Vishnu Vardhan @ Vishnu Pradhan v. The State of Uttar Pradesh
Background
Three individuals: Vishnu Vardhan, T. Sudhakar, and Reddy Veeranna: jointly purchased land in Gautam Budh Nagar, Uttar Pradesh in 1997, part of which was later acquired by NOIDA for a commercial hub, entitling the owners to large compensation. Over the following two decades, Reddy allegedly maneuvered through a series of suits, a disputed compromise, and proceedings from which Vishnu and Sudhakar were kept out, ultimately securing a High Court order in 2021 declaring him the sole owner and entitled to full compensation. Vishnu challenged this before the Supreme Court through a civil appeal and a separate writ petition, alleging that Reddy had practised fraud on the courts at multiple stages to cut out his co-owners.
Decision Breakdown
After an extensive 148-paragraph review of the tangled decades-long litigation history, the Supreme Court held that Reddy had indeed played fraud on the courts to secure exclusive ownership and compensation, and that "fraud unravels everything": a judgment or order obtained by fraud is a nullity that can be set aside even years later. The Court set aside the High Court's 2021 order declaring Reddy sole owner, declared its own earlier 2022 order in a related appeal (also procured by fraud) a nullity, and recalled a subsequent 2023 order, all done using the Court's inherent powers, going beyond the specific relief Vishnu had sought because of the trio's overall "unbecoming conduct." The underlying writ petition was remanded in its entirety to the High Court, with directions to implead Vishnu and Sudhakar and decide compensation and ownership afresh after hearing all parties, with the Chief Justice of the High Court requested to personally preside over the bench given the scale of the fraud detected. Vishnu's separate writ petition before the Supreme Court was dismissed since the same relief was now available through the remanded proceedings.
Lesson Learnt
Courts will unwind even long-final judgments and orders, however old, if they are shown to have been obtained through fraud on the court: finality of litigation cannot be used as a shield to protect a dishonest litigant's ill-gotten gains, and co-owners who are deliberately kept out of proceedings affecting their property can get those proceedings reopened.