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Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Civil Property & InheritanceSupreme Court of India

K.S. Manjunath and Others vs. Moorasavirappa @ Muttanna Chennappa Batil (Since Deceased by his LRs) and Others

Not available · 2025 INSC 1298Decided 10 Nov 2025
Not available
Justice J.B. Pardiwala · Justice R. Mahadevan

Background

In 2000, the original owners ("Original Vendors") of about 354 acres of agricultural land in Haveri, Karnataka executed an unregistered Agreement to Sell (ATS) in favour of certain buyers ("Original Vendees") who paid part of the sale consideration as earnest money. Before the sale was completed, the same land was subsequently sold to other purchasers ("Subsequent Purchasers," the appellants here). The Original Vendees sued for specific performance of the ATS, and the dispute over whose claim to the land should prevail, the earlier agreement-holders or the later purchasers claiming to be bona fide buyers without notice, reached the Supreme Court after the Karnataka High Court ruled in favour of the Original Vendees.

Decision Breakdown

The Supreme Court dismissed the Subsequent Purchasers' appeals, upholding the High Court's decision granting specific performance in favour of the Original Vendees and rejecting the appellants' claim to be bona fide purchasers for value without notice of the earlier agreement. However, recognising that nearly 18 years had passed since the sale deeds in the appellants' favour were executed, the Court directed the Original Vendees to pay the appellants the balance sale consideration with 16% annual interest, plus an additional Rs. 5 crore over and above that amount, before the appellants are required to execute the sale deed and hand over possession: a step taken "to do substantial justice" given the long passage of time.

Lesson Learnt

A prior unregistered Agreement to Sell can defeat a later sale deed if the later buyer had notice (or ought reasonably to have had notice) of the earlier agreement, but courts can temper harsh outcomes with monetary compensation when very long delays have intervened, rather than leaving one side to bear the entire cost of the delay.

K.S. Manjunath and Others vs. Moorasavirappa @ Muttanna Chennappa Batil (Since Deceased by his LRs) and Others – Legal Case Shots | LegalAware