P. Ravindranath vs. Sasikala

Not available · 2024 INSC 533Decided 15 Jul 2024
Not available
Justice Vikram Nath · Justice Prashant Kumar Mishra

Background

In 1981, the original owners of a Bangalore property agreed to sell it to the respondent-plaintiffs for Rs. 29,000, with Rs. 12,000 paid as advance and the balance due within three months (extendable due to a government restriction on registering similar plots). When the plaintiffs did not pay the balance or get the sale deed executed for over a year and a half, the sellers declared the advance forfeited and the agreement cancelled, and in 1983 sold portions of the property to other buyers, including the appellant. The plaintiffs then sued for specific performance; the trial court and the Karnataka High Court both ruled in their favour and ordered the sale deed executed in their name, leading the subsequent purchaser (appellant) to appeal to the Supreme Court.

Decision Breakdown

The Supreme Court held that specific performance is a discretionary relief, and a plaintiff seeking it must plead and prove (with specific facts, not vague averments) that they were continuously "ready and willing" to perform their own obligations under the contract. It found the plaintiffs had never specifically pleaded or proved details of the alleged government registration ban, never tendered the balance payment or a draft sale deed, and remained silent for nearly two years after the sellers' final notice of cancellation before filing suit: conduct inconsistent with genuine readiness and willingness. Concluding the lower courts erred in decreeing specific performance, the Supreme Court allowed the appeal and dismissed the suit, but to balance equities after 43 years, directed the appellant to pay the original plaintiffs Rs. 24 lakhs (refunding advance with appreciation) plus Rs. 6 lakhs in litigation costs.

Lesson Learnt

In a suit for specific performance of a property sale agreement, courts will refuse to enforce the contract if the buyer cannot show through specific, timely conduct, not just vague statements, that they remained ready and willing to pay and complete the purchase; silence and delay can be fatal to the claim even where the seller may also be at fault.

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