Supreme Court Limits Arbitrator Mandate Under Section 29-A, Declares Adoptive Maternity Leave Restriction Unconstitutional

The Supreme Court has delivered a series of significant rulings reported in Volume 8, Part 4 of the Supreme Court Cases (2026), addressing critical issues in arbitration, maintenance rights, insolvency jurisdiction, criminal evidence, money laundering, and maternity benefits. The volume clarifies statutory mandates and constitutional boundaries across diverse legal domains.

Arbitrator Becomes Functus Officio for Missing Statutory Deadline

In Mohan Lal Fatehpuria v. Bharat Textiles ((2026) 8 SCC 569), the Court interpreted Section 29-A of the Arbitration and Conciliation Act, 1996. The sole arbitrator was mandated to pass an award within one year from March 1, 2022, i.e., by February 28, 2023. The arbitrator failed to do so, and neither party applied for an extension of time. The Court held that in view of the mandate contained in Section 29-A(4), the sole arbitrator became functus officio. The ruling reinforces the strict timeline regime introduced by the 2015 and 2019 amendments, confirming that the mandate terminates automatically upon expiry of the extended period without a court order or party agreement extending time.

Widowed Daughter-in-Law Entitled to Maintenance from Father-in-Law's Estate

In Kanchana Rai v. Geeta Sharma ((2026) 8 SCC 562), the Court addressed the rights of a widowed daughter-in-law under the Hindu Adoptions and Maintenance Act, 1956. The appellant became a widow after the death of her father-in-law. The Court held that she is entitled to claim maintenance from his estate under Sections 22, 21(vii), 19, and 4 of the Act. The decision affirms that the liability to maintain a widowed daughter-in-law devolves upon the estate of the father-in-law, securing her right to residence and maintenance even after his demise.

NCLT Lacks Jurisdiction Over Complex Trade Mark Title Disputes

In Gloster Ltd. v. Gloster Cables Ltd. ((2026) 8 SCC 589), the Court delineated the jurisdiction of the National Company Law Tribunal (NCLT) under Section 60(5) of the Insolvency and Bankruptcy Code, 2016. The Court held that the NCLT lacks jurisdiction to adjudicate complex trade mark title disputes or determine intellectual property ownership through insolvency proceedings. The ruling preserves the domain of specialised IP tribunals and civil courts for resolving rival claims over trade mark ownership, preventing the insolvency forum from becoming a vehicle for adjudicating substantive IP rights.

Absence of Struggle Injuries Significant in Dowry Death Prosecution

In Rahul v. State of U.P. ((2026) 8 SCC 575), the Court examined the relevancy of medical evidence in a charge under Sections 304-B and 498-A of the Indian Penal Code, 1860. The post-mortem report attributed death to asphyxia as a result of ante-mortem hanging. No antemortem injuries were found apart from the ligature mark, and no signs of resistance, restraint, or physical assault were observed. The Court held that while medical evidence by itself does not determine whether death is suicidal or homicidal, the complete absence of injuries ordinarily expected in a struggle assumes considerable evidentiary significance where the prosecution alleges homicidal violence involving several accused acting in concert. This observation led to the quashing of the charge-sheet.

Proceeds of Crime Include Equivalent Value Property Under PMLA

In Nav Nirman Builders & Developers (P) Ltd. v. Union of India ((2026) 8 SCC 627), the Court expanded the interpretation of proceeds of crime under Section 2(1)(u) read with Explanation and Section 2(1)(v) of the Prevention of Money Laundering Act, 2002. The Court held that the definition is wide enough to include property which is equivalent in value to the property directly or indirectly obtained from criminal activity relating to a scheduled offence. Consequently, such equivalent property can be attached if the direct proceeds of crime are not otherwise available. This ruling significantly broadens the attachment powers of the Enforcement Directorate.

What Is the Supreme Court's Ruling on Maternity Leave for Adoptive Mothers Under the Social Security Code?

The Supreme Court in Hamsaanandini Nanduri v. Union of India ((2026) 8 SCC 485) struck down Section 60(4) of the Social Security Code, 2020, insofar as it restricts maternity benefits for adoptive mothers to cases where the adopted child is below three months of age. The Court held that this classification violates Articles 14 and 21 of the Constitution. The ruling mandates that adoptive mothers are entitled to maternity leave irrespective of the age of the adopted child, aligning statutory benefits with constitutional guarantees of equality and dignity.

These judgments collectively underscore the Supreme Court's role in enforcing statutory timelines in arbitration, protecting vulnerable family members, demarcating tribunal jurisdictions, scrutinising prosecutorial evidence in serious offences, expanding anti-money laundering reach, and eliminating discriminatory conditions in social security legislation.