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Supreme Court of India 2022-12-14 allowed

Desh Raj & Ors vs Rohtash Singh

Bench: 2 — Surya Kant, Bela M. Trivedi

In Brief

The appellants (co-owners) entered into agreements to sell agricultural land to the respondent with a fixed execution date (16 August 2004) and time explicitly made essential. The respondent failed to execute the sale deed on that date, leading to forfeiture of earnest money. Years later, when land acquisition proceedings made performance impossible, the respondent sued for specific performance and refund of earnest money. The Supreme Court held that the contract had already terminated upon the respondent's non-performance on the stipulated date. Since time was essential, the respondent could not later claim specific performance or earnest money recovery. The Court rejected the lower courts' logic of unjust enrichment, holding that forfeiture was valid under the contract's clear terms and Section 74 of the Contract Act.

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Contract Law Specific Performance Property Law Earnest Money Time as Essence of Contract Forfeiture Land Acquisition Civil Procedure

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