### Case Title: Maharaj Singh v. Karan Singh (Dead) Through LRs, 2024 INSC 491
Brief Facts:
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Parties Involved: Maharaj Singh (Plaintiff) and Karan Singh (Defendant, now deceased, represented by legal representatives).
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Contractual Agreement: Maharaj Singh entered into a contract with Karan Singh for the purchase of immovable property.
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Subsequent Sale: Karan Singh sold the same property to another party while the original contract with Maharaj Singh was still in force.
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Legal Action: Maharaj Singh filed a suit for specific performance of the contract, seeking enforcement against Karan Singh and the subsequent purchasers.
Events Timeline:
1.
Contract Date: Initial agreement between Maharaj Singh and Karan Singh.
2.
Subsequent Sale: Karan Singh sells the property to a third party.
3.
Filing of Suit: Maharaj Singh files a suit for specific performance.
4.
Lower Court Decisions: Decisions in lower courts lead to the appeal to the Supreme Court.
5.
Supreme Court Hearing: Detailed arguments from both sides are heard.
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Judgment Date: Supreme Court delivers the final judgment.
Sections Involved:
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Section 19(B) of the Specific Relief Act (SRA): This section deals with the enforcement of contracts against subsequent purchasers who have notice of the original contract.
Arguments from Both Sides:
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Plaintiff (Maharaj Singh):
- Argued for specific performance of the original contract.
- Claimed the subsequent purchasers had notice of the existing contract and thus should be bound by it.
- Asserted that cancellation of subsequent sale deeds is not necessary for enforcing specific performance.
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Defendant (Karan Singh's LRs and Subsequent Purchasers):
- Contended that the subsequent sale was valid and should not be disturbed.
- Argued that without cancellation of the subsequent sale deeds, specific performance cannot be enforced.
- Claimed that they were bona fide purchasers without notice of the original contract.
Judicial Observations:
- The Supreme Court noted the principle that specific performance is an equitable remedy meant to enforce valid contractual obligations.
- It emphasized the importance of notice, stating that subsequent purchasers with notice of the original contract cannot claim protection against specific performance.
- The Court observed that requiring cancellation of subsequent sale deeds would unnecessarily complicate the enforcement of original contracts and is not mandated under Section 19(B) of the SRA.
Decision:
- The Supreme Court directed the subsequent purchasers to join the original vendor in executing the sale deed in favor of Maharaj Singh.
- It ruled that Maharaj Singh did not need to seek the cancellation of subsequent sale deeds, thus simplifying and expediting the legal process.
Conclusion:
The Supreme Court's ruling reinforces the enforceability of contracts under Section 19(B) of the Specific Relief Act against subsequent purchasers who have notice of the original contract. This decision underscores the importance of protecting contractual rights and ensures that equitable remedies are efficiently administered without unnecessary procedural hurdles.
For a detailed judgment, you can refer to the full text
here.