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Supreme Court of India 2019-09-26 allowed

NARAYNAMMA AND ANR ETC ETC vs GOVINDAPPA AND ORS. ETC ETC

Bench: 3 — Navin Sinha, B.R. Gavai, Arun Mishra, M.R. Shah

In Brief

Govindappa sought specific performance of an agreement to sell land made with Bale Venkataramanappa, who had received a 15-year alienation restriction on the property. The agreement was executed in 1990, during the restriction period (which ended in 1988). The Supreme Court held that agreements violating statutory alienation restrictions are void and unenforceable during the restricted period. Applying the doctrine ex turpi causa non oritur actio (no action arises from unlawful conduct), the Court held that when both parties are equally culpable in breaching such restrictions, the Court will not grant relief through specific performance, as doing so would actively assist in enforcing an illegal agreement contrary to public policy. The Court dismissed the suit and upheld the trial court's order.

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Land Law Specific Performance Statutory Restrictions on Alienation Illegality and Public Policy Ex Turpi Causa Non Oritur Actio Karnataka Land Reforms Contract Law Equitable Relief

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