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Supreme Court of India 2020-11-03 allowed

SHRI RAM SAHU (DEAD) THROUGH LRS vs VINOD KUMAR RAWAT & ORS

Bench: 2 — Ashok Bhushan, M. R. Shah

In Brief

The Supreme Court quashed the High Court's review order that had deleted observations regarding the plaintiff's possession of a disputed house. The High Court had reviewed its earlier appellate judgment solely on the ground that no specific issue on possession was framed at the trial stage, despite possession being pleaded and evidence being led. The Court held that review jurisdiction under CPC Order 47 Rule 1 is strictly limited and cannot be used to correct findings based on merit. Non-framing of a formal issue does not vitiate findings when the matter was pleaded and evidence was led without objection. The Court restored the appellate observations on possession, finding the High Court had exceeded its review jurisdiction.

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Civil Procedure Review Jurisdiction Possession Sale Deed Injunction

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