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Supreme Court of India 2025-12-15 allowed

DANESH SINGH & ORS vs HAR PYARI (DEAD) THR. LRS. & ORS

Bench: 2 — J. B. PARDIWALA, R. MAHADEVAN

In Brief

A bank mortgaged agricultural property to recover a loan in 1970. During the pending recovery suit, a judgment-debtor sold portions to Har Pyari and her husband (pendente lite transferees). After the decree was passed, an auction of the mortgaged property was held and confirmed in favour of the appellants. Har Pyari's successors filed a separate suit claiming the property was void and sought possession. The Supreme Court held that pendente lite transferees are bound by the doctrine of lis pendens and cannot maintain a separate suit outside Order XXI CPC's exclusive remedial mechanisms. The Court applied Section 52 of the Transfer of Property Act, reaffirming that transfers during pending litigation are void as against the decree-holder. It directed equitable monetary relief of ₹75 lakhs to the respondents within six months to balance justice given the 40+ year litigation history.

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Civil Procedure Transfer of Property Act Doctrine of Lis Pendens Execution of Decrees Auction Sales Judgment-Debtors Third Parties Mortgage and Foreclosure Limitation Equity and Remedies

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