In Brief
Appellants claimed ownership of agricultural land in Gwalior, relying partly on a prior court decree obtained by their ancestors and their long-standing possession. The trial court ruled in their favour, but the High Court reversed this decision, holding that the earlier decree was not binding on the Union of India since it was passed without the Union being impleaded as a party. The Supreme Court dismissed the appeal, affirming that: (1) additional evidence cannot fill evidentiary gaps at the appellate stage except in exceptional circumstances under the applicable procedural rule; (2) a decree passed without impleading the actual owner cannot bind that owner; and (3) in title suits, the plaintiff must prove ownership through credible documentary evidence, not merely rely on prior decrees or long possession.
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