Shyam Kumar Inani v. Vinod Agrawal & Ors.
Case at a glance
Provisions considered
- Transfer of Property Act, 1882 ss. 52, 53A
- Indian Contract Act, 1872 s. 29
- Specific Relief Act s. 16(c)
- Specific Relief Act, 1963 s. 16(c)
- Limitation Act, 1963
- Code of Civil Procedure, 1908 s. 96
Judgment
No enforceability bar due to vagueness – Boundaries identifiable – Undervaluation not conclusive of mala fides – The defendants also contended that the Agreement to Sell was vague and lacked specific demarcation of boundaries, and that the consideration was below market rate: Held: Agreement not invalid for lack of precise boundaries or lower- than-market consideration – No mala fides established – The Court clarified that minor imprecision in boundary description does not affect enforceability where the property can otherwise be identified with certainty – Further, undervaluation alone does not establish fraud or invalidate the contract when possession, consideration, and intention to perform are established. [Paras 34.6] Case Law Cited Thiruvengadam Pillai v. Navaneethammal [2008] 3 SCR 23 : (2008) 4 SCC 530; Mst. Kharbuja Kuer v. Jangbahadur Rai & Ors. [1963] Supp. 1 SCR 456 : AIR 1963 SC 1203; Vidyadhar Vishnupant Ratnaparkhi v. Manikrao Babarao Deshmukh and Ors. [1999] 1 SCR 1168 : (1999) 3 SCC 573; Janki Vashdeo Bhojwani & Anr. v. Indusind Bank Ltd. and Anr. [2004] Supp. 6 SCR 681 : (2005) 2 SCC 217; Rajesh Kumar v. Anand Kumar [2024] 5 SCR 612 : 2024 SCC OnLine SC 981; Thomson Press (India) Ltd. v. Nank Builders & Investors (P) Ltd. [2013] 2 SCR 74 : (2013) 5 SCC 397 – distinguished. Krishna Mohan Kul v. Pratima Maity and Ors. [2003] Supp. 3 SCR 496 : (2004) 9 SCC 468; Yogesh Goyanka v. Govind [2024] 7 SCR 668 : 2024 SCC OnLine SC 169 – referred to.
Questions this judgment answers
Which statutory provisions did this judgment involve?
Transfer of Property Act, 1882 — ss. 52, 53A; Indian Contract Act, 1872 — s. 29; Specific Relief Act — s. 16(c); Specific Relief Act, 1963 — s. 16(c); Limitation Act, 1963; Code of Civil Procedure, 1908 — s. 96.
Which court decided this case, and when?
Supreme Court of India, on 12 Nov 2024. The bench was VIKRAM NATH, PRASHANT KUMAR MISHRA.
Precedent status how later indexed judgments have treated this case
No known negative treatment found in the Courts & Cases corpus.
This is a result about the indexed corpus, not a finding that the judgment remains good law. Coverage may be incomplete.