In Brief
The Jharkhand State Housing Board challenged a court decree granting the plaintiff permanent injunction to protect possession of land he had purchased and improved. The Board claimed it had acquired the land through government proceedings and sought to evict the plaintiff. The Supreme Court held that while a plaintiff may sometimes seek injunction without declaring title, when the defendant raises a genuine cloud over title—as the Board did through land acquisition documents—the plaintiff must seek declaration of title as a prerequisite. The Court set aside the lower courts' decrees, finding they erred in granting bare injunction without resolving the title dispute first.
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