The Supreme Court held that the High Court erred in dismissing substantive prayers (declaratory reliefs) in the appellants’ suit while deciding an interim injunction appeal. It ruled that unregistered documents’ validity must be examined during trial, not at the interim stage under Section 49 of the Registration Act, 1908. The Court emphasized that interim proceedings cannot adjudicate the suit’s merits, restoring the matter for proper trial with protection against dispossession. The judgment reaffirms the distinction between interim relief and final determination of rights.
Facts Of The Case:
The case involved a dispute over tenancy rights in a shop (Shop No. 5, Bajarang Krupa Building, Mumbai) among the descendants of three brothers—Magruram, Deepnarayan, and Baburam Chotanki Gupta—who were co-tenants. The appellants, Mahendra Magruram Gupta and another, claimed that Deepnarayan (predecessor of respondent No. 1, Rajdai Shaw) transferred his tenancy rights to Magruram through a notarized affidavit dated 22.02.1990. Later, Deepnarayan’s widow, Antadevi, relinquished her rights in favor of appellant No. 1 via a declaration dated 18.04.1998. Relying on these documents, the appellants filed a suit (Civil Suit No. 2217 of 2012) seeking declarations of the documents’ validity and injunctions against dispossession.
The Trial Court denied interim relief, which the appellants challenged before the High Court. The High Court, while granting limited protection against dispossession, dismissed the declaratory reliefs (prayers a & b) citing Section 49 of the Registration Act, 1908, as the documents were unregistered. It also directed that the remaining prayers (c, d, e) be considered in a separate suit filed by respondent No. 1 for possession. The Supreme Court held this approach erroneous, ruling that the High Court could not decide the suit’s merits at the interim stage. It restored the suit for trial, clarifying that the documents’ admissibility and validity must be examined during the full trial.
Procedural History:
The case originated as a civil suit (Civil Suit (L) No. 2217 of 2012) filed by the appellants before the Bombay City Civil Court, seeking declaratory reliefs and injunctions based on unregistered agreements. The Trial Court dismissed their application for interim relief on 21.12.2012. The appellants then appealed to the Bombay High Court (Appeal from Order No. 476 of 2013), which partially allowed the appeal by granting limited protection against dispossession but erroneously dismissed the declaratory reliefs under Section 49 of the Registration Act, 1908, at the interim stage. The High Court also directed that the remaining reliefs be considered in a separate suit (Suit No. 443 of 2013) filed by the respondent.
Aggrieved by this decision, the appellants approached the Supreme Court via Special Leave Petitions (SLP (C) Nos. 37012-37013 of 2013). The Supreme Court, in its judgment dated 08.05.2025, set aside the High Court’s order, restored the original suit for trial, and clarified that the validity of unregistered documents must be examined during the full trial, not at the interim stage. The Court also granted protection against dispossession pending the suit’s disposal.
Court Observation:
The Supreme Court made several critical observations while setting aside the High Court’s order. It emphasized that the High Court committed a jurisdictional error by adjudicating the substantive merits of the suit – particularly the validity of unregistered documents under Section 49 of the Registration Act, 1908 – at the interim injunction stage. The Court clarified that such determinations must be made only during the full trial after evidence is led.
The bench strongly disapproved of the High Court’s approach of partially dismissing the suit while hearing an appeal against interim relief, noting this amounted to a premature adjudication of rights. It observed that interim proceedings are meant only to preserve the status quo, not to decide the case’s merits. The Court also found the High Court’s direction to re-agitate certain prayers in the respondent’s parallel suit as legally unsustainable, as it would lead to a fragmented adjudication of the dispute.
Significantly, the Supreme Court upheld the principle that unregistered documents may still be admissible for collateral purposes, and their evidentiary value must be properly assessed during trial. The judgment reinforces the distinction between interim protection and final determination of rights, safeguarding the appellants’ opportunity to prove their case in the trial court.
Final Decision & Judgement:
The Supreme Court allowed the appeal and set aside the impugned judgment of the Bombay High Court dated 14.08.2013. The Court restored Civil Suit (L) No. 2217 of 2012 to its original position before the Bombay City Civil Court for fresh consideration and full trial on merits. Significantly, the apex court granted interim protection to the appellants by restraining the respondents from dispossessing them from the suit premises pending final disposal of the suit. The bench clarified that it had not expressed any opinion on the merits of the case, leaving all substantive issues – including the validity and admissibility of the unregistered agreements – to be determined by the trial court after proper examination of evidence. The Court imposed no costs and disposed of all pending applications, while emphasizing that the High Court had erred in dismissing substantive prayers at the interim stage and in directing fragmented adjudication of the dispute across two separate suits. This judgment reaffirms the fundamental principle that interim proceedings should not be used to decide substantive rights that require full trial.
Case Details:
Case Title: Mahendra Magruram Gupta & Anr. vs. Rajdai Shaw & Ors. Citation: 2025 INSC 651 Appeal Number: Civil Appeal No(s). [Not Specified] of 2025 (Arising out of SLP (C) No(s). 37012-37013 of 2013) Date of Judgment: May 8, 2025 Bench: Justice Pamidighantam Sri Narasimha & Justice Joymalya Bagchi
Download The Judgement Here