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Supreme Court of India 2024-11-21 dismissed

MANJIT SINGH & ANR vs DARSHANA DEVI & ORS

Bench: 2 — J.B. Pardiwala, R. Mahadevan

In Brief

The Supreme Court affirmed a High Court judgment that allowed the original plaintiff's suit for specific performance of an oral sale agreement from 1986. The subsequent purchasers (appellants) challenged this, claiming protection as bona fide purchasers under Section 19(b) of the Specific Relief Act. The Court held that good faith protection requires not mere honesty but due care and attention. Since the subsequent purchasers failed to inquire about the existing mortgagee's interest in the property—despite knowing of encumbrances—they had constructive notice. Their willful abstention from making inquiries amounted to reckless disregard of consequences, negating bona fide purchaser status. The appeal was dismissed and the original decree for specific performance was upheld.

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Contract Law Specific Relief Property Law Bona Fide Purchaser Civil Procedure

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