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Supreme Court of India 2020-03-19 allowed

NAND RAM (D) THROUGH LRS. & ORS vs JAGDISH PRASAD (D) THROUGH LRS

Bench: 2 — L. Nageswara Rao, Hemant Gupta

In Brief

The appellants (legal heirs) sued to recover possession of leased land that the respondent (original lessee) refused to surrender after the lease expired in 1974. The Land Acquisition Court had previously ruled in compensation proceedings that the lease ended because rent was unpaid. The High Court dismissed the suit, holding this ruling operated as res judicata and the suit was time-barred. The Supreme Court reversed, holding that a finding made solely to deny compensation does not operate as res judicata in a separate possession suit, as the two proceedings concerned different issues. The Court also held that Article 67 of the Limitation Act (12-year period from lease expiry) applied, not the shorter periods the respondent claimed. The suit was therefore timely filed. The respondent's attempt to claim adverse possession failed because he had not openly renounced his tenant status before asserting hostile title.

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Land Law Transfer of Property Limitation Land Acquisition Civil Procedure Tenancy Res Judicata Adverse Possession

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