Hailing from India’s first heritage village, Justice Sanjay Karol’s remarkable career showcases his passion not just for upholding the Rule of Law, but also for humanitarian causes from time to time. Justice Karol’s career trajectory has been defined by his consistent commitment to principles enshrined in the Constitution and heartfelt respect and pride for the judicial institution.
As he bids farewell to the Supreme Court, we have therefore curated not just the notable judgments rendered by Justice Karol, but also some heart touching anecdotes which reveals his zeal to reach out to the common man and help them.
EARLY LIFE AND EDUCATION
Justice Sanjay Karol was born on 23 August 1961 and hails from village Garli — the first heritage village of India, District Kangra, Himachal Pradesh.1 He completed his schooling from St. Edwards School, Shimla and obtained a bachelor’s degree in History from Government Degree College, Shimla2 and a degree in Law at the Himachal Pradesh University.3
CAREER TRAJECTORY
As an Advocate
Justice Karol enrolled as an advocate in 1986 and practiced across fora at Delhi and other High Courts. He practiced in Constitutional, Taxation, Corporate, Civil and Criminal matters and appeared as Counsel in the Inter-State water Dispute (BBMB Project) in the Supreme Court of India.4 He was appointed Advocate General of the State of Himachal Pradesh in 1998 and served in that capacity till 2003. He was conferred the designation of Senior Advocate in 1999.5
As a Judge
Justice Karol was elevated as a Judge of the Himachal Pradesh High Court on 8 March 20076 and later discharged his duties as Acting Chief Justice of the same High Court from 25 April 2017 to 5 October 2018.
Justice Karol served Himachal Pradesh High Court for a period of eleven and a half years.7 He was also the patron-in-chief of Himachal Pradesh Legal Services Authority and the Chancellor of the Himachal Pradesh National Law University.
He was then appointed as Chief Justice of Tripura High Court on 9 November 20188 and was also the patron-in-chief of Tripura Legal Services Authority. Justice Karol served as Chief Justice of Tripura High Court until his transfer to the Patna High Court9 where he was appointed as Chief Justice on 11 November 2019 and furthermore served as the Chancellor of the Chanakya National Law University.
Justice Sanjay Karol was elevated as Judge of the Supreme Court of India on 6 February 2023.10
Did you Know? When Justice Karol took charge as Chief Justice of Tripura High Court, the number of pending cases was 60,724. Due to Justice Karol’s active and concerted efforts, the figure significantly reduced to 26,834 as on 31 August 2019.11
At Justice Sanjay Karol’s farewell ceremony hosted by the Supreme Court Advocates-on-Record Association (SCAORA), CJI Surya Kant praised Justice Karol for combining constitutional commitment, accessibility, compassion and institutional dignity during his judicial career.
CJI Surya Kant commended Justice Karol for pursuing administrative reform while retaining a human approach to litigation. He further stated that Supreme Court would miss “a judge who lived the Constitution” and insisted that the Constitution is a living document meant to be practiced daily, not just cited.12
In his response, Justice Karol reminded young advocates that law is a profession of service to society, urging them to remain committed to constitutional values and to “live the Constitution.”
“Have you seen the picture Oh My God? The way movies ridicule the judiciary! They say vakalat dukaan hai. Aisa bilkul nahi hai… Be alive. And live the Constitution is all I can say.”13
NOTABLE JUDGMENTS AT SUPREME COURT
Did you Know? During his 3-year tenure in the Supreme Court, Justice Sanjay Karol authored over 240 judgments and was part of over 1000 decisions.14
In a landmark decision, the Division Bench of Sanjay Karol and N. Kotiswar Singh, JJ., while considering the extraordinary delay of two-and-a-half decades in the adjudication of a compensation claim; and the proper valuation of the contribution made by a homemaker to her family and society, recognised Homemakers as “Nation Builders”, and introduced a new compensatory head titled “loss of domestic care” towards the “homemaker’s contribution towards smooth functioning of the household, the loss of maternal support for children and loss of spousal support/the support and care of their child who is an adult, for the parents of the deceased”, fixed at ₹30,000 per month subject to periodic enhancement payable at her death. The Court also issued comprehensive directions to be followed while deciding motor accident claims and enhanced the compensation in the instant case from ₹8,43,400 awarded by the High Court to ₹62,77,900, together with the same interest regime prescribed by the High Court.
[Shishu Pal v. Surjeet, 2026 SCC OnLine SC 1114]
Also Watch: Supreme Court Recognises Homemakers’ Unpaid Work; Creates ‘Loss of Domestic Care’ Compensation Head
While deciding this appeal challenging Orissa High Court’s decision to reduce the compensation amount so determined by the Motor Accidents Claims Tribunal (MACT), the Court had to deliberate that whether to assess the annual income of a deceased person/claimant under the Motor Vehicles Act, 1988 (MV Act), the Income Tax Returns (ITRs) for the previous year is appropriate or average of the past 2/3 years is to be taken into consideration. The Division Bench of Sanjay Karol* and N. Kotiswar Singh, JJ., noting that ITRs being statutory documents, are an important reference point when it comes to assessing one’s income for the purposes of compensation under the MV Act, laid down important guidelines for assessment annual income of salaried persons and self-employed individuals using ITRs in respect of determining the compensation in motor accident claims.
[Rashmirekha Tripathy v. Sriram General Insurance Co. Ltd., 2026 SCC OnLine SC 1256]
In a case originated from a challenge to a conviction and sentence of death confirmed by the Patna High Court, however, during the course of proceedings, the Court’s attention was drawn to a recurring and deeply concerning issue — inordinate delay in filing appeals and special leave petitions (SLPs) in matters involving legal aid, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., issued directions institutionalising reforms in the legal aid system, making timelines binding and directing structural changes to ensure timely filing of appeals and effective access to justice.
[Shankar Mahto v. State of Bihar, 2026 SCC OnLine SC 606]
Introduction of Romeo — Juliet clause to curb misuse in age determination
While considering this appeal concerning nature of the legal duty cast on the police to draw up a medical report determining the age of a victim while investigating POCSO Act offences, the Division Bench of Sanjay Karol* and N. Kotiswar Singh, JJ., held that determination of age of the victim is a matter of trial and not at the stage of bail.
Furthermore, taking note that repeated judicial notice has been taken of the misuse of POCSO Act the Court directed that a copy of the judgment be circulated to the Secretary, Law, Government of India, to consider initiation of steps as may be possible to curb this menace inter alia, the introduction of a Romeo — Juliet clause exempting genuine adolescent relationships from the stronghold of this law; enacting a mechanism enabling the prosecution of those persons who, by the use of these laws seeks to settle scores etc.
[State of U.P. v. Anurudh, 2026 SCC OnLine SC 40]
Not Married, But Still Protected: Supreme Court Extends Section 498-A IPC to Live-In Relationships
In a landmark judgment raising an important question whether Section 498-A, Penal Code, 1860 (IPC) extends to a man in a live-in relationship, while harmonising the principles of strict interpretation of penal statutes with purposive construction of socially beneficial legislation, the Division Bench of Sanjay Karol* and N. Kotiswar Singh, JJ., held that:
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Section 498-A to be applicable to “live-in relationships” that qualify as “relationships in the nature of marriage” with the intent to marry being established as an intrinsic part thereof.
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The protection extends only to relationships between 2 consenting adults.
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The proposition of law as laid down should be limited to Section 498-A IPC only, and this extended interpretation shall not affect any other provision.
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The safeguards against arrest laid down in Arnesh Kumar v. State of Bihar, (2014) 8 SCC 273 shall be strictly followed. No live-in partner or relative should be arrested without the mandated preliminary safeguards.
Accordingly, the Court upheld the Karnataka High Court’s refusal to quash the criminal proceedings with direction that the criminal proceedings should continue before the trial court, and the observations in the judgment shall not influence adjudication on merits.
[Lokesh B.H. v. State of Karnataka, 2026 SCC OnLine SC 1470]
Husband Must Prove Wife’s Adultery “Ex-Facie” to Deny Interim Maintenance: Supreme Court Clarifies Scope of S. 125(4) CrPC
While deciding a case wherein the Court had to consider the husband’s obligation to pay maintenance on account of wife’s adultery, the Division Bench of Sanjay Karol* and Vipul M. Pancholi, JJ., clarified that since the stipulation in Section 125(4), Criminal Procedure Code, 1973 (CrPC) is that if adultery is proved, then the wife would neither be entitled to interim nor final maintenance; therefore, Court opined that if a husband files an application under Section 125(4) CrPC and is, at the first instance, able to establish the charge of adultery through evidence ex facie, then only, there can be said to be a bar to interim maintenance.
[Himanshu Chordia v. State of Rajasthan, 2026 SCC OnLine SC 1461]
Purpose of the trade is irrelevant once UPSI possession and trading are established: Supreme Court
In an appeal filed under Section 15-Z, Securities and Exchange Board of India Act, 19921 (SEBI Act) challenging the judgment and order dated 19 April 2022 passed by the Securities Appellate Tribunal, Mumbai (SAT), whereby the SAT, while allowing the said appeal, quashed and set aside the order dated 24 May 2021 passed by the whole-time member (WTM), SEBI holding the respondents guilty of insider trading under the SEBI Act, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., set aside the SAT’s order holding that where an insider trades in securities while in possession of unpublished price sensitive information (UPSI), Regulation 4(1), SEBI (Prohibition of Insider Trading) Regulations, 2015 (2015 PIT Regulations) creates a presumption that the trade was motivated by the UPSI. Once possession of UPSI and trading during its currency are established, the reasons for undertaking the trade or the purposes to which the sale proceeds are applied are not relevant for determining insider trading. The Court further held that the defences specifically enumerated in Regulation 4(1) are not exhaustive, but any additional defence must be of the same or similar nature as those expressly provided.
[SEBI v. Rajeev Vasant Sheth, 2026 SCC OnLine SC 1539]
The appeals arose from Karnataka High Court judgments awarding compensation to victims of electrocution, with the High Court treating the liability as absolute and adopting the multiplier method under the Motor Vehicles Act, 1988 (MV Act) for quantifying compensation. While examining the maintainability of writ petitions under Article 226, Constitution of India in cases of electrocution and clarifies the nature of liability imposed on electricity authorities, the Division Bench of Sanjay Karol* and N. Kotiswar Singh, JJ., held that an electrocution claim against a State electricity authority attracts strict liability, not absolute liability. Further, where material facts are disputed, the appropriate remedy ordinarily lies before the competent adjudicatory forum and not before High Court under Article 226 of the Constitution. The Court clarified that compensation in electrocution cases must be assessed on the basis of “just and reasonable, fair compensation”, rather than by mechanically applying the multiplier method prescribed under the MV Act.
However, the Court found that the present cases involved substantial disputed questions of fact, making the writ jurisdiction inappropriate. Accordingly, the Court allowed both appeals, quashed and set aside the judgments of the Single Judge and Division Bench of the Karnataka High Court, holding that the writ petitions seeking compensation were not maintainable because of the disputed questions of fact.
[Karnataka Power Transmission Corpn. Ltd. v. Rekha, 2026 SCC OnLine SC 1545]
In a matter concerning the integrity of the electoral process and the prevention, investigation and prosecution of election-related offences, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ. emphasised the need to safeguard free and fair elections and issued a series of directions aimed at curbing the use of black money and other inducements in elections. The Court, inter alia, held that:
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Free and fair elections are fundamental to the functioning of constitutional democracy, and the use of black money and electoral inducements can seriously undermine that process.
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Article 324 confers wide powers upon the Election Commission to preserve the integrity of elections, particularly in areas not occupied by legislation, but such powers must operate within the constitutional and statutory framework.
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Seizure of cash or other valuables during elections must be accompanied by adequate procedural safeguards, including recording of written reasons establishing a prima facie nexus with a suspected electoral offence.
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Election-related criminal investigations should be pursued expeditiously, with an endeavour to complete investigation within 1 year and periodic reporting to the Election Commission.
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Election-related prosecutions should, as far as possible, be brought to their logical conclusion before the next election cycle, and High Courts may designate appropriate courts for expeditious disposal.
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Criminal cases relating to candidates in a particular election cycle cannot be withdrawn merely as a consequence of a change in political government. Withdrawal requires judicial scrutiny, and approval of the High Court concerned is mandatory.
[State of Karnataka v. Prathik Parasrampuria, 2026 SCC OnLine SC 1587]
While considering an appeal against the Punjab and Haryana High Court’s decision relegating the claimants to a civil suit in a compensation claim arising from a fatal stray bull attack, a Division Bench comprising of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., held that after the efflux of nearly 2 decades, directing the claimants to pursue a civil remedy would leave them “remediless”, rendering such a course unjust, unfair and inequitable.
Observing that bovine-related accidents are “not few and far between”, the Court awarded a lump sum compensation of ₹15 lakhs to the appellant, while issuing a series of recommendations to the Union and State Governments for the implementation of cattle laws, development of a compensation mechanism for bovine-related accidents, mandatory tagging of animals, and strengthening of animal shelter management to safeguard both human lives and animal welfare. Citing government data, the Court noted that animal attacks killed 1,130 persons across India in 2018, 1,425 in 2019, and 1,305 in 2020.
[Nisha v. Municipal Council Sangrur, 2026 SCC OnLine SC 1464]
In a civil appeal arising from a challenge to a compromise decree passed in a partition suit nearly three decades earlier, a Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., dismissed the appeal and upheld the orders of the Trial Court and the Patna High Court setting aside the compromise decree. The Court held that a compromise under Order 23 Rule 3, Civil Procedure Code, 1908 (CPC) must be in writing and signed by the parties or by a duly authorised representative acting with express authorisation or under exigent circumstances, and that a counsel cannot act merely on implied authority to bind a party to a compromise affecting valuable property rights. Accordingly, the Court affirmed the setting aside of the compromise decree and directed that the partition suit be decided through a full-fledged trial on merits.
[Krishna Kumar Ojha v. Jitendra Chaudhary, 2026 SCC OnLine SC 1255]
The appeal challenged the Gujarat High Court’s order refusing to quash proceeding and Chief Judicial Magistrate’s summoning order dated 8 November 2017, arising from a complaint alleging that the appellant had failed to disclose the full extent of landed property owned by herself and her spouse while contesting for the post of Councillor, while holding that the disclosure obligation extended to the spouse’s independently owned assets, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., found that the Representation of the People Act, 1951 (RP Act) did not govern municipal elections. The Court nevertheless treated the erroneous cognizance taken by the Magistrate under the RP Act as a curable irregularity and remanded the matter for fresh cognizance under the appropriate law, without deciding the merits of the allegations.
[Chandrikaben Kishor Dafda v. State of Gujarat, 2026 SCC OnLine SC 1252]
In an appeal challenging the setting aside of conviction and sentence under Section 376 IPC and other provisions of the SC/ST Act, on ground of inconsistencies in the prosecution’s story, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., stated that a truthful witness may make honest mistakes or omit immaterial details, and such normal variation should not result in wholesale rejection of evidence. However, when omissions or contradictions relate to material facts that form the foundation of the prosecution version, they assume significance and may create reasonable doubt. The Court reiterated that minor or trivial inconsistencies or discrepancies in the testimony of witnesses do not by themselves make the evidence unreliable.
“When it comes to inconsistencies and omissions in testimonies, which is one of the primary grounds on which the reasoning of the High Court rests, it is well recognised that human perception, memory and narration are imperfect.”
[State of H.P. v. Hukum Chand, 2026 SCC OnLine SC 462]
During the course of the hearing in a pending civil appeal, the Court’s attention was drawn to the provisions of the Muslim Personal Law (Shariat) Application Act, 1937, particularly Section 4 and the absence of compliance with the said provision. A Division Bench of Sanjay Karol and Augustine George Masih, JJ., impleaded the Union of India through the Secretary, Department of Legislation, and the State of Uttar Pradesh through its Chief Secretary as party respondents and issued notice, so that the appropriate governmental authorities before it could clarify the position regarding compliance.
The Court directed the newly added respondents to file an affidavit indicating the latest status in the meantime. The Court requested the parties to file a convenience compilation within one week. The matter to be listed on 18 February 2026.
[Gohar Sultan v. Sheikh Anis Ahmad, 2026 SCC OnLine SC 246]
In a significant ruling on the rights of government employees, the Supreme Court has held that Dearness Allowance (DA) is a statutory and enforceable right, and not a discretionary benefit that a State can withhold citing financial constraints. The Bench of Sanjay Karol* and Prashant Kumar Mishra, JJ., made it clear that once Dearness Allowance becomes payable under the governing rules, the State is legally bound to release it, observing that denial of such dues directly impacts employees’ right to life and livelihood under Article 21 of the Constitution.
[State of W.B. v. Confederation of State Government Employees, 2026 SCC OnLine SC 155]
In a significant ruling on the proof of customary law governing Oraon tribal succession, the Division Bench of Sanjay Karol* and N.K. Singh, JJ. held that an uncle-in-law cannot induct his niece’s husband as a ghardamad (resident son-in-law) under the recognised customary law of the Oraon tribal community to confer inheritance rights over ancestral property. The Court reiterated that the party relying upon a custom bears the burden of proving its existence, antiquity, certainty, and continuous observance, and that courts cannot recognise or enforce an unproved custom. Accordingly, finding that the respondents had failed to establish the alleged custom, the Court set aside the concurrent judgments of the trial court, the First Appellate Court, and the Jharkhand High Court, and allowed the appeal.
[Bejla Oraon v. Kali Das Oraon, 2026 SCC OnLine SC 1302]
In an appeal, revolving around long-standing question of whether the preferential right conferred upon Class I heirs under Section 22, Hindu Succession Act, 1956 (Hindu Succession Act) extends to inherited agricultural land, wherein the First Appellate Court upheld the plaintiff’s preferential right and the High Court affirmed the First Appellate Court’s judgment, the Division Bench of Sanjay Karol* and N. Kotiswar Singh**, JJ., upheld the impugned judgments, holding that:
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Section 22, Hindu Succession Act applies to inherited agricultural land.
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Babu Ram v. Santokh Singh, (2019) 14 SCC 162, correctly states the law and does not require reconsideration by a larger Bench.
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Atam Prakash v. State of Haryana, (1986) 2 SCC 249, does not invalidate Section 22, Hindu Succession Act.
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Parliament possessed legislative competence under Entry 5, List III to enact Section 22.
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Since the plaintiff asserted his preferential right before execution of the sale deed, no separate challenge to the sale deed was necessary.
[Mahinder v. Puran Singh, 2026 SCC OnLine SC 1335]
In a civil appeal arising out of special leave petition (SLP) concerning compensation under the Motor Vehicles Act, 1988 (Motor Vehicles Act) where the deceased, who had last travelled in the appellant’s car, was later found murdered, the Division Bench of Sanjay Karol* and Augustine George Masih, JJ., set aside the impugned judgments of the Motor Accident Claims Tribunal (Tribunal) awarding compensation and High Court affirming the same, holding that deceased’s death did not arise out of the use of the motor vehicle within the meaning of the Motor Vehicles Act. Consequently, neither the owner nor the insurer incurred liability to pay compensation under the Act.
The Court held that a claim under Sections 165 and 166, Motor Vehicles Act is maintainable only where the claimant establishes a causal nexus between the injury or death and the use of the motor vehicle. Although the expression “arising out of” receives a broad interpretation and compensation proceedings are governed by the standard of preponderance of probabilities, the existence of “some link whatsoever between the car, and the death has to be established”. Mere presence or involvement of a vehicle in the chain of circumstances, without evidence linking the use of the vehicle to the injury, is insufficient to attract statutory liability under the Act.
[Dilip Agarwal v. Rajshri Agarwal, 2026 SCC OnLine SC 1374]
While examining the constitutional limits of the powers vested in the National Commission for Scheduled Castes (NCSC) under Article 338 of the Constitution in terms of adjudicating service disputes concerning deprivation of the Scheduled Castes’ rights and issuing binding directions, the Division Bench of Sanjay Karol* and Augustine George Masih, JJ., held that although the NCSC and similar constitutional commissions under Articles 338-A and 338-B perform a socially beneficial function, “the Legislature has prescribed a role that is recommendatory and advisory, but certainly not adjudicatory”. while NCSC has powers to requisition documents and receive evidence, but it does not have the power to make an order in furtherance of that evidence. Thus, NCSC does not possess adjudicatory authority to issue binding directions in service matters.
Consequently, the Court set aside the Bombay High Court’s judgment and declared NCSC’s direction requiring the appellant, Mumbai Port Authority, to pay arrears within 30 days was contrary to the Constitution and non est in law.
[Mumbai Port Authority v. National Commission for Scheduled Castes, 2026 SCC OnLine SC 1398]
While determining an important question in an appeal, whether the appellant’s application for grant of remission to the State of Haryana would be governed by the “Policy Regarding Release of Life Convicts 2002” (2002 Policy) dated 12 April 2002 or the subsequent Policy, “Premature Release of Life Convicts 2008” (2008 Policy) dated 13 August 2008 notified by the Jails and Judicial Department, Government of Haryana, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., held that the appellant’s remission claim must be considered under the 2002 Policy, not under the later 2008 Policy. The Court held that a remission policy that is substantively framed for the exercise of the Governor’s power under Article 161 of the Constitution retains its constitutional character even if issued in the form of a government memorandum. A later remission policy framed under Sections 432 and 433, Criminal Procedure Code, 1973 (CrPC) cannot override, supersede or nullify that constitutional policy.
[Parveen Kumar v. State of Haryana, 2026 SCC OnLine SC 1250]
Supreme Court: In an appeal while examining the scope of the doctrine of proportionality in sentencing while considering whether imprisonment for the remainder of the convict’s natural life under Section 376-D, Penal Code, 1860 was justified, the Division Bench of Sanjay Karol* and Augustine George Masih, JJ., affirmed the conviction of the appellant under Section 376-D IPC, but modified the sentence from imprisonment for the remainder of natural life to rigorous imprisonment for 20 years with benefit of remission, if otherwise admissible in law, holding that while the statute mandates at least the minimum punishment, it does not require that every conviction must necessarily result in imprisonment for the remainder of natural life. Sentencing must conform to the doctrine of proportionality, thereby, “striking a judicious balance between the interest of the victim, society and the accused, after following the due process of law”.
[Ehsaan v. State (NCT of Delhi), 2026 SCC OnLine SC 1356]
In an appeal filed by the wife of a deceased train passenger, challenging the concurrent dismissal of her compensation claim by the Railway Claims Tribunal, Bhopal Bench, and the Madhya Pradesh High Court, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ. allowed the appeal, holding that compensation under Section 124-A, Railways Act, 1989 cannot be denied merely because the deceased’s railway ticket was not recovered after an untoward incident. The Court reiterated that the provision embodies a no-fault liability regime and is intended to provide expeditious relief to victims and their dependants. It held that while the claimant must initially establish the foundational facts of the journey and occurrence of the incident, such burden can be discharged through relevant evidence, including an affidavit, after which the burden shifts to the Railways to rebut the claim. The Court emphasised that a technical approach cannot defeat the beneficial purpose of the legislation and that the absence of a ticket on the deceased’s person, particularly where the ticket may have been lost along with belongings during the accident, is not by itself sufficient to deny compensation.
[Lata v. Union of India, 2026 SCC OnLine SC 1350]
While deciding an appeal arising from the rejection of a claim for shortage of goods during railway transit, a Division Bench of Sanjay Karol* and Vipul M. Pancholi, JJ., held that where goods are booked at “owner’s risk”, liability of the Railway Authorities can be fastened only upon proof of negligence or misconduct under Section 97, Railways Act, 1989. The Court observed that in cases where the consignment is not verified by Railway employees, the burden of proving the quantity of goods lies upon the consignor, consignee or endorsee under Section 65(2) of the Act. Finding that the goods were loaded without railway supervision, the sender’s weight was accepted, and the railway receipt contained a “said to contain” endorsement, the Court held that the appellant failed to establish negligence on the part of the Railways and dismissed the appeal.
[Bajaj Trading Co. v. Union of India, 2026 SCC OnLine SC 1343]
While deliberating over this case, the Court had to decide whether money received as mediclaim, in terms of a mediclaim policy, is deductible from an award passed by a Motor Accident Claims Tribunal (MACT) or not. The Division Bench of Sanjay Karol* and Vipul M. Pancholi, JJ., after taking a serious note of considerable number of contrary High Court opinions on the issue, clarified that amount received as part of mediclaim/medical insurance is not deductible from compensation as calculated by the MACT adjudicating a claim for compensation under the Motor Vehicle Act, 1988 (MVA), which may also include compensation under the head of medical expenses, if claimed.
“Till such times the opposing views exist, judicial uncertainty is in play for settled precedents ensure definitive outcomes but if contrary views exist, it becomes a matter of choice to follow one and leave aside the other, and it remains no longer, a matter of law.”
[New India Assurance Co. Ltd. v. Dolly Satish Gandhi, 2026 SCC OnLine SC 861]
While presenting a disturbing instance of prolonged investigative delay where a criminal complaint lodged in 2007 remained unresolved even after nearly 2 decades and challenging High Court’s order refusing to issue directions for filing of a charge-sheet despite repeated orders of the Magistrate and despite the complainant’s persistent efforts to secure completion of investigation, the Division Bench of Sanjay Karol* and Augustine George Masih, JJ., reaffirmed that “the right to speedy trial is intrinsically linked to Article 21 of the Constitution” and held that the High Court erred in not taking the note of the inordinate delay in filing of the chargesheet and intervening in the matter.
[Sahil Abdulsattar Mansuri v. Safimahamad Fafirbhai Mansuri, 2026 SCC OnLine SC 1073]
In an appeal, arising out of a decades-long family property dispute concerning agricultural land and the applicability of the doctrine of constructive res judicata under Section 11, Civil Procedure Code, 1908 (CPC), a Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., held that the appellant’s suit seeking declaration of title and possession could not be barred by constructive res judicata merely because such relief had not been claimed in earlier proceedings challenging specific sale deeds executed by a general power-of-attorney holder. Observing that the appellant’s title under a 1960 transfer deed had remained undisputed until subsequent mutation proceedings threatened his rights, the Court held that there was no occasion for him to assert title over the larger parcel of land in the earlier suits. Emphasising that the application of constructive res judicata depends on the facts of each case and should not result in harsh or inequitable consequences, the Court set aside the High Court’s judgment and allowed the appeal.
[Makardhwaj Ram v. Jagdish Rai, 2026 SCC OnLine SC 1112]
In an appeal concerning the limitation applicable to proceedings for revocation of probate under Section 263, Succession Act, 1925, a Division Bench of Sanjay Karol* and Vipul M. Pancholi, JJ., held that an application seeking revocation of probate is governed by Article 137, Limitation Act, 1963 and must be filed within 3 years from the date on which the right to apply accrues. Rejecting the respondents’ plea that they acquired knowledge of the probate only in 2019, the Court held that the notice served upon them in mutation proceedings in 2013 constituted constructive notice, and their failure to inquire into the basis of the appellant’s claim amounted to wilful abstention. Observing that such conduct could not be attributed to a reasonably prudent person, the Court concluded that the application for revocation filed in 2022 was hopelessly time-barred. Accordingly, the Court set aside the judgment of the Division Bench and restored the Single Judge’s order dismissing the revocation application on the ground of limitation.
[Dhiraj Dutta v. Anirban Sen, 2026 SCC OnLine SC 996]
In an appeal challenging the concurrent decisions of the District Judge, Darjeeling and the Calcutta High Court, which had refused permission to the appellant-mother to dispose of minor’s inherited immovable property pursuant to a development agreement under Section 8, Hindu Minority and Guardianship Act, 1956 (the Act), the Division Bench of Sanjay Karol* and N. Kotiswar Singh, JJ., allowed the appeal and granted the appellant the necessary permission to give effect to and realise the development agreement, holding that where a development agreement converts an undivided and comparatively unproductive interest in land into tangible residential accommodation and secure monetary benefits that are demonstrably beneficial to the child, permission ought to be granted subject to adequate safeguards. The Court further held that court exercising jurisdiction under Section 8 of the Act must independently determine whether a proposed transaction involving a minor’s immovable property is necessary or evidently advantageous to the minor. The guardian’s consent cannot substitute judicial scrutiny.
[Shephali Chakraborty v. State of W.B., 2026 SCC OnLine SC 1064]
In an appeal raising an important question concerning the scope of compensation claims under the Motor Vehicles Act, 1988 (the Act) as to whether appellant, Bruhat Bangalore Mahanagara Palike (BBMP), could be saddled with liability, for grievous injuries suffered by the claimant when a branch of a roadside tree fell upon an autorickshaw in which he was travelling, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., held that falling of a tree branch during heavy rain may constitute an unforeseen natural occurrence beyond the contemplation of authorities, however, it does not by itself, constitute an accident “arising out of the use of a motor vehicle” within the meaning of Sections 165 and 166 of the Act, especially when the vehicle plays no active or proximate role in causing the injury and its presence is merely incidental. Therefore, the Court held that, in such circumstances, fastening liability upon the appellant under the Act would be unfair. Nevertheless, taking note of the claimant’s life-altering injuries, including permanent paraplegia, and invoking its extraordinary powers under Article 142 of the Constitution, the Court enhanced the compensation to ₹ 25 lakhs and directed its payment in the interest of complete and humane justice.
[Bruhat Bangalore Mahanagara Palike v. K.K. Umesh Kumar, 2026 SCC OnLine SC 1111]
Supreme Court cancels businessman Satinder Singh Bhasin’s bail in Grand Venice scam case
In batch of applications filed by allottees of the ‘Grand Venice’ project, seeking cancellation of bail granted to the petitioner (Director of Bhasin Infotech and Infrastructure Pvt. Ltd. (BIIPL)), in connection with FIRs alleging non-delivery of units, siphoning of funds collected from investors, and irregularities in allotment of land allegedly in collusion with public officials, on the ground of violations of certain bail conditions imposed upon him, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., cancelled the bail granted to the petitioner and instructed him to surrender within 1 week from the date of this judgment.
[Satinder Singh Bhasin v. State (NCT of Delhi), 2026 SCC OnLine SC 521]
In an appeal arising from Madras High Court’s judgment dated 3 February 2023, dismissing a civil revision petition filed by the appellant challenging an arbitral award on the ground that appropriate remedy lays under the Arbitration and Conciliation Act, 1996 (Arbitration and Conciliation Act) and not under Article 227 of the Constitution of India, the Division Bench of Sanjay Karol* and Vipul M. Pancholi, JJ., affirmed the impugned order, holding that the appropriate relief for a legal representative to challenge an arbitral award was under Section 34, Arbitration and Conciliation Act and not under Article 227 or Section 115, Civil Procedure Code, 1908 (CPC). The Court also reaffirmed that the Arbitration Act is a self-contained code and that judicial interference outside its framework is permissible only in exceptional circumstances.
[V.K. John v. S. Mukanchand Bothra, 2026 SCC OnLine SC 640,]
In an appeal raising short but significant issue as to whether use of the word “can” in an arbitration clause in the contract, necessitate the reference of all disputes to arbitration or recourse to other dispute resolution mechanisms, including that of the civil court, open for the parties, the Division Bench of Sanjay Karol* and Nongmeikapam Kotiswar Singh, JJ., dismissed the appeal, holding that use of expression “can” in Clause 25 of the arbitration agreement indicates merely the future possibility of referring disputes to arbitration and as such, it cannot be said to be a binding arbitration agreement. The Court further held that such an agreement can only come into existence when both parties agree to the same.
[NagreeKa Indcon Products (P) Ltd. v. Cargocare Logistics (India) (P) Ltd., 2026 SCC OnLine SC 630]
Bail Order of Wrestler Sushil Kumar in Sagar Dhankhar murder case set aside
In a criminal appeal filed against the order passed by Delhi High Court, wherein, the High Court granted bail to Olympian Wrestler Sushil Kumar’s (accused) in the Sagar Dhankhar murder case, the Division Bench of Sanjay Karol* and Prashant Kumar Mishra, JJ. viewed that the High Court had erroneously passed an order releasing the accused on bail. Thus, the Court set aside the impugned order passed by the High Court and directed the accused to surrender before the court concerned within one week.
[Ashok Dhankad v. State (NCT of Delhi), 2025 SCC OnLine SC 1690]
In the present case, the appellant-convict suspected infidelity of his wife and that his three children were not his own, brutally assaulted them, which resulted in their death. The 3-Judges Bench of Vikram Nath, Sanjay Karol*, and Sandeep Mehta, JJ., while affirming the findings of the Courts below regarding the appellant’s conviction for the barbaric and ruthless murders of his family members, opined that the High Court, despite having considerable information, did not consider it appropriately and sufficiently, in relation to the findings of report that detailed the appellant’s social and psychological backdrop. The Court, after considering the total circumstances that drove the appellant to the point of committing the crime of a most reprehensible nature, opined that death penalty might not be appropriate and thus, party allowed the appeals to the extent that he was released from death row, and held that he should await his last breath in prison, without remission.
[Byluru Thippaiah v. State of Karnataka, 2025 SCC OnLine SC 1455]
While considering an appeal wherein the Court had to deliberate that whether a tribal woman (or her legal heirs) would be entitled to an equal share in her ancestral property or not; the Division Bench of Sanjay Karol* and Joymalya Bagchi, JJ., opined that, unless otherwise prescribed in law, denying the female heir a right in the property only exacerbates gender discrimination, which the law should ensure to weed out. Therefore, in keeping with the principles of justice, equity and good conscience, read along with the overarching effect of Article 14 of the Constitution, the Court held that in the instant case, since the Plaintiffs were D’s (Tribal woman heir) legal heirs, they are entitled to their equal share in the property of their maternal grandfather.
[Ram Charan v. Sukhram, 2025 SCC OnLine SC 1465]
While considering the instant appeal challenging conviction and sentence of death penalty to the appellant (convict) which was affirmed by Madras High Court via the impugned judgment; the 3 Judges Bench of Vikram Nath, Sanjay Karol* and Sandeep Mehta, JJ., emphasised need of a legislative framework to compensate accused persons who have been suffering long incarcerations only for them to be cleanly acquitted. The Court further took strict note of the faulty investigation and especially the treatment of the DNA evidence in ways that rendered the samples useless for the purposes of the case. Hence, the Court issued the guidelines which must be followed in all cases where DNA Evidence is involved.
[Kattavellai v. State of T.N., 2025 SCC OnLine SC 1439]
The Division Bench of Sanjay Karol* and Prashant Kumar Mishra, JJ. held that the fundamental right guaranteed under Article 19(1)(g) of the Constitution, the right to practise any profession or to carry on any occupation, trade or business, includes the right not to carry it on as well, thereby extending constitutional protection to decisions of voluntary closure by businesses. Read more
[Harinagar Sugar Mills Ltd. v. State of Maharashtra, 2025 SCC Online SC 1303]
In a batch of civil appeals by the dependents of the deceased against the Madhya Pradesh High Court’s decision, seeking enhanced amount of compensation under the Motor Vehicles Act, 1988 on account of death of 24-year-old deceased, the Division Bench of Sanjay Karol and Prashant Kumar Mishra, JJ. allowed the appeal and modified the amount from Rs.9,77,200/- to Rs. 17,52,500/-. Placing reliance upon N. Jayasree v. Cholamandalam MS General Insurance Company Ltd., (2022) 14 SCC 712, wherein, it was said that the term “legal representative” should be given a wider interpretation for the purpose of Chapter XII of the MV Act and it should not be confined only to mean the spouse, parents and children of the deceased, the Court held that the father and younger sister of the deceased, both not financially independent, were falling under the definition of legal representatives to claim the compensation under the Motor Vehicles Act, 1988, and they were considered as dependents upon the income of the deceased, as he was doing wholesale business of selling fruits to meet the day-to-day expenses of the family.
[Sadhana Tomar v. Ashok Kushwaha, 2025 SCC OnLine SC 554]
Application of force must be with the intent to outrage modesty of woman: SC
In a criminal appeal assailing the Allahabad High Court’s judgment, whereby the accused person’s application under Section 482 of the Code of Criminal Procedure, 1973 (‘CrPC’) to quash the chargesheet and proceedings for an offence under Section 354 and 506 of the Penal Code, 1860 (‘IPC’) was allowed, the Division Bench of CT Ravikumar and Sanjay Karol*, JJ. held that the sum total of the circumstances, submissions and documents on record, did not point to the committal of any offence against the complainant. Hence, the Court set aside the impugned judgement of the High Court of Judicature and resultantly, the criminal proceedings arising out of FIR were also quashed qua the present accused person.
[Naresh Aneja v. State of U.P., (2025) 2 SCC 604]
In a criminal appeal against a decision of the Madras High Court, wherein, the accused person’s application under Section 482 of the Code of Criminal Procedure, 1973 for quashing the chargesheet/ final report and proceedings pending before the Special Court for Protection of Children from Sexual Offences Act, 2012 (‘POCSO’) was dealt with and the High Court while acquitting him of all the charges due to lack of evidence, directed to transfer all the relevant documents to CBI for re-investigation, the Division Bench of CT Ravikumar and Sanjay Karol*, JJ. held that the High Court’s decision was bad in law and therefore quashed and set aside. Acquitting the accused of all the charges, the Bench quashed all the proceedings subsequent to such direction.
[P. Manikandan v. CBI, 2024 SCC OnLine SC 3808]
In a special leave petition criminal challenging the Patna High Court’s order staying the investigation in a case wherein, the accused persons were accused of subjecting a female to allegations of witchcraft and also disrobing her, the Division Bench of CT Ravikumar and Sanjay Karol*, JJ. was aghast over the High Court’s order and directed the Trial Court concerned to take the matter on day to day basis. The Court observed-
“Dignity goes to the very core of the existence of an individual in society. Any action which undermines dignity either by an act of another person or that of the State is potentially going against the spirit of the Constitution of India, which guarantees the security of all persons by ensuring that justice, liberty and equality are avouched for each and every person. By extension, if the dignity of a person is compromised, their human rights, available to them by virtue of them being humans and guaranteed by various enactments, both national and international, are imperilled.”
[Rajeev Kumar Upadhyay v. Srikant Upadhyay, 2024 SCC OnLine SC 3807]
In a civil appeal against a decision of the Andhra Pradesh High Court dismissing an appeal under Section 96 of the Civil Procedure Code, 1908 (‘CPC’) and Cross Objections filed under Order XLI Rule 22 respectively, against a judgment and decree pertaining to a property dispute in favour of the respondents, the Division Bench of C.T. Ravikumar and Sanjay Karol*, JJ. dealt with the issue that whether the present appellant/ original defendants were entitled to the entire property, in line with the position that their mother, by virtue of the Hindu Succession Act, 1956, would have absolute rights over the subject property and, therefore, be able to bequeath the same by way of Will to her successors. The Bench dismissing the appeal, clarified that the partition deed of 1933 clears that 3.55 Cents of land would be enjoyed by appellants’ mother as a life interest and thereafter would devolve upon the two lines of succession. The absolute rights extended only to 2.09 Cents of land, as per the partition deed of 1933.
[Kallakuri Pattabhiramaswamy v. Kallakuri Kamaraju, 2024 SCC OnLine SC 3379]
Aadhar not proof of date of birth; SC affirms age determination using School Leaving Certificate
While deciding the instant appeal wherein the appellants were aggrieved by Punjab and Haryana High Court’s decision to reduce compensation awarded to them by the Motor Accidents Claim Tribunal (MACT) and applying the date of birth as stated in the deceased person’s Aadhar card to determine the applicable multiplier; the Division Bench of Sanjay Karol* and Ujjal Bhuyan, JJ., took judicial notice of the Circular No.08 of 2023 issued by Unique Identification Authority of India, wherein it was stated that an Aadhar Card, while can be used to establish identity, it is not per se proof of date of birth. Hence, the Court found no error with MACT’s method of age determination of the deceased person, based on his School Leaving Certificate.
[Saroj v. Iffco-Tokio General Insurance Co., 2024 SCC OnLine SC 3038]
While considering the instant appeal challenging the order passed by Telangana High Court, refusing to quash proceedings under Section 406 of Penal Code, 1860 and Section 6 of the Dowry Prohibition Act, 1961; the Division Bench of J.K Maheshwari and Sanjay Karol*, JJ., pointed out that the position of law has remained consistent throughout since 1985, till date, regarding the sole authority of the woman in respect of her ‘stridhan’ as has also been held recently in Mala Kar v. State of Uttarakhand, 2024 SCC OnLine SC 1049. The jurisprudence as has been developed by the Supreme Court, is unequivocal with respect to the singular right of the female (wife or former wife), being the sole owner of ‘stridhan’ with husband having no right over it. The Court further concluded that a father too, has no right when the daughter is alive, well, and entirely capable of making decisions such as pursuing the cause of the recovery of her ‘stridhan’.
[Mulakala Malleshwara Rao v. State of Telangana, 2024 SCC OnLine SC 2285]
Deciding the issues relating to the stage for challenging the validity of sanction under the Unlawful Activities (Prevention) Act, 1967 (‘UAPA’), the Division Bench of CT Ravikumar and Sanjay Karol*, JJ held that the validity of sanction should be challenged at the earliest instance available, before the Trial Court. The Court further explained that if such a challenge is raised at an appellate stage it would be for the person raising the challenge to justify the reasons for bringing the same at a belated stage. Such reasons would have to be considered independently so as to ensure that there is no misuse of the right of challenge with the aim to stall or delay proceedings. The Court also held that the timelines mentioned in Rules 3 & 4 of the Unlawful Activities (Prevention) (Recommendation & Sanction of Prosecution) Rules, 2008 (‘2008 Rules’) are couched in mandatory language and, therefore, have to be strictly followed. The Court, however, clarified that the observations made in this judgment shall apply prospectively.
[Fuleshwar Gope v. Union of India, 2024 SCC OnLine SC 2610]
Involuntary or forced narco-analysis test impermissible: SC
In a criminal appeal against Patna High Court’s decision, which had allowed narco-analysis testing of accused persons during an ongoing criminal investigation, the Division Bench of Sanjay Karol* and Prasanna B. Varale, JJ. held that compelling an accused to undergo such a test without free consent violates their fundamental rights under Articles 20(3) and 21 of the Constitution. Reaffirming its decision in Selvi v. State of Karnataka, (2010) 7 SCC 263, the Court reiterated that involuntary administration of narco-analysis tests is unconstitutional and any information obtained therefrom cannot be used as evidence.
[Amlesh Kumar v. State of Bihar, 2025 SCC OnLine SC 1326]
In a criminal appeal filed by the convict against the impugned judgment passed by the Chhattisgarh High Court, wherein the Court convicted the accused under Section 302 of Penal Code, 1860 (‘IPC’), the division bench of Abhay S. Oka and Sanjay Karol*, JJ., while setting aside the impugned judgment, observed that the High Court has confirmed the view of the Trial Court awarding life imprisonment without supplying any cogent reasons. Further, acquitted the convict of all charges and set her at liberty. Further, it said that although there is a requirement by law to disclose the aspects required to adjudicate in a criminal matter, such duty cannot unreasonably and unwarrantedly step over the fundamental right of privacy.
[Indrakunwar v. State of Chhattisgarh, 2023 SCC OnLine SC 1364]
Silence of minor victim in a sexual assault case cannot accrue benefit to the accused: Supreme Court
In a criminal appeal filed by the respondent against the Rajasthan High Court’s finding of acquittal in a case concerning the sexual assault of a minor girl, the Division Bench of Vikram Nath and Sanjay Karol*, JJ., allowed the appeal and set aside the judgment of acquittal passed by the Rajasthan High Court which had reversed the Trial Court’s conviction of the accused.
“Trauma has engulfed her in silence. It would be unfair to burden her young shoulders with the weight of the entire prosecution. A child traumatized at a tender age by this ghastly imposition upon her has to be relieved of being the basis on which her offender can be put behind bars. In almost all other cases, the testimony of the prosecutrix is present and forms an essential part of the conviction of an accused, but at the same time, there is no hard and fast rule that in the absence of such a statement a conviction cannot stand, particularly when other evidence, medical and circumstantial, is available pointing to such a conclusion.”
[State of Rajasthan v. Chatra, 2025 SCC OnLine SC 566]
Every document pertaining to election is important and efforts should be made to preserve the same: SC
In a civil appeal filed against the order of the Allahabad High Court, by which the High Court had set aside the order of the Election Tribunal for re-counting of votes, the Division Bench of Sanjay Karol* and N. Kotiswar Singh, JJ. held that the order for re-counting of votes was not illegal, since three out of four candidates had questioned the veracity of the election and important documents were missing and their absence was unexplained. The Court held that the sanctity of each vote has to be protected and if the presiding officers’ records are missing and cannot be verified, the final election outcome is questionable. The Court found that a re-count was justified.
[Vijay Bahadur v. Sunil Kumar, (2025) 4 SCC 180]
Death sentence commuted to life imprisonment for man accused of murdering his own children
In criminal appeals filed by the appellant challenging the judgment of the Karnataka High Court which had confirmed his conviction and death sentence for murder of his own two children, the Division Bench of Vikram Nath, Sanjay Karol*, and Sandeep Mehta, JJ., noting that the accused had no criminal antecedent, had good relations with the deceased and all mitigating circumstances were not considered, commuted the death sentence of the accused to imprisonment for life.
[Ramesh A. Naika v. Registrar General, 2025 SCC OnLine SC 575]
In a plea against approval by the Genetic Engineering Appraisal Committee’s (‘GEAC’) for environmental release of Dhara Mustard Hybrid-11 (DMH-11) mustard, the Division Bench of B.V Nagarathna and Sanjay Karol, JJ. delivered split verdict. Justice Nagarathna* quashed the approval given by the GEAC and the Ministry of Environment Forests and Climate Change (‘MoEFCC’), whereas Justice Sanjay Karol* upheld the approval to the genetically mutated mustard. Justice Karol held that the decision of the GEAC to grant conditional approval was not vitiated by non-application of mind, or any other principle of law, on part of the body, which itself is an expert body. National Policy on GM crops was unanimously called for directing the Union of India to evolve a National Policy on GM crops in the realm of research, cultivation, trade and commerce in the country, in consultation with all stakeholders, such as, experts in the field of agriculture, biotechnology, State Governments, representatives of the farmers, etc.
[Gene Campaign v. Union of India, 2024 SCC OnLine SC 1793]
SC on Non-recording of a disclosure statement in language known to accused
The three Judge Bench of B.R. Gavai, Vikram Nath and Sanjay Karol*, JJ. while considering seminal issues relating to non-recording of a disclosure statement in same language known to accused and DNA evidence, set aside the conviction death sentence for offence under Sections 302, 376, 377 and 201 IPC upon noting that the statutory safeguards in reference to language were not complied with, causing prejudice to the appellant in terms of authority wherein it was laid down that the accused in a particular case was not acquainted with the English language and if by reason of the absence of adequate arrangements to have the proceedings interpreted to him in the language he understands, he is prejudiced in his trial, obviously it might be a ground which may be raised on his behalf in an appeal against his conviction.
[Prakash Nishad v. State of Maharashtra, 2023 SCC OnLine SC 666]
SC Enhances Motor Accident Claim Compensation
In an appeal questioning the correctness of the judgment and order passed by the High Court arising out of the judgment passed by the Third Motor Accident Claims Tribunal, the Division Bench of CT Ravikumar and Sanjay Karol*, JJ. enhanced the compensation reiterating that, if the deceased is holding a permanent job, 30% addition to the actual salary is to be made when the age of the deceased is between 40 to 50 years.
[Rojalini Nayak v. Ajit Sahoo, 2024 SCC OnLine SC 1901]
The Division Bench JK Maheshwari and Sanjay Karol*, JJ. answered the question that whether a person who is entitled to receive compensation by way of a claim before the Motor Accident Claims Tribunal can be said to have given up its status as an ‘indigent person’, by virtue of the amount slated to be received (compensation). The Court allowed the appeal to file an appeal as an ‘indigent person’, as her indigency was not extinguished by the compensation awarded, for she did not receive the money at the time of filing the appeal.
The Court noted that the ground, upon which the appellant’s application to file the appeal as an indigent person was rejected, was that she had received compensation by way of the Award of the Tribunal, and therefore, she was not indigent and said that the impugned order had belied the said recording of the High Court as it was on record that the appellant was not paid at that point in time. Hence, the Court said that even though was awarded a sum, her indigency was not extinguished thereby.
[Alifiya Husenbhai Keshariya v. Siddiq Ismail Sindhi, 2024 SCC OnLine SC 1093]
The Calcutta High Court, in the impugned verdict, while answering the question that whether the West Bengal Tenancy Act, 1997 (‘Tenancy Act’) or the Transfer of Property Act, 1882 (‘TP Act’) was to be applied for framing of the issues in the instant landlord-tenant dispute, held that the Tenancy Act would govern the same. The petitioner-landlord, whilst the pendency of the SLP sought direction for payment of rent and other associated benefits for the property. The Division Bench of JK Maheshwari and Sanjay Karol*, JJ. directed the tenant to deposit Rs.5,15,05,512/- with the Registry of the Court. The Bench also held that mesne profits are payable on continuation of possession by tenant after expiry, determination, forfeiture or termination of lease.
[Bijay Kumar Manish Kumar Huf v. Ashwin Bhanulal Desai, 2024 SCC OnLine SC 980]
Supreme Court upholds permanent status for Tamil Nadu Medical Services Corporation Employees
In a set of two cross civil appeals one by the Tamil Nadu Medical Services Corporation Limited (‘Corporation’) and the other by the Tamil Nadu Medical Services Corporation Employees Welfare Union (‘Union’), against the judgment and order of the Madras High Court wherein the grant of permanent status to the workmen employed in the Corporation was in question, the Division Bench of Sanjay Karol* and Prasanna Bhalachandra Varale, JJ. held that the Corporation could not have denied the permanent status to the workmen if they have worked consecutively for more than 480 days in a period of 24 months. The Court also concluded that the Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981 was applicable to the Corporation.
[T.N. Medical Services Corpn. Ltd. v. T.N. Medical Services Corpn. Employees Welfare Union, 2024 SCC OnLine SC 982]
In an appeal regarding medical negligence filed by the appellant for enhancement of compensation, the division bench of Sanjay Karol* and Aravind Kumar, JJ. while setting aside the impugned orders of the National Consumer Disputes Redressal Commission (‘NCDRC’) and State Consumer Disputes Redressal Commission (‘State Commission’), directed the Hospital to pay a sum of Rs.5 lakhs accompanied by interest at 9% from the date of the award passed by the District Consumer Disputes Redressal Forum (‘District Forum’) to the appellant, within a period of four weeks from the date of this judgment. The Court also imposed a cost of Rs.50,000/- in litigation cost.
[Jyoti Devi v. Suket Hospital, 2024 SCC OnLine SC 581]
Criminal Court bound by Civil Court’s declaration that cheque was only for purpose of security: Supreme Court
The Division Bench of Sanjay Karol* and Aravind Kumar, JJ. quashed concurrent conviction for offence under Section 138 of the NI Act, 1881, arising from the dishonour of a cheque due to insufficient funds upon considering that the Court in criminal jurisdiction imposed both sentence and damages, and reiterating that the Court in criminal jurisdiction would be bound by the civil Court having declared the cheque, the subject-matter of dispute, to be only for the purposes of security.
[Prem Raj v. Poonamma Menon, (2024) 6 SCC 143]
In a suit for declaration of title, lasting for about a decade, the Division Bench of Hrishikesh Roy and Sanjay Karol*, JJ. allowed the appeal against the High Court’s decision and discussed the interplay between adverse possession and limitation in property disputes. It was held that a person claiming adverse possession should show, as to on what date he got the possession; the nature of his possession; whether the factum of possession was known to the other party; how long his possession has continued; and that his possession was open and undisturbed.
[Vasantha v. Rajalakshmi, 2024 SCC OnLine SC 132]
Grant of bail based on parity is not a claim of right: Supreme Court
The Division Bench of Vikram Nath and Sanjay Karol*, JJ., while dealing with an appeal against cancellation of grant of anticipatory bail observed that grant of bail based on parity is not a claim of right. The same is well-established and reiterated that applying this principle of parity, the Court is required to focus on the role attached to the accused whose application is under consideration.
[Sabita Paul v. State of W.B., 2024 SCC OnLine SC 374]
In an appeal against judgment passed by Bombay High Court confirming award passed by the Central Government Industrial Tribunal (‘CGIT’) on 30-03-2017 rejecting the demand of Bharatiya Kamgar Karmachari Mahasangh (‘Union’) for reinstatement with full back wages, the Division Bench of Abhay S. Oka and Sanjay Karol*, JJ., upheld the benefits which the Union was entitled to and set aside the said award and its confirmation.
[Bharatiya Kamgar Karmachari Mahasangh v. Jet Airways Ltd., 2023 SCC OnLine SC 872]
Can License to practice medicine be suspended as a punishment for Contempt of Court? SC Answers
In a case where the Supreme Court was called upon to decide whether the suspension of license to practice medicine can be handed down under the Contempt of Courts Act, 1971, the bench of BR Gavai and Sanjay Karol*, JJ has answered in negative and has held that awarding such punishment will be a complete disregard for the statutory text of the Contempt of Courts Act 1971.
[Gostho Behari Das v. Dipak Kumar Sanyal, 2023 SCC OnLine SC 889]
Adherence to Article 14 by State is necessary even while acting in Contractual Realm: Supreme Court
In a batch of civil appeals against the Judgment and Order of the Madras High Court, the three Judge Bench of B.R. Gavai, Sanjay Karol* and Aravind Kumar, JJ., said that the State must abide by Article 14 of the Constitution of India even if its action was in the contractual realm.
[Madras Aluminium Co. Ltd. v. T.N. Electricity Board, 2023 SCC OnLine SC 783]
The 3-judge bench of BR Gavai, Vikram Nath and Sanjay Karol, JJ has awarded life imprisonment to 4 convicts in the 1996 Lajpat Nagar Bomb Blasts case that killed 13 persons and left 38 persons injured. The Court held that the prosecution proved the guilt of the accused in question in the commission of the crime and found them to be part of a conspiracy as under Section 120-B Penal Code, 1860.
[Mohd. Naushad v. State (NCT of Delhi), 2023 SCC OnLine SC 784]
UAPA | Justice Sanjay Karol’s opinion on reliance on American decisions to read down Section 10 UAPA
In a reference made on behalf of the Union of India and the State of Assam to larger bench, against the judgment and order passed in Arup Bhuyan v. Union of India, (2011) 3 SCC 377 as well as State of Kerala v. Raneef, (2011) 1 SCC 784, pursuant to the order passed by this Court in Arup Bhuyan v. State of Assam, (2015) 12 SCC 702, the full bench comprising of M. R. Shah*, C.T Ravikumar and Sanjay Karol*, JJ. upheld the constitutional validity of Section 10(a)(i) of the Unlawful Activities and Prevention Act, 1967 (‘UAPA’). Sanjay Karol J. concurred with the views taken by the Bench but traced the development of law on the issue in India and the application of the decisions rendered by the Courts in the United States of America. Thus, he held that placing reliance on decisions rendered in a distinct scenario as well as a demonstrably different constitutional position, especially in cases which involve considerations of national security and sovereignty, was not justified.
[Arup Bhuyan v. State of Assam, 2023 SCC OnLine SC 338]
NOTABLE JUDGMENTS AT HIGH COURT
Did You Know? When Justice Karol was Acting Chief Justice of Himachal Pradesh High Court, he saved a milkman suffering from seizure by helping him reach hospital timely.15
The Division Bench of Sanjay Karol, CJ* and S. Kumar, J., directed the Chief Secretary, Government of Bihar to take all steps ensuring the establishment of State Mental Health Authority as per Section 45 of the Mental Health Care Act, 2017. The Bench remarked that
“It appears that mental health of a person and/or treatment of those who are in need, more so during the time of COVID-19, is the least priority of the State Government.”
[Akanksha Maviya v. Union of India, 2022 SCC OnLine Pat 305]
Sanitation is personal and private, inextricably linked to human dignity. At the same time, sanitation has an essential public health dimension. A recent judgment by the Division bench of Sanjay Karol, CJ* and S. Kumar J*. observed that the right to sanitation comes within the scope of Article 21 and therefore, directed the State, National Highway Authority of India (NHAI), and Oil Marketing Companies (OMC) to construct public toilets and public conveniences on highways across the state of Bihar.
[National Highway Projects v. State of Bihar, 2022 SCC OnLine Pat 1048]
A Division Bench of Sanjay Karol, CJ. and S. Kumar, J. declared Bihar Municipal (Amendment) Act, 2021 as unconstitutional to the effect of amendments carried out in Sections 36, 37, 38 and 41, Bihar Municipal Act, 2007, by virtue of amending Sections 2, 3, 4 and 5.
[Ashish Kumar Sinha v. Union of India, 2022 SCC OnLine Pat 3472]
In a case relating to the reservation to the backward class category for the post of Counsellors in Municipalities, the division bench of Sanjay Karol, CJ.* and S. Kumar, J. has held that the reservation of seats for Other Backward Classes (OBC) and Extremely Backward Classes (EBC) in urban local body elections was illegal and directed the State Election Commission to re-notify seats reserved for the OBC in the local polls as general category. In this case, the petitioner wanted the elections to the Municipal Body, to be conducted without providing reservation to the Backward Class Category, for it be in breach of the three-fold test and in the absence of reservation, the seats would be left open for General Category. However, pending adjudication the Election Commission issued a notification fixing the schedule for elections in October, 2022, while the posts of Deputy Chief Councilor of Municipalities are reserved for specified categories.
[Sunil Kumar v. State of Bihar, 2022 SCC OnLine Pat 3005]
PAN card and Aadhaar Card not a proof of Indian Citizenship for Foreign National: Patna HC
The Division Bench of Sanjay Karol, CJ. and S. Kumar, J. answered the question that “Can the foreign national’s voter ID Card; PAN Card; Aadhaar Card; acquiring education or immovable property in India; having a Bank Account, function as proof of Indian Citizenship?” in negative. Indian citizens can marry a foreign national under the Special Marriage Act 1954. The Bench also said that foreign national does not become an Indian citizen on marriage with a citizen under the Act. After the marriage, the foreign national has an option to get registered as an Indian citizen. Even then, the person must fulfil the requirement of residency before they can apply for Indian Citizenship.
[Kiran Gupta v. State Election Commission, 2020 SCC OnLine Pat 1641]
Did You Know? In 2019, as Chief Justice of Tripura High Court, Justice Sanjay Karol initiated a cultural program — ‘An Evening with the Angels’ on Teacher’s Day for the benefit of underprivileged children.16
No person including State shall sacrifice any animal/bird within temples: Tripura HC
In a PIL, the Division Bench of Sanjay Karol, CJ*. and Arindam Lodh, J. answered the questions that “whether act of the State in offering an animal for sacrifice in the Temples in Tripura, can be said to be a secular activity and as to whether prohibiting the same would infringe the Fundamental right, as envisaged under Article 25(1) of the Constitution of India?” and that “whether the age long practice of 500 years of sacrificing animals, after stoppage of practice of human sacrifice, in Tripureswari Devi Temple, Udaipur, Gomati District, Tripura can be construed as an essential and integral part of religion, as protected under Article 25(1) of the Constitution of India?” The Bench prohibited and banned animal/birds sacrifice in the temples and directed that- no person including the State shall be allowed to sacrifice of any animal/bird within the precincts of any one of the temples within the State of Tripura; and no person shall sacrifice such animal within the precincts of any of the temples within the State of Tripura.
[Subhas Bhattacharjee v. State of Tripura, 2019 SCC OnLine Tri 441]
Documents forming genesis of opinion in passing an order of preventive detention must be supplied to Detenu: Tripura HC
In a Habeas Corpus petition, the Division Bench of Sanjay Karol, CJ., and Arindam Lodh, J. held that not each and every document is required to be supplied to the detenu, but then the documents forming genesis of the opinion of the competent authority in passing an order of preventive detention, necessarily have to be supplied.
[Shyam Manik Debnath v. State of Tripura, 2019 SCC OnLine Tri 453]
Did you Know? During 2018 water crisis in Shimla, control room of Shimla Municipal Corporation faced a surprise checking in the wee hours by Acting Chief Justice Sanjay Karol, who went through the records to take note of public grievances. Not only this, but Justice Karol even inspected several localities at night to take stock of water supply situation.17
Shimla Water Crisis | Himachal Pradesh HC directs no supply of water tankers to VIPs
The Himachal Pradesh High Court took suo motu cognizance of the water crisis in the State’s capital Shimla and the Division Bench of Sanjay Karol, ACJ., and Ajay Mohan Goel, J., gave stern directions that:
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No water through water tankers shall be supplied by the Municipal Corporation, Shimla to any individual, more so in a VIP area, be it the Judges (including the Acting Chief Justice), Ministers, MLA’s Bureaucrats, Police Officers and commercial establishments;
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All construction activity within Shimla planning area shall forthwith remain suspended for at least one week;
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An endeavor shall be made by the Chief Secretary, Government of Himachal Pradesh/Commissioner, Municipal Corporation, Shimla, to immediately approach the Army Authorities for diverting the water used for watering the Golf Course at Annadale, situated within the Municipal limits of Shimla town as also the Indian Institute of Advanced Studies, which has got huge water storage tanks, to meet emergent situation of lack of supply of potable drinking water within the Municipal limits of Shimla town;
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All car washing operations within Shimla town shall remain suspended for a period of one week.
[State of H.P., In re, 2018 SCC OnLine HP 720]
LECTURES, SEMINAR AND CONFERENCE
Constitutional Vision, Social Engineering & Distributive Justice18
In a webinar organised by NUALS, Kochi in collaboration with CAN Foundation on 18 September 2020, where then Chief Justice of the Patna High Court, Justice Sanjay Karol, delivered the keynote address on “Social Engineering & Distributive Justice: High Courts Under Our Constitution”.
Justice Karol emphasised that the Constitution is not merely a legal text but embodies a “bold new social vision” for India. It represents the transformation of a society emerging from colonial rule and seeks to create conditions for dignity, equality and individual development.
“Our Constitution sets out a bold new social vision; Recent legal writers have persuasively demonstrated that the ordinary citizens of India were clearly conscious of the Constitutional text and were vigorously engaged with its language and framework of values of a judicial court. The Constitution is a living reality experienced by the people in their vocabulary and behaviour towards institutions and to other citizens is a counterpoint to this, and the critical commentaries also to draw attention to the collaborative, ideologically diverse yet ultimately unelected an elite makeup of constituent assembly.”
Justice Karol stressed the importance of the separation of powers. He stated that judiciary should not assume the functions of the Executive or Legislature. Social-welfare policies and their implementation are primarily matters for the elected branches, while courts must ensure that constitutional rights and limits are respected.
He attached considerable importance to Part IV — the Directive Principles of State Policy, describing them as a primary constitutional articulation of socio-economic entitlements. These principles encompass areas such as health, education, livelihood and social welfare and impose a positive constitutional vision upon the State.
Juvenile Justice19
During a webinar on “Juvenile Justice” dated 11 July 2020, organised by Juvenile Justice Monitoring Committee, Patna High Court with the object to bring all the stake holders at one platform and to sensitize them on the issue of Juvenile Justice in the time of global pandemic. In the opening address, Justice Karol stated that Bihar accounts for nearly one-tenth of India’s population and as per the 2011 Census, around 30% of Bihar’s population is below 14 years and 40% is below 18 years.
He stated that children must be taught to respect, rather than fear, the law and courts. Constitutional values and the ideals of the framers of the Constitution should be instilled in them so that they grow up with respect and love for the Constitution.
“It is our duty, it is the duty of the State, it is the duty of the society also to see that we have a bright future of these children and that would only make India become a great superpower one day.”
Justice Karol stated that the key challenge is implementing juvenile justice laws in their true letter and spirit, requiring active participation of lawyers, the legal fraternity, State Legal Services Authorities and Juvenile Justice Boards. Special attention must be given to the deprived, marginalised, downtrodden and excluded, bringing them within the framework of justice and social protection.
He further stated that whether dealing with matters inside or outside the courtroom, all stakeholders must act with compassion, maturity and positivity, approaching each matter from the child’s perspective and seeking to understand the child’s circumstances and viewpoint.
Role of Law Students and Lawyers20
In his address as Chief Guest at an event organised by National Law Institute University (NLIU), Bhopal, Justice Sanjay Karol highlighted the growing disconnect between legal education, students’ career aspirations and the realities of India’s justice-delivery system.
Justice Karol observed that many students from prestigious law institutions aspire to become lawyers like those portrayed in Suits — associated with sophisticated corporate practice, rather than lawyers as portrayed in the more grounded Maamla Legal Hain. He cautioned that the attraction of high-paying corporate careers is increasingly shaping the priorities of law students, potentially distancing them from the realities and struggles of ordinary litigants.
Justice Karol emphasised that actual justice-delivery system at the ground level is markedly different from its glamorous portrayal on television. He pointed to narratives such as Panchayat and Maamla Legal Hai as better reflecting the delays, confusion and structural difficulties faced in the justice system. He stated that the duty of every law student and lawyer is to “transform the lives of the 140 crore Indians regardless of their stature, their economic or social position”.
Justice Karol also urged students to internalise the values of the Constitution and apply them in their daily lives, rather than treating constitutional principles merely as academic concepts.
Air Law and Public Interest21
Addressing young lawyers at the AIL Sarin National Rounds of the 15th Sarin International Air Law Moot Court Competition, Army Institute of Law, Mohali, Justice Karol stressed that the objective of every legal professional should ultimately be service to society and its people and upholding justice for the larger public good.
He highlighted the growing need for specialists in international air law, particularly as aviation becomes increasingly important to everyday life and commerce. He emphasised that air-law specialists must consider the impact of the aviation industry on the global environment, as this aspect had hitherto received inadequate legal attention.
Referring to approximately 4.17 lakh domestic air travellers every day, Justice Karol observed that the increasing scale of air travel correspondingly increases the industry’s responsibility to ensure safety, efficiency and security. He called for legal checks on airline refund policies and on the unrestrained escalation of airfares during crisis situations.
Justice Karol also emphasised the need to make air-booking applications more useful to the masses by making them vernacular-language friendly, thereby improving accessibility for passengers who may not be comfortable using English-language platforms.
Justice v. Judgment: Lawyers’ Role in Justice Delivery22
While addressing at the Seminar & Capacity Building Programme on Pro-Bono Legal Services, Dr B.R. Ambedkar National Law University, Sonepat. Justice Karol emphasised that in a constitutional system, “there is a huge difference between justice and judgment” and that a judgment is not necessarily justice.
He reminded students and lawyers that they are not merely dealing with files or legal documents, but with human lives, underscoring the human dimension of the legal profession. He stressed that lawyers have as much responsibility for justice as judges. The responsibility of delivering justice therefore extends beyond the Bench to the Bar. He urged law students not to lose their passion for learning, observing that when the desire to learn ends, progress also stops.
Justice Karol described the judiciary as the third pillar of democracy and said that its strength depends upon better coordination and relations between judges and lawyers. He further stated that respect for India and the Constitution is non-negotiable, describing it as something beyond debate or question.
Drawing an analogy with individual vocations, he said that some people get the opportunity to serve as advocates while others serve as judges—the roles differ, but both contribute to the administration of justice.
Climate Change and Environment Law
While speaking at the launch of Book “Climate Change: The Policy, Law and Practice” by advocate Jatinder (Jay) Cheema in July 2024,23 Justice Karol noted that parts of rivers are drying up because of rising temperatures as well as human intervention. He linked the condition of rivers to wider ecological consequences affecting flora, fauna and communities.
Justice Karol stressed that climate instability is already affecting Indian agriculture. He noted that nearly 58% of India’s population depends on agriculture and allied activities, making the deterioration of agricultural conditions a major socio-economic concern.
Apart from climate change, he identified heavy use of chemical fertilisers, over-irrigation and excessive groundwater extraction as factors eroding agricultural conditions. He specifically referred to the situation in Punjab as an example.
At the legal-policy level, he advocated treating climate change as a distinct field of law, rather than merely as a subset of environmental law.
“It is the need of the hour for everyone to be made aware of environmental laws, the impact of climate change, and the modern practices that need to be adopted.”
At the SILF Climate Change Conference & Awards 2025,24 Justice Sanjay Karol highlighted smog and pollution of the Yamuna River as the two biggest environmental issues confronting Delhi. He stressed that protection of the environment cannot be treated as the responsibility of only the judiciary, executive or legislature. individual citizens also bear responsibility for protecting the environment, making environmental protection a shared societal obligation. He stated that environmental protection not merely as a governmental or institutional obligation, but is a responsibility owed to future generations.
LEGACY
Justice Sanjay Karol’s journey reflects a distinctive blend of constitutional commitment, institutional responsibility and human sensitivity. From his early years at the Himachal Pradesh High Court to his tenure as Chief Justice of the Tripura and Patna High Courts and, eventually, as a Judge of the Supreme Court, his career has been marked by an endeavour to make the law meaningful in the lives of ordinary people. His efforts towards reducing pendency, strengthening access to justice and engaging with legal-aid and grassroots concerns demonstrate that judicial administration, for him, was inseparable from public service.
His judgments across constitutional, criminal, civil, motor accident, property, environmental and social justice matters further illustrate an approach that seeks to balance legal principle with fairness, dignity and practical consequences. The recognition of homemakers as “Nation Builders”, directions for systemic legal-aid reform, protection of constitutional rights, and emphasis on humane and just compensation are among the strands that run through his judicial work.
The tribute paid by CJI Surya Kant at Justice Karol’s farewell ceremony perhaps captures this legacy most appropriately, a judge who combined constitutional commitment with accessibility, compassion and institutional dignity, and who, in the words of the CJI, “lived the Constitution.” Justice Karol’s own message to young advocates—that law is a profession of service to society and that one must not merely cite the Constitution but “live the Constitution”, offers a fitting reflection of the philosophy that has characterised his judicial career.
Ultimately, Justice Karol’s journey demonstrates that the enduring contribution of a judge is measured not only by the judgments authored, but also by the values brought to the institution and the people whose lives are touched by the law. He is a role model for young lawyers and a true inspiration to all those who believe in the rule of law. As a law student or legal professional, we can learn from him about the importance of compassion, accessibility and a continuing commitment to justice.
*Judge who authored the judgment
1. https://www.sci.gov.in/judge/justice-sanjay-karol/.
2. https://thc.nic.in/FCJprofile-SK.html.
3. https://main.sci.gov.in/chief-justice-judges.
4. https://thc.nic.in/FCJprofile-SK.html.
5. https://main.sci.gov.in/chief-justice-judges.
6. https://thc.nic.in/FCJprofile-SK.html.
7. https://main.sci.gov.in/chief-justice-judges.
8. https://thc.nic.in/FCJprofile-SK.html.
9. https://www.scconline.com/blog/post/2019/10/30/patna-hc-transfer-order-of-chief-justice-sanjay-karol-to-the-high-court-of-tripura/.
10. https://main.sci.gov.in/chief-justice-judges.
11. https://thc.nic.in/notification/Report%201%2030.10.2019.pdf.
12. CJI Surya Kant hails Justice Karol as “a judge who lived the Constitution” at SCAORA farewell
13. CJI Surya Kant hails Justice Karol as “a judge who lived the Constitution” at SCAORA farewell
14. www.scconline.com | Judge only and Coram only feature
15. https://www.hindustantimes.com/india-news/man-suffers-seizure-on-shimla-street-acting-chief-justice-proves-to-be-his-saviour/story-Cszy9UF6nkDMo4r2CcdetJ.html.
16. https://thc.nic.in/notification/Report%201%2030.10.2019.pdf.
17. https://www.deccanherald.com/india/acting-cjs-night-vigil-check-water-shortage-shimla-672881.html.
18. CAN- NUALS Webinar | “About time we sensitized Constitutional bodies of their Constitutional duties”: Chief Justice Karol
19. Webinar on Juvenile Justice.
20. The Telegraph India — “Indian law students idolise ‘Suits’ over ‘Maamla Legal Hain’: Justice Sanjay Karol”
21. Need for international air law specialists: Justice Karol
22. Stay passionate about learning, Justice Karol advises law students
23. Construction of dams have turned Sutlej into rivulet: SC judge
24. Yamuna pollution, smog biggest environmental issues in Delhi: SC Judge Sanjay Karol
