Kesar Bai vs. Genda Lal & Anr.
Background
The original plaintiffs (respondents here) sued for a declaration of ownership and a permanent injunction over a piece of land in Madhya Pradesh, claiming title first under a 1967 registered sale deed and, alternatively, by adverse possession. The trial court dismissed the suit outright. The First Appellate Court rejected the sale-deed claim but still granted a permanent injunction, holding the plaintiffs had perfected title by adverse possession. The High Court, in second appeal, actually ruled the adverse-possession finding wrong in law (since claiming ownership by sale deed and by adverse possession are mutually contradictory pleas), yet still upheld the injunction in the plaintiffs' favour, prompting the defendant (Kesar Bai) to appeal to the Supreme Court.
Decision Breakdown
The Supreme Court held this was internally inconsistent: once the High Court itself found that the plaintiffs could not simultaneously claim ownership by sale deed and by adverse possession, and answered the substantial question of law on adverse possession against the plaintiffs, there was no valid basis left to protect their possession through a permanent injunction. A person who fails to establish either ownership route is, at best, an encroacher, not someone entitled to injunctive protection of "title." The Court therefore set aside both the High Court's and the First Appellate Court's judgments and restored the trial court's original dismissal of the suit.
Lesson Learnt
A plaintiff cannot simultaneously rely on two legally contradictory claims to title (a sale deed and adverse possession) and expect a court to protect possession on the strength of a claim it has itself already rejected: legal remedies must follow logically from the findings actually made, not survive by default.