SCO.LR | 2026 | Volume 6 | Issue 1

Volume 6 Issue 1 of the Supreme Court Observer Law Reports (SCO.LR) is here. In this Issue, we shortlist five judgements of the Supreme Court from last week covering:

• Regularisation of wrongfully allotted public land
• CCI’s authority to reopen approvals 
• State legislations prohibiting betting and gambling 
• GST on online betting and gambling
• Timeline for pronouncing reserved judgements 

Like always, our SCO.LR judgements come with concise summaries, illustrative mindmaps and an easy citation feature. Find more such well-formatted judgements on the SCO.LR landing page. 

********** 

The Supreme Court Observer Law Reports 

SCO.LR | Volume 6 | Issue 1 

25 May – 30 May 2026

 *********

Regularisation of Wrongfully Allotted Plot

Raheja Corp. Private Limited v State of Maharashtra

26 May 2026

Citations: 2026 INSC 551 | 2026 SCO.LR 6(1)[1]

Bench: Justices P.S. Narasimha and Alok Aradhe

The Supreme Court held that it is better for public interest to regularise wrongly allotted public land by charging the market value rather than demolishing it, as it has created long-term social and economic benefits. 

In 2003, the City and Industrial Development Corporation of Maharashtra (CIDCO) allotted a 3,611 sq metre plot in Sector 30A, Vashi, Navi Mumbai to K. Raheja Corp. at Rs. 10,250 per sq metre on an individual application. Subsequently, the appellant invested Rs. 450 crore and made a fully operational shopping mall and hotel. The Bombay High Court in 2014 held the allotment illegal and directed that the land be restored to its “original condition”, requiring that the shopping mall and hotel be demolished. The appellant then filed an application for regularisation and an appeal before the Supreme Court. The state government set up a committee to examine the feasibility and terms of regularisation. 

The Supreme Court set aside the High Court’s judgement. It applied the recommendations of the committee stating that the appellant is liable to pay the market value of the land, as it was in 2014—Rs. 54,400 per sq.meter. The Bench noted that the mall has 150 retailers with 8000 individuals employed.

Key words/phrases: Irregular allotment of land—Land developed with commercial establishments—High Court directs land to be converted to its original condition—Demolition of land—Regularisation application—Supreme Court directs regularisation at market value—Livelihoods and employment—High Court judgement set aside

Read the Judgement here. 

Mindmap

**********

Re-opening of Approval for Combination under Competition Act

Amazon.com NV Investment Holdings LLC v Competition Commission of India

27 May 2026

Citations: 2026 INSC 576 | 2026 SCO.LR 6(1)[2]

Bench: Justices Vikram Nath and Sandeep Mehta

The Supreme Court held that when a company notifies a combination, it must present the transaction to the Competition Commission of India (CCI) in substance, listing all inter-connected steps and commercial arrangements. However, the company is not required to adopt the regulator’s preferred characterisation or labelling of those rights or agreements.

In November 2019, Amazon acquired a 49 percent stake in Future Coupons after securing approval from the CCI under Section 31(1) of the Competition Act, 2002. In June 2021, the CCI issued a show cause notice alleging suppression of material facts in the aftermath of the Amazon-Future dispute. The CCI kept the approval in abeyance in December 2021. It imposed penalties on Amazon and directed it to file a fresh application. This was affirmed by the National Company Law Appellate Tribunal (NCLAT).

The Supreme Court set aside NCLAT and CCI’s order. It held that Amazon had notified its combination in substance and provided the CCI with the relevant agreements. Further, the CCI lacked the authority to suspend a concluded approval,  there being  a limitation barring the reopening of a case after the passage of a year,  under Section 20(1) of the Act. 

Key words/phrases: Approval of combination by the Competition Commission of India under Section 31(1)—Show cause notice issued with alleged irregularities—Upheld by NCLAT—Reopening barred under proviso to Section 20(1) after one year has passed—NCLAT and CCI Order set aside

Read the Judgement here. 

Mindmap

**********

Betting and Gambling in Games of Skill

State of Tamil Nadu v Junglee Games India

27 May 2026

Citations: 2026 INSC 594 | 2026 SCO.LR 6(1)[3]

Bench: Justices J.B. Pardiwala and R. Mahadevan

The Supreme Court held that betting on games of skill amounts to gambling and is not protected under Article 19(1)(g). 

The respondents — gaming companies — challenged the constitutionality of amendments made to the Tamil Nadu Gaming Act, 1930 and the Karnataka Police Act, 1963, in the Madras and Karnataka High Courts respectively. The amendments prohibit betting and gambling. The High Courts held that states cannot regulate betting on activities based on skill under Entry 34 of State List. The state governments appealed against the judgements on the ground that “betting and gambling” under Entry 34 cannot be read rigidly to invalidate legislative competence. 

The Supreme Court set aside the judgements, noting that even a game of skill played with stakes on the outcome amounts to “betting” under Entry 34. Further, Entry 34 does not include protection from betting on games of skill. 

Key words/Phrases: Betting and gambling—Entry 34 of State List—Seventh Schedule—Protection afforded to games of skill—Amendment to State Legislations—Betting and gambling prohibited—Challenge to amendments—Entry 34 does not include betting on game of skill—Amendments set aside—Civil Appeal—Betting on game of skill amounts to gambling—High Court judgements set aside. 

Read the Judgement here. 

Mindmap

**********

Goods and Service Tax on Online Gaming

Directorate General of Goods and Services Tax Intelligence (HQs) v Gameskraft Technologies Private Limited

27 May 2026

Citations: 2026 INSC 595 | 2026 SCO.LR 6(1)[4]

Bench: Justices J.B. Pardiwala and R. Mahadevan

The Supreme Court held that the character of betting and gambling does not depend on whether the game is of skill or chance but whether there is an existence of stakes. The online gaming activities played on digital platforms constitute betting and gambling for the purpose of the Goods and Service Tax (GST) framework. 

Tax authorities issued show cause notices seeking 28 percent GST on the actionable claims arising from betting and gambling. In May 2023, the Karnataka High Court quashed the notice to Gameskraft Technologies, holding that online rummy is a game of skill beyond betting and gambling. The tax authority approached the Supreme Court. Other gaming operators, fantasy sports platforms and casino interests filed challenges to the levy and the 2023 CGST amendments. The Supreme Court heard the batch together.

The Bench set aside the Karnataka High Court judgement. It restored the show cause notice against Gameskraft, and upheld the levy as constitutionally valid. It held the 2023 amendments clarificatory and retrospective.

Keywords/phrases: Show cause notice levying 28 percent tax on gambling and betting—Karnataka High Court quashes notice—Authorities appeal to the Supreme CourtStakes amount to Betting and gambling irrespective of games of skill or chance—Levy upheld—Karnataka High Court judgement set aside

Read the Judgement here. 

Mindmap

**********

Pronouncement of Reserved Judgements by High Courts

Pila Pahan @ Peela Pahan v State of Jharkhand

29 May 2026

Citation: 2026 INSC 604 | 2026 SCO.LR 6(1)[5]

Bench: Chief Justice Surya Kant and Justice Joymalya Bagchi

The Supreme Court held that delay in pronouncement of a reasoned judgement causes irreparable loss to the parties. It issued comprehensive guidelines under Article 142, for the pronouncement of reserved judgements, uploading of judgements, monitoring of delayed matters and remedies available to litigants in cases of prolonged delay before High Courts.

The petitions arose from delays in the pronouncement of criminal appeals reserved by the Jharkhand High Court. The petitioners had been convicted in separate criminal cases and had preferred appeals before the High Court, where arguments were heard and judgements reserved between January and June 2022. The petitioner approached the Supreme Court alleging undue delay in the delivery of the reserved judgements. During the proceedings, the Supreme Court called for reports from High Courts across the country regarding matters in which judgements had been reserved but remained unpronounced, and regarding delays in uploading judgements after pronouncement.

The Supreme Court held that High Courts should endeavour to pronounce reasoned judgements within three months of reserving judgement. It observed that the right to life and personal liberty under Article 21 extends to every stage of a proceeding

Keywords/phrases: Delayed pronouncement of reserved judgements—High Courts—Article 21—Article 142—Reserved judgements remained unpronounced for months and years—Reasoned judgements—Three months from date of reserving judgement

Read the Judgement here. 

Mindmap