Thursday, 24 July 2014

Whether condition of obtaining certificate U/S 230-A of Income Tax Act can be said to be condition precedent for enforceability of decree?


Now coming to the first submission of the Learned Counsel for the Decree Holder, no doubt a consent decree presupposes an agreement which has been arrived at between the parties and in terms of which agreement, the parties desire that the proceedings be disposed of. The consent decree in the instant case, no doubt reflects the agreement which was arrived at between the parties in the said Suit. However, the said agreement cannot be equated with an agreement of which the enforcement is sought in a Suit. The agreement in question in the instant matter has translated itself into a decree and therefore all the attributes of a decree would be applicable to it. The submission of the Learned Counsel for the Decree Holder based on clause 4 seems to be attractive at the first blush, but does not hold water on deeper scrutiny. As indicated above, the decree in question was enforceable from day one as the Court in question was not required to do anything further in the matter for the decree being made enforceable. Therefore, the analogy sought to be drawn by the Learned Counsel appearing on behalf of the Decree Holder with an agreement which contains a covenant providing for compliance as and when the Plaintiff calls upon the Defendants to do so cannot be applied in the facts of this case, as though in the instant case the Suit has been disposed of in terms of the agreement, the agreement is nevertheless a decree passed in the Suit and would therefore be executable in terms of Article 136 of the Limitation Act. Though the submission based on clause 4 does not seem to have been urged before the Executing Court, this Court has proceeded to consider the same as the same impinges upon the entitlement of the Decree Holder to get the decree executed.
12. In so far as the submission based on Section 230-A of the Income Tax Act is concerned, in my view, the said condition of obtaining the certificate under Section 230-A of the Income Tax Act cannot be said to be a condition precedent for the enforceability of the decree and therefore cannot extend the period of limitation or suspend the period of limitation till such time as the certificate is obtained. The Executing Court has therefore rightly observed that whether the Decree Holder could have waited indefinitely for the Judgment Debtors to get the said certificate and whether the period of limitation would stand suspended till such time. In my view, the repeal of Section 230-A from the Statute Book in the year 2001, cannot aid the case of the Decree Holder as the decree was enforceable right from day one.
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
 CIVIL APPELLATE JURISDICTION
Shri Rajendra Singh s/o Chandrama Singh
Vs
Deenanath Keshav Bhoir

Decided On: 13.06.2013


 Citation: 2013(4)ABR1169, 2013(5)ALLMR821, 2013(5)BomCR804, 2013(4)MhLj409

Rule, with the consent of the learned counsel for the parties 
made returnable forthwith and heard.
2
The   writ   jurisdiction   of   this   Court   under   Article   227   of   the 
Constitution of India is invoked against the Judgment and Order dated 21 st 
April 2012 passed below Exhibit­1 in Special Darkhast No.28 of 2010 by 
which   the   Executing   Court   has   held   that   in   so   far   as   the   execution   of 
conveyance is concerned, the same is barred by limitation.
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The facts necessary to be cited for an adjudication of the above 
3
Petition can be stated thus :­
The Petitioner herein is the original Plaintiff in Special Civil 
Suit No.1208 of 1994.  The Respondents herein are the original Defendants 
in the  said  suit.  The  said  suit  was filed for  specific performance  of  the 
Agreement of Sale dated 25th January 1994, which Agreement of Sale was 

in   respect   of   the   suit   lands.   The   cause   for   filing   the   said   suit   was   the 
reluctance of the Defendants in complying with the terms and conditions 
of the said Agreement of Sale dated 25 th January 1994. In the said suit the 
relief sought was in respect of specific performance of the said Agreement 
of Sale dated 25th January 1994 as also the letter dated 18th October 1994. 
During   the   pendency   of   the   said   suit,   the   parties   entered   into   a 
compromise which was recorded in the Consent Terms which were drawn 
up. The said Consent Terms were filed in the said suit on 5 th January 1995 
and the said suit was decreed in terms of the said Consent Terms. It has 
been recorded in the said Consent Terms which have been signed by the 
parties that the Defendants have received a sum of Rs.25,50,000/­ from 
the Plaintiff i.e. the Petitioner herein in full and final settlement towards 
the consideration of the suit lands.  The Defendants undertook to execute 

conveyance in respect of the suit lands.  The Defendants also undertook to 
produce the  Certificate under Section 230­A of the Income Tax Act, 1961 
on or before execution of the conveyance.   The said Consent Terms also 
provided   that   the   Plaintiff   i.e.   the   Petitioner   herein   would   provide   a 
residential flat admeasuring 600 sq.ft. free of cost to the Defendants which 
would stand in the name of Prema Dinanath Bhoir.   It is the case of the 
Plaintiff that after filing of the Consent Terms dated 5 th January 1995, he 

requested Dinanath Keshav Bhoir – the original Defendant No.1 on many 
occasions when they met personally to obtain the said Certificate under 
Section 230­A of the Income Tax Act.   However, the said Dinanath Bhoir 
did not take any steps to obtain the said Certificate.  On 12 th July 1998 the 
said Dinanath Bhoir died. It is the case of the Plaintiff that thereafter he 
followed up the matter with Ramesh Dinanath Bhoir and Ranjan Dinanath 
Bhoir requesting them to get the said Certificate as it was the obligation of 
the Defendants to get the said Certificate under the said Consent Terms. 
However,   in   spite   of   the   repeated   requests   of   the   Plaintiff,   the   said 
Certificate was not obtained by either Ramesh Bhoir or Ranjan Bhoir. It is 
the case of the Plaintiff that thereafter on 1 st June 2001 there was a repeal 
of Section 230­A of the Income Tax Act by virtue of which the said Section  
230­A stood deleted from the statute book.   It is the case of the Plaintiff 
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that he was ready to provide the residential flat admeasuring 600 sq.ft as 
per the said Consent Terms to the Defendants. However, the Defendants 
demanded money in lieu of the flat as consideration. After discussion it 
was agreed between the parties that the Plaintiff would pay an amount of 
Rs.11,00,000/­ in lieu of the flat. According to the Plaintiff, he has paid the 
amount   of   Rs.8,00,000/­   by   cheque   and   Rs.3,00,000/­   by   cash   to   the 
Defendants, which the Defendants have accepted and issued a receipt for 

the same. It is the case of the Plaintiff that after the receipt of the amounts 
in lieu of the flat and in view of the fact that the Defendants had already 
received   the   amount   of   consideration   as   per   the   Consent   Terms,   the 
Defendants would come forward for execution of the Conveyance Deed. 
The   Plaintiff   accordingly   prepared   a   draft   Conveyance   Deed   and   called 
upon   the   Defendants   for   signing   the   same.   However,   the   Defendants, 
according to the Plaintiff, for the reasons best known to them, refused to 
sign the Conveyance Deed.  
4
The Plaintiff by his Advocates letter / notice dated 12­1­2010 called 
upon the Defendants to execute the conveyance within 15 days from the 
date   of   the   receipt   of   the   said   letter/notice   in   respect   of   the   lands 
mentioned in Annexure­A of the Consent Terms. On the Defendants failing 
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to comply with the said notice, the Plaintiff filed Special Darkhast No.28 of 
2010 for execution of the consent decree dated 5­1­1995 passed in the said 
Suit.   The   Plaintiff   whilst   seeking   execution   of   the   said   decree   had   also 
sought   other   connected   reliefs   which   are   mentioned   in   the   execution 
application. The list of the suit properties was also annexed to the said 
execution application being Annexure­A. The prayers in the said Special 

Darkhast No.28 of 2010 are reproduced hereunder for ready reference :­
“(1)  The Notices under O.21 R.22 of C.P
.C. May be 
issued to the Defendants calling upon them to show 
cause   why   the   Decree   should   not   be   executed 
against them.
(2) It is  prayed that simultaneously the  Notices 
under O.21 R.34(2) of C.P
.C. May be issued to the 
Defendants and the draft of the Sale Deed of the 
suit property may be served on the Defendants.
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(3) If  the  Defendant  objects to  the  Draft  which 
may be heard & decided. The Draft of the Sale Deed 
may be approved as per the provision under O.21 
R.34(3) of C.P
.C.
(4) The   Commissioner   may   be   appointed   to 
execute   the   Conveyance   Deed/Sale   Deed   and   be 
directed to sign the said Sale Deed on behalf of the 
Defendants and the said Conveyance Deed may be 
registered in the Office of the Sub­Registrar Thane. 
(As per Provision under O.21 R.34(4) & 6 of C.P
.C. 
AND

(5) The D.H. Ready to pay the costs and expenses 
of   Stamp   Duty   &   Registration   charges   as   would 
payable   and   Sundry   expenses   etc.   directly   at   the 
time of registering the said Deed of Conveyance by 
the Commissioner.
wp-6777-12.sxw
(6) The Defendants are interfering the possession 
of the Plaintiff over the lands described in Annexure 
A and hence Defendants may also be served with 
notice   under   O.21   R.   32(1)   of   C.P   for   willful 
.C.
disobedience of Decree.

(7) The   Moveable   Property   of   the   Defendants 
may be attached by Issue of Warrant of Attachment 
under O.21 R.32(1) r.w. 43 of  C.P
.C. And may be 
sold   under   O.21   R.   32(3)   of   C.P   and   to   pass 
.C.
further   orders   of   awarding   compensation   to 
Plaintiff from the amount realized in Auction Sale.
(8) Any other Orders as deem fit and proper may 
be passed.
(9) D.H. Crave leave to add, alter, amend, herein 
and pray for any other relief.”
In the said execution application, the Judgment Debtors filed their reply 
which   was   numbered   as   Exhibit­13   and   inter   alia   took   up   various 
contentions amongst which was the contention that a fraud was practiced 
on the Judgment Debtors/Defendants in the matter of filing the Consent 
Terms  in   the  said  Suit.   The   Judgment   Debtors  also   filed   an   application 
(Exhibit 24) for framing of a preliminary issue of limitation in so far as the 
maintainability of the said Special Darkhast No.28 of 2010, is concerned. 

The application for framing the said issue of limitation was founded on the 
fact   that   since   the   consent   decree   is   dated   5/1/1995   the   execution 
application   filed   in   the   year   2010   was   hopelessly   barred   by   limitation 
having regard to Article 136 of the Limitation Act. In the said application, 
the Judgment Debtors had also prayed that till the said point of limitation 
is decided, the execution of the decree be stayed. 
In so far as the application for Stay (Exhibit 17) of the decree 

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was concerned, the Executing Court considered the said application and on 
the ground that since the execution proceeding has been registered, the 
same is within limitation and therefore the application Exhibit 17 for stay 
of   the   execution   proceeding   could   not   be   entertained   and   accordingly 
rejected   the   same   by   order   dated   24­2­2011.   The   said   order   was 
challenged by the Judgment Debtors by filing a Writ Petition in this Court 
being Writ Petition No.2128 of 2011. The said Writ Petition was allowed by 
a Learned Single Judge of this Court and the Learned Single Judge held 
that the direction to register the execution Petition, can by no stretch of 
imagination   be   held   to   be   conclusive   determination   of   the   issue   of 
limitation. The Learned Judge therefore set aside the said order dated 24­
2­2011 and remanded the matter back to the Trial Court for deciding the 

objection as regards the maintainability of the execution Petition afresh on 
the point of limitation.

On   remand,   the   Executing   Court   has   passed   the   impugned 
order   dated   21/04/2012   by   which   the   Executing   Court   held   that   the 
execution proceeding is not barred by limitation entirely and that the same 
is barred only in respect of the conveyance of the Suit property which is 

sought. The   Executing Court as can be seen held that obtaining of the 
certificate under Section 230­A of the Income Tax Act cannot be said to be 
a condition precedent for enforceability of the decree, in the sense which 
would   suspend   the   limitation   period.   The   Executing   court   held   that   a 
perusal of the entire decree no where discloses that the enforceability of 
the  decree was to take place after happening of a certain specified event. 
The Executing Court, in so far as the aspect of certificate under Section 
230­A of  the  Income   Tax Act  is concerned, observed  that  the   period  of 
limitation would not stand suspended indefinitely till such time as the said 
certificate   under   Section   230­A   of   the   Income   Tax   Act   was   obtained. 
However, as indicated above, the Executing Court held that the aspect of 
the   possession   of   the   property   and   also   the   aspect   that   the   Defendants 
would not disturb the possession of the Plaintiff in so far as the said reliefs 

are concerned, there is no limitation as such according to the Executing 
Court for their enforcement. The Executing Court therefore held that the 
execution proceeding is beyond limitation only in so far as the conveyance 
sought of the Suit property is concerned. As indicated above, it is the said 
order dated 21­4­2012 which is impugned in the present Petition. 
SUBMISSIONS   ON   BEHALF   OF   THE   PETITIONER   BY   THE  

That the application for execution of the decree is filed within 
(A)

LEARNED COUNSEL SHIR G S GODBOLE
time considering the stipulations in the decree;
(B)
That the decree in question is a declaratory decree in respect 
of the suit lands mentioned in Annexure­A to the suit.   The 
(C) 
said decree is therefore valid and binding on the parties;
That   the   entire   consideration   has   been   paid   and   the 
conveyance was to be executed as and when called upon by 
the Petitioner, therefore, the application for execution as filed 
in the year 2010 is not beyond limitation;

That the decree incorporates the agreement which has been 
(D)
arrived   at   between   the   parties.     By   virtue   of   the   said 
agreement a new contract is brought into force.   In terms of 
clause   12   in   the   event   the   Respondents   fail   to   execute   the 
conveyance in favour of the Petitioner when called upon to do 
so,  the   clause   provides  that  the   same   can  be   done   through 

Court   Commissioner.     Therefore,   the   occasion   to   file   the 
execution application would arise only when the Respondents 
denied execution of the conveyance when called upon to do so 
(E)
by the Petitioner.
That the Plaintiff called upon the Respondents to execute the 
conveyance   by   letter/notice   dated   12/1/2010.   The   date   of 
(F)
reckoning for limitation would be the said date i.e. 12/1/2010 
from which the limitation would start to run in so far as the 
application for execution is concerned.
That   the   Petitioner   has   paid   the   further   amounts   to   the 
Defendants in lieu of the constructed area which was to be 

handed   over   to   the   Respondents   and   the   same   was   done 
between   the   period   2004­2007   and   therefore   the   execution 
years of the said amount being paid.
(G)
application filed in the year 2010 was within the period of 12 
That since Section 230A of the Income Tax Act was repealed 
on   01/06/2001,  the   Execution   Application  filed   in   the   year 
That   the   execution   of   the   decree   stands   apart   from   the 
(H)

2010 was therefore within limitation;
enforceability of the decree. The enforceability of the decree 
in the instant case arose only when the Respondents failed to 
comply with the notice issued by the Petitioner on 12/1/2010 
as regards execution of the conveyance;
(I)
That the judgment reported in AIR 1999 SC 3421 in the case 
of  W.B.   Essential   Commodities   Supply   Corporation   v/s.  
Swadesh Agro Farming and Storage Pvt. Ltd and another 
has no application in the facts of the present case, as in the 
instant case the conveyance was to be executed only after the 

Defendants were to obtain the certificate under Section 230A 
of the Income Tax Act.  Such was not the case in the judgment 
in  W.B.   Essential   Commodities   Supply   Corporation's  case 
(Supra)   where   the   Apex   Court   was   concerned   with   the 
enforceability of a money decree, which was not contingent 
upon the happening of any extraneous event.
SUBMISSIONS ON BEHALF OF THE RESPONDENTS BY THE  


LEARNED SENIOR COUNSEL SHRI SHAILESH SHAH.
(I)
That though there was an agreement between the parties, the 
said   agreement   translated   itself   into   a   decree   which   was 
passed by the Executing Court in terms of the said agreement;
(II)
That the  Petitioner  cannot  rely upon  the  said  agreement  to 
contend that the cause for filing the application for execution 
would arise only when there was refusal to comply with the 
decree by the Defendants. Since in the instant case, the decree 
has been passed in terms of the agreement which has been 
arrived at between the parties, the period of limitation that 

would apply would be one in respect of a decree and not one 
(III)
in respect of a contract;
That the Petitioner cannot rely upon the said agreement so as 
to seek applicability of the provisions relating to a contract.  If 
the   Petitioner   seeks  enforcement  of  the   agreement,  then  he 
ought to have filed a suit for specific performance and not an 

application for execution of the decree. The said clause would 
not   aid   the   Petitioner   to   contend   that   Article   136   of   the 
Limitation   Act   would   not   apply.     According   to   the   learned 
Senior Counsel for the Respondents for the purposes of Article 
136 of the Limitation Act what is relevant is the enforceability 
of the decree and not executability of the decree.  The learned 
Senior Counsel sought to rely upon the judgments of the Apex 
Court reported in 1]  AIR 1999 SC 3421  in the case of  W.B. 
Essential   Commodities   Supply   Corporation   v/s.   Swadesh  
Agro Farming and Storage Pvt. Ltd and another and 2]  AIR  
2001  SC  3404  in  the   case   of  Hameed  Joharan  v/s  Abdul  
Salam  in support of the said contention.

(IV)
That   the   submission   based   on   clause   12   viz.   that   the 
conveyance was to be executed as and when called upon by 
the   Petitioner   was   not   a   point   which   was   urged   before   the 
Executing Court and has been urged for the first time in this 
Court. The Petitioner is therefore dis­entitled to raise the said 
point as the said point was not for consideration before the 
(V)

Executing Court.
That the  receipts in respect of payments made between the 
year 2004­2007 do not mention that the said payments were 
towards the constructed portion which was to be handed over 
to  the  Defendants  by  the   Petitioner,  and  therefore,  the  said 
receipts cannot aid the Petitioner to get the time extended;
(VI)
That   Section   18(1)   of   the   Limitation   Act   would   have   no 
application as the receipts in question are after the decree has 
been passed by the Executing Court; and would also not apply 
in view of clause (c).
(VII)

That the permission to be obtained under Section 230A would 

not   postpone   the   execution   unless   the   specified   date   was 
mentioned by which date the permission was to be obtained, 
as rightly observed by the Executing Court, enforceability of 
the   decree   cannot   be   postponed   indefinitely   on   the   ground 
that the permission under Section 230A of the Income Tax Act 
was   to   be   obtained.   The   learned   Senior   Counsel   for   the 
Respondents in support of the said contention sought to place 
reliance   on   the   judgment   of   a   learned   Single   Judge   of   this 
Court reported in 2003(5) Bom. C.R. 565 in the case of Om  
others.
Prakash Navani & another v/s Juno Changas Pereira and  
CONSIDERATION
9
In   the   context   of   the   submissions   made   by   the   Learned 
Counsel for the parties and especially the submissions made on behalf of 
the Decree Holder, it would be apposite to reproduce the relevant clauses 
of the said decree dated 5/1/1995 which are clauses 3, 4, 5, 6, 7, 9, 10 and 
12.
“3.  The   defendants   agree   and   confirm   that   the 
plaintiff is in possession of all the lands described in 
Annexure “A” to these Consent Terms and the plaintiff 

has   been   put   in   possession   of   the   said   land   in   part 
performance of the agreement to sell executed by the 
defendant No.1 in favour of the plaintiff.

4.
The defendant shall sell and convey all the lands 
described   in   Annexure   “A'   hereto   in   favour   of   the 
plaintiff   or   his   nominee   or   nominees   as   and   when 
called upon to do so. The defendants declare that they 
have received a total sum of Rs.25,50,000/­ from the 
plaintiff in full and final settlement of price of the said 
lands described in Annexure A hereto. The defendants 
undertake to execute conveyance in respect of the said 
lands   described   in   Annexure   A     as   and   when   called 
upon   to   do   so   by   the   plaintiff   or   his   nominee   or 
nominees. The defendants shall join all persons, if any, 
to the said conveyance for effectively transferring the 
said   lands   in   favour   of   the   plaintiff   or   his 
nominee/nominees. The said conveyance shall be duly 
registered   under   the   provisions   of   the   Indian 
Registration Act, 1908 and the Defendants shall appear 
in the office of the concerned sub­registrar for lodging 
the   conveyance   and   for   admitting   execution   thereof. 
The Plaintiff shall provide to the defendants jointly a 
residential flat free of cost admeasuring 600 sq.feet of 
carpet area i.e. 750 sq.feet built up in any one of the 
building   to   be   constructed   on   the   said   lands   which 
shall stand in the name of Kum. Prema Dinanath Bhoir.

5. 
The defendants shall produce a Certificate under 
Section   230­A   of   the   Income   Tax   Act,   1961   on   or 
before   execution   of   the   Conveyance.   The   defendants 
shall   do   all   such   acts,   deeds   and   things   which   are 
necessary and required for effectively transferring the 
said lands in favour of the plaintiff or his nominee or 
nominees as aforesaid.
6.
The   defendants   shall   execute   an   Irrevocable 
General Power of Attorney in favour of the plaintiff or 
his nominee or nominees as per the draft prepared by 
the   plaintiff   or   his   nominees   as   the   case   may   be   in 

7.
It is hereby declared that the Power of Attorney 
dated   25th  January,   1994,   the   declaration   dated   25th 
January 1994 is valid and subsisting and binding on 
the defendants.
respect   of   the   properties   described     in   Annexure   A 
hereto.
9.
The plaintiff shall be entitled to develop the said 
lands by construction of building or buildings thereon 
and by selling flats and premises therein.

10. It   is   declared   that   the   defendants   have   no 
subsisting right, title or interest of whatsoever nature 
in respect of the said lands or any part thereof.
10
12. In the event of the defendants failing to execute 
the   conveyance   as   aforesaid   or   failing   to   get   the 
conveyance   registered,   some   fit   and   proper   person 
should be appointed as court Commissioner to execute 
the conveyance on behalf of the defendants and get the 
same duly registered in the office of the sub­registrar.” 
On   behalf   of   the   Decree   Holder   much   store   was   laid     on 
clauses 4 and 5 to buttress the submission that the execution proceeding as 
filed was within limitation. It was the submission of the Learned Counsel 
appearing on behalf of the Decree Holder that the Suit has been disposed 
of in terms of the agreement which was arrived at between the parties and 
which agreement is reflected by the various clauses of the consent terms. It 
was  the   submission  of  the  Learned  Counsel  appearing  on  behalf   of   the 
Decree Holder that the Defendants were obliged in terms of clause (4) to 

sell and convey the lands covered in Annexure­A in favour of the Plaintiff 
or his nominee  or nominees as and when  called upon to do so. It was 
further the submission of the Learned Counsel for the Decree Holder that 
the Defendants had undertaken to execute conveyance in respect of the 
properties mentioned in Annexure A as and when called upon to do so by 
the   Plaintiff   or   his   nominee   or   nominees.   The   Learned   Counsel   would 
therefore contend that the occasion to file the execution proceeding arose 

when the Defendants failed to comply with the advocate's notice dated 12­
1­2010 as it is by the said notice that the Decree Holder called upon the  
Defendants to execute the conveyance in his favour. It was the submission 
of   the   Learned   Counsel   for   the   Decree   Holder   that   the   execution 
proceeding as filed in the year 2010 therefore cannot be said to be beyond 
limitation.   It   was   also   the   submission   of   the   Learned   Counsel   for   the 
Decree   Holder   that   it   was   the   obligation   of   the   Defendants   to   get   the 
certificate under Section 230­A of the Income Tax Act and that they had 
failed to discharge the said obligation. However, fortunately for the Decree 
Holder the said Section 230­A was repealed in the year 2001 and therefore 
the execution Petition filed in the year 2010 can be said to be in limitation.

Before   adverting   to   the   aforesaid   submissions,   it   would   be 

relevant to consider the nature of the decree of which execution is sought. 
A reading of the aforesaid clauses 3, 4, 5, 6, 7, 9, 10 and 12 unmistakably 
and   unequivocally   lead   to   a   conclusion   that   the   decree   in   question     is 
enforceable from day one and that the said decree was not a conditional 
decree or was contingent upon the happening of certain events.
Now coming to the first submission of the Learned Counsel for 


the Decree Holder, no doubt a consent decree presupposes an agreement 
which   has   been   arrived   at   between   the   parties   and   in   terms   of   which 
agreement,   the   parties   desire   that   the   proceedings   be   disposed   of.   The 
consent decree in the instant case, no doubt reflects the agreement which 
was   arrived   at   between   the   parties   in   the   said   Suit.   However,   the   said 
agreement cannot be equated with an agreement of which the enforcement 
is sought in a Suit. The agreement in question in the instant matter has 
translated itself into a decree and therefore all the attributes of a decree 
would be applicable to it. The submission of the Learned Counsel for the 
Decree Holder based on clause 4 seems to be attractive at the first blush, 
but does not hold water on deeper scrutiny. As indicated above, the decree 
in question was enforceable from day one as the Court in question was not 
required to  do anything further in the matter for the decree being made 

enforceable. Therefore, the analogy sought to be drawn  by the Learned 
Counsel   appearing   on   behalf   of   the   Decree   Holder   with   an   agreement 
which   contains   a   covenant   providing   for   compliance   as   and   when   the 
Plaintiff calls upon the Defendants to do so cannot be applied  in the facts  
of this case, as though in the instant case the Suit has been disposed of in 
terms of the agreement, the agreement is nevertheless a decree passed in 
the Suit and would therefore be executable in terms of Article 136 of the 

Limitation Act. Though the submission based on clause 4 does not seem to 
have been urged before the Executing Court, this Court has proceeded to 
consider   the   same   as   the   same   impinges   upon   the   entitlement   of   the 
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Decree Holder to get the decree executed.
In so far as the submission based on   Section 230­A of the 
Income Tax Act is concerned, in my view, the said  condition of obtaining 
the certificate under Section 230­A of the Income Tax Act cannot be said to 
be a condition precedent for the enforceability of the decree and therefore 
cannot extend the period of limitation or suspend the period of limitation 
till   such   time   as   the   certificate   is   obtained.   The   Executing   Court   has 
therefore   rightly   observed   that   whether   the   Decree   Holder   could   have 
waited indefinitely for the Judgment Debtors to get the said certificate and 

whether the  period of limitation would stand suspended till such time. In 
my view, the repeal of Section 230­A from the Statute Book in the year 
2001,   cannot   aid   the   case   of   the   Decree   Holder   as   the   decree   was 
enforceable right from day one.
Now   coming   to   the   Judgment   in  Hameed   Joharan's  case 
14
(Supra), the Apex Court in the said Judgment held that for the purposes of 

Article 136 what is relevant is as to when the decree became enforceable 
and not when decree became executable. The Apex Court further held that 
if no  conditions are attached to the decree and the same has been passed 
declaring the rights of the parties finally and the Court  is not required to 
deal with the matter any further, then the decree becomes enforceable on 
the   day   when   it   was   passed.   The   test   according   to   the   Apex   Court   is 
whether the Court is left out something for being adjudicated at a later 
point of time or is the decree contingent upon the happening of an event 
i.e. to say the Court by its own order postpones the enforceability of the 
decree. In the event of there being no postponement by a specific order of 
Court, the decree is enforceable immediately. In the facts of the present 
case, the decree nowhere discloses that it specifies some future date for its 
enforcement, the court has not postponed the enforceability of the decree 

by   any   order.   Hence   the   decree   in   question   in   the   present   case   was 
enforceable from day one i.e. 5­1­1995. The said Judgment therefore can 
hardly said to aid the case of the Decree Holder in so far as getting over 
the aspect of limitation is concerned.
In  W.B.   Essential   Commodities   Supply   Corporation's  case 
15
(supra) the Apex Court was concerned with the enforceability of a money 

decree.   The   Apex   Court   held   that   a   decree   or   order   is   said   to   be 
enforceable when it is executable, and for a decree to be executable, it 
must be in existence.   The Apex Court further held that a decree would be 
deemed to come into existence immediately on the pronouncement of the 
judgment. In the facts of the case before it where the decree was a money 
decree,   the   Apex   Court   held   that   the   decree   became   enforceable 
immediately   on   the   pronouncement   of   the   judgment,     and   therefore,   it 
cannot   be   said   that   the   delay   in   drawing   up   the   decree   renders   it 
unenforceable from the date of the judgment.   The Apex Court held that 
only in cases where an extraneous event is to happen or there is a statutory 
bar that the decree is not enforceable from the date of its pronouncement. 
The view taken by the Apex Court in W.B. Essential Commodities Supply 
Corporation's case (supra) can therefore be said to be the consistent view 

of the Apex court on the said point.   
In Omprakash Navani's case (supra) a Learned Single Judge 
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of this Court was also concerned with the execution of a consent decree 
passed in a Suit. In the said proceeding also, an issue of limitation was 
raised   questioning   the   maintainability   of   the   execution   Petition.   In   the 
context of the above Petition, clause (5) of the consent decree passed in 

the   said   Suit   is   relevant   and   for   ready   reference   is   reproduced   herein 
under: 
(5) the defendant Nos.1 and 2 do obtain permission of 
the  Board of  Trustees of  the  Port of Bombay to  the 
assignment   of   the   lease   of   the   said   immovable 
property   in   favour   of   the   Plaintiffs.   The   Plaintiffs 
undertake to this Hon'ble court to accept such terms 
and conditions that  may be imposed by the Board of 
Trustees of the Port of Bombay and not to raise any 
objection thereto.
The consent decree passed in the said case was dated 20­8­1983 and the 
Execution   Application   No.259   of   2002   was   therefore   undisputedly   filed 
after the period of 12 years prescribed by Article 136. A submission was 
sought to be advanced on behalf of the Decree Holders/Plaintiffs in the 
said case that the said decree was a conditional decree and the same would 
became   enforceable   only   upon   happening   of   the   event   of   obtaining 

permission by Bombay Port Trust for the assignment of the lease of the said 
immovable property in favour of the Plaintiffs. The said submission was 
not countenanced by a Learned Single Judge of this Court. The Learned 
Single Judge held that on a reading of the clauses of the said decree, it 
could not be said that the same was a conditional decree as the said decree 
became enforceable from the day when it was passed unless the decree 
itself specifies some future date for its enforcement. The Learned Judge 

observed that in the said case, there is no specific date provided for the 
enforcement of the decree. The facts in Navani's case (Supra) can be said 
to be on all fours with the facts of the present case as in  Navani's  case 
(Supra) the permission of the Board of Trustees of  the Port of Bombay was 
to be obtained where as in the present case, the certificate under Section 
230­A of the Income Tax Act was to be obtained. Hence   in my view, the 
fact that the permission under Section 230­A was to be obtained would not 
make the decree in question a conditional decree so as to extend the period 
of limitation or suspend the period of limitation from running till such time 
as the certificate was obtained.  

The   Learned   Counsel   appearing   for   the   Decree   Holder   also 
sought to rely upon Section 18(1) of the Limitation Act to contend that 
as been accepted by the Judgment Debtors between the 
years 2004 to 2007 in lieu of the flat admeasuring 600 sq.ft. which was to 
be handed over to the Judgment Debtors, the limitation period would get 
extended as a fresh period of limitation would have to be computed from 
the date of payment and therefore the application filed in the year 2010 
was within time. In so far as the said submission is concerned, a serious 
objection   was   taken   on   behalf   of   the   Judgment   Debtors   to   the   said 

submission on the ground that the receipts which are sought to be relied 
upon in the present Petition do not disclose that the payment was made in 
lieu of the flat which was to be handed over to the Judgment Debtors. 
Secondly,   the   Learned   Counsel   appearing   for   the   Decree   Holder   would 
rightly  rely  upon   clause   (c)    of   Section   18  of  the   Limitation  Act  which 
carves   out   an   exception   in   so   far   as   the   application   for   execution   of   a 
decree is concerned, the said clause (c) provides that an application for 
execution   shall   not   be   deemed   to   be   an   application   in   respect   of   any 
property or right. Hence Section 18 (1) would have no application to the 
execution of a decree in the  present case and therefore the receipts which 
are   sought   to   be   relied   upon   for   payments   being   made   in   lieu   of   the 
constructed portion  to be handed over to the Judgment Debtors, would 
not in any manner aid the Decree Holder in getting the time extended.

For   the   above   mentioned   reasons   there   is   no   merit   in   the 
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above Petition. The impugned Judgment and Order of the Trial Court does 
not   merit   any   interference   in   the   writ   jurisdiction   of   this   Court   under 
Article   227   of   the   Constitution   of   India.   The   above   Writ   Petition   is 
accordingly dismissed. Rule discharged with no order as to costs.

[R.M.SAVANT, J]


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