Vijay A. Mittal & Ors. v. Kulwant Rai (Dead) Thr. LRs. & Anr.
Background
In 1979, a property owner (acting as Karta of his Joint Hindu Family) agreed to sell a property to the plaintiffs, but instead sold it to other buyers in 1981 at a higher price. The original plaintiffs sued for specific performance of the first agreement; the original owner's legal heirs defended on the ground the property was joint family property requiring consent, and that the later sale was valid. The trial court dismissed the suit, but the first appellate court and then the High Court both ruled in the plaintiffs' favour, holding the later sale was a collusive attempt to defeat the first agreement.
Decision Breakdown
The Supreme Court upheld the concurrent factual findings of three lower courts/forums that the plaintiffs were always ready and willing to perform their part of the agreement, and that one of the Karta's own sons had signed the agreement, showing the family's consent, which bound all the legal heirs. The Court found no error in these factual findings and dismissed the appeal on the core question. However, to finally end litigation that had run since 1982, the Court used its special constitutional power (Article 142) to also direct that the family of the original owner refund the money received from the later, now-invalidated buyers, so no further separate lawsuit would be needed between them.
Lesson Learnt
Findings of fact upheld by two or more courts in a row are very hard to overturn in the Supreme Court; and the Court will sometimes go beyond simply deciding "who wins" to also order practical, complete relief (like ordering a refund) so the same dispute does not spawn fresh litigation for years.