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Supreme Court of India 2018-11-16

Rakesh Malhotra vs Kamaljit Singh Sandhu & Ors

Bench: 2 — M.R. Shah

In Brief

A property buyer sought specific performance of an agreement to sell dating back to 1987 and filed suit in 2004. The trial court awarded only recovery of amounts paid. The appellate court granted specific performance, but the High Court reversed this, finding no prayer for specific performance in the original plaint and applying limitation principles. The Supreme Court upheld the High Court, holding that relief cannot be granted without a specific prayer in the plaint and that the 17-year delay bars the suit. The Court dismissed the appeal but directed the property owners to pay Rs. 10 lakh ex-gratia as settlement.", <parameter name="principles">["A court cannot grant a relief that was not specifically prayed for in the suit.", "The application to amend the plaint must be granted to add new prayers; if dismissed and attained finality, the opportunity to seek that relief is lost.", "The law of limitation and equitable principles apply to suits for specific performance; inordinate delay in approaching the court without taking steps to enforce rights constitutes a bar.", "An unregistered agreement to sell cannot be admitted as evidence for its main purpose but only for collateral purposes under the Indian Evidence Act."]

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Contract Law Specific Performance Civil Procedure Real Property Limitation Agreement to Sell

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