Mahadeo Oraon vs The State Of Jharkhand on 31 July, 2026

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    Jharkhand High Court

    Mahadeo Oraon vs The State Of Jharkhand on 31 July, 2026

    Author: Rajesh Shankar

    Bench: Rajesh Shankar

                                                Neutral Citation No. (2026:JHHC:22664)
    
    
    
    
             IN THE HIGH COURT OF JHARKHAND AT RANCHI
                      Cont. Case (Civil) No.1010 of 2025
                                        -----
               Mahadeo Oraon, son of Late Bhukhla Oraon, resident of
               Madhukam, Ratu Road, Ranchi, P.O. Hehal, P.S. Sukhdeo Nagar,
               District Ranchi.
                                                                   .......... Petitioner.
                                      -Versus-
               1. The State of Jharkhand
               2. Ghanshyam Kumar, son of not known to the petitioner, at
                   present working and posted as Circle Officer, Hehal, Hehal
                   Anchal, Ranchi, P.O. & P.S. Hehal, District Ranchi.
               3. Santosh Kumar Chaudhary, son of Sri Govind Chaudhary
               4. Savitri Devi, wife of Mahesh Kumar Saw
               5. Narayan Saw, son of Late Ramdhani Saw
               6. Prem Kumar Sao, son of Late Ram Jatan Saw
               7. Manju Devi, wife of Gyani Saw
               8. Mohan Lal Sahu, son of Late Moti Lal Sahu
               9. Kaushal Ambike, son of Late Suresh Lal Sahu
               10. Archana Devi, wife of Mahesh Prasad Sahu
               11. Ram Lakhan Yadav, son of Late Ram Sagar Yadav
               12. Sanjay Kumar Sahu, son of Rameshwar Sahu
               13. Gudiya Devi, wife of Ajay Sahu
               14. Rounak Kumar, son of Late Anil Sao
                                                          .......... Opposite Parties.
                                        -----
               CORAM : HON'BLE MR. JUSTICE RAJESH SHANKAR
                                        -----
               For the Petitioner :        Mr. Atul Rai, Advocate
               For the State        :      Md. Shahabuddin, SC-VII
               For O.P. Nos.3 to 14:       Mr. Sachin Kumar, Advocate
                                           Mr. Gaurav Raj, Advocate
                                        -----
               CAV on 24.07.2026                  Pronounced on 31.07.2026
    
    Rajesh Shankar, J.
    

    1. Heard the learned counsel for the parties and perused the

    materials placed on record.

    SPONSORED

    2. The present contempt case has been filed alleging willful,

    deliberate and intentional violation of the order/judgment dated

    22.10.2024 passed in W.P.(C) No.5461 of 2024.

    3. Brief background of the case is that the petitioner filed writ

    petition being W.P.(C) No. 5461 of 2024 for issuance of

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    Neutral Citation No. (2026:JHHC:22664)

    direction upon the Circle Officer, Hehal Anchal, Ranchi (opposite

    party no.2 herein) to dispose of the petitioner’s representation

    seeking restoration of possession over the land appertaining to

    R.S. Plot No.319, Khata No.179 measuring an area of 45 decimals

    situated at village-Madhukam, P.S.-Sukhdeo Nagar, District-

    Ranchi (hereinafter referred to the said land) which had been

    restored under Section 71A of the Chota Nagpur Tenancy Act,

    1908 vide order dated 13th December, 1996 passed in S.A.R.

    Case No.169 of 1993-94 and the said order was upheld up to the

    High Court.

    4. In the said writ petition, the following facts were averred by the

    petitioner:-

    (i) The petitioner preferred an application under Section

    71A of the Chota Nagpur Tenancy Act, 1908 seeking

    restoration of the said land in his favour which was

    registered as S.A.R. Case No.169 of 1993-94 and the

    Special Officer, S.A.R. Court, Ranchi vide order dated

    13.12.1996 allowed the restoration of the said land in

    favour of the petitioner.

    (ii) Aggrieved with the said order, Shanti Devi & others

    preferred S.A.R. Appeal No.570 R15/1997 under the

    provisions of Section 48(4) of the C.N.T. Act which was

    dismissed vide order dated 15.07.1998 passed by the

    Deputy Commissioner, Ranchi.

    (iii) Thereafter, S.A.R. Revision No.120 of 1998 was filed by

    Shanti Devi & others before the Commissioner, South

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    Chhotanagpur Division, Ranchi who allowed the said

    revision in favour of the said persons vide order dated

    18.05.1999.

    (iv) Aggrieved with the said order, the petitioner preferred

    a writ petition before this Court being C.W.J.C. No.2383

    of 1999(R) which was allowed vide order dated

    01.05.2009 quashing the order dated 18th May,

    1999 passed by the revisional authority i.e. the

    Commissioner, South Chhotanagpur Division, Ranchi.

    (v) Thereafter, Shanti Devi & others preferred

    L.P.A. No.341 of 2009 and Mohan Sao & others

    preferred L.P.A. No.342 of 2009. Both the said L.P.As.

    were dismissed for default by a Division Bench of this

    Court vide order dated 11.04.2017. Subsequently,

    C.M.P. No.-201 of 2017 was filed by Shanti Devi &

    others seeking restoration of the said L.P.As., however,

    the same was also dismissed for default vide

    order dated 5.12.2018.

    (vi) The aforesaid sequence of litigation suggests that the

    order of restoration passed by the SAR Court, Ranchi

    on 13.12.1996 in SAR Case No.169 of 1993-94 has

    become final up to this Court. The petitioner has not

    yet received any notice in connection with the present

    case from the Supreme Court of India and as such he

    has the reasons to believe that the aforesaid persons

    i.e. Shanti Devi & others and Mohan Sao & others have

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    not challenged the order passed by the learned Division

    Bench of this Court dismissing the aforesaid L.P.A.s and

    C.M.P. for default.

    5. In course of argument in the said writ proceeding, the learned

    counsel for the State concurred the submission made on behalf

    of the petitioner. The Court having observed the aforesaid facts,

    disposed of the writ petition directing the opposite party no.2 to

    take up the present matter, issue notices to the concerned

    persons i.e. Shanti Devi & others and Mohan Sao & others who

    were said to be in possession of the land in question. The

    opposite party no.2 was further directed to verify the fact that

    the orders passed in C.W.J.C. No.2383 of 1999(R), L.P.A. No.341

    of 2009 with L.P.A. No.342 of 2009 and C.M.P. No.201 of 2017

    had not been set aside till that date and thereafter to handover

    the possession of the land to the petitioner in accordance with

    law preferably within 12 weeks from the date of

    receipt/production of a copy of the said order.

    6. The present contempt case was earlier taken up for consideration

    by this Court on 22.08.2025 and on the said date, the learned

    counsel appearing on behalf of the opposite party no.2 stated

    that an interlocutory application was filed seeking extension of

    time to comply the order dated 22.10.2024 passed in W.P.(C)

    No.5461 of 2024. However, no such interlocutory application was

    found on record and the case was adjourned for the next week.

    On 16.01.2026, the opposite party no.2 by pressing I.A.

    No.11663 of 2025 sought more time to comply the order dated

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    22.10.2024 and to file compliance affidavit, which was allowed

    by this Court, granting four weeks’ further time.

    7. In the meantime, I.A No. 2413 of 2026 dated 11.02.2026 was

    filed by 12 applicants seeking intervention in the present case

    stating that they were residing over R.S. Plot No.319, Khata

    No.179, measuring an area of 45 decimals situated at village

    Madhukam, P.S. Sukhdeo Nagar, District Ranchi, which is the

    subject land in the present contempt case. They also averred that

    altogether 11 settlement agreements were executed between

    them and the petitioner from 19.12.2019 to 31.12.2020 whereby

    they were permitted by the petitioner to remain in possession of

    the land in lieu of payments of about Rs.1.08 crore made by them

    on different dates. They further claimed that the said material

    facts were suppressed by the petitioner in the writ petition and

    thus obtained the order dated 22.10.2024 from this court by

    playing fraud.

    8. This court vide order dated 13.02.2026 directed the opposite

    party no. 2 to file a show cause affidavit specifically stating as to

    whether in compliance of the order dated 22.10.2024, the

    applicants were issued notice(s) and if so, whether they were

    given opportunity to produce documents in support of the facts

    that they had paid considerable amount by way of settlement to

    the petitioner and as to whether any such order was passed by

    him before taking steps for evicting the applicants from the said

    land. By the said order, this court also directed the opposite party

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    no.2 to stay his hands from taking any coercive steps against the

    applicants (intervenors) with respect to the said land.

    9. On 08.05.2026, when the matter came up for further

    consideration, this court observed that the petitioner while filing

    W.P.(C) No. 5461 of 2024 and the present contempt petition did

    not even whisper about the fact regarding execution of 11

    settlement agreements and receipt of Rs.1.08 crores by him paid

    at the instance of the opposite parties/intervenors. Under the said

    circumstance, this court was of the prima facie view that the

    petitioner had suppressed the material facts and had tried to

    mislead the Court amounting to perjury.

    10. Having observed so, this court directed for issuance of show

    cause notice to the petitioner calling upon him as to why an

    appropriate order under suitable provisions of law be not passed

    against him.

    11. Pursuant to the directions issued by this court on 08.05.2026, the

    petitioner filed show cause affidavit dated 17.06.2026 stating that

    the subject matter of controversy between the parties started in

    the year 1993 and attained finality in the year 2018 through

    adjudication at different forums up to the Division Bench of this

    Court. The writ petition being W.P.(C) No. 5461 of 2024 was filed

    for the sole and limited purpose of securing compliance of the

    order dated 13.12.1996 passed in SAR Case No.169 of 1993-94

    by the opposite party no.2, as the said order was upheld up to

    the High Court. The Petitioner genuinely believed that the private

    agreements, being matters of a disputed and collateral nature,

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    had no bearing on an innocuous prayer made in the writ petition

    and such facts were not required to be pleaded. As per his

    understanding, only those facts having a direct bearing on the

    writ petition were required to be incorporated and the

    agreements were not among those.

    12. It is further stated that documents relied upon by the opposite

    party nos.3 to 14 are the Agreements to Sale which do not

    transfer any title or possession in law. Moreover, the Agreements

    to Sale contained a specific condition that in the event of

    dishonour of cheques issued by them, the agreements would

    stand terminated. Some of the cheques issued by the opposite

    party nos.3 to 14 were in fact dishonoured, and consequently

    the Agreements to Sale could not have been given effect to. The

    Petitioner therefore did not consider these incomplete and

    terminated agreements with material breach to be germane to,

    or having a bearing upon, the prayer for restoration of land made

    in the writ petition as well as the contempt proceeding.

    13. It is further stated that the land of the petitioner is governed by

    the Chotanagpur Tenancy Act, 1908 and the Agreements to Sale

    were executed in direct contravention of Sections 46 and 48 of

    the CNT Act, 1908 read with Section 23 of the Indian Contract

    Act, 1872, which prohibit transfer of Scheduled Tribe land without

    the required statutory sanction. A contract made in contravention

    of a statutory prohibition was otherwise void under Section 23 of

    the Contract Act. The petitioner being a member of scheduled

    tribes was aware of the fact that no private agreement

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    could lawfully override the statutory protection provided to his

    land, and that any agreement to the contrary was a nullity. He

    therefore did not consider it necessary or meaningful to disclose

    about execution of the agreements which were void ab initio and

    could not have conferred any right upon the opposite party nos.3

    to 14 as a matter of law.

    14. It is also averred that the petitioner had been engaged in

    prolonged litigation since the year 1993 and trying hard to get

    the said land restored in his favour, however, in that process, he

    was facing great difficulty. In this state of helplessness and

    vulnerability, he was coerced and pressurized by the

    intervenors/opposite party nos.3 to 14 to execute agreements to

    sale at half of the market rate, payable in three annual

    installments. In fact, the petitioner did not sign those agreements

    with free will or with a full and informed appreciation regarding

    their legal consequences. Even otherwise, an agreement

    executed under coercion is voidable under the Indian Contract

    Act, 1872.

    15. It is also pleaded in the show cause affidavit that the present

    contempt case was filed against the State of Jharkhand and the

    Circle Officer, Hehal, Ranchi (Opposite Party No. 2) arraying them

    as opposite parties alleging wilful and deliberate violation of the

    order dated 22.10.2024 passed in W.P.(C) No.5461 of 2024 by

    not delivering possession of the said land to the Petitioner. The

    Petitioner’s dispute with the opposite party nos.3 to 14 regarding

    execution of the agreements was a separate, collateral matter

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    which had no relevance with the specific prayer for enforcement

    of the order passed in the aforesaid writ petition.

    16. It is further stated that the petitioner filed the instant contempt

    case anticipating that in compliance of the order dated

    22.10.2024 passed in W.P.(C) No. 5461 of 2024, the opposite

    party no.2 would issue notices to the intervenors (i.e. opposite

    party nos.3 to 14), who would then have a full and fair

    opportunity to appear, place all the documents including the

    agreements in question before the opposite party no.2 and

    raise their contentions in defence. As such, the petitioner did

    not consider it necessary to disclose the fact regarding execution

    of said agreements in the contempt case. Though the opposite

    party nos.3 to 14 accepted the notices issued by the opposite

    party no.2, but failed to place the said agreements before him.

    They also did not furnish any satisfactory explanation regarding

    their continued possession over the said land. It was a serious

    omission on the part of opposite party nos.3 to 14 in not raising

    the issue of execution of the agreements in question before the

    opposite party no.2 despite having received the notices and the

    opportunity provided for that purpose. Thus, the

    petitioner cannot be penalised for such failure of the said

    opposite parties.

    17. It is also stated that after the opposite party nos.3 to 14 filed I.A.

    No. 2413 of 2026 on 11.02.2026 raising the issue pertaining to

    existence of the agreements, the petitioner did not deny the said

    fact, rather in his rejoinder affidavit dated 05.05.2026, he

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    acknowledged the execution of the agreements and explained the

    entire surrounding circumstances before this Court, including the

    fact of coercion, dishonoured cheques etc. of the opposite party

    nos.3 to 14 and the invalidity of the agreements. These facts

    clearly suggest bonafide of the petitioner.

    18. The petitioner has further stated in the show cause affidavit that

    the charge of perjury is not attracted in the present case. Under

    section 227 of the Bharatiya Nyaya Sanhita, perjury is the offence

    of deliberately making false statement or producing false

    evidence on oath or affirmation about which the maker either

    knows to be false at the time of making/producing it or does not

    believe it to be true. The petitioner had not made any false

    statement on affidavit and the allegation against him is solely

    premised on his omission of not having explicitly disclosed the

    fact of execution of the settlement agreements. An omission,

    however, cannot be treated as perjury.

    19. The learned counsel for the petitioner by putting reliance to the

    judgments of the Hon’ble Supreme Court rendered in the cases

    of M/s S.J.S. Business Enterprises (P) Ltd. Vs. State of

    Bihar & Others, reported in (2004) 7 SCC 166; Arunima

    Baruah Vs. Union of India & Others, reported in (2007) 6

    SCC 120; and Government of NCT of Delhi & Another Vs.

    BSK Realtors LLP & Another, reported in (2024) 7 SCC

    370; submits that there are three essential requirements for

    denying relief to the petitioner on the ground of suppression of

    facts; (i) the facts must be material, (ii) withholding of the same

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    must be deliberate and (iii) even if the court finds some element

    of suppression or non-disclosure of facts, it must ask itself

    whether the relief would still be denied.

    20. The learned counsel appearing on behalf of opposite parties 3 to

    14 submits that altogether 11 settlement agreements were

    executed between the petitioner and the opposite parties 3 to 14

    whereby they were allowed to remain in possession of the said

    land and in lieu thereof a payment of about Rs. 1.08 Crores was

    made to the petitioner by way of cheques. It is further submitted

    that the said material fact was not averred in the writ petition and

    as such the petitioner obtained the order dated 22.10.2024 by

    playing fraud on the Court. Moreover, though few cheques given

    to the petitioner got dishonoured, however, the opposite party

    nos.3 to 14 handed over other cheques in lieu thereof to the

    petitioner which were duly honoured by the Bank and the amount

    was also transferred to his bank account.

    21. In support of the aforesaid contentions, the learned counsel for

    opposite parties 3 to 14 puts reliance on the judgment of the

    Hon’ble Supreme Court rendered in the case of State of M.P.

    Vs. Narmada Bachao Andolan & Another, reported in

    (2011)7 SCC 639.

    22. It appears from the materials placed on record by the opposite

    party nos.3 to 14 that after dismissal of C.M.P. No. 201 of 2017,

    the petitioner entered into settlement agreements with the

    opposite party nos. 3 to 14 and conveyed right, title, interest and

    possession of the land occupied by them. As per the terms and

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    conditions of the said settlement agreements, the petitioner

    received consideration of the said transaction by way of different

    cheques.

    23. The facts regarding execution of the said settlement agreements

    and receipt of cheques from the opposite party nos. 3 to 14 has

    not been denied by the petitioner, though he has claimed that

    the said agreements had no bearing with the subject matter of

    the writ petition being W.P.(C) No. 5461 of 2024 and as such the

    fact of execution of the settlement agreements with the opposite

    party nos.3 to 14 was not disclosed in the writ petition.

    24. I do not find any substance in the said argument of the learned

    counsel for the petitioner. The writ petition being W.P.(C) No.

    5461 of 2024 was filed by the petitioner seeking restoration of

    possession of the land in question in terms with the order dated

    13.12.1996 passed in S.A.R Case No. 169 of 1993-94 under

    section 71-A of the Act, 1908, which was upheld up to the High

    Court. However, even prior to filing of the said writ petition, the

    petitioner by way of settlement agreements, had himself

    conveyed possession of the said land to the opposite parties and

    had also received consideration for the same. Hence, the factum

    of execution of settlement agreements was certainly a material

    fact and the same was required to be disclosed by the petitioner

    in the said writ petition. The petitioner has claimed that some of

    the cheques given by the opposite party nos.3 to 14 have been

    dishonoured and as such the said agreements have rendered null

    and void. Though the opposite party nos.3 to 14 have explained

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    this fact as mentioned in the foregoing paragraph, yet even if the

    said claim of the petitioner is treated to be true, then also, the

    petitioner was required to disclose the said fact in the writ

    petition, which he did not do. The petitioner had also not arrayed

    the opposite party nos.3 to 14 as respondents in W.P.(C) No.5461

    of 2024 and obtained the order dated 22.10.2024 from this court

    by suppressing the material facts.

    25. In the case of Moti Lal Songara Vs. Prem Prakash @ Pappu

    and Another, reported in (2013)9 SCC 199, the respondents

    had obtained the order of discharge from the High Court by

    concealing the fact of framing of charge by the trial court. It was

    thus held that anyone who takes recourse to the method of

    suppression in a court of law, is, in actuality, playing fraud with

    the court and the maxim supressio veri, expressio falsi, i.e.,

    suppression of the truth is equivalent to the expression of

    falsehood, gets attracted. It was further held that as the order

    had been obtained by practising fraud and suppressing material

    fact before a court of law to gain advantage, the said order cannot

    be allowed to stand.

    26. In the case of Vishnu Vardhan alias Vishnu Pradhan vs.

    State of Uttar Pradesh and Others, reported in 2025 SCC

    OnLine SC 1501, the Hon’ble Supreme Court has held as

    under:-

    “50. Moving ahead, it is equally well settled that suppression of
    even a single material fact can be fatal before writ courts. In this
    context, one may usefully refer to the decision of this Court
    in S.J.S. Business Enterprises (P) Ltd. v. State of Bihar where the
    law has succinctly been stated as follows:

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    Neutral Citation No. (2026:JHHC:22664)

    13. As a general rule, suppression of a material fact by a
    litigant disqualifies such litigant from obtaining any relief.

    This rule has been evolved out of the need of the courts to
    deter a litigant from abusing the process of court by
    deceiving it. But the suppressed fact must be a material
    one in the sense that had it not been suppressed it would
    have had an effect on the merits of the case. It must be a
    matter which was material for the consideration of the
    court, whatever view the court may have taken …

    (emphasis ours)”

    27. In Vishnu Vardhan (Supra.) the Hon’ble Supreme Court has cited

    various earlier judicial pronouncements and held that the Courts

    have consistently nullified orders obtained through fraudulent

    means. Key excerpts from some of these decisions read thus:-

    “a. In United India Insurance Co. Ltd. v. Rajendra Singh and
    others
    , reported in (2000)3 SCC 581, this Court reiterated that
    fraud unravels everything:

    3. “Fraud and justice never dwell together” (fraus et jus
    nunquam cohabitant) is a pristine maxim which has
    never lost its temper over all these centuries. Lord
    Denning observed in a language without equivocation
    that “no judgment of a court, no order of a Minister can
    be allowed to stand if it has been obtained by fraud, for,
    fraud unravels everything” (Lazarus Estates
    Ltd. v. Beasley, [[1956] 1 Q.B. 702 : [1956] 1 All ER 341
    : [1956] 2 WLR 502 (CA)]).

    b. In Shrisht Dhawan (Smt) v. Shaw Bros., reported in (1992)1
    SCC 534, it was held:

    20. Fraud and collusion vitiate even the most solemn
    proceedings in any civilised system of jurisprudence. It is
    a concept descriptive of human conduct. Michael Levi
    likens a fraudster to Milton’s sorcerer, Comus, who
    exulted in his ability to, ‘wing me into the easy-hearted
    man and trap him into snares’. It has been defined as an
    act of trickery or deceit. In Webster’s Third New
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    Neutral Citation No. (2026:JHHC:22664)

    International Dictionary fraud in equity has been defined
    as an act or omission to act or concealment by which one
    person obtains an advantage against conscience over
    another or which equity or public policy forbids as being
    prejudicial to another. In Black’s Legal Dictionary, fraud
    is defined as an intentional perversion of truth for the
    purpose of inducing another in reliance upon it to part
    with some valuable thing belonging to him or surrender
    a legal right; a false representation of a matter of fact
    whether by words or by conduct, by false or misleading
    allegations, or by concealment of that which should have
    been disclosed, which deceives and is intended to
    deceive another so that he shall act upon it to his legal
    injury……..

    c. In A.V. Papayya Sastry and others v. Govt. of A.P. and others,
    reported in (2007)4 SCC 221, this Court held:

    21. Now, it is well-settled principle of law that if any
    judgment or order is obtained by fraud, it cannot be said
    to be a judgment or order in law. Before three centuries,
    Chief Justice Edward Coke proclaimed:

    “Fraud avoids all judicial acts, ecclesiastical or temporal.”

    22. It is thus settled proposition of law that a judgment,
    decree or order obtained by playing fraud on the court,
    tribunal or authority is a nullity and non est in the eye of
    the law. Such a judgment, decree or order–by the first
    court or by the final court–has to be treated as nullity by
    every court, superior or inferior. It can be challenged in
    any court, at any time, in appeal, revision, writ or even
    in collateral proceedings.

    23. ***

    24. In Duchess of Kingstone, Smith’s Leading Cases,
    13th Edn., p. 644, explaining the nature of fraud, de
    Grey, C.J. stated that though a judgment would be res
    judicata and not impeachable from within, it might be
    impeachable from without. In other words, though it is
    not permissible to show that the court was “mistaken”, it
    might be shown that it was “misled”. There is an essential
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    Neutral Citation No. (2026:JHHC:22664)

    distinction between mistake and trickery. The clear
    implication of the distinction is that an action to set aside
    a judgment cannot be brought on the ground that it has
    been decided wrongly, namely, that on the merits, the
    decision was one which should not have been rendered,
    but it can be set aside, if the court was imposed upon or
    tricked into giving the judgment.

    25. It has been said: fraud and justice never dwell
    together (fraus et jus nunquam cohabitant); or fraud and
    deceit ought to benefit none (fraus et dolus nemini
    patrocinari debent).

    d. The judgment by Denning, L.J. in Lazarus Estates
    Ltd. (supra), which has since been quoted with approval by this
    Court in a catena of decisions including Nidhi Kaim (supra),
    asserted intolerance for fraud in legal proceedings in the
    following words:

    No court … will allow a person to keep an advantage
    which he has obtained by fraud. […] Fraud unravels
    everything. The court is careful not to find fraud unless
    it is distinctly pleaded and proved; but once it is proved,
    it vitiates judgments, contracts and all transactions
    whatsoever….”

    28. In the case of Narmada Bachao Andolan (Supra.), as has

    been relied upon by the learned counsel for the opposite parties

    3 to 14, the Hon’ble Supreme Court has held that whenever the

    court comes to a conclusion that the process of the court is being

    abused, the court would be justified in refusing to proceed further

    with the matter. This rule has evolved out of the need of the

    courts to deter a litigant from abusing the process of the court by

    deceiving it. However, the concealed fact must be a material one

    in the sense that had it not been suppressed, it would have an

    effect on the merit of the case/order. It has further been held

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    that a person who suppresses the material facts from the court is

    guilty of suppressio veri and suggestio falsi i.e. suppression or

    failure to disclose what a party is bound to disclose, which may

    amount to fraud.

    29. Thus, it is no more res-integra that suppression of even a single

    material fact can be fatal before the Courts muchless the writ

    Courts and the same would amount to fraud on the Courts. A

    judgment, decree or order obtained by playing fraud on the court,

    tribunal or authority is a nullity and non est in the eye of law.

    Such a judgment, decree or order has to be treated as nullity by

    every court. It can be challenged in any court, at any time, in

    appeal, revision, writ or even in collateral proceedings.

    30. In the case in hand, the petitioner neither arrayed the opposite

    party nos.3 to 14 as respondents before the writ Court nor

    disclosed the material fact about execution of the settlement

    agreements and receipt of consideration by him paid at the

    instance of the opposite party nos. 3 to 14 to settle the dispute.

    Undoubtedly, the said suppression of fact was deliberate. Thus,

    this Court is of the view that the petitioner had obtained the order

    dated 22.10.2024 by playing fraud on this court and as such the

    said order is a nullity in the eye of law and has no legal effect.

    31. The other limb of the argument of the learned counsel for the

    petitioner is that the settlement agreements were executed by

    the petitioner under pressure and coercion and as such the same

    are nonest having no legal force. The said argument of the

    learned counsel for the petitioner is nothing but a face saving

    17
    Neutral Citation No. (2026:JHHC:22664)

    device and far from the truth. Curiously enough, the petitioner

    neither initiated any legal proceeding against the opposite party

    nos.3 to 14 in that regard nor the said fact was even averred in

    the writ petition being W.P.(C) No. 5461 of 2024.

    32. Since the order dated 22.10.2024 passed in W.P.(C) No. 5461 of

    2024 has itself been declared as nullity in the eye of law, there is

    no question of proceeding further with the present contempt case

    filed by the petitioner alleging wilful disobedience of the order

    dated 22.10.2014. The principle “when infrastructure collapses,

    superstructure is bound to collapse” is also applicable in the

    present case. It is well settled that a litigant, who attempts to

    pollute the stream of justice or touches the pure fountain of

    justice with tainted hands, is not entitled to any relief.

    33. It needs to be mentioned here that the petitioner has played

    fraud with the Court by suppressing the material facts which were

    vital for the adjudication of the writ petition as those facts were

    the development subsequent to passing of the order of

    restoration of land in S.A.R Case No. 169 of 1993-94. Had those

    facts been disclosed in the writ petition, this Court might not have

    passed the order dated 22.10.2024 in absence of the opposite

    party nos. 3 to 14. The suppression of the said material facts has

    certainly caused great prejudice to the opposite party nos. 3 to

    14.

    34. This Court also takes note of a dangerous trend of few

    unscrupulous litigants misrepresenting the Courts by suppressing

    18
    Neutral Citation No. (2026:JHHC:22664)

    the material facts just to obtain favourable orders from the

    Courts.

    35. In the case of Chandra Shashi Vs. Anil Kumar Verma,

    reported in (1995) 1 SCC 421, the Hon’ble Supreme Court has

    held that anyone who takes recourse to fraud, deflects the course

    of judicial proceedings; or if anything is done with oblique motive,

    the same interferes with the administration of justice. Such

    persons are required to be properly dealt with, not only to punish

    them for the wrong done, but also to deter others from indulging

    in similar acts which shake the faith of people in the system of

    administration of justice.

    36. In the case of Dalip Singh Vs. State of Uttar Pradesh and

    others, reported in (2010) 2 SCC 114, the Hon’ble Supreme

    Court has aptly observed that the truth constituted an integral

    part of the justice- delivery system which was in vogue in the pre-

    Independence era and the people used to feel proud to tell the

    truth in the courts irrespective of the consequences. However,

    post-Independence period has seen drastic changes in our value

    system. The materialism has overshadowed the old ethos and the

    quest for personal gain has become so intense that those involved

    in litigation do not hesitate to take shelter of falsehood,

    misrepresentation and suppression of facts in the court

    proceedings.

    37. In the present case, by filing show cause affidavit dated

    17.06.2026, the petitioner, on the one hand seeks apology from

    this court for inconvenience caused to it due to non-disclosure of

    19
    Neutral Citation No. (2026:JHHC:22664)

    the fact regarding execution of the settlement agreements

    between him and the opposite party nos. 3 to 14, however on the

    other hand, he tries to justify his conduct by stating that the said

    fact was not a material one for disposal of the writ petition being

    W.P.(C) No. 5461 of 2024. Thus, the said show cause affidavit

    also suffers from lack of bonafide.

    38. So far as the conduct of the opposite party no.2 is concerned,

    this court is of the view that in purported compliance of the order

    of this court dated 22.10.2024, he exceeded his jurisdiction by

    taking steps to demolish the structures standing over the said

    land. This court had not directed the opposite party no.2 to

    demolish the structures, he was rather directed to issue notices

    to the opposite party nos. 3 to 14 and to hand over possession of

    the said land to the petitioner, if the orders of different

    forums/Courts were found intact. If the opposite party no.2 had

    found that certain structures were erected over the land in

    question, he was required to seek appropriate clarification of the

    order of this court before taking such a drastic step of

    demolishing the same. Unfortunately, the opposite party no.2

    proceeded to demolish the structure standing over the said land.

    The said approach and conduct of the opposite party no.2

    deserve to be highly deprecated by this court. He is thus warned

    to be careful in future while executing any order of the court of

    law.

    39. Considering the conduct of the petitioner, as discussed

    hereinabove, he deserves to be imposed an exemplary cost.

    20

    Neutral Citation No. (2026:JHHC:22664)

    Accordingly, the petitioner is directed to pay cost of Rs.1,00,000/-

    (rupees one lakh) to each of the opposite party nos.3 to 14 i.e.

    Rs.12.00 Lakh (rupees twelve lakh) in total within four weeks

    from the date of this order. Both the parties are, however, at

    liberty to take appropriate recourse as available under law with

    respect to right, title and interest over the said land.

    40. The contempt petition is disposed of in above terms.

    41. All pending I.As, if any, are also disposed of.

    (Rajesh Shankar, J.)
    31 July, 2026
    st
    Sanjay/AFR
    Uploaded on 31.07.2026

    21



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