Pramod Shroff Vs Mohan Singh Chopra - In the light of the above legal precedents, it can be said that though the framing of issues in an ex parte suit is not mandatory by virtue of Order XIV Rule 6 of CPC, but the judgment must be in conformity with the provisions of the Code. Thus, Order XX Rule 4 of CPC comes into picture.

 SCI (2026.04.09) in Pramod Shroff Vs Mohan Singh Chopra  [2026 INSC 378, CIVIL APPEAL NO.              OF 2026 (ARISING OUT OF SLP (C) NO.20779 OF 2025) ] held that;-

• Order XX Rule 4(2) states that judgments of Courts shall contain a concise statement of the case, the points for determination, the decision thereon, and the reasons for such decision.

• Further, it held that in a case which has proceeded ex parte, the court is not bound to frame issues under Order XIV and deliver the judgment on every issue as required by Order XX Rule 5. Yet the trial court should scrutinize the available pleadings and documents, consider the evidence adduced, and would do well to frame the “points for determination” and proceed to construct the ex parte judgment dealing with the points at issue one by one.

•  Furthermore, this Court in Maya Devi v. Lalta Prasad [(2015) 5 SCC 588], has held that in case the Defendant has been proceeded against ex parte, it is the duty of the court to pass the decree only after ascertaining the factual and legal veracity of the claim of the Plaintiff.

• What a judgment should contain is indicated in Order XX Rule 4(2) which says that a judgment ‘shall contain a concise statement of the case, the points for determination, the decision thereon, and the reasons for such decision.

• the Apex Court explained that ‘points for determination’ in Rule 4(1) are obviously nothing but ‘issues’ contemplated by Rules 1 and 3 of Order XIV. In practice, the trial court first frames issues (points of controversy) after examination of pleadings, the judgment then recites these as “points for determination” and answers them.

• The court must give its finding on each point. Order XX Rule 5 CPC further reinforces this: if issues have been framed in the suit, the court “shall state its finding or decision, with reasons, upon each separate issue”, unless deciding one issue resolves the suit. Thus, points for determination ensure that every controverted issue is  addressed. A judgment that omits discussion of issues in dispute is defective.

• Points for determination are the court’s restatement of the disputed questions (issues) that were placed before it, and the judgment must answer each. They serve to concentrate the court’s reasoning and ensure completeness of adjudication.

•  In Sayeda Akhtar v. Abdul Ahad [ (2003) 7 SCC 52], it was held that omission to frame an important issue may sometimes cause prejudice to parties resulting in failure to lead evidence on the point.

•  In the light of the above legal precedents, it can be said that though the framing of issues in an ex parte suit is not mandatory by virtue of Order XIV Rule 6 of CPC, but the judgment must be in  conformity with the provisions of the Code. Thus, Order XX Rule 4 of CPC comes into picture.

Excerpts of the Order;

# 1. Leave granted.

# 2. The present appeal raises an important question touching upon the procedural obligations of a civil court while adjudicating a suit ex parte, and more particularly, whether the absence of formal framing of issues vitiates such proceedings, and what constitutes a    legally sustainable judgment in such circumstances.

# 3. The appeal before the High Court was heard ex parte. The Respondent, despite service, chose not to enter appearance before the courts below or before this Court. On 05.12.2025, Mr. Anup Kumar, learned Counsel, who was present in the Court was appointed as Amicus Curiae to assist this Court in this matter. He was directed to get in touch with Respondent directly in writing, apprise him about pendency of present appeal, his right to engage a counsel of his choice and his right of being represented through a legal aid counsel. Having done so, still the Respondent remains unrepresented.

# 4. The instant appeal assails the judgment and order dated 21.01.2025 (hereinafter referred as “Impugned Judgment”) passed by the High Court of Calcutta (hereinafter referred as “High of 2018 filed by the Appellant (Plaintiff) herein and affirmed the judgment and decree dated  26.10.2017 passed by the City Civil Court at Calcutta (hereinafter referred as “trial court”), vide which suit filed by the Appellant for specific performance for agreement to sell was dismissed ex parte.

# 5. The brief facts are that the original owner of the property executed a 75 years lease in favour of the Khimjis. Thereafter, Khimjis constructed a building on the said property by the name of “Shalimar Apartments”. During construction, the Khimjis entered into a partnership with other persons under the name and style of Gulmohar Properties to complete the construction and sell out the flats therein on ownership basis including, Flat No. 61 in the Shalimar Apartments lying and situate at 42-B, Shakespeare Sarani, Kolkata-700017, along with a car parking space (hereinafter referred as “the suit property”).

# 6. Later, Gulmohar Properties executed an agreement for sale in relation to the suit   property, in favour of the Balwanis, with a clause for assignment.

# 7. Pursuant to assignment clause, the Balwanis transferred the property to Mohan Singh Chopra (Respondent-defendant) by a tripartite registered sale deed, in which Gulmohar Properties, the Balwanis and the Respondent were signatories.

# 8. On 27.01.1977, agreement for sale relating to suit property was executed between Respondent as Vendor and Appellant as Vendee in consideration of ₹95,000/- out of which ₹90,000/- was paid with an undertaking that balance of ₹5,000/- would be paid on the date of execution of Deed of Conveyance and presentation of the same before the Registrar of Assurance. Appellant was also put into the possession of the suit property. Respondent also handed over the original documents, indenture, Title Deeds etc. to the Appellant. On various occasions request was made to the  Respondent to execute the Conveyance Deed by the Appellant but the same did not fructify.

# 9. The Appellant, with a grievance that despite repeated requests Respondent neither accepted balance amount of ₹5,000/- nor executed Deed of Conveyance in his favour, filed a suit for specific performance for agreement to sell dated 27.01.1977 against the Respondent (Defendant) in relation to the suit property.

# 10. The courts below rejected the claim of the Appellant on the ground that Appellant failed to prove the title of the Respondent in the suit property.

# 11. The counsel for Appellant submitted that since no issue qua the title of the Respondent was framed, the onus to prove the same did not fall on the Appellant and the Appellant was not put to notice of the said issue and therefore could not be expected to lead evidence in support of the same. Both the Courts below have disregarded the procedure prescribed i.e., for issues to be framed before trial, as the same  puts the parties to notice of the facts that are required to be proved in a given case.

# 12. Having heard the learned Counsel for the Appellant, learned Amicus Curiae, and considering the written submissions filed by the Appellant and learned Amicus Curiae, we find it apposite that prior to undertaking and answering the aforementioned submissions as raised, it is imperative to delve into the statutory provisions as well as the existing jurisprudence as developed by this Court while dealing with such provisions relatable to what are the essential requirements of a valid judgment in an ex parte civil suit? And whether the courts below have discharged their obligation in accordance with law while deciding the suit ex parte?

# 13. Sub-section 9 of the section 2 of the Civil Procedure Code, 1908 (hereinafter referred as “CPC”) provides that "judgment" means the statement given by the Judge of the grounds of a decree or order.

# 14. Section 2(2) of the CPC provides that "decree" means the formal expression of an adjudication which, so far as regards the court expressing it, conclusively determines the rights of the parties with regard to all or any of the matters in controversy in the suit and may be either preliminary or final.

# 15. Order XIV Rule 1(6) explicitly provides that framing of issues is not required where the defendant at the first hearing of the suit makes no defense.

# 16. Order XX Rule 4(2) states that judgments of Courts shall contain a concise statement of the case, the points for determination, the decision thereon, and the reasons for such decision.

• “ORDER XX

• 4. Judgments of Small Cause Courts.—(1) Judgments of a Court of Small Causes need not contain more than the points for determination and the decision thereon.

• (2) Judgments of other Courts.—Judgments of other Courts shall contain a concise statement of the case, the points for determination, the decision thereon, and the reasons for such decision.”

# 17. Though, the framing of issues where defendant does not present a defense is not mandated, still the importance of framing of issues cannot be underscored. This Court in the case of Makhan Lal Bangal v. Manas Bhunia and Others [(2001) 2 SCC 652], while stressing upon the importance of framing of issues held it as an imperative stage in any civil proceedings as it narrows down the scope of trial by separating wheat from the chaff. Therefore, the real dispute between the parties is determined and the conflict between the parties is narrowed. The petition may be disposed of at the first hearing if it appears that the parties are not at issue on any material question of law or of fact and the Court may at once pronounce the judgment.

# 18. Further, in Ramesh Chand Ardawatiya v.Anil Panjwani [(2003) 7 SCC 350], it has been opined that the burden of proof on the Plaintiff is not too heavy in ex parte civil suits. The Plaintiff, however, must show prima-facie proof qua the existence of relevant facts and circumstances out of which the cause of action has arisen. Therefore, evincing that the court proceeds to record evidence of the Plaintiff qua the cause of action and accordingly decrees the suit. Further, it held that in a case which has proceeded ex parte, the court is not bound to frame issues under Order XIV and deliver the judgment on every issue as required by Order XX Rule 5. Yet the trial court should scrutinize the available pleadings and documents, consider the evidence adduced, and would do well to frame the “points for determination” and proceed to construct the ex parte judgment dealing with the points at issue one by one.

# 19. Furthermore, this Court in Maya Devi v. Lalta Prasad [(2015) 5 SCC 588], has held that in case the Defendant has been proceeded against ex parte, it is the duty of the court to pass the decree only after ascertaining the factual and legal veracity of the claim of the Plaintiff.

# 20. This Court while considering the essential requirements of a judgment in Balraj Taneja and Another v. Sunil Madan and Another [(1999) 8 SCC 396] has held that Judgment as defined in Section 2(9) of the CPC means the statement given by the Judge of the grounds for a decree or order. What a judgment should contain is indicated in Order XX Rule 4(2) which says that a judgment ‘shall contain a concise statement of the case, the points for determination, the decision thereon, and the reasons for such decision. It should be a self-contained document from which it should appear as to what were the facts of the case and what was the controversy which was tried to be settled by the court and in what manner.

“Points for Determination” – Meaning and Role

# 21. The points for determination in a judgment are essentially the legal and factual issues the court must resolve. They correspond to the issues framed during trial (Order XIV), but   in the judgment they are stated as the point(s) to be decided. In Rameshwar Dayal v. Banda (dead) through his LRs and Another [(1993) 1 SCC 531], the Apex Court explained that ‘points for determination’ in Rule 4(1) are obviously nothing but ‘issues’ contemplated by Rules 1 and 3 of Order XIV. In practice, the trial court first frames issues (points of controversy) after examination of pleadings, the judgment then recites these as “points for determination” and answers them. These points focus the judgment on the exact matters in controversy between the parties. By explicitly listing points, the judgment guides the parties and the Appellate court to see what questions were in contest. The court must give its finding on each point. Order XX Rule 5 CPC further reinforces this: if issues have been framed in the suit, the court “shall state its finding or decision, with reasons, upon each separate issue”, unless deciding one issue resolves the suit. Thus, points for determination ensure that every controverted issue is  addressed. A judgment that omits discussion of issues in dispute is defective. It was held that a Small Causes Court judgment which has not even stated the points for determination and given a finding thereon, is obviously not a judgment within the meaning of Section 2(9) of CPC.

# 22. Points for determination are the court’s restatement of the disputed questions (issues) that were placed before it, and the judgment must answer each. They serve to concentrate the court’s reasoning and ensure completeness of adjudication.

# 23. Even when a defendant fails to appear or file a written statement, the court cannot dispense with the points for determination altogether. In Balraj Taneja (supra), it was argued that if no written statement is filed the facts as set out in the plaint would be deemed to be admitted and thus, the court need not indicate the points. This Court while rejecting this submission held that ‘whether it is a case which is contested by  the defendants by filing a written statement, or a case which proceeds ex parte and is ultimately decided as an ex parte case, or is a case in which the written statement is not filed and the case is decided under Order VIII Rule 10, the court has to write a judgment which must be in conformity with the provisions of the Code or at least set out the reasoning by which the controversy is resolved’. In other words, even in default or ex parte suits, the court should identify the legal points (even if obvious) and give a reasoned answer. Simply granting a decree on default is not enough under Section 2(9) of CPC doing so would be a “material irregularity”. Thus, points should be framed (or recited from existing pleadings) and addressed regardless of default.

# 24. The true scope for framing issues is that evidence let in on issue on which the parties actually went to trial should not be the foundation for decision of another and different issue, which was not present to the minds of the parties and on which they had no opportunity   of adducing evidence. But that rule has no application to a case where the parties go to a trial with knowledge that a particular question is in issue, though no specific issue has been framed thereon and adduce evidence relating thereto. Please refer to Nagubai Ammal and Others v. B. Shama Rao and Others [(1956) 1 SCC 698].

# 25. In Sayeda Akhtar v. Abdul Ahad [ (2003) 7 SCC 52], it was held that omission to frame an important issue may sometimes cause prejudice to parties resulting in failure to lead evidence on the point. But where the parties were not only aware of the point in controversy but also led evidence and advanced their submissions, this Court held that the High Court was not justified in interfering with the finding of facts of the courts below.

# 26. In the light of the above legal precedents, it can be said that though the framing of issues in an ex parte suit is not mandatory by virtue of Order XIV Rule 6 of CPC, but the judgment must be in  conformity with the provisions of the Code. Thus, Order XX Rule 4 of CPC comes into picture.

# 27. The courts must determine “points for determination”, which are like issues, and answer them to resolve the matter of controversy between the parties.

# 28. Though framing of issues, as mentioned above, although, is not mandatory yet, if the omission to frame the same causes prejudice to the parties, then the same can vitiate the trial. The test for finding as to omission to frame the issues have caused prejudice to the parties or not can be laid down on the touchstone as to whether parties that go to trial had knowledge that (i) a particular question is in issue and (ii) had opportunity to lead evidence on that issue.

# 29. In the present case, the controversy is regarding suit for specific performance of an agreement to sell, therefore, it is important to consider as to what are the key essentials in a suit for specific  performance that a Plaintiff must prove to succeed.

# 30. As laid down in Man Kaur (dead) by LRs v.Hartar Singh Sangha [ (2010) 10 SCC 512], there must be a valid contract; that defendant committed breach of and readiness and willingness of the plaintiff to perform his part of contract.

# 31. In present case, all the three essentials are present. However, the suit was dismissed for lack of title in favour of the Respondent. No issues or points for determination were framed for the same. Appellant at no point was given an opportunity to lead evidence on the same. In the absence of any issues, and especially in the absence of any pleading contesting title of the Respondent, the Appellant could not be expected to prove such title in a suit for specific performance of Agreement to sell. Therefore, omission to frame issues has caused prejudice to the Appellant.

# 32. Hence, the judgment and decree passed by the trial court does not fulfil the requirements of a judgment as provided for under the Code of Civil Procedure, 1908. The judgments and decree of both the courts below are, therefore, not in accordance with law and thus, set-aside.

# 33. As a result;

• i) Matter shall stand remanded to the trial court for fresh consideration and decision.

• ii) The Appellant-Plaintiff shall appear before the trial court on 04.05.2026.

• iii) Trial court shall issue notice on the Respondent and grant time for completion of pleadings.

• iv) The court shall frame issues and accord opportunity to the parties to lead evidence.

• v) The court shall proceed to decide the same at the earliest keeping in view the fact that the suit is of the year 2007.

# 34. The Appeal is disposed of in above terms.

# 35. There shall be no order as to cost.

# 36. Pending application(s), if any, also stands disposed of.

# 37. We acknowledge and appreciate the constructive assistance rendered by the learned Amicus Curiae and the learned Counsel for the Appellant to this Court.

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United India Insurance Co.Ltd Vs Sayona Colors Pvt. Ltd - It is a settled principle that fraud vitiates all solemn acts, and no person can be permitted to take advantage of his own wrong. In S.P. Chengalvaraya Naidu v. Jagannath, this Court held that a judgment or decree obtained by playing fraud is a nullity in the eyes of law. Similarly, in A.V. Papayya Sastry v. Government of Andhra Pradesh, it was reiterated that fraud vitiates all judicial acts, whether in rem or in personam.

 SCI (2026.03.17) in United India Insurance Co.Ltd Vs Sayona Colors Pvt. Ltd [2026 INSC 287, CIVIL APPEAL NO. 6100 OF 2024] held that;-

• It is a settled principle that fraud vitiates all solemn acts, and no person can be permitted to take advantage of his own wrong. In S.P. Chengalvaraya Naidu v. Jagannath (1994) 1 SCC 1 :1993 SCC OnLine SC 318, this Court held that a judgment or decree obtained by playing fraud is a nullity in the eyes of law. Similarly, in A.V. Papayya Sastry v. Government of Andhra Pradesh (2007) 4 SCC 221 : 2007 SCC OnLine SC 317, it was reiterated that fraud vitiates all judicial acts, whether in rem or in personam.

• Applying the aforesaid principles, we are of the considered view that once it is established that the claim itself is founded on fraud, the entire edifice of the claim collapses and no relief can be granted. Quantification of loss cannot override the foundational requirement of a genuine and bona fide claim.

Excerpts of the Order;

Heard learned counsel for the parties.

# 2. The appellant-Insurance Company is aggrieved by the order dated 04.12.2023 passed by the National Consumer Disputes Redressal Commission [For short, “NCDRC”], New Delhi in Consumer Complaint No. 171 of 2012, whereby the complaint was partly allowed and the appellant was directed to pay a sum of Rs.3,33,63,642/- (Rupees Three Crores Thirty Three Lakhs Sixty Three Thousand Six Hundred and Forty Two) along with interest at the rate of 6% per annum from 08.07.2012, within a period of six weeks, failing which, the rate of interest would stand enhanced to 9% for the same period, and Rs.50,000/- (Rupees Fifty Thousand) was directed to be paid towards litigation costs.

# 3. The learned counsel appearing for the appellant submitted that the claim made by the respondent is fraudulent, being founded on a deliberate act of sabotage resulting in a fire in the respondent’s godown. It was contended that the fire incident occurred on 25.03.2011, which the respondent attributed to a short circuit, pursuant to which a claim of Rs. 28,20,65,797/- (Rupees Twenty Eight Crores Twenty Lakhs Sixty Five Thousand Seven Hundred and Ninety Seven) was raised for the alleged loss.

# 4. It was further submitted that the timing and quantum of insurance coverage assume significance. Initially, the respondent had obtained an insurance policy for Rs. 15,00,00,000/- (Rupees Fifteen Crores), which was enhanced to Rs. 19,00,00,000/- (Rupees Nineteen Crores) on 07.03.2011. In addition, another policy for Rs. 17,00,00,000/- (Rupees Seventeen Crores) was obtained for the period from 28.11.2010 to 27.11.2011. The fire incident occurred shortly thereafter on 25.03.2011, raising serious doubt regarding the bona fides of the claim.

# 5. The learned counsel further submitted that upon investigation, the surveyor opined that the fire was not caused by a short circuit, but appeared to a deliberate human act. This conclusion was further supported by an independent expert opinion obtained from Truth Labs.

# 6. It was also contended that the respondent claimed the existence of substantial stock allegedly procured shortly prior to the incident and after enhancement of the insurance coverage. However, upon verification, the agencies shown to have supplied the said material, were found to be either non-existent at the given addresses or were not engaged in the trade of the goods claimed to have been supplied.

# 7. It was further urged that the respondent relied upon a report of the Gujarat Forensic Science Laboratory (GFSL) which indicated the presence of ethyl alcohol, an inflammable substance. According to the appellant, the sample sent namely, parts of the switchboard, had already been burnt, thereby rendering the sample itself unreliable; therefore, the said GFSL report cannot be treated as conclusive.

# 8. It was submitted that a holistic evaluation of all attending circumstances is necessary to determine whether the fire was accidental or deliberate. In the present case, the proximity of procurement of material to the incident, enhancement of insurance coverage, and the discovery that the alleged suppliers lacked the capacity to supply such goods cumulatively establish that the claim is not genuine.

# 9. On the aspect of quantification, the learned counsel submitted that the surveyor’s assessment of loss of Rs. 3,33,63,642/- (Rupees Three Crores Thirty Three Lakhs Sixty Three Thousand Six Hundred and Forty Two) merely reflects the extent of physical damage to the godown and cannot be treated as an admission of liability. It was contended that if the loss itself is consequence of a deliberate and fraudulent act, no claim under the policy would be maintainable, irrespective of the extent of damage. Accordingly, it was prayed that the impugned order passed by the NCDRC be set aside.

# 10. Per contra, the learned counsel appearing for the respondent submitted that during the subsistence of the insurance coverage, an accidental fire occurred on 25.03.2011 in the respondent’s godown due to a short circuit. The incident was duly intimated to the appellant on the same day and was also recorded with the local police. It was contended that the respondent suffered a loss of Rs.28,20,65,797/- (Rupees Twenty Eight Crores Twenty Lakhs Sixty Five Thousand Seven Hundred and Ninety Seven) that the GFSL report conclusively establishes that the fire was accidental in nature.

# 11. In response to a query raised by this Court regarding the authenticity of the alleged suppliers, the learned counsel for the respondent submitted that the claim was made based on the actual supplies, and affidavits of such suppliers had been placed on record. However, it was submitted that the respondent had not independently verified the actual existence or credentials of such suppliers.

# 12. We have considered the rival submissions and perused the material available on record.

# 13. It is evident from the record that the present case involves a fraudulent insurance claim. The respondent enhanced the insurance coverage and procured an additional policy in close proximity to the incident, which raises serious doubt regarding the bona fides of the claim.

# 14. In this context, the Truth Labs Report establishes, through GC-MS analysis of fire debris, the presence of hydrocarbon residues consistent with kerosene in the area identified as the seat of the fire (Zones IX A and X A). Significantly, such traces were absent in samples collected from areas away from the origin of the fire. That apart, the presence of kerosene, a known fire accelerant, at the seat of the fire clearly indicates that it was introduced externally to initiate the fire, thereby ruling out an accidental cause and pointing toward deliberate arson for gain. Further, forensic examination of the electrical infrastructure such as power supply wires, switchboards, and lighting systems, revealed no evidence of short circuit or electrical malfunction. The absence of overheating, annealing, or bead formation in the wiring conclusively negates an electrical cause.

# 15. Additionally, the conduct of the respondent reinforces the inference of fraud. There was delay in furnishing samples and subsequent reliance on fabricated analytical reports, indicating a clear attempt to mislead the investigation. Thus, the forensic report concludes that the fire was the result of deliberate human intervention, with a strong likelihood of it being engineered for unlawful gain.

# 16. The Surveyor’s report corroborates the above conclusions. It reveals material discrepancies between the VAT returns submitted by the Suppliers of the respondent and those filed with the Commercial Taxes Department. The alleged suppliers, in whose names’ invoices were produced to substantiate the claim, were found to be non-existent or unrelated to the claimed transactions, and the invoices produced were evidently fabricated. Notably, the respondent failed to rebut these findings with credible material.

# 17. The investigation further discloses manipulation of accounts and records with a view to inflate the claim. Both the forensic and Surveyor reports unequivocally establish violation of policy conditions, warranting repudiation.

# 18. In view of the above, it stands conclusively established that the fire was not accidental but was the result of a deliberate and orchestrated act of arson.

# 19. Despite these categorical findings, the NCDRC proceeded to allow the claim in part merely on the premise that a fire incident had occurred. Such an approach is legally unsustainable, as it disregards the overwhelming evidence of fraud and deliberate misconduct on the part of the respondent.

# 20. It is a settled principle that fraud vitiates all solemn acts, and no person can be permitted to take advantage of his own wrong. In S.P. Chengalvaraya Naidu v. Jagannath (1994) 1 SCC 1 :1993 SCC OnLine SC 318, this Court held that a judgment or decree obtained by playing fraud is a nullity in the eyes of law. Similarly, in A.V. Papayya Sastry v. Government of Andhra Pradesh (2007) 4 SCC 221 : 2007 SCC OnLine SC 317, it was reiterated that fraud vitiates all judicial acts, whether in rem or in personam.

# 21. Applying the aforesaid principles, we are of the considered view that once it is established that the claim itself is founded on fraud, the entire edifice of the claim collapses and no relief can be granted. Quantification of loss cannot override the foundational requirement of a genuine and bona fide claim.

# 22. There is no concept of partial or equitable relief in cases tainted by fraud. Courts and adjudicatory fora cannot grant compensation merely because some loss is shown to have occurred, when the claim itself is vitiated by fraudulent conduct. An insurance contract cannot be used as an instrument of unjust enrichment. The NCDRC therefore, fell into error in awarding Rs.3,33,63,642/- (Rupees Three Crores Thirty Three Lakhs Sixty Three Thousand Six Hundred and Forty two) towards the alleged loss sustained by the respondent.

# 23. In view thereof, we have no hesitation in holding that the respondent is not entitled to any amount under the policy, and the claim deserves to be rejected in toto.

# 24. Accordingly, the appeal is allowed. The impugned order passed by the NCDRC is set aside. The claim of the respondent stands repudiated. The appellant-Insurance company is absolved of any liability arising out of the said claim. The amount deposited by the appellant before the Registry of this Court shall be refunded to it, along with accrued interest, within a period of two weeks from today.

# 25. Before parting, we deem it appropriate to observe that fraudulent insurance claims involving staged incidents are not uncommon and have serious ramifications on the integrity of the insurance system and public confidence therein.

# 26. In view of the categorical finding of fraud committed in relation to the insurance claim by the respondent, we direct the Commissioner of Police, Ahmedabad, to constitute a Special Investigation Team (SIT) headed by an officer not below the rank of Deputy Commissioner of Police, to conduct a comprehensive investigation into the incident, including the persons involved in the alleged fraud. The investigation shall be completed within a period of three months from today and a report shall be submitted before this Court in a sealed cover. The Commissioner of Police, Ahmedabad, shall ensure full logistical and institutional support to the SIT and shall remain responsible for compliance with these directions.

# 27. The Registry is directed to list the matter on 21.07.2026 at 2.00 PM before the same Bench, treating it as a tied-up / part- heard. A copy of this order shall be communicated to the Commissioner of Police, Ahmedabad, forthwith. 

CIVIL APPEAL NO. 10019 OF 2024 In view of the order passed in Civil Appeal No. 6100 of 2024, of even date, the present appeal stands dismissed.

2. Pending application(s), if any, shall stand disposed of.

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