Sunday, 6 November 2016

When court can grant temporary injunction restraining creation of third party interest in suit property?

Merely because Section 52 of the Transfer of
Property Act is existing and operative, it does not mean that the

plaintiff is not entitled to pray for and get interim injunction
when   there   is   clear  prima   facie  case   in   favour   of   the
respondent/plaintiff to protect the suit property pending disposal
of   the   suit.     The   discretionary   relief   of   interim   injunction   is
granted on the basis of prima facie case, balance of convenience,
and consideration of irreparable loss with a view to protect the
suit property as it is and not to allow creation of irreversible
situation whereby legal and valid claim of the plaintiff is likely to
be defeated by transfer/alienation of the suit property by the
defendant in the case.  Dishonesty of litigant intending to defeat
the probable decree, can be prevented by appropriate interim
order, when necessary in the facts and circumstances of the case.
IN THE HIGH COURT OF JUDICATURE AT BOMBAY,
NAGPUR BENCH, NAGPUR
APPEAL AGAINST ORDER NO.8 OF 2015
Harish Bulchand Tejwani,

V
Nandlal Hakikatrai Motwani,

CORAM : A. P. BHANGALE, J. 
DATE : AUGUST 14, 2015
Citation: 2016 (1) ALLMR 127

1.    By   this   appeal   against   order   preferred   under   Order
XLIII Rule 1(r) of the Code of Civil Procedure, the legality and
validity of grant of interim injunction passed below order Exh.5
on 26.9.2014, in Special Civil suit No.83 of 2013, by learned Civil

Judge Senior Division, Akola is questioned before this Court.
2. According   to   learned   counsel   for   the
appellant/defendant,   interim   injunction   order   restraining   the
appellant/defendant, his agents, servants, representatives or any
other persons claiming through him from alienating, transferring
or   creating   third   party   interest   in   the   suit   property   pending
disposal of Special Civil suit No.83 of 2013 ought not to have
been passed 
3. It   appears   that   the   suit   property   as   alleged   by   the
respondent/plaintiff   was   owned   and   possessed   by   the
appellant/defendant who shifted to Ulhasnagar, District Thane.
The appellant/defendant was searching prospective purchaser for
the   suit   property   whereas   respondent/plaintiff   needed   to
purchase the same.   Thus, there was suit  transaction in the
nature of agreement to sell (Isar Chitthi).   The sum of Rs.1.51
Lacs   was   paid   as   earnest   money   by   way   of   Cheque   as   the
appellant/defendant agreed to execute the sale deed of the suit

property within six months.  It also appears that there was prior
legal notice from the respondent/plaintiff on 29.8.2013 whereby
the appellant/defendant was called upon to execute the sale deed
after   receiving   the   notice   and   after   accepting   the   balance
consideration in the sum of Rs.4.49 Lacs but the said notice was
returned as “Not Claimed”.  
Under   these   circumstances,   according   to   learned
counsel for the respondent/plaintiff, the appellant/defendant was
likely to create third party interest while transferring the suit
property   at   higher   rate   in   order   to   defeat   the   claim   of   the
respondent/plaintiff.   Therefore, interim injunction was sought
restraining   the   appellant/defendant,   his   agents,   servants,
representatives or any other persons claiming through him from
alienating, transferring or creating third party interest in the
suit property pending disposal of the civil suit.
4. It   appears   that   learned   Trial   Judge   considered   the
ground for grant of interim injunction and passed the reasoned
order   whereby   the   appellant/defendant,   his   agents,   servants,

representatives, or any other persons claiming through him were
restrained from alienating, transferring or creating third party
interest in the suit property pending disposal of the suit.
5. Learned   counsel   for   the   appellant/defendant   made
reference to the oral judgment of learned Single Judge of this
Court in the case of Mukhtar Khan Akram Khan ..vs.. Abdul
Talib Abdul Wahed  in Appeal Against Order No.109 of 2014
decided   on 25.3.2015  contending   that  since Section  52 of  the
Transfer   of   Property   Act   is   in   operation,   such   temporary
injunction could not have been granted.   As according to him,
this Court while passing the oral judgment in Appeal Against
Order   No.109   of   2014   on   25.3.2015   considered   the   effect   of
Section 52 of the Act as sufficient to protect the party to the suit
from alienation pending disposal of the suit.  
6. I have seen the copy of the oral judgment pointed out to
me.   In the case cited (supra) there was a case of the appellant
therein that an agreement to purchase the house property was

entered   into  for   consideration   of   Rs.14.00   Lacs   while   earnest
money in the sum of Rs.4.00 Lacs was paid to the respondent.  As
the   respondent   did   not   execute   the   sale   deed   as   agreed,   the
appellant filed the suit for specific performance of agreement in
which interim injunction was sought.   The Trial Court holding
that the appellant failed to make out a  prima facie  case had
rejected the application for grant of interim injunction.
7. The facts in the present  case are different  than the
facts   which   appear   in   the   case   cited   (supra).     The   interim
injunction was granted by the Trial Court in this case to ensure
that suit property must not change its hands pending disposal of
the   special   civil   suit   and   the   Trial   Court   was   satisfied   upon
consideration   of  prima   facie  case   to   restrain   the
appellant/defendant, his agents, servants, representatives or any
other persons claiming through him from alienating, transferring
or   creating   third   party   interest   in   the   suit   property   pending
disposal of the suit.  Merely because Section 52 of the Transfer of
Property Act is existing and operative, it does not mean that the

plaintiff is not entitled to pray for and get interim injunction
when   there   is   clear  prima   facie  case   in   favour   of   the
respondent/plaintiff to protect the suit property pending disposal
of   the   suit.     The   discretionary   relief   of   interim   injunction   is
granted on the basis of prima facie case, balance of convenience,
and consideration of irreparable loss with a view to protect the
suit property as it is and not to allow creation of irreversible
situation whereby legal and valid claim of the plaintiff is likely to
be defeated by transfer/alienation of the suit property by the
defendant in the case.  Dishonesty of litigant intending to defeat
the probable decree, can be prevented by appropriate interim
order, when necessary in the facts and circumstances of the case.
8. In view of above discussion, I find that no interference
is warranted in the impugned order in this appeal against order
since well reasoned order has been passed below order Exh.5 on
26.9.2014, in Special Civil suit No.83 of 2013, by learned Civil
Judge Senior Division, Akola upon  prima facie  consideration of
the matter.  Hence, the appeal needs to be dismissed.

9. In the result, the appeal against order is dismissed. The
parties   shall   appear   and   co­operate   with   the   trial   Court   for
expeditious final disposal of the pending suit.   The trial court
shall endeavour to dispose of the suit finally as expeditiously as
possible on its own merits according to law.
                                                                 
Print Page

No comments:

Post a Comment