V. Thiagarajan vs K. Paramasivam on 20 April, 2026

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    ADVERTISEMENT

    Madras High Court

    V. Thiagarajan vs K. Paramasivam on 20 April, 2026

    Author: C.V. Karthikeyan

    Bench: C.V. Karthikeyan

                                                                                 AS No. 153 of 2014
    
    
                                      IN THE HIGH COURT OF JUDICATURE AT MADRAS
    
                                               RESERVED ON       : 09.03.2026
    
                                               PRONOUNCED ON :      20.04.2026
    
                                                       CORAM
    
                                      THE HON'BLE MR JUSTICE C.V. KARTHIKEYAN
                                                         AND
                                        THE HON'BLE MR.JUSTICE K.RAJASEKAR
                                                 AS No. 153 of 2014 and
                                                 CMP No.28262 of 2025
                    V. Thiagarajan
                                                                                 ..Appellant(s)
                                                          Vs
                    1. K. Paramasivam
    
                    2. P. Bhuvaneswari
    
                    3. R. Manickam
    
                    4. B. Balasubramaniam
    
                    5. P. Jayakumar (died)
    
                    6. P. Geetha
    
                    7. T.K.N. Masilamani
    
                    8. G. Venkatesan
    
                    9. M. Maragathavalli
    
                    10.P. Sivalingam
    
                    11.K. Sakthivel
    
                    12.R. Ramesh
    
                    13.A. Sakthivel
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                    14.Priya
    
                    15.Master Sachin
                       Represented By Natural Guardian Mother
                       (14th Respondent) Priya
    
                         (R5 Died, R14 And 15 are Brought On Record
                         As Lrs Of Deceased 5th Respondent Viz.,
                         P.Jayakumar, Vide Order Of Court Dated
                         20/03/2023 Made In CMP.No.16359/2022 In
                         AS.No.153/2014)
    
                    16.M/s.Annapoorani Shanmugasundram
                       Construction (p) Ltd.,
                       Rep. by its Managing Director, NH 47,
                       Sankari Main Road, Ariyanoor,
                       Salem -636 308.
    
                    17.V.Nihal Chand
    
                    18.V.Dhinesh Kumar
    
                    19.M/s.Mahalakshmi Media (p) Ltd.,
                       Rep. by its Managing Director, Old No.194,
                       New No.216, Rayapettah, Bharathi Salai,
                       Chennai -600 014.
    
                         (R16 to R19 are impleaded as party respondents
                         vide court order dated 15.12.2025 made in
                         CMP.No.28266/2025 in AS.No.153/2014)
                                                                                  ..Respondent(s)
    
                    PRAYER: Appeal filed under Section 96 of the Code of Civil Procedure to set
                    aside the judgment and decree dated 21.12.2012 passed in OS No.231 of 2008
                    by the II Additional District Judge, Salem insofar as rejection of a part of the
                    suit prayer.
                                  For Appellant(s):     Mr. R. Parthasarathy (Senior Advocate)
                                                        for Ms.S.Rekha
                                  For Respondent(s):    Mr.Prasanth Narayanan for R17 & R18
                                                        No appearance – R1 to R16 & R19
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                                                            JUDGMENT
    

    (Judgment of the Court was delivered by C.V.Karthikeyan J.)

    The plaintiff in O.S.No.231 of 2008, on the file of the II Additional

    SPONSORED

    District Court at Salem aggrieved by that portion of the judgment, wherein, the

    relief of specific performance was not granted as against the fifth and sixth

    defendants has filed the present appeal.

    2.The suit in O.S. No.231 of 2008 had been filed by the plaintiff/appellant

    herein, V.Thiagarajan seeking a judgment and decree of specific performance

    against the 1-6 defendants by directing them to execute a sale deed after making

    provisions to discharge the encumbrance of the 7-9 defendants over the suit

    properties, failing which, for the Court to execute the sale deed on behalf of the

    1-6 defendants and for permanent injunction restraining the 1-6 defendants from

    creating or registering any deed in respect of the suit property with respect to

    third parties and for costs of the suit.

    3.In the plaint, it had been contended that the plaintiff V.Thiagarajan and

    the first and second defendants, K.Paramasivam, P.Bhuvaneswari and one

    Rangasamy, son of Kandasamy of Kandarkulamanickam Village had entered

    into an agreement of sale for the sale of the properties morefully described to

    the schedule to the plaint at Rs.3,11,000/- per acre. The terms and conditions of

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    the agreement were reduced into writing on 06.09.2006. It was stated that the

    first and the second defendants and the said Rangasamy received a sum of

    Rs.1,00,000/- as advance from the representative of the plaintiff, Valliappa

    Chettiar. The agreement of sale was signed by the said Valliappa Chettiar on

    behalf of the plaintiff and by the first and second defendants and by the said

    Rangasamy. Rangasamy was the elder brother of the first defendant. The said

    property had fallen into the share of the first defendant and the said Rangasamy,

    under a compromise decree in a suit for partition in O.S.No.805 of 1992. The

    other properties under the agreement were also purchased by the second

    defendant. It was also agreed by the parties that the sale deed would be

    executed along with the legal heirs in favour of the plaintiff after receipt of the

    balance sale consideration on or before 31.10.2006. The first and the second

    defendants and the said Rangasamy had also agreed to discharge and clear all

    loans and encumbrances over the suit properties before executing the sale deed.

    4.It was also contended that the first and second defendants and

    Rangasamy received an additional part sale consideration of Rs.2,50,000/- in

    cash on 01.11.2006. They also made entries in the agreement of sale on

    21.09.2006 and on 01.11.2006. The time for executing the sale deed was

    extended till 31.01.2007. It was contended that efforts were taken by them to

    clear the existing debts. The plaintiff claimed that he was always ready and

    willing to perform his part of the agreement.

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    5.Thereafter, the first and second defendants and Rangasamy received a

    further advance of Rs.50,000/- on 06.12.2006 and a further sum of

    Rs.10,00,000/- by demand draft on 08.12.2006 towards the part repayment of

    the existing loan and to settle Indian Overseas Bank which had initiated steps

    under the SARFAESI Act to recover dues from the fifth defendant. Necessary

    endorsements were also made in the agreement of sale. A further advance of

    Rs.5,00,000/- had been paid by demand draft on 28.12.2006 to meet out the

    payment to the Indian Overseas Bank. It was contended that yet another

    advance of Rs.8,00,000/- was received on 05.01.2007 which entry was also

    made in the agreement of sale. It was therefore contended that the first and

    second defendants and Rangasamy had received a total sum of Rs.32,00,000/-

    towards the sale consideration and had undertaken to execute the sale deed in

    favour of the plaintiff along with their sons and daughters.

    6.The plaintiff then issued a notice on 27.01.2007, calling upon them to

    execute the registered sale deed on 31.01.2007. It was also contended that that

    a reply was issued raising false contentions. The plaintiff claims to have waited

    for the defendants at the Sub Registrar’s Office on 31.01.2007. In the reply

    notice, the first and second defendants and Rangasamy denied the sale

    agreement. They sought for a copy of the agreement. Thereafter, they sent a

    further reply on 14.02.2007 once again denying the existence of the agreement
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    and setting up a contention of loan transactions owing to which, they had signed

    in blank stamp papers towards security for the repayment of the loan. It was

    further contended that K.Rangasamy died intestate leaving behind the third and

    fourth respondents as his legal representatives. The fifth and sixth defendants

    were the son and daughter of the first and second defendants.

    7.It was further stated in the plaint that the fourth defendant sent an

    Advocate notice on 13.02.2007 claiming ½ share in the suit property along with

    the sixth defendant and stating that he was not connected with the agreement of

    sale. The plaintiff issued a reply reiterating the facts. The seventh defendant

    then caused a public notice to be issued in the Daily Thanthi Newspaper on

    23.12.2006 inviting claims from the general public over the suit properties. It

    was stated that the seventh defendant had a claim for recovery of money under a

    promissory note and had also obtained a decree against the first defendant in

    O.S.No.157 of 2004, on the file of the Fast Track Court, which suit had been

    filed seeking recovery of a sum of Rs.5,74,000/- together with subsequent

    interest. Thereafter, the eighth defendant also raised a claim under a mortgage

    deed. The ninth defendant claimed to be a creditor of the family of the first

    defendant and filed a civil suit on the file of the Principal District Court at

    Erode and a decree was also passed for a sum of Rs.6,33,555/-. The suit

    property was also attached for enforcement of the decree. The plaintiff had also

    filed an objection petition before the Sub Registrar, Magudanchavadi on
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    09.02.2007 preventing the defendants from entering into any agreement. It was

    also contended that the 10-12 defendants were subsequent purchasers of the suit

    properties. It was under those circumstances, that the suit had been filed

    seeking specific performance of the agreement of sale dated 06.09.2006.

    8.The first defendant filed a written statement which was adopted by the

    second defendant. In his written statement, he stated that he and the third

    defendant Rangasamy were brothers and further contended that the fifth and

    sixth defendants were not parties to the agreement of sale. They did not receive

    any consideration towards the sale of the land. It was further contended that

    there was no privity of contract between the third and fourth defendants and the

    plaintiff or his father. It was therefore contended that the suit should be

    dismissed against the third and fourth defendants. It was contended that these

    defendants got divided by an oral partition on 15.12.2007. It was contended

    that the 2-4 defendants had entered into an agreement of sale on 16.02.2007 to

    sell their property to one A.Sakthivel for Rs.54,69,000/- and had received an

    advance of Rs.20,00,000/- and Rs.5,00,000/- and had also put him in

    possession. It was contended that there was no cause of action against the sixth

    defendant and that the suit should be dismissed.

    9.The fifth defendant filed a separate written statement stating that the

    plaintiff had not signed the agreement of sale dated 06.09.2006 and that one
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    Valliappan had signed the sale agreement. It was also stated that this defendant,

    namely, the fifth defendant had also not signed the agreement nor in the

    endorsement made for alleged receipt of advance sale consideration. The

    defendant disclaimed all knowledge about the agreement. Even the advance

    sale consideration was not paid to this defendant. It was contended that this

    defendant and his sister/sixth defendant were each entitled to an undivided 1/3 rd

    share in the properties of their father. It was further contended that these

    defendants and the third and the fourth defendants had entered into an

    agreement of sale with one A.Sakthivel and had received an advance of

    Rs.20,00,000/- and Rs.5,00,000/- towards the total sale consideration of

    Rs.54,69,000/- and had also put the said Sakthivel in possession. It was

    contended that the suit against this defendant was not maintainable. It was

    therefore claimed that the suit should be dismissed.

    10.The seventh defendant filed a written statement which was adopted by

    the ninth defendant. In the said written statement, it had been contended that

    the agreement of sale dated 06.09.2006 was not binding on the seventh and

    ninth defendants. It was further contended that there was no privity of contract

    between the plaintiff and these defendants. They were not aware of the loan

    obtained by the first, second, fifth and sixth defendants. They were also not

    aware about the advance sale consideration received by the other defendants.

    They further claimed that they were not liable to make any payment to the bank
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    as stated in the plaint. They alleged collusion between the plaintiff and the first

    and second defendants. They also stated that the plaintiff was never ready and

    willing to perform his part of the agreement. They also sought dismissal of the

    suit.

    11.The tenth defendant filed a written statement again disputing the

    agreement of sale said to have been entered into by the plaintiff with the first

    and second defendants and one Rangasamy. It had been further stated that this

    defendant was the purchaser of three acres of land in S.No.141/5, 80-1/2 cents

    in S.No.141/1, 16-1/2 cents of land in S.No.141/2 and 2.55 acres in S.No.140/1

    totally 6.52 acres of land each with specified four boundaries along with a Well

    in S.No.141/5 of Kandarkula Manickam Village of Sankari Taluk for valuable

    consideration. These properties are part of the suit property. The defendant had

    purchased the said land from the sixth defendant through her power of attorney,

    the second defendant on 02.03.2009 before the filing of the suit under a

    registered sale deed. The survey numbers were wrongly given in the sale deed

    and therefore, a rectification deed was also registered in the Sub Registrar’s

    office at Magudanchavadi. It had also been stated that the vendor had obtained

    title by inheritance. It had been further stated that this defendant had sold the

    properties purchased along with other properties in the same village to one

    Annapoorani Shanmugasundaram Constructions Private Limited, by way of a

    registered sale deed dated 26.10.2009 registered at the Sub Registrar office at

    Magudanchavadi and the Company had been put in possession and enjoyment
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    of the said land. It had been stated that these facts were known to the plaintiff

    and still he had not impleaded the said Company as a party to the suit. The

    defendant stated that the agreement on the basis of which the plaintiff had filed

    the suit was a false and fabricated agreement. It was therefore urged that the

    suit should be dismissed as against this defendant.

    12.The thirteenth defendant filed a written statement questioning and

    disputing the agreement of sale dated 06.09.2006 relied on by the plaintiff. All

    the averments in the plaint were denied. It had been stated that this defendant

    had purchased 50 cents of land in S.No.140/1, 1.75 acres of land in S.No.140/2,

    totally 2.25 acres of land with specified four boundaries in Kandarkular

    Manickam village at Sankari Taluk for valuable consideration from the third

    and fourth defendants on 16.07.2009 under a document registered in the office

    of the Sub Registrar, Magudanchavadi. It had been further stated that the

    defendant had also purchased 8.12 ½ acres of land from the first and second

    defendants for valid consideration again under a registered sale deed dated

    16.07.2009 registered in the office of the Sub Registrar, Magudanchavadi. It

    had been stated that the vendors, namely, the first, second, third and fourth

    defendants had derived the properties under a compromise decree in O.S.

    No.805 of 1982 in the Sub Court, Salem. They had sold the land for urgent

    family needs. The vendors of the defendants had also sold the other portions of

    the land of the property to the 10-12 defendants. It was stated that this
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    defendant had sold the land purchased by him to Annapoorani

    Shanmugasundaram Constructions Private Limited by a registered sale deed

    dated 26.10.2009. This defendant stated that the plaintiff had not impleaded the

    subsequent purchaser as a party to the suit. It had been contended that the 1-5

    defendants had sold the properties and discharged their debts to third parties and

    this defendant had actually paid a sum of Rs.54,69,000/- towards purchase of

    the properties. It was therefore contended that the plaintiff had not come to the

    Court with correct facts. It was therefore contended that the suit should be

    dismissed.

    13.On the basis of the above pleadings, the learned Trial Judge had

    framed the following issues:

    (i) Whether the plaintiff, defendants 1 and 2 and Rangasamy entered

    into a sale agreement in respect of the suit properties?

    (ii) Whether the plaintiff paid a sum of Rs.32,00,000/- towards the sale

    consideration on various dates?

    (iii) Whether the suit properties are the ancestral properties of the

    defendants and the sale agreement will not bind the legal heirs of

    defendants 1 and 2?

    (iv) Whether the sale agreement will bind the defendants 3,4 and 5,6?

    (v) Whether the defendants 7 to 9 are necessary parties to this suit?

    (vi) Whether the plaintiff was ready and willing to perform his part of

    the contract?

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    (vii) Whether the plaintiff is entitled for the relief of specific

    performance after making provision to discharge the

    encumbrances of the defendants 7 to 9?

    (viii) Whether the plaintiff is entitled for the relief of permanent

    injunction prayed for?

    (ix) To what relief, if any the plaintiff is entitled?

    14.During trial, on the side of the plaintiff, the father of the plaintiff

    C.Valliappa was examined as PW1 and the plaintiff was examined as PW2.

    One further witness was examined as PW3. The plaintiff marked Exs.A1 to

    A23. Ex.A1 was the agreement of sale dated 06.09.2006. Exs.A2 to A8 were

    endorsements made for the receipt of further advance sale consideration in

    Ex.A1. Exs.A9, A10, A11, A13, A14 & A15 were notices exchanged between

    the parties. The communications sent by the Indian Overseas Bank to the fifth

    defendant were marked as Exs.A16 and A17. The sale deed in favour of the

    tenth defendant was marked as Ex.A23.

    15.On the side of the defendants, the first defendant, the fourth defendant

    and the tenth defendant were examined as DW1, DW2 and DW3 respectively.

    They however did not mark any documents.

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    16.On the basis of the oral and documentary evidence, the learned Trial

    Judge held with respect to the issue Nos.1 to 4 which revolved around the

    agreement of sale dated 06.09.2006 and whether the suit properties were

    ancestral properties and will bind the legal representatives of the first and

    second defendants and will bind the third, fourth, fifth and sixth defendants, that

    the agreement under Ex.A1 dated 06.09.2006 had been entered into by the

    plaintiff and the first and second defendants and Rangasamy. It had been

    provided in the agreement that the suit properties belonged to Rangasamy and

    the first defendant who were both brothers and who had been allotted the

    properties in O.S.No.805 of 1992 and belonged to the second defendant through

    purchase. The sale price had been determined at Rs.3,11,000/- per acre. A sum

    of Rs.1,00,000/- had been paid as advance. Thereafter, there were further

    advances paid of Rs.5,00,000/- and Rs.2,50,000/- and Rs.50,000/- and a sum of

    Rs.10,00,000/- and a further sum of Rs.5,00,000/- and a sum of Rs.8,00,000/-.

    Endorsement in this regard in Ex.A1 had been marked as Exs.A2 to A8. It had

    therefore been found that the plaintiff had paid a total sum of Rs.32,00,000/- as

    advance sale consideration. It was also found that the plaintiff had issued a

    notice under Ex.A9, calling upon the said first and second defendants and

    Rangasamy to execute the sale deed. Further notices were exchanged between

    the parties. It was noted that the defendants had various loans which had to be

    settled before they could effectively execute the sale deed.

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    17.It was also noted that Ex.A1 agreement of sale had not been signed by

    the plaintiff, but by his father and there was no recital in Ex.A1 that his father

    was a representative of the plaintiff and had signed Ex.A1 in that capacity.

    However, the learned Trial Judge held that the agreement of sale can be

    enforced. It had been signed by the vendors and delivered to the purchasers and

    had been accepted. It was therefore held that agreement of sale is enforceable

    against the signatories of the agreement. It was also noted that PW1, PW2 and

    PW3 had clearly spoken about the execution of Ex.A1 agreement of sale and the

    endorsements in Exs.A2 to A8. It was also found that while making

    endorsements, they had also affixed their thumb impressions.

    18.It was also noted that DW1 K.Paramasivam first defendant was an

    Advocate and knew the legal consequences of signing papers and documents.

    Therefore, the contentions of the first defendant that he had signed blank papers

    were rejected by the Trial Court. It was also noted that it was not open to DW1

    to question the endorsements. It was also further noted that DW3 was not a

    party to the agreement of sale. He had however purchased the suit properties

    after the institution of the suit. He had initiated steps to settle the loans of the

    first and second defendants by selling the suit properties to third parties

    disregarding the pendency of the suit.

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    19.It was held that Ex.A1 agreement to sale was true and valid and

    supported by consideration as shown by the endorsements in Exs.A2 to A8. The

    total extent of the suit properties was 23 acres and 81 cents. It was also noted

    that though the total area was not shown, it was evident from the description of

    the agreement. It was also reiterated that the agreement was binding on the

    signatories to the agreement.

    20.It was however found that in Ex.A1 the first defendant and the

    deceased Rangasamy who had both signed the agreement did not do so as Karta

    of the joint family. There was no recital that there were existing debts making it

    necessary for them to enter into the agreement of sale for family necessity. It

    was also found that as seen from Ex.A20, decree in O.S.No.805 of 1992,

    properties were allotted to each one of the defendants and admittedly, the 3-6

    defendants were not parties to the agreement of sale. It was therefore held that

    the agreement of sale could not be enforced against the share of the 3-6

    defendants. It was held therefore that the agreement could be enforced only in

    respect of ½ share of the first defendant in A schedule property, 1/3 rd share of

    the deceased Rangasamy in B schedule property and the property purchased by

    the second defendant. It had been stated that the agreement cannot be enforced

    against the other sharers of the property which fell to the 3-6 defendants. In

    view of these reasons, the suit was partly decreed only with respect to the shares
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    of the first and second defendants and Rangasamy and dismissed with respect to

    the shares of the 3-6 defendants.

    21.Questioning that judgment and decree, the plaintiff had filed the

    present appeal.

    22.Heard arguments advanced by Mr.R.Parthasarathy, learned Senior

    Counsel for the appellant, Mr.Prasanth Narayanan learned counsel for R17&

    R18. There was no representation for the other respondents. The 17th and 18th

    respondents are subsequent purchasers of the suit properties.

    23.Mr.R.Parthasarathy, learned Senior Counsel for the appellant pointed

    out the agreement of sale marked as Ex.A1 dated 06.09.2006 and argued that

    the appellant had entered into the said agreement with the first and second

    defendants in the suit and the deceased Rangasamy who was the brother of the

    first defendant to purchase the suit properties. He pointed out that the suit

    properties had been allotted to the first defendant and to his brother Rangasamy

    in a suit for partition in O.S.No.805 of 1992, the decree of which had been

    marked as Ex.A20. The learned Senior Counsel stated that the other properties

    covered under the agreement had been purchased by the second defendant who

    was the wife of the first defendant. The learned counsel therefore contended

    that the first and second defendants and Rangasamy were absolute owners of the
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    properties and they have signed in their independent capacity. It was also

    pointed out by the learned Senior Counsel that more than ample evidence was

    recorded to show that 3-6 defendants had incurred debts and particularly, the

    fifth defendant had borrowed amounts from the Indian Overseas Bank and

    SARFAESI notice had also been issued.

    24.The learned Senior Counsel contended that the plaintiff had paid

    substantial amounts as advance towards the settlement of the loans and to clear

    the property of its encumbrances. The sale consideration had been determined

    at Rs.3,11,000/- per acre and the plaintiff had paid a total advance of

    Rs.32,00,000/- to the defendants and this fact had been established by the

    endorsements made in Ex.A1 under Exs.A2 to A8. The learned Senior Counsel

    contended that merely because the properties had been sold by some of the

    defendants to other third parties, it would not invalidate the agreement or

    extinguish the right of the plaintiff to enforce the agreement. The learned

    Senior Counsel argued that the subsequent purchasers who had purchased

    portions of the properties pending suit would be bound by the decree.

    25.In this connection, the learned Senior Counsel placed specific reliance

    on the following passages of the judgment of the Hon’ble Supreme Court in

    Dastagirsab Vs. Sharanappa alias Shivasharanappa Police Patil (D) by LRs.

    and others reported in 2025 SCC Online SC 1983.

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    11. Right of a Karta to sell joint family
    property is well settled. Karta enjoys wide
    discretion with regard to existence of legal
    necessity and in what way such necessity can be
    fulfilled. Whether legal necessity existed justifying
    the sale would depend on facts of each case. In
    Beereddy Dasaratharami Reddy v. V. Manjunath,
    this Court succinctly elucidated:

    “6. Right of the Karta to execute agreement to
    sell or sale deed of a joint Hindu family property is
    settled and is beyond cavil vide several judgments of
    this Court including Sri Narayan Bal v. Sridhar Sutar,
    (1996) 8 SCC 54], wherein it has been held that a joint
    Hindu family is capable of acting through its Karta or
    adult member of the family in management of the joint
    Hindu family property. A coparcener who has right to
    claim a share in the joint Hindu family estate cannot
    seek injunction against the Karta restraining him from
    dealing with or entering into a transaction from sale of
    the joint Hindu family property, albeit post alienation
    has a right to challenge the alienation if the same is
    not for legal necessity or for betterment of the estate.

    Where a Karta has alienated a joint Hindu family
    property for value either for legal necessity or benefit
    of the estate it would bind the interest of all undivided
    members of the family even when they are minors or
    widows. There are no specific grounds that establish
    the existence of legal necessity and the existence of
    legal necessity depends upon facts of each case. The

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    Karta enjoys wide discretion in his decision over
    existence of legal necessity. and as to in what way such
    necessity can be fulfilled. The exercise of powers given
    the rights of the Karta on fulfilling the requirement of
    legal necessity or betterment of the estate is valid and
    binding on other coparceners.

    7. Elucidating the position in Hindu law, this
    Court in Kehar Singh v. Nachittar Kaur, (2018) 14
    SCC 445 has referred to Mulla on Hindu Law and the
    concept of legal necessity to observe thus: (SCC pp.
    449-51, paras 20-21 & 26)

    “20. Mulla in his classic work Hindu Law while
    dealing with the right of a father to alienate any
    ancestral property said in Article 254, which reads as
    under:

    ‘Article 254

    254. Alienation by father.-A Hindu father as
    such has special powers of alienating coparcenary
    property, which no other coparcener has. In the
    exercise of these powers he may:

    (1) make a gift of ancestral movable property to
    the extent mentioned in Article 223, and even of
    ancestral immovable property to the extent mentioned
    in Article 224;

    (2) sell or mortgage ancestral property, whether
    movable or immovable, including the interest of his

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    sons, grandsons and great-grandsons therein, for the
    payment of his own debt, provided the debt was an
    antecedent debt, and was not incurred for immoral or
    illegal purposes (Article 294).’

    21. What is legal necessity was also succinctly
    said by Mulla in Article 241, which reads as under:

    ‘Article 241

    241. What is legal necessity.- The following
    have been held to be family necessities within the
    meaning of Article 240:

    (a) payment of government revenue and of debts which
    are payable out of the family property;

    (b) maintenance of coparceners and of the members of
    their families;

    (c) marriage expenses of male coparceners, and of the
    daughters of coparceners;

    (d) performance of the necessary funeral or family
    ceremonies;

    (e) costs of necessary litigation in recovering or
    preserving the estate;

    (f) costs of defending the head of the joint family or any
    other member against a serious criminal charge;

    (g) payment of debts incurred for family business or

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    other necessary purpose. In the case of a manager
    other than a father, it is not enough to show merely
    that the debt is a pre-existing debt;

    The above are not the only indices for concluding as to
    whether the alienation was indeed for legal necessity,
    nor can the enumeration of criterion for establishing
    legal necessity be copious or even predictable. It must
    therefore depend on the facts of each case. When,
    therefore, property is sold in order to fulfil tax
    obligations incurred by a family business, such
    alienation can be classified as constituting legal
    necessity.’
    (See Hindu Law by Mulla “22 nd Edition”.)
    ***

    26. Once the factum of existence of legal
    necessity stood proved, then, in our view, no co-
    coparcener (son) has a right to challenge the sale
    made by the karta of his family. The plaintiff being a
    son was one of the co-coparceners along with his
    father Pritam Singh. He had no right to challenge such
    sale in the light of findings of legal necessity being
    recorded against him. It was more so when the plaintiff
    failed to prove by any evidence that there was no legal
    necessity for sale of the suit land or that the evidence
    adduced by the defendants to prove the factum of
    existence of legal necessity was either insufficient or
    irrelevant or no evidence at all.”

    12. Plaintiff co-parcener has assailed the
    sale transaction undertaken by 1st defendant-Karta
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    on the ground it was not made for legal necessity
    but to meet his expensive and wasteful habits.

    Evidence has come on record 1st defendant-Karta
    had previously sold various properties of the HUF.
    Though it is the plaintiff’s case that such sales were
    not for legal necessities, he has not challenged any
    of these transactions. To justify his present claim,
    the plaintiff asserts the 1st defendant assured him
    money derived from such sales would be settled in
    favour of the sons including the plaintiff and that
    no other properties would be sold. It is further the
    plaintiff’s case, no money was settled in his favour
    or that of the 2nd defendant but substantial sums
    were settled in favour of 3 rd and 4 th defendant.

    Though the plaintiff alleges 1 st defendant acted in
    a biased and unfair manner, admittedly the
    plaintiff has not taken any steps for recovery of
    such outstanding dues earlier or even in the
    present suit.

    13. In view of such conduct, the Trial Court
    rightly inferred the earlier sale transactions of
    HUF properties were for financial needs and the
    plea that the previous HUF assets were disposed of
    to meet the Karta’s extravagant habits was an
    afterthought.

    14. With regard to the sale of the suit land to
    5th defendant, the Trial Court noted that during
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    cross-examination the plaintiff admitted his father
    had informed him that the property had been sold
    to meet family needs. High Court completely
    glossed over this fact and reversed the finding on a
    specious logic that the sale of the suit land for
    Kashibai’s marriage was improbable as the
    marriage had already taken place prior to the sale
    in question.

    26.Pointing out that the Karta of the Joint Hindu Family had a right to sell

    the property, the learned Senior Counsel argued that even if it were to be

    assumed that the first defendant and Rangasamy were deemed to be the Kartas

    of their respective families, the agreement of sale entered into by them, would

    bind the third, fourth, fifth and sixth defendants. The learned Senior Counsel

    stated that the Hon’ble Supreme Court had very clearly stated in the

    aforementioned judgment that the Karta had a right to sell the joint family

    property.

    27.The learned Senior Counsel stated that the property had been

    admittedly allotted to the first defendant and to Rangasamy under a partition

    suit in O.S.No.805 of 1992 and therefore, the suit properties could be dealt by

    them on their behalf and on behalf of their legal representatives/co-sharers in

    the Joint Hindu Family. It was also noted by the learned Senior Counsel that

    the second defendant had independently purchased portions of the suit

    properties which were governed under the agreement of sale. The learned

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    Senior Counsel therefore assailed the reasonings of the Trial Court that the

    agreement would not bind 3-6 defendants. The learned Senior Counsel therefore

    urged that this Court should set aside that findings of the Trial Court and decree

    the suit in entirety.

    28.The learned counsel for the 17th and 18th respondents however disputed

    this contention. According to him, the properties had been sold again and again

    to other defendants and there had been subsequent transactions even during the

    pendency of the suit. The plaintiff had kept quiet when these transactions had

    taken place. The learned counsel pointed out that there was a duty on the part

    of the plaintiff to seek injunction restraining further alienations. The learned

    counsel argued that the plaintiff/appellant should have filed an application if

    there were further transactions that they could be done only by obtaining leave

    of the Court. The learned counsel pointed out that Section 54 of the Transfer of

    Property Act provided that an agreement holder would not have any right or

    interest over the property. The title holder of the property would always be at

    liberty to deal with the property.

    29.The learned counsel pointed out that the subsequent sale deeds have

    not been sought to be set aside by the plaintiff. They have been also executed

    for valid sale consideration. He very specifically pointed out that the third,

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    fourth, fifth and six defendants were entitled to independent shares on and from

    the date of their birth. The first defendant or deceased Rangasamy had no right

    to act on their behalf since they had attained the age of majority and were

    capable of dealing with their shares. The Karta can act on behalf of a minor, but

    not on behalf of co-parceners who had attained the age of majority.

    30.The learned counsel placed reliance on the judgment of the Hon’ble

    Supreme Court in Angadi Chandranna Vs. Shankar and Others reported in 2025

    SCC Online SC 877 and more particularly to paragraph No.17, wherein, it had

    been held as follows:

    17. It cannot be disputed that the properties divided
    among Defendant No.1 and his brothers through
    partition deed dated 09.05.1986, are joint family
    properties. However, as per Hindu law, after partition,
    each party gets a separate and distinct share and this
    share becomes their self-acquired property and they
    have absolute rights over it and they can sell, transfer,
    or bequeath it as they wish. Accordingly, the properties
    bequeathed through partition, become the self- acquired
    properties of the respective sharers.

    31.Placing reliance on the dictum laid by the Hon’ble Supreme Court, the

    learned counsel stated that the Trial Judge had correctly dismissed the suit

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    against 3-6 defendants who were the earlier/erstwhile owners/vendors of the

    property and after several transactions, the property had devolved on to the 16 th

    & 17th respondents.

    32.We have carefully considered the arguments advanced and perused the

    material records.

    33.The following points arise for consideration:

    (i) Whether the agreement of sale entered into
    by the first defendant and his brother Rangasamy
    would bind their legal heirs/3-6 defendants?

    (ii) Whether the agreement of sale entered into
    by a Karta of the joint family would be binding on
    other Co-Parceners who had attained the age of
    majority?

    (iii)Whether the agreement of sale would be
    binding on the 3-6 defendants?

    34.Since the evidence adduced overlap, all the three points are taken up

    for discussion and determination together.

    35.The appellant had entered into an agreement of sale on 06.09.2006 to

    purchase the land described in the plaint from the first defendant and his brother

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    Rangasamy who had been allotted shares under Ex.A20, partition decree in

    O.S.No.805 of 1992, on the file of the Sub Court at Salem. There were other

    properties in the agreement of sale. They had been purchased by the second

    defendant who was the wife of the first defendant. There is no covenant in the

    agreement of sale that the first defendant and Rangasamy had entered into the

    agreement of sale as Karta of a Joint Hindu Family. There is no dispute about

    the agreement which has been marked as Ex.A1. There is no dispute over the

    advance sale consideration received which receipts were marked as Exs.A2 to

    A8. However, even during the pendency of the suit, the suit properties had been

    dealt with by 3-6 defendants. They had sold the properties to the 10 th defendant

    and subsequently also to the 13th defendant. The said defendants had also taken

    possession of the properties. The properties had been further sold and the 16-18

    defendants had also purchased the properties. There is no relief sought in the

    plaint to declare that these sale deeds are null and void.

    36.The Trial Judge had held that since the properties had devolved under

    partition, definite shares had been allotted to 3-6 defendants. In this connection,

    the learned Trial Judge had noted that the said defendants were not signatories

    to the sale agreement.

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    37.It is also seen from Ex.A1 that quite apart from their being no recital

    that the agreement of sale had been entered by the first defendant and by the

    brother Rangasamy as Kartas of their respective Joint Hindu Families, there was

    also no recital about the existing debts and that therefore the agreement of sale

    had been entered into by them. There was no recital that the agreement of sale

    had been entered into by them out of family necessity.

    38.Ex.A20 is the decree in O.S.No.805 of 1992. That was a partition suit

    filed by the first and fifth defendants against the deceased Rangasamy and third

    and fourth defendants. It is thus seen that the suit was not only between the first

    defendant and the deceased Rangasamy, but also the parties to the suit were the

    fifth defendant as plaintiff and the third and fourth defendants as defendants. In

    that particular suit, the A Schedule properties as described in that suit were

    allotted to the first and fifth defendants and the B Schedule properties as

    described in that suit were allotted to Rangasamy and to the third and fourth

    defendants. It is thus seen that in the A schedule properties in that suit, the fifth

    defendant had an undivided ½ share. Similarly, in the B schedule properties in

    that suit, the third and fourth defendants were each entitled to an undivided 1/3 rd

    share along with Rangasamy. These defendants were not parties to the

    agreement of sale. They had independent shares.

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    39.It can therefore never be stated that the first defendant and Rangasamy

    were Kartas of their Joint Hindu Families. They had an independent share and

    the third, fourth and fifth defendants had independent shares allotted to them.

    40.The dictum of the Hon’ble Supreme Court in Angadi Chandranna

    referred supra reported in 2025 SCC Online SC 877 is therefore directly

    applicable, since, when separate and distinct shares are allotted in a partition,

    then such shares become an acquired property and the allottees have absolute

    rights over the said shares.

    41.As a matter of fact, the properties which had been allotted to the first

    defendant and to the fifth defendant had been separately given and the

    properties allotted to Rangasamy and third and fourth defendants had been

    separately given. It is thus seen that the properties are independent and distinct.

    There were two separate branches, namely, that of the first defendant and the

    fifth defendant and that of Rangasamy and the third and fourth defendants. The

    first, second, fifth and sixth defendants and also the third and fourth defendants

    had conveyed various portions of the suit schedule properties to third parties,

    namely, 10-13 defendants. Subsequently, 10-13 defendants have sold various

    portions of the suit properties to the 16-19th defendants. These facts have been

    stated in the written statement also. There was no relief sought that these sale

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    deeds are null and void. There are no pleadings that these sale deeds are not

    binding on the plaintiff. We therefore hold that the agreement of sale had not

    been entered into by the first defendant and Rangasamy as Kartas of their

    respective Joint Hindu Families. The agreement of sale can bind only to their

    shares and not the shares of the 3-5 defendants.

    42.We answer the points framed for consideration accordingly.

    43.In view of these reasons, we hold that the learned Trial Judge had

    come to a correct conclusion that specific performance cannot be granted on the

    shares of 3-6 defendants. We find no infirmity in the said reasoning.

    44.In view of the above, the Appeal Suit stands dismissed confirming the

    Judgment and Decree of the Trial Court. No costs. Consequently, connected

    miscellaneous petition is also closed.

    (C.V.K.,J.) (K.R.S.,J.)
    20.04.2026
    Index: Yes/No
    Speaking/Non-speaking order
    Neutral Citation: Yes/No
    sli

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    To

    The II Additional District Court,
    Salem.

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    AS No. 153 of 2014

    C.V.KARTHIKEYAN, J.

    AND
    K.RAJASEKAR, J.

    sli

    Pre-delivery Judgment in
    AS No. 153 of 2014 and
    CMP No.28262 of 2025

    20-04-2026

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