Rajesh Kumar vs. Anand Kumar & Ors.
Background
In 1996, the appellant entered into an agreement to purchase about 145 acres of land in Jabalpur district, Madhya Pradesh, from the power-of-attorney holder of several co-owners, paying earnest money and further instalments, with the sale-deed deadline repeatedly extended up to 31 May 1997. Before that final deadline, on 14 May 1997, the very same power-of-attorney holder instead sold the same land to a different set of buyers who were aware of the appellant's earlier agreement. The appellant, though aware of this sale and having even objected to its registration in 1997, did not file a suit for specific performance until 9 May 2000: the very last day permitted under the law of limitation. The trial court decreed in his favour, but the High Court of Madhya Pradesh reversed that decree.
Decision Breakdown
The Supreme Court upheld the High Court's dismissal of the suit. Relying on its own precedents (including K.S. Vidyanadam and Atma Ram v. Charanjit Singh), the Court held that specific performance is a discretionary equitable remedy, and a plaintiff's long, unexplained delay in suing despite clear knowledge of the seller's breach can by itself disentitle him to that relief: merely filing within the three-year limitation period is not enough if the plaintiff sits on his rights until the last possible moment. The appeal was dismissed and the High Court's judgment upheld.
Lesson Learnt
Being technically within the limitation period is not enough to win specific performance of a property sale agreement. Courts expect a buyer who learns the seller has reneged to act with reasonable promptness, not wait until the eleventh hour to sue.