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Kapadam Sangalappa and Others vs. Kamatam Sangalappa and Others

Not available · 2025 INSC 1307Decided 11 Nov 2025
Not available
Justice Prashant Kumar Mishra · Justice Vipul M. Pancholi

Background

For nearly a century, two family groups of the Kuruba community in Anantapur District, Andhra Pradesh, the Kapadam family of Gungulakunta village and the Kamatam family of Yerrayapalli village, have disputed the right to perform pooja and hold custody of the idols and ritual articles of Lord Sangalappa Swamy. A 1933 compromise decree settled the dispute by having the idols alternate between the two villages every six months and pooja duties rotate every three months. Decades later, in 1999, the Kapadam family alleged the Kamatam family had refused to rotate the idols as agreed, and sought to execute the 1933 compromise decree.

Decision Breakdown

The Supreme Court held that the burden of proving a violation of the compromise decree rested on the Kapadam family, as the decree-holders seeking execution, and that they had failed to produce cogent proof that the Kamatam family had actually breached the rotation terms. Since a court cannot allow execution of a decree based on mere presumption without evidence, the Court found the executing court had erred in ordering execution, and that the High Court had rightly reversed that order. The appeals were dismissed, leaving the executing court's order set aside.

Lesson Learnt

A party seeking to enforce an old compromise decree bears the burden of actually proving that the other side broke its terms. Courts will not order enforcement based on unproven allegations, no matter how long-standing or emotionally significant the underlying dispute.

Official source (sci.gov.in)View Judgment (PDF)

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