In the case of Satish Jain vs. State of Madhya Pradesh, a complex land ownership dispute has been ongoing, involving various legal intricacies and prolonged court battles. The recent judgment by the Supreme Court of India provides significant directions on the matter, shedding light on the rights and obligations of the parties, particularly Satish Jain and the State of Madhya Pradesh.
Facts
- Satish Jain filed a civil suit against Rama and the State of Madhya Pradesh for a declaration, permanent injunction, and mandatory injunction regarding the ownership of land.
- The suit land was under dispute as defendant No.1 had allegedly been in adverse possession for 50-60 years.
- After objections, the Trial Court allowed the State’s application on 22.12.2004.
- An agreement from 30.07.1991 stated that BMC would pay Rs. 30,00,000 to Satish Jain for vacating the land to construct a bus stand.
- BMC was impleaded as defendant No.3 in the case.
- The appellant filed for objections to the arbitrator’s award on 09.11.2004.
- The arbitrator’s award required Satish Jain to pay Rs. 30,00,000 to BMC for land allotment as per the 1991 agreement.
- The Trial Court decreed the suit ex-parte on 22.06.1990.
- An appeal was allowed on 09.01.2004 and the case remanded to the Trial Court for a decision on merits.
- The suit is still pending before the Trial Court.
- The Appellate Court directed to hear the parties on merits and decide the appeal in accordance with the law.
- The State’s appeal under Section 96 of the Code of Civil Procedure was dismissed due to an 8-day delay.
- A civil revision by the State was allowed by the High Court on 13.08.2003.
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Arguments
- The Madhya Pradesh High Court allowed the Civil Revision Civil Appeal No. 201 of 2005 filed by Satish Jain against the State of Madhya Pradesh.
- The High Court set aside the Trial Court’s order dated 22.12.2004.
- The High Court directed the Trial Court to proceed in implementing the award of the Arbitrator in accordance with the law.
- The appeal by the State of Madhya Pradesh is challenging the correctness of the High Court’s judgment and order.
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Analysis
- BMC was bound to use the land for the purpose it was allotted for by the State.
- BMC should have taken steps to remove the unauthorized possession of the plaintiff.
- The agreement dated 30.07.1991 was void after the basis for entering into it was set aside.
- The agreement would lose credibility as the ex-parte decree was set aside, and the suit was to proceed further.
- No rights had been crystallized to the parties based on the agreement.
- There seemed to be collusion between BMC and the plaintiff.
- The ex-parte decree being set aside meant that the plaintiff had no basis to act on the agreement anymore.
- The suit land was owned by the State, and no party relied on it.
- The agreement mentioned the plaintiff’s claim under the ex-parte decree and the dismissal of the First Appeal.
- The plaintiff had not been granted any declaration till date in the ongoing suit.
- Plaintiff’s right under the ex-parte decree was extinguished
- BMC should not have relied on the said agreement after the decree was extinguished
- Trial Court was justified in setting aside the award
- High Court erred in not considering relevant aspects and relying on the statement made by the Appellant-State regarding land allotment to BMC
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Decision
- All applications are still pending before the Trial Court or disposed of/withdrawn by the State.
- The appeal is allowed, and the impugned order is set aside.
- The order rejecting the report of the arbitrator is also set aside.
- Trial Court to proceed further according to law for implementing the award.
- Relevant facts leading to the appeal are briefly stated.
Case Title: THE STATE OF MADHYA PRADESH Vs. SATISH JAIN (DEAD) BY LRS. (2024 INSC 315)
Case Number: C.A. No.-006884-006884 / 2012
