by the apex Akhada Panchayat and officially appointed by the Commissioner of Endowments on July 6, 2000.
  • Prior Rounds of State Litigation: Shortly after his appointment, the appellant engaged in litigation to force the Endowments Department to hand over the secular management of the Mutt to him. The department retaliated by suo motu canceling his appointment order in 2003, an action that was subsequently set aside by a Single Judge of the High Court in 2006. Following mandatory government orders, the secular management and vast properties were formally returned to the appellant in late 2006.
  • The 2023 Charges and Physical Seizure: Following temporary suspension cycles between 2018 and 2020 triggered by local newspaper reports, the newly constituted Dharmika Parishad passed a unified resolution on May 09, 2023, authorizing the simultaneous preparation of charges and suspension orders against the appellant. On June 8, 2023, the Parishad simultaneously issued 16 charges, suspended the appellant, and appointed an administrator (“Fit Person”). On the very same day, the Endowments Department physically seized the Mutt office and expelled the appellant from his residence while he was away on a pilgrimage.

2. The Ex-Parte Enquiry Report & Removal

The three-member enquiry committee conducted its entire proceedings ex-parte on a single day, July 19, 2023, after serving a notice to the appellant via WhatsApp just five days prior. The appellant’s advocate had transmitted three separate requests via email and personal delivery seeking a copy of the 600 pages of relied-upon evidence and a one-month extension due to the appellant falling ill with viral fever in Ayodhya. The committee discarded these requests on technical grounds (characterizing them as an “unsigned letter on WhatsApp”) and submitted its report on August 1, 2023, finding all 16 charges proved.

The charges included executing an unauthorized sale agreement of Mutt property, purchasing assets in his personal name, violating monastic customs, delaying employee benefits, and failing to pay statutory department dues. On November 24, 2023, the Dharmika Parishad issued the formal Removal Order, which was confirmed by the State Government via a Government Order (G.O.Ms. No. 581) on December 8, 2023.

3. Legal Analysis & Core Reasoning of the Court

A. Foundations of Procedural Fairness in Religious Offices

The Supreme Court emphasized that the removal of a Mathadhipathi is not a simple administrative exercise. It actively impacts substantive civil rights, specifically the right to hold a religious office and pursue a spiritual vocation. Under Article 14 of the Constitution, the rule of audi alteram partem operates with full force in such quasi-judicial proceedings. Citing Canara Bank v. V. K. Awasthy (2005), the Court reiterated that a precise, unambiguous notice accompanied by the complete evidentiary materials forming the baseline of the accusations is a non-negotiable requirement of fair play. An abstract opportunity to defend oneself without a full disclosure of the evidence is entirely illusory.

B. The Legal Absurdity of Purported Service by Affixation

The state robustly argued that the principles of natural justice were satisfied because the 27-page charge memo had been served via email and by affixing it to the door of the Mahant’s residence under a Panchanama on June 9, 2023. The Supreme Court completely rejected this defense, exposing a structural contradiction:

  • The state’s own photographic records proved that the Endowments Department had already physically seized the entire Mutt premises and locked out the appellant on June 8, 2023.
  • The Court noted that for the state to dispossess an individual from his residence, assume total physical control of the doors, and then claim valid legal service by pasting notices on those very doors is a “legal absurdity”. Once an individual is locked out by the state, the legal fiction of constructive notice collapses because they no longer have physical access to see the door. Furthermore, the records showed that only the 6-page “Fit Person” appointment order was pasted, while the 600 pages of supporting documents were completely omitted.

[ THE STRUCTURAL BREACH OF SERVIC

The respondents argued that any procedural gaps in the initial enquiry were cured because the appellant was later given a chance to submit detailed written explanations to a final show-cause notice on November 3, 2023, and was granted a personal hearing with his lawyers on November 16, 2023.

The Supreme Court rejected this argument, clarifying that an opportunity afforded on the back of a fundamentally tainted, ex-parte enquiry report—compiled without supplying the relied-upon documents—cannot substitute for a valid statutory enquiry under Section 51(2) of the 1987 Act. A fair hearing at a later stage cannot breath legal life into a process that was structurally compromised and predetermined from its inception.

D. Piercing the Procedural Vacuum via Article 142

The ordinary course of action following the quashing of a removal order would be to remand the matter back to the statutory body (Dharmika Parishad) for a de novo enquiry. However, the Supreme Court determined that a simple remand would leave the appellant’s civil and religious rights unprotected due to severe structural impediments:

  1. The Institutional Taint: The Dharmika Parishad is composed entirely of state nominees and ex-officio government functionaries. The officials who would sit on a reconstituted board are the very individuals whose prior hostile conduct and rushed, ex-parte procedures created the initial legal infirmities. REMANDING the dispute to them would re-create the exact conditions of bias.
  2. The Procedural Vacuum: Section 51(2) authorizes the Parishad to frame charges but leaves a complete statutory vacuum regarding the execution of an independent, neutral enquiry. The state had filled this gap by misapplying Rule 26 of the 2009 Rules—designed purely for internal administrative committees—to create a disciplinary body. This effectively allowed the adjudicating authority to act as investigator, prosecutor, and judge.
  3. The Concept of Mahantship: Relying on the landmark constitutional authority in The Commissioner, H.R.E. Madras v. Sri Lakshmindra Thirtha Swamiar of Sri Shirur Mutt (1954), the Court reiterated that in the legal concept of Mahantship, the elements of religious office and property administration are seamlessly blended and cannot be detached. Keeping the Mutt under the indefinite control of a state-appointed “Fit Person” while a lawful Mahant is active violates Article 26 of the Constitution.

4. Final Decretal Directions & Interim Regime

Invoking its plenary and supplementary powers under Article 142 of the Constitution to do complete justice, fill procedural vacuums, and ensure a completely fair, unbiased resolution, the Supreme Court ordered a case-specific interim regime:

A. Setting Aside of Impugned Actions

The High Court’s judgment dated May 09, 2025, the Dharmika Parishad’s Removal Order dated November 24, 2023, the government’s confirmation order (G.O.Ms. No. 581), and the original 2023 enquiry report are all set aside.

B. Appointment of a One-Man Independent Enquiry Committee

  • The Arbitrator: Boddepalli Rama Rao, a retired District Judge, is appointed as a one-man independent enquiry committee to review the 16 charges afresh.
  • Procedural Protections: The Principal District Judge at Chittoor must provide a neutral venue within the Tirupati Court Complex and depute two court staff to assist the committee.
  • The Timeline: The state must hand over all 600 pages of supporting materials to the committee within two weeks, which will then immediately supply them to the appellant. The appellant will have a minimum of four weeks to submit his statement of defense. The committee must afford full opportunities for the cross-examination of witnesses and submit its final report to the Endowments Department within one year.

C. Reinstatement and the Six-Member Administrative Committee

The appellant is immediately restored to his office and legal status as the Mathadhipathi of the Mutt, enabling him to conduct all core religious and spiritual activities. However, to guarantee absolute transparency over the Mutt’s extensive, vulnerable estates during the pending enquiry, the Court constituted a six-member Administrative Committee to assist and oversee secular functions under Section 55(2)(b) of the Act:

Position Committee Member Professional Background / Profile
Chairman Hon’ble Mr. Justice (Retd.) Duppala Venkata Ramana Retired Judge of the High Court of Andhra Pradesh / Madhya Pradesh.
Member Swami Madhav Prapanna Charya Eminent religious representative affiliated with Ramanuj Kot, Ujjain; expert in Vaishnava Sampradaya and monastic customs.
Member Mr. Manish Kapooria Retired Indian Police Service (IPS) Officer (Madhya Pradesh Cadre).
Member Mr. Y.V. Raviprasad Senior Advocate, Andhra Pradesh.
Member Mr. Manish Taskar Professional Chartered Accountant based in Hyderabad.
Member State Nominee An official nominated by the Andhra Pradesh Endowment Department within one week.

D. The Administrative Committee’s Mandate

  • The committee shall act strictly in a supervisory and facilitative capacity, without displacing the appellant’s spiritual authority.
  • It must prepare a comprehensive asset inventory of all movable and immovable Mutt properties within three months.
  • It must protect Mutt lands from encroachment and track all active litigations.
  • Strict Restraint: No asset alienation, leasing, mortgaging, or creation of third-party rights over Mutt properties shall take place without the prior, written permission of the Administrative Committee.
  • All expenses and a sitting fee (₹25,000 for the Chairman; ₹10,000 for members) shall be defrayed directly from the Mutt’s internal funds, and the committee must endeavor to meet at the head office at least once every three months.

E. Finality of the Interim Regime

This arrangement serves as an interim regime operational only until the Endowment Department passes its final order based on the independent retired judge’s report[cite: 20]. If the final report is adverse and results in a new removal order, the appellant retains the liberty to file a statutory appeal within one month[cite: 20]. Given its highly unique facts, this order shall not be treated as a legal precedent to supplant the statutory authority of the Dharmika Parishad in other cases[cite: 20].

2026 INSC 592

Arjun Dass  V. State of Andhra Pradesh And Others (D.O.J. 29.05.2026)

2026 INSC 592 click here to view full text of judgment

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Political Rivalry & Limits of Bail: SC Cancels Sentence Suspension for Mastermind in Murder

November 2, 2026 No Comments

This criminal appeal arose from a challenge to an order of the High Court suspending the sentences of the accused respondents following their conviction for a murder stemming from political rivalry over a Sarpanch election. The appellant, father of the deceased victim, contested the High Court’s routine suspension of sentences, which was granted primarily due to the heavy backlog and long pendency of criminal appeals. The Supreme Court partly allowed the appeal, ruling that while the suspension of sentence for the co-accused (where key prosecution witnesses turned hostile) did not warrant interference, the suspension granted to “A1” (the mastermind behind the conspiracy) was legally flawed. Emphasizing that courts cannot casually release convicts of heinous crimes simply due to systemic court delays, the Supreme Court cancelled the bail of A1 and directed him to surrender.

  • Background and Trial Conviction:
    • The crime involved the assassination of a candidate standing for bye-elections as a Sarpanch, orchestrated out of political rivalry.
    • “A1” (a government teacher whose faction lost influence) was convicted under Section 302 read with Section 120B IPC and sentenced to life imprisonment for masterminding the conspiracy, while other co-accused were convicted under Section 120B with 10 years of imprisonment.
    • The High Court suspended the sentences of the accused largely due to the impossibility of disposing of pending appeals in the near future.
  • Supreme Court’s Analysis Regarding the Mastermind (A1):
    • On a prima facie evaluation of evidence, the Supreme Court noted that witnesses testified to open threats made by A1 in the Returning Officer’s office stating the deceased would not stay alive until the election.
    • Furthermore, evidence from an Assistant Commissioner (PW40) established that A1 was present at a police station without provocation on the fateful day, pointing toward a deliberate attempt to create an alibi.
    • Given the compelling evidence of motive, threats, and calculated conspiracy, the High Court erred in granting bail to A1 solely based on appeal pendency.
  • Analysis Regarding the Co-Accused:
    • The prosecution alleged that the other respondents assisted by changing vehicle number plates, booking rooms, and purchasing SIM cards for the perpetrators.
    • However, material witnesses (such as PW8, PW12, PW13, PW27, PW66, PW67, and PW68) turned hostile or failed to establish the allegations, leaving insufficient direct material to disturb the High Court’s suspension of sentence for these co-accused.
  • Caution Against Routine Suspension of Sentences for Heinous Crimes:
    • The Court strongly criticized the knee-jerk practice of releasing convicts of heinous offences merely because appeals cannot be heard immediately, noting that it perils civil society and undermines public trust.
    • The bench underscored that courts must exercise circumspection, balance actual incarceration against appeal pendency, and remain sensitive to the trauma of victims’ families, since convicted persons no longer enjoy the presumption of innocence.
  • Final Orders and Directions:
    • The appeals were partly allowed.
    • The order suspending the sentence of A1 stands cancelled; he was directed to surrender before the Trial Court within two weeks.
    • The High Court’s order suspending the sentences of the other accused/respondents was left undisturbed.

2026 INSC 1180

Hanuman Prasad Hanuta Ram v. State of Rajasthan & Ors. (D.O.J. 27.10.2026)

2026 INSC 1180 click here to view full text of judgment

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Weaponisation of Criminal Law in Failed Relationships: SC Sets Aside Prosecution for Rape and Cheating

November 2, 2026 No Comments

This criminal appeal arose from a common order passed by the High Court of Kerala, which dismissed the appellant’s revision petition and miscellaneous case, thereby refusing to discharge him from charges under Sections 376, 420, 493, 494, and 495 of the IPC. The complainant had alleged that the appellant deceived her into a temple marriage in 1996 while concealing his prior marriage and children, and that her consent to sexual relations over seven years was vitiated by this misconception. The Supreme Court allowed the appeal and discharged the appellant, holding that the essential ingredients of the alleged offences were entirely absent because the complainant admitted to discovering the appellant’s prior marriage within six months of cohabitation yet voluntarily continued the relationship for years. Citing a worrying trend of converting failed consensual relationships into criminal prosecutions, the Court emphasized that criminal law cannot be weaponized to settle personal scores or exact revenge following emotional discord.

  • Factual Background & Lower Court Proceedings:
    • The appellant and respondent No. 2 lived together from 1996 to 2003 following a purported marriage ceremony at a temple in Mysuru.
    • After the relationship ended and domestic violence proceedings filed in 2008 were dismissed, respondent No. 2 filed a second private complaint that led to an FIR in 2011 for offences punishable under Sections 376, 420, 493, 494, and 495 of the IPC.
    • The Trial Court dismissed the appellant’s discharge application, and the Kerala High Court upheld that decision, ruling that a prima facie case of rape under misconception of fact was made out.
  • Legal Principles on Discharge (Section 277 CrPC):
    • Reaffirming principles from Prafulla Kumar Samal and Sajjan Kumar, the Supreme Court reiterated that at the stage of discharge, the court must sift and weigh evidence for the limited purpose of finding a prima facie case or grave suspicion. If the probability of the commission of the offence is non-existent, the accused is entitled to be discharged.
  • Analysis of Alleged Offences:
    • Rape (Section 376/375): The Court noted that the complainant admitted to being informed of the appellant’s prior marriage by his brother within six months of cohabitation, yet she continued to live with him voluntarily. A consensual relationship cannot be retrospectively branded as rape merely because the relationship soured years later.
    • Cheating (Section 420): There was no evidence that any deceit induced the complainant to deliver property or alter/destroy any “valuable security” as defined under Section 30 of the IPC.
    • Deceitful Cohabitation & Bigamy (Sections 493, 494, 495): Because the complainant continued cohabiting with full knowledge of the prior marriage and failed to establish a valid formal marriage beyond vague temple rituals, the core statutory ingredients were not satisfied.
  • Censure of Criminalizing Failed Relationships:
    • The Court expressed deep concern over a growing trend where courts witness consensual relationships that end in emotional discord being retrospectively combed for criminal elements.
    • While emphasizing the gravity of genuine sexual assault and the need to protect bodily autonomy, the Court cautioned that the justice system must not be turned into a tool for vengeance or financial coercion when adult relationships fail.
  • Final Order and Relief:
    • The Supreme Court set aside the impugned orders of the High Court and Trial Court.
    • The appellant’s discharge application was allowed, and he was completely discharged from all charges.

2026 INSC 1179

Santhosh Kumar N.P. v. State (Station House Officer, Kadirur Police) & Another (D.O.J. 30.10.2026)

2026 INSC 1179 click here to view full text of judgment

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Judicial Discipline Overruled: The Illegality of Reviewing Binding Precedents on Tariff Fixation and Sinking Funds

November 2, 2026 No Comments

This appeal arose from a patent breach of judicial discipline by the Appellate Tribunal for Electricity, which allowed a review petition after more than five years and overturned a 2019 tariff fixation order that had strictly followed a binding precedent of the Supreme Court (Bhaskar Shrachi Alloys Limited v. Damodar Valley Corporation). The underlying issue concerned whether the “Sinking Fund” created by the Damodar Valley Corporation (DVC) for redeeming bonds could be factored in as an item of expenditure in tariff determination alongside asset depreciation. The Supreme Court strongly criticized the Tribunal for overstepping the narrow contours of review, violating Article 141 of the Constitution, and attempting to rewrite settled tariff principles under the guise of correcting a “double benefit”. Consequently, the Supreme Court set aside the impugned review order, restored the original 2019 Tribunal judgment, and imposed exemplary costs on the review petitioner and the intervening public sector undertaking.

  • Background and Statutory Context:
    • The dispute relates to tariff fixation for DVC for the period 2009 to 2014 under the Electricity Act, 2003, the DVC Act, 1948, and the CERC Tariff Regulations, 2009.
    • DVC is a statutory corporation created (on the lines of the US Tennessee Valley Authority) not only to generate power but also to handle flood control, irrigation, and socio-economic development of the Damodar Valley.
    • Under Section 40 of the DVC Act and Regulation 43 of the 2009 Regulations, DVC is permitted to recover both depreciation (stipulated by the C&AG) and funds established under Section 40 (such as Sinking Funds for bond redemption) through tariff recovery.
    • The core issue regarding the validity of the Sinking Fund as a pass-through in tariff had already been conclusively settled by the Supreme Court in Bhaskar Shrachi Alloys Limited v. DVC ((2018) 8 SCC 281), which underscored the overriding protective effect of the fourth proviso to Section 14 of the Electricity Act, 2003.
  • The Tribunal’s Erroneous Review Order:
    • Following the 2018 Supreme Court judgment, the Appellate Tribunal in 2019 upheld the CERC’s tariff order allowing the Sinking Fund.
    • However, upon a review petition filed by consumers (Maithan Alloys), the Tribunal reversed its stand after 5 years, ruling that allowing both depreciation on capital assets and contributions to the Sinking Fund amounted to an impermissible “double allowance” or duplication.
  • Supreme Court’s Legal Analysis & Findings:
    • Scope of Review: Citing established principles (such as State of West Bengal v. Kamal Sengupta), the Supreme Court reiterated that an error which requires a long process of reasoning or debate cannot be termed an “error apparent on the face of the record”. A tribunal cannot sit in appeal over its own judgment or review it based on a supposed misconception that escaped notice.
    • Violation of Judicial Discipline and Article 141: The Tribunal’s action in reviewing an order based on a direct, binding Supreme Court precedent was labeled as “innovating at pleasure” and a clear violation of Article 141 of the Constitution.
    • Substantive Legality of Sinking Funds: The Court reaffirmed that Section 40 of the DVC Act departs from general accounting principles to accommodate DVC’s unique statutory mandate, allowing Sinking Funds to be treated as a first charge/expense deductible before net profits are determined.
  • Relief and Costs Awarded:
    • The impugned review order of the Tribunal was set aside, and the original Tribunal order dated May 17, 2019, was restored.
    • Noting that the review petition was an abuse of process and that the intervenor Public Sector Undertaking (Steel Authority of India Ltd.) ill-advisedly supported a breach of judicial discipline, the Court imposed exemplary costs:
      • 2,00,000 (Rupees Two Lakh) to be paid by the 1st Respondent (Maithan Alloys Limited) to DVC.
      • 1,50,000 (Rupees One Lakh and Fifty Thousand) to be paid by the Steel Authority of India Limited (SAIL) to DVC.
    • Failure to pay within one month will attract an 18% per annum interest rate.

2026 INSC 1178

Damodar Valley Corporation v. Maithan Alloys Limited & Ors. (D.O.J. 30.10.2026)

2026 INSC 1178 click here to view full text of judgment

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Strangers to a Consent Decree: Safeguarding Rights and Access to Appeal Against Fraudulent Compromises

November 2, 2026 No Comments

This appeal arose from a challenge to interim orders and a final judgment passed by the High Court of Gujarat, which condoned an 11-year delay, granted leave to appeal to non-parties (strangers to the suit), and maintained an ad interim injunction. The dispute centered around a 2012 specific performance suit that culminated in a consent decree in 2013, through which the appellant ultimately secured a sale deed in 2022 via a Court Commissioner. The original respondents (heirs/members of a Hindu Undivided Family), alleging fraud and collusion, sought to challenge the consent decree. The Supreme Court dismissed the appellant’s appeals, holding that the statutory bar under Section 96(3) and Order XXIII Rules 3 and 3A of the CPC applies only to parties to a compromise, and that strangers whose independent rights are prejudiced can maintain an appeal with the leave of the court. The Court also upheld the condonation of delay and the interim protection, emphasizing that non-parties cannot be deemed to have prior knowledge of a collusive decree.

  • Background and Procedural Context:
    • A civil suit for specific performance (Civil Suit No. 322 of 2012) was filed by a housing society against the heirs of an original land owner, which rapidly ended in a compromise consent decree on April 29, 2013.
    • Execution proceedings were initiated in 2020, leading to a registered sale deed executed by a Court Commissioner in June 2022 in favour of the appellant, Girishbhai Natwarlal Patel (who had previously acted as a power-of-attorney holder for the defendants in the suit).
    • Respondent Nos. 1 to 9, claiming through a family HUF that held historical revenue interests, discovered the alienation in 2023, filed an appeal with an application for leave to appeal, and secured an ex parte ad interim injunction from the High Court in 2024, which was later confirmed along with an 11-year delay condonation.
  • Maintainability of Appeal by a Stranger to a Consent Decree:
    • The Supreme Court clarified that while Section 96(3) of the CPC and Order XXIII Rule 3A bar parties to a compromise from challenging a consent decree via separate suits or standard appeals, these provisions do not apply to strangers to the decree.
    • Non-parties who assert an independent legal interest that is prejudicially affected by a fraudulent or collusive decree are entitled to seek leave to appeal under Section 96 of the CPC.
  • Principles Governing Leave to Appeal for Non-Parties:
    • Citing precedents such as N. Krishna Murthy, Jatan Kumar Golcha, and H. Anjanappa, the Court reiterated that a stranger cannot file an appeal unless they qualify as an “aggrieved person” whose legal rights or interests are directly jeopardized.
    • The material on record—including the appellant’s dual role under a power of attorney for the defendants while linked to the plaintiff society—disclosed a sufficient prima facie grievance to warrant appellate scrutiny, without foreclosing the final merits.
  • Validity of Condonation of Delay:
    • The 11-year delay was validly condoned because the contesting respondents were not parties to the original suit and could not be imputed with constructive knowledge of the proceedings from the date of the decree.
    • Their explanation regarding discovering the revenue mutation changes in 2023 and acting promptly thereafter justified the exercise of judicial discretion.
  • Supreme Court’s Final Directions:
    • The appeals filed by the appellant were dismissed in entirety.
    • The Supreme Court requested the High Court of Gujarat to expedite the hearing of the main First Appeal and dispose of it within three months.

2026 INSC 1177

Girishbhai Natwarlal Patel v. Gautam Punjabhai Palkhiwala (Dead) by LRs & Ors. (D.O.J. 30.10.2026)

2026 INSC 1177 click here to view full text of judgment

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