Supreme Court: The major married son who is also earning and not fully dependent on the deceased, would be still covered by the expression “legal representative” of the deceased and entitled to get compensation

5.1.1. While holding that the legal representatives of the

deceased are entitled to move an application for

compensation by virtue of clause (c) of Section 166(1) of the

Act, it was observed,

“…The major married son who is also earning

and not fully dependent on the deceased,

would be still covered by the expression “legal

representative” of the deceased. This Court

in Manjuri Bera had expounded that liability

to pay compensation under the Act does not

cease because of absence of dependency of

the legal representative concerned…”

(Para 12)

REPORTABLE

IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

CIVIL APPEAL NO. OF 2026

(Arising out of SLP (C) No.18553 of 2023)

SAMEEM BEGUM AND OTHERS  Vs K. VENKAT SWAMY AND ANOTHER.

Author: N.V. ANJARIA, J.

Citation: 2026 INSC 864.

Dated: AUGUST 14, 2026.

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Bombay HC: How to appreciate evidence in murder case if accused takes the plea of alibi?

The evidence of the present matter shows that accused No. 1 was living in the room with the deceased where the murder took place. Accused No. 1 is an agriculturist. The evidence on the record does not show that accused has any relative at Alandi and there was any reason for him for going to Alandi and staying there for such a long time, for about six days. In ordinary course, a male member of family where there is only one adult male member does not leave station for days together. The male member stays at home in the night time and he leaves home in the day time for work. Though the Trial Court has held that explanation is given by accused No. 1 that he was out of station one day prior to the date of incident, the statement given by accused No. 1 under section 313 of Cr.P.C. shows that accused No. 1 contended that he had left home three days prior to the date of incident. In the statement under section 313 of Cr.P.C., accused No. 1 has further contended that he returned to his village Warud Kazi on 4.12.2004 and he had learnt first time on 3.12.2004 about the incident. Thus, he admits that he was able to keep contact with his family if he was at Alandi and he admits that he was not at station up to 4.12.2004. In view of provision of section 114 of Evidence Act, it was necessary for accused No. 1 to give particulars as to where he was living in Alandi for the period given by him, for about six days. He could have examined witnesses and he could have produced some record if such record was created to create a probability that on the night between 1.12.2004 and 2.12.2004 he was not at Warud Kazi. That is not done by accused No. 1. {Para 19}

 IN THE HIGH COURT OF BOMBAY (AURANGABAD BENCH)

Criminal Appeal No. 2 of 2006

Decided On: 18.01.2018

The State of Maharashtra Vs. Ramnath

Hon'ble Judges/Coram:

T.V. Nalawade and Sunil K. Kotwal, JJ.

Author: T.V. Nalawade, J.

Citation: MANU/MH/0078/2018,2018 ALL MR (CRI) 3825.

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Supreme Court: Under which circumstances the court can convict accused based on call detail records and location data of the mobile numbers used by accused?

 The call detail records further amplify the incriminating previous conduct of A1 on the date of incident. The records reveal that A1 was in constant touch with A2, A3 and A5 before the incident. Further, A3, A4 and A5 were in constant touch with each other. The prosecution has relied upon a chart prepared on the basis of the call detail records of the accused persons and it indicates that all the accused persons were in contact with each other. Even without this chart, the call records are quite clear. To add to it, the location data of the mobile numbers used by the accused persons reveals that all the accused persons were present around the restaurant at the time of the incident. Furthermore, the location of A3 to A6 was also traceable at the same spot where the deceased was found in the Honda Accord car at around 12:05 AM after the incident. In such circumstances, the courts have drawn a reasonable inference that the accused persons were acting in a coordinated manner and had an overwhelming nexus with the offence. 

{Para 17}

 In the Supreme Court of India

(Before Dipankar Datta and Satish Chandra Sharma, JJ.)

Criminal Appeal No(s). 3866 of 2025

Piyush Shyamdasani  Vs State of Uttar Pradesh 

Decided on July 20, 2026

Citation: 2026 SCC OnLine SC 1357. Read full judgment here: Click here.

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Supreme Court: Whether the court can convict the accused if Mobile numbers relied upon by the prosecution were not in the name of the accused persons?

 The appellants herein seek to question the findings on the ground that the mobile numbers reflected in the call detail records did not belong to the accused persons. This, in fact, is another incriminating circumstance because the numbers did not belong to the accused persons, but they were found running in the mobile devices recovered from the possession or at the instance of the accused persons. Thus, they were using fake numbers to conceal their identities and to evade surveillance. Notably, A1 was admittedly using two numbers - one registered in his own name and one in the name of his employee (a worker in his factory). Both the numbers were mentioned by him in his original complaint after the incident. The number used by A4 was found running in the mobile phone recovered from him, and the number used by A5 was installed in his phone, which was left by him at his home when he fled away after the incident. When called by the investigators, the call was picked up by the mother of A5 and she disclosed that it was used by A5 only. Again, no rebuttal has been advanced to dispute these facts. {Para 19}

20. The call details reveal that the accused persons were in constant touch with each other using these numbers, irrespective of the persons in whose names the numbers were officially registered. The evidence on record has indicated sufficient nexus between the numbers reflected in the call detail records and the accused persons. If there was any discrepancy in this evidence, the accused persons could have led counter evidence to that effect. However, they failed to rebut this crucial technical evidence. The Court cannot set aside consistent evidentiary findings on bare assertions, without any cogent evidence to support the assertions.

 In the Supreme Court of India

(Before Dipankar Datta and Satish Chandra Sharma, JJ.)

Criminal Appeal No(s). 3866 of 2025

Piyush Shyamdasani  Vs State of Uttar Pradesh 

Decided on July 20, 2026

Citation: 2026 SCC OnLine SC 1357

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