Shruti Manav Sharma v. Sunanina Singh
Background
An elderly widow (the original plaintiff) alleged that her granddaughter and the granddaughter's husband, while she lived in their household, used undue influence to make her transfer valuable family shareholding, LLP interests, and sale proceeds worth over Rs. 1,000 crores into their names, leaving other family members with a tiny fraction of the estate. She sued for cancellation of the transfers and obtained a temporary injunction from a Single Judge of the Delhi High Court freezing the disputed properties pending trial. A Division Bench of the High Court reversed that injunction on appeal, engaging in a detailed re-examination of the Will, the transfers, and applicable statutes. After the original plaintiff's death, her legal representatives (including the appellant, another granddaughter) pursued the appeal to the Supreme Court.
Decision Breakdown
The Supreme Court restored the Single Judge's injunction, holding that the Division Bench had exceeded the limited scope of appellate review over a discretionary injunction order. An appellate court can only interfere with a temporary injunction if the trial court's discretion was exercised arbitrarily, capriciously, perversely, or contrary to settled principles - it cannot substitute its own view merely because it might have reached a different conclusion. The Court found the Single Judge's order to be properly grounded in the three settled requirements for injunctions (prima facie case, balance of convenience, and irreparable injury), whereas the Division Bench had improperly conducted a "mini-trial," delving into the merits of the Will's interpretation and disputed facts that should be decided only after full trial. The Court also criticized the broader practice of courts writing lengthy, merits-laden injunction orders instead of confining themselves to the three settled conditions.
Lesson Learnt
A temporary injunction is only a preservative "holding order," not a decision on the merits - appellate courts must not turn an injunction appeal into a rehearing of the underlying case, and interference is warranted only when the lower court's discretion was clearly arbitrary or contrary to settled legal principles, not simply because the appellate judges would have decided differently.