Tuesday, 8 September 2026

Bombay HC: Outsider's Alienation Of Joint Family Property Cannot Be Challenged In Partition Suit Between Coparceners

Here, the alienation is not done by a coparcener, but the same is done by an outsider i.e. Khot family. Therefore, the issue of alienation by Khot family to BCT cannot be a subject matter of suit for partition between Patil family members. Whether Khots had title to pass on to BCT is something which cannot be decided in suit for partition of joint family properties of Patils. Knowing this well, the alienation by Khots to BCT is consciously kept out of the scope of the suit by the Plaintiffs. The alienation made by Khot family in favour of BCT is questioned independently by a suit filed by Defendant No. 1. Knowing this difficulty, Plaintiffs have consciously kept the challenge to alienation not only outside the purview of the main suit, but have consciously not included the prayer for challenging the Indentures dated 14 January 1971 and 28 October 2009 even in the proposed amended prayers. Since the issue of permissibility to challenge alienation by a coparcener of joint family property in a partition suit is irrelevant in the facts and circumstances of the present case, it is not necessary to discuss the ratio of the judgment of Calcutta High Court in Ganeshmull Surana and of Madras High Court in Chinnasamy Naidu (supra). {Para 27}

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

CIVIL APPELLATE JURISDICTION

WRIT PETITION NO.1918 OF 2016

Arun Narayan Patil and Ors. Vs  Jayshree Jaywant Patil and Ors. 

CORAM : SANDEEP V. MARNE, J.

Dated : 27 August 2026.

Citation:2026:BHC-AS:35171


1) By this Petition, Petitioners/Plaintiff Nos.1(a) to 1(d) have challenged Order dated 14 September 2015 passed by the learned Judge, City Civil Court Mumbai, rejecting Chamber Summons Nos. 718 of 2010 and 1089 of 2011 filed for amendment of the plaint in S.C. Suit No. 9984 of 1991.

2) Plaintiffs have instituted S.C. Suit No. 9984 of 1991 for

declaration of properties as Hindu Undivided Family (HUF) properties and seeking partition thereof by metes and bounds. The suit was originally instituted in this Court as High Court Suit No. 1212 of 1991. The suit properties in Exhibit E included land bearing Survey No.151A situated at Village-Nahur, Mumbai Suburban District. Plaintiffs claim that even the said land bearing Survey No.151A is a joint family property. By Indenture dated 14 January 1971, the land bearing Survey No.151A admeasuring 38,374.72 sq.m. was transferred by Ratansey Karsandas and Ors. (Khots of

Bhandup) to Bafna Charitable Trust. In their Suit for partition, Plaintiffs

made averments not to implead Bafna Charitable Trust as party

defendants so as to avoid misjoinder, even though property bearing

Survey No.151A was sought to be declared as joint family property and

partition thereof was sought.

3) In Suit No. 1212 of 1991, Court Receiver was appointed in

respect of the suit properties, including the land bearing Survey No, 151A.

Bafna Charitable Trust got aggrieved by the appointment of Court

Receiver qua land purchased by it in Survey No.151A and filed Notice of

Motion No. 3479 of 2004 under Order 40 Rule 1(2) of the Code of Civil

Procedure, 1908 (Code) seeking deletion of land bearing Survey No.151A

from the Suit and for discharge of the Court Receiver. By order dated 1

August 2008, this Court allowed Notice of Motion No. 3479 of 2004,

directing deletion of land bearing Survey No.151A from the Suit and

discharging the Court Receiver in respect thereof by granting liberty to

the Plaintiffs to adopt appropriate proceedings against Bafna Charitable

Trust. The order dated 1 August 2008 has attained finality on account of

dismissal of the Appeal by the Division Bench on 17 October 2008 and order dated 14 May 2009 passed by the Hon’ble Supreme Court in SLP (C) No. 11531 of 2009.

4) On 28 October 2009, Bafna Charitable Trust (BCT) conveyed

the plot of the land bearing Survey No.151A admeasuring 38374 sq.m. in

favour of Respondent No.72 - M/s. Atul Builders and Estates Ltd. (Atul

Builders). Plaintiffs filed Chamber Summons No. 718 of 2010 in the Suit

seeking to amend the plaint to implead the Trust and seeking a

declaration that it has no right in Survey No.151A. Another Chamber

Summons being Chamber Summons No. 1089 of 2011 was filed in the Suit

seeking impleadment of Respondent No.72 -Atul Builders and seeking

similar relief qua it. By order dated 12 August 2011, this Court dismissed

both the Chamber Summons. Plaintiffs preferred Appeal against the

single judge order and by order dated 1 December 2011, the order dated

12 August 2011 was set aside by consent and the Chamber Summons were

remanded for fresh consideration.

5) Suit No. 1212 of 1991 was transferred to the City Civil Court

in the year 2012 and was renumbered as S.C. Suit No.9984 of 1991. By

common order dated 14 September 2015, the Court has dismissed both

the Chamber Summons Nos. 718 of 2010 and 1089 of 2011. Aggrieved by

order dated 14 September 2015 passed by the City Civil Court, the

Petitioners, who are original Plaintiff Nos.1(a) to 1(d), have filed the

present petition.

6) The Petition is opposed by Atul Builders (Respondent No.

72). None has appeared on behalf of BCT. However, since the petition is pending since the year 2015 and the trial of the suit is withheld, I have proceeded to decide the petition on merits rather than awaiting appearance on behalf of BCT. Accordingly, I have heard the learned counsel appearing for the Petitioners and Respondent No.72.

7) Mr. Nirman Sharma, the learned counsel appearing for the

Petitioners would submit that the City Civil Court has grossly erred in

dismissing both the Chamber Summons. He submits that there are

apparent inconsistencies in the order of the City Civil Court. That in

para-20 of the order, the Court has rejected the ground of limitation but

has proceeded to dismiss the Chamber Summons observing that the same

could not have been filed after a delay of 20 long years. Mr. Sharma

invites the attention of this Court to the order dated 1 August 2008

passed by this Court in Notice of Motion No. 3479 of 2004 submitting that

the specific liberty was granted to the Plaintiffs to adopt appropriate

proceedings. He submits that this Court directed deletion of land bearing

Survey No.151A from the Suit only on account of non-impleadment of

BCT to the Suit. That a specific finding to that effect is recorded in para-

22 of the order dated 1 August 2008. That, deletion of the property

bearing Survey No.151A was sought by the BCT only on the ground that it

was not impleaded as a party Defendant to the Suit. That the said

inadvertence was sought to be corrected by seeking to implead BCT as

well as its assignee - Atul Builders as party Defendants to the Suit by

filing application for amendment.

8) Mr. Sharma further submits that this is a pre-trial

amendment and therefore the Trial Court ought to have been liberal in granting the same. In support, he relies on judgment of the Apex Court in

the case of Life Insurance Corporation of India vs. Sanjeev Builders

Private Limited & Anr1. He further submits that the amendment does not

change the nature of the Suit in any manner. That it is permissible for a

coparcener to challenge alienation of joint family properties by another

co-parcener in the partition suit and in support, he relies on judgment of

Calcutta High Court in Ganeshmull Surana Versus. Nagraj Surana2 and

of Madras High Court in Chinaswamy Naidu Versus. Amsaveni Ammal &

Ors.3. He submits that when Plaintiffs attempted to get themselves

impleaded in the Suit filed by Defendant No.1 against BCT (Suit No. 8031

of 1984) impleadment of Plaintiffs is opposed both by BCT, as well as by

Atul Builders. He invites attention of this Court to order dated 8 August

2017 passed by the Hon’ble Supreme Court in that regard. He submits

that the call on impleadment of Plaintiffs in that suit would be decided

based on the outcome of the present Petition. He submits that if the

amendments are disallowed, Plaintiffs would be rendered remediless in

respect of unauthorised joint family property alienation in favour of BCT

and Atul Builders. He submits that the issue of limitation is a mixed

question of law and fact and cannot be gone into at the stage of deciding

application for amendment. That Plaintiffs are not questioning alienation

but are merely seeking a declaration that land bearing Survey No.150A is

a joint family property in which BCT and Atul Builders have no right, title

or interest. That such prayer in a partition suit can never be treated as

barred by limitation. That the case does not involve the proposed

amendment being hopelessly time barred. That there are also

1 (2022) 16 SCC 1

2 1951 SCC Online Cal 309

3 MANU/TN/0470/1985

inconsistent findings in the impugned order. He therefore submits that

the impugned order is liable to be set aside. He prays for Writ Petition

being made absolute in terms of prayers made therein.

9) Mr. Tulzapurkar, the learned senior advocate appearing for

Respondent No.72 opposes the Petition. He submits that no interference

is warranted in the well-considered order passed by the City Civil Court.

That the proposed amendments are hopelessly time-barred. That the

alienation of land bearing Survey No.151/A in favour of BCT has occurred

on 14 January 1971 and Chamber Summons No. 718 of 2010 filed in 2010

seeking to challenge that alienation is clearly barred by limitation under

Article 58 of the Limitation Act, 1963. That the averments in para-13 of

the plaint clearly indicates knowledge on the part of the plaintiffs about

the said alienation. In support of his contention that the proposed

amendment is barred by limitation, he relies on judgment of the Apex

Court in South Konkan Distilleries and Anr. Versus. Prabhakar Gajanan

Naik & Ors4. That there is a conscious exclusion of challenge to the

Indenture dated 14 January 1971 from the suit. That what is consciously

sought to be excluded cannot be sought to be included in the Suit after

substantial delay. That right to sue qua Indenture dated 14 January 1971

had accrued before filing of the Suit and despite having knowledge of the

said transaction, Plaintiffs consciously avoided to seek any relief against

BCT. That therefore the application for amendment is rightly rejected.

10) Mr. Tulzapurkar further submits that even otherwise, the

issue of validity of Indenture dated 14 January 1971 cannot be included in

4 (2008) 14 SCC 632


a partition suit. He submits that in a partition suit, unauthorised

alienation made in favour of a third party cannot be questioned as the

same constitutes a different cause of action. In support of his contention

that the issue of alienation cannot be subject matter of the present Suit,

Mr. Tulzapurkar relies upon the judgment of the Apex Court in Trinity

Infraventures Ltd. & Ors. Versus. M.S. Murthy & Ors.5 and of Delhi High

Court in Shri Sanjive Shukla Versus. Shri, Rajiv P. Shukla6. That, in any

case, alienation in the present case is not made by Patil family, but the

same is made by altogether different persons, namely Khot family. That

Suit No. 8031 of 1984 has already been filed in the City Civil Court by

Defendant No.1, challenging the Indenture dated 14 January 1971. That

therefore there is absolutely no cause for including any reliefs relating to

land bearing Survey No.151A or for questioning rights of BCT/Atul

Builders qua that land in the present Suit. That the proposed amendments

would clearly change the nature of the Suit and he relies on judgment of

the Apex Court in Asian Hotels (North) Limited Versus. Alok Kumar

Lodha & Ors.7

11) Mr. Tulzapurkar submits that even otherwise, the alienation

of 14 January 1971 in favour of BCT or alienation of 28 October 2009 in

favour of Atul Builders is not subject matter of challenge even in the

proposed amendments. He submits that liberty granted by this Court by

order dated 1 August 2008 cannot be construed to mean liberty to amend

the plaint and reinclude the land bearing Survey No.151A which was

specifically directed to be deleted by this Court. That the amendments

5 2023 SCC Online SC 738

6 2015 SCC Online Del 8943

7 (2022) 8 SCC 145

seeks to overreach the order passed by this Court on 1 August 2008. He submits that the City Civil Court has rightly dismissed both the chamber summons for amendment. He prays for dismissal of the Petition.

12) Rival contentions urged on behalf of the parties now fall for

my consideration.

13) Petitioners are Plaintiff Nos.1(a) to 1(d) in High Court Suit

No.1212 of 1991 which is renumbered as S.C. Suit No.9984 of 1991 after

being transferred to the City Civil Court. Petitioners are aggrieved by

common order dated 14 September 2015 passed by the City Civil Court

rejecting two applications for amendment filed by them, Chamber

Summons Nos.718 of 2010 and 1089 of 2011. The first amendment

application in the form of Chamber Summons No.718 of 2010 was filed for

impleadment of proposed Defendant No.65 to 71, being BCT and its

members/trustees, as party Defendants to the Suit and for seeking a

declaration that they have no right, title or interest in respect of the land

bearing Survey No.151A. The second amendment application being

Chamber Summons No.1089 of 2011 was filed seeking impleadment of

Atul Builders as party Defendant No.72 to the Suit and seeking similar

declaration of it having no right, title or interest in the suit property

bearing Survey No.151A. Both the Chamber Summons have been rejected

by the City Civil Court by common order dated 14 September 2015.

14) In the Suit as originally filed in the year 1991, the land

bearing Survey No.151A was included in the list of suit properties at Exh.

E. Well before filing of the Suit, land bearing Survey No.151A was

alienated by Khot family in favour of BCT by Indenture dated 14 January

1971. The alienation was thus not by any coparcener of the Patil joint

family but the same was done by altogether different persons. Plaintiffs

had knowledge about such alienation and it appears that one of the joint

family members (Defendant No.1) has instituted Suit No.8031 of 1984

challenging the said alienation. Plaintiffs referred to the alienation in

favour of BCT, as well as filing of Suit No.8031 of 1984 by Defendant No.1

in para-13 of the plaint which reads thus:

13. The Plaintiffs say that it is the allegation of the said Bafna that by a Deed of

settlement dated 14th January 1971 made between Rattansey karsandas and

others (viz. Khat of Bhandup / Bhandup Estate) the said Khats gifted the

proportion mentioned in the statement Ex.‘F’ hereto to the Bafna Charitable

Trust. The Plaintiffs submit that the purported gift is void ab initio as the said

khots/Inamdars had no subsisting rights in respect of the said properties, which

are part of the properties described in Ex.'E' hereto. The Plaintiffs say that in

the present suit, they have not joined the said Bafna as a party Defendant in

order not to cause misjoinder of the cause of action and/or parties and

particularly because the Defendant No.1 has filed a suit bearing Suit no.8031 of

1984 against the said Bafna and others in the City Civil Court for the following

reliefs:-

xxx

15) Thus, despite being aware of the position that Khot family

had alienated land bearing Survey No.151A in favour of BCT by Indenture

of 14 January 1971, Plaintiffs consciously did not implead BCT so as to

avoid the vice of misjoinder of cause of action. However, though BCT was

not impleaded as party defendant to the Suit nor alienation of 1971 was

questioned in the Suit, Plaintiffs somehow included land bearing Survey

No.151A in the list of suit properties in S.C. Suit No.9984 of 1991.

16) After Plaintiffs were successful in seeking appointment of a

Court Receiver qua suit properties including land bearing Survey No.151A by the Division Bench order in the year 1994, BCT got aggrieved by appointment of Court Receiver qua the land owned by it and accordingly filed Notice of Motion No.3479 of 2004 for deletion of land bearing Survey No.151A and for discharge of the Court Receiver. It appears that similar prayer was also sought by some other persons qua land bearing Survey No.77.

17) Notice of Motion No. 3479 of 2004 filed by BCT was allowed

by this Court by order dated 1 August 2008, thereby directing deletion of

land bearing Survey No.151A from the suit, as well as discharging the

Court Receiver qua the said land. The order dated 1 August 2008 has

attained finality on account of dismissal of the Appeal by order dated 17

October 2008 and by dismissal of Special Leave Petition filed in the

Supreme Court by order dated 14 May 2009. Plaintiffs read order dated 1

August 2008 as grant of liberty to them to file application for

impleadment of BCT as party defendant to the Suit. This belief of the

Plaintiff emerges from the objection raised by the BCT that it was never

impleaded as party defendant to the Suit or to the application seeking

appointment of Court Receiver, but still the Court Receiver was clamped

on the property owned by the Trust. No doubt, the Trust did raise such an

objection and this Court was also convinced with the said objection of

non-impleadment, which is apparent from the finding of the Court in

para-22 of the order, which reads thus:

22. In the present case the Applicants have asserted their title to the property

by virtue of the registered deed and they are in possession of the property. If

any of the parties to the suit wanted to affect either of these rights in any

manner, it would have been necessary for them to take recourse to due process

of law by filing an action against the Applicants. They cannot possibly be placed in a more advantageous position by filing a suit against each other without impleading the Applicants and obtaining the drastic order of appointment of a Court Receiver which materially affects the Applicant’s rights. In such cases, the only course according to me is to discharge the Court Receiver, set-aside the order appointing the Court Receiver and leave it to the parties to adopt proceedings in accordance with law against the Applicants.

18) Thus, non-impleadment of BCT was considered as one of the

factors relevant for holding that the Court Receiver could not have been

appointed without impleadment of a necessary party (BCT). However, this

Court did not stop at only discharging the Court Receiver, but also

directed deletion of land bearing Survey No.151A from the list of suit

properties. In the operative part of the order, this Court has held as

under:

30. In the circumstances, the Notice of Motion is made absolute in terms of

prayers (a) and (b). It is needless to add that this order will not affect the rights

of the parties to the proceedings from adopting appropriate proceedings against

the Applicants. Only with a view to enabling the Plaintifis to adopt appropriate

proceeding and not on merits it is ordered that the Applicants shall not create

any third party rights in respect of the suit properties for a period of four weeks

from today.

19) Mr. Sharma submits that a specific liberty was granted to the

Plaintiffs to adopt appropriate proceedings and accordingly the City Civil

Court ought to have allowed the Chamber Summons for impleadment of

BCT to the suit, which was a shortfall/inadvertence on the part of the

Plaintiffs in the suit as originally filed. I am unable to agree. The words

'adopt appropriate proceedings' in para-30 of the order does not mean

redoing of something which was expressly prohibited by this Court. If

only Court Receiver was to be discharged on account of non-impleadment

of BCT, what Mr. Sharma contends would have been right. However, this

Court walked a step further and directed even deletion of land bearing Survey No.151A from the list of suit properties. The order has now attained finality. Therefore, once land bearing Survey No.151A stood deleted from the array of the suit, the same could not have been sought to be re-included by amendment of the Suit.

20) There is also a reason why land bearing Survey No.151A

cannot be included nor the BCT can be impleaded as party Defendant to

the suit in the peculiar facts and circumstances of the present case. As

observed above, there is conscious exclusion of BCT from the suit in view

of averments made in para-13 of the plaint which are culled out in the

preceding paras. Plaintiff has deliberately and consciously kept BCT out

of the suit on account of Defendant No.1 filing Suit No. 8031 of 1984

against the Trust. Therefore, if BCT is now permitted to be impleaded in

the suit, the same would give rise to inconsistent position being taken by

the Plaintiffs. Plaintiffs believe that validity of Indenture of 1971 cannot

be subject matter of the present suit as the same is a subject matter of

Suit No. 8031 of 1984. This appears to be a reason why even in the

proposed amendment, there is no challenge to the Indenture dated 14

January 1971. The prayers in the Schedule of amendment application

(Chamber Summons No.718 of 2010) are reproduced below:

(h-i) that it be declared that the Defendant Nos. 65 to 69 and the Defendant No.

70 have no right, title or interest in respect of the lands bearing Survey No.

151A corresponding to CTS No. 448, 448A, 4488, 449, 449/1, 450, 450/1, 451,

452, 452/1 to 3, 453, 453/1 to 2, 454, 455, 456, 456/1, 457, 457/1 to 2, 458, 459,

460, 461, 461A, 518, 519, 520, 521, and Survey No. 77 corresponding to CTS

Nos. 478 and 479, and Survey No. 80 corresponding to CTS No 833 of Village

Nahur, Taluka Kurla, B. S. D. in the of the Properties of the Joint Family, at

Exhibit "E" "Part I A of the Plaint, and shown in the Plans annexed by the City

Survey Officer, Mulund to the letter dated 9.3.2005 addressed to the Court

Receiver, High Court, Bombay.

21) Similarly, there is also no challenge to the Indenture dated 28

October 2009 by which Respondent No.72 -Atul Builders has purchased

land bearing Survey No.151A from BCT. The prayers sought to be added in

the suit through Chamber Summons No. 1089 of 2011 are as under:

a) that the Plaintiffs be allowed to implead the Respondents as the Defendant

No. 72 to the Suit.

b) that the Properties bearing Survey No. 151A corresponding to CTS No. 448,

448A, 448B, 449, 449/1, 450, 450/1, 451, 452, 452/1 to 3, 453, 453/1 to 2, 454,

455, 456, 456/1, 457, 457/1 to 2, 458, 459, 460, 461, 461A, 518, 519, 520, 531,

and Survey No. 77 corresponding to CTS Nos. 478 and 479, and Survey No. 80

corresponding to CTS No 833 of Village Nahur, Taluka Kurla, B. S. D. of the

Properties of the Joint Family, at Exhibit "E" "Part I A of the Plaint, and shown

in the Plans annexed by the City Survey Officer, Mulund to the letter dated

9.3.2005 addressed to the Court Receiver, High Court, Bombay, be restored

and/or added to the particulars at Exhibit "E" to the Plaint.

22) Thus, there is no challenge by the Plaintiffs either to

Indenture dated 14 January 1971 or 28 October 2009. On the other hand,

there is challenge to Indenture dated 14 January 1971 in Suit No.8031 of

1984. It is therefore highly debatable as to whether Plaintiff can seek

declaration of absence of title in favour of BCT or in favour of Atul

Builders without raising a challenge to the two Indentures. In that sense,

the proposed amendments are clearly faulty. In any case, even if a

challenge to the said two Indentures was to be included in the proposed

amendments, yet the same could not have been granted.

23) Mr. Tulzapurkar has attempted to suggest an extreme proposition that a coparcener can never question alienation by another coparcener of joint family in a suit for partition. In support, he relies on judgment of the Apex Court in Trinity Infraventures Ltd. (supra) in which it has held in para-115 as under:

115. But in a simple suit for partition, the parties cannot assert title against strangers, even by impleading them as proforma respondents. The strangers who are impleaded in a partition suit, may have nothing to say about the claim to partition. But they may have a claim to title to the property and such a claim cannot be decided in a partition suit.

(emphasis added)

24) In my view, however, the judgment in Trinity Infraventures

Ltd merely enunciates the principle that in a simple suit for partition,

parties cannot assert title against strangers. It does not mean that

alienation made by a coparcener of joint family property can never be questioned in a partition suit. Similar reliance by Mr. Tulzapurkar on judgment of the Delhi High Court in Shri Sanjive Shukla (supra) appears to be inapposite. The Delhi High Court has held in para-14 of the judgment as under:

14. Thus, it is clear that the scope of the relief in a suit for partition cannot be changed to a suit for eviction and possession by impleading third parties, who are neither necessary nor proper parties to the original suit. It was while keeping in mind the aforesaid settled law that the order dated 29.04.2009 came to be passed in I.As No. 1461/2007 and 1465/2007, applications filed by the interveners for seeking impleadment. The said order has admittedly attained finality as neither the plaintiff, nor the defendants or the intervenors have challenged the same in appeal. Once the predecessor Bench has declined to implead the interveners as parties in the present suit, by this application, the plaintiff cannot be permitted to convert a partition suit into a suit for declaration, eviction, possession, etc. Therefore, any relief prayed for by the plaintiff in the present application for directions to the local police to evict the trespassers/squatters has to be turned down. The Court declines to convert the present suit for partition into a suit for declaration, eviction, possession, etc., that too, after a preliminary decree has already been passed in the suit as long back as on 23.01.2012. In case a cause of action has arisen in favour of the plaintiff, it is for him to seek his remedies against the said third parties in independent proceedings.


25) All that the Delhi High Court has held is that in a suit for partition, the issue of eviction cannot be mixed. Therefore, the judgment of the Delhi High Court in Shri Sanjive Shukla can also not be read in support of an abstract principle that in no case alienation made by a coparcener in a joint family property can ever be questioned in a partition suit.

26) In fact, the law appears to be otherwise. It is permissible to

challenge alienation of joint family property by Karta or by another

coparcener even in a suit for partition. The challenge cannot be

independent of suit for partition. Unless shares of coparceners are

determined, it is not possible to know whether the alienation by the

Defendant is of the property falling in the share of Plaintiff. Therefore, only a combined suit for partition and alienation can resolve the lis relating to validity of alienation. I would stop here since it is not necessary to go into the larger issue of permissibility to challenge alienation by a coparcener of joint family property in a suit for partition in the facts and circumstances of the present case.

27) Here, the alienation is not done by a coparcener, but the same is done by an outsider i.e. Khot family. Therefore, the issue of alienation by Khot family to BCT cannot be a subject matter of suit for partition between Patil family members. Whether Khots had title to pass on to BCT is something which cannot be decided in suit for partition of joint family properties of Patils. Knowing this well, the alienation by Khots to BCT is consciously kept out of the scope of the suit by the Plaintiffs. The alienation made by Khot family in favour of BCT is questioned independently by a suit filed by Defendant No. 1. Knowing this difficulty, Plaintiffs have consciously kept the challenge to alienation not only outside the purview of the main suit, but have consciously not included the prayer for challenging the Indentures dated 14 January 1971 and 28 October 2009 even in the proposed amended prayers. Since the issue of permissibility to challenge alienation by a coparcener of joint family property in a partition suit is irrelevant in the facts and circumstances of the present case, it is not necessary to discuss the ratio of the judgment of Calcutta High Court in Ganeshmull Surana and of Madras High Court in Chinnasamy Naidu (supra).

28) Coming to the aspect of limitation, in my view, the City Civil

Court has rightly held the proposed amendments to be grossly time

barred. Mr. Sharma has attempted to highlight inconsistencies in the

findings recorded by the City Civil Court on the issue of limitation. He has

invited attention of this Court to findings recorded in para-20 of the

impugned order which reads thus:

20] As the Hon'ble Bombay High Court laid down the law that Article 137 of

Limitation Act is not applicable to Order 6 Rule 17 of CPC, in my considered

view there is no substance in the objection as raised by the respondents that the

claim as made by plaintiffs in the chamber summons is barred by limitation.

Thus, in my view on this ground the chamber summons as taken out by

plaintiffs can not be rejected.

29) He submits that having held that the objection of limitation

was rejected, the City Civil Court could not have once again gone into the

issue of limitation involved in proposed amendments for rejection of the

Chamber Summons. In my view, the findings relating to limitation

applicable for proposed amendments are to be found in para-26 of the

Order, which are as under:

26] The Hon'ble Apex Court in the matter of "Rajesh Kumar" referred supra held

that the object of the rule is that Courts should try the merits of the case that

come before them and should, consequently, allow all amendments that may be

necessary for determining the real question in controversy between the parties

provided it does not cause injustice or prejudice to the other side. Order 6 Rule

17 consist of two parts whereas the first part is discretionary and leaves it to the

Court to order amendment of pleading. The second part is imperative and

enjoins the Court to allow all amendments which are necessary for the purpose

of determining the real question in controversy between the parties. The real

controversy test is the basic or cardinal test and it is the primary duty of the

Court to decide whether such an amendment is necessary to decide the real

dispute between the parties. If it is, the amendment will be allowed, if it is not

the amendment will be refused. Bearing in mind the above legal position if the

chamber summons is considered in its correct perspective it seems that the

plaintiffs by way of present chamber summons want to incorporate the claim of

cancellation of settlement deed dated 4.10.1971 and setting aside of consent

decree passed in Suit No. 1340/1985 after a period of 20 years of filing suit,

though they were aware about it way back in 1991, in my considered view under

these set of facts the discretionary powers vested in this court under Order 6

Rule 17 of CPC cannot be exercised in favour of plaintiffs. I say so because

without joining the respondents as party defendants and adding the survey

numbers to the suit the real dispute between the parties which is in respect of

partition and separate possession can be set at rest. In my further view as the

purported amendment is applied at very belated stage, no purpose would be

served even if the proposed respondents are made party defendant and the

survey numbers 151-A, 77 and 80 added to the suit. Thus, I hold that the

chamber summons as taken out by plaintiffs is devoid of any merit and fit to be

rejected. Thus, I answer the above points accordingly and proceed to pass

following order.

30) What is recorded by the Trial Court in para-20 of the Order

are findings related to application of period of limitation for filing

Chamber Summons. The City Civil Court has held that Article 137 of

Limitation Act is not applicable to Order 6 Rule 17 of the Code. It is well

settled position that an application for amendment can be filed any time

during pendency of the suit and the Legislature has not prescribed any

particular time limit from the date of filing of the suit for moving an


amendment application. In that sense, the observations in para-20 of the

order were quite unnecessary. The aspect of limitation is relevant, not for

the purpose of filing of amendment application but the same is relevant

in the context of the proposed amendment sought. If the Court arrives at

the conclusion that the proposed amendment is barred by limitation, the

amendment can be refused. The law in this regard is well settled by the

judgment of the Apex Court in Life Insurance Corporation of India vs.

Sanjiv Builders Pvt. Ltd. (supra) wherein the Hon’ble Apex Court has

summarised the principles relating to amendment of pleadings and has

held that when amendment is found to be grossly barred by limitation,

the court would be justified in rejecting the same. The principles

summarised by the Hon’ble Apex Court in paras-71 to 71.11 of the

judgment as under:

71. Our final conclusions may be summed up thus:

71.1. Order 2 Rule 2CPC operates as a bar against a subsequent suit if the

requisite conditions for application thereof are satisfied and the field of

amendment of pleadings falls far beyond its purview. The plea of amendment

being barred under Order 2 Rule 2CPC is, thus, misconceived and hence

negatived.

71.2. All amendments are to be allowed which are necessary for determining the

real question in controversy provided it does not cause injustice or prejudice to

the other side. This is mandatory, as is apparent from the use of the word

“shall”, in the latter part of Order 6 Rule 17CPC.

71.3. The prayer for amendment is to be allowed:

71.3.1. If the amendment is required for effective and proper adjudication of the

controversy between the parties.

71.3.2. To avoid multiplicity of proceedings, provided

(a) the amendment does not result in injustice to the other side,

(b) by the amendment, the parties seeking amendment do not seek

to withdraw any clear admission made by the party which confers a

right on the other side, and


(c) the amendment does not raise a time-barred claim, resulting

in divesting of the other side of a valuable accrued right (in

certain situations).

71.4. A prayer for amendment is generally required to be allowed unless:

71.4.1. By the amendment, a time-barred claim is sought to be introduced,

in which case the fact that the claim would be time-barred becomes a

relevant factor for consideration.

71.4.2. The amendment changes the nature of the suit.

71.4.3. The prayer for amendment is mala fide, or

71.4.4. By the amendment, the other side loses a valid defence.

71.5. In dealing with a prayer for amendment of pleadings, the court should

avoid a hypertechnical approach, and is ordinarily required to be liberal

especially where the opposite party can be compensated by costs.

71.6. Where the amendment would enable the court to pin-pointedly consider

the dispute and would aid in rendering a more satisfactory decision, the prayer

for amendment should be allowed.

71.7. Where the amendment merely sought to introduce an additional or a new

approach without introducing a time-barred cause of action, the

amendment is liable to be allowed even after expiry of limitation.

71.8. Amendment may be justifiably allowed where it is intended to rectify the

absence of material particulars in the plaint.

71.9. Delay in applying for amendment alone is not a ground to disallow the

prayer. Where the aspect of delay is arguable, the prayer for amendment could

be allowed and the issue of limitation framed separately for decision.

71.10. Where the amendment changes the nature of the suit or the cause of

action, so as to set up an entirely new case, foreign to the case set up in the

plaint, the amendment must be disallowed. Where, however, the amendment

sought is only with respect to the relief in the plaint, and is predicated on facts

which are already pleaded in the plaint, ordinarily the amendment is required to

be allowed.

71.11. Where the amendment is sought before commencement of trial, the court

is required to be liberal in its approach. The court is required to bear in mind the

fact that the opposite party would have a chance to meet the case set up in

amendment. As such, where the amendment does not result in irreparable

prejudice to the opposite party, or divest the opposite party of an advantage

which it had secured as a result of an admission by the party seeking

amendment, the amendment is required to be allowed. Equally, where the

amendment is necessary for the court to effectively adjudicate on the main

issues in controversy between the parties, the amendment should be allowed.

(See Vijay Gupta v. Gagninder Kr. Gandhi [Vijay Gupta v. Gagninder Kr. Gandhi,

2022 SCC OnLine Del 1897] .)

(emphasis added)

31) In the present case, Plaintiffs are seeking to incorporate a

prayer in the plaint that BCT does not have any right, title or interest in

land bearing Survey No.151A. Such relief is sought without challenging

Indenture dated 14 January 1971. They had knowledge of the said

Indenture at least at the time of filing of the Suit as is apparent from the

findings in para-13 of the plaint. However, amendment application for

seeking relief against BCT was filed by the Plaintiffs (Chamber Summons

No. 718 of 2010) in May 2010. The amendment sought to be incorporated

is thus grossly barred by limitation. Even the amendment sought in

Chamber Summons No. 1089 of 2011 qua Atul Builders would be barred by

limitation since Atul Builders has merely stepped into the shoes of BCT.

When challenge to alienation in favour of BCT is barred by limitation,

consequently even relief sought qua Atul Builders would also be barred by

limitation. It cannot even be contended by the Plaintiffs that what is

sought to be introduced through amendments is a mere different or new

approach to the existing suit. Introduction of a new or additional

approach can be permitted provided time barred cause of action is not

sought to be introduced [Para 71.4.1 of LIC Vs. Sanjeev Builders]. Here

reliance by Mr. Tulzapurkar on judgment of the Apex Court in South

Konkan Distilleries (supra) is also apposite, in which it is held in para 23

as under:

23. The learned counsel for the appellants, however, relied on a decision of this

Court in A.K. Gupta & Sons Ltd. v. Damodar Valley Corpn. [AIR 1967 SC 96] in

order to satisfy us that the prayer for amendment for a sum already specified in

the plaint or such other amount as was to be determined after accounts, ought

to be allowed though the suit for recovery of money was barred when the amendment was sought. In our view, that decision of this Court stands on a different footing altogether and will not be of any help to the appellants. In that decision, it was made clear that the amendment of pleadings introducing new case cannot be allowed, if suit on such case is barred. In that decision also, it was made clear that in the matter of allowing amendment of pleadings, the general rule is that a party is not allowed by amendment to set up a new case or a new cause of action, particularly when a suit on the new cause of action is barred. However, an exception was given in that decision

saying where the amendment does not constitute the addition of a new cause of

action or raise a different case, but amounts merely to a different or additional

approach to the same facts, the amendment is to be allowed even after expiry of

the statutory period of limitation. We have already observed that there is no

quarrel on the proposition enunciated by this Court in the aforesaid decision. As

held hereinabove, the date on which the application for amendment of the

written statement and the counterclaim was filed, the claim was already barred

by limitation. Therefore, if a fresh suit was filed on the amended claim, there

cannot be any dispute that the same could also be barred by the law of

limitation. Under these circumstances and applying also the principles laid

down in the aforesaid decision in A.K. Gupta [AIR 1967 SC 96] , in the facts of

this case, we are of the view that since even on the date of filing of the

application for amendment of the written statement and the

counterclaim, the claim was barred and no fresh suit could be filed on

such amended claim and, therefore, the two courts below had acted

within their jurisdiction in rejecting the prayer for amendment of the

written statement and the counterclaim. It may not be out of place to

mention that following the principle laid down in A.K. Gupta case [AIR 1967 SC

96] this Court again in Vineet Kumar v. Mangal Sain Wadhera [(1984) 3 SCC 352 :

AIR 1985 SC 817] expressed the same view to which we have already adhered to.

(emphasis added)

32) It is also seen that if the amendment is allowed, the same

would alter the nature of the suit. An enquiry in a suit for partition of

joint family properties will get diverted into validity of alienation made by Khot Family in favour of BCT. Khot Family are not party defendants to the suit. BCT was consciously excluded from the suit by making averments in para-13 of the plaint. In such circumstances, enquiry into validity of transactions between Khot family and BCT would clearly alter the nature of the suit and any relief qua acquisition of title by BCT would amount to misjoinder of cause of action. The principle of Plaintiff being dominus litis cannot be applied in the present case for introduction of new parties to the suit (BCT and Atul Builders) since neither they are necessary parties nor the alienation made in their favour can form subject matter of challenge in the present suit. Reliance by Mr. Tulzapurkar on judgment of the Apex Court in Asian Hotels (North) Ltd. in this regard is apposite, in which it has held in para-36 and 37 of the judgment as under:

36. The High Court while allowing the amendment application in exercise of

powers under Order 6 Rule 17 of the Code of Civil Procedure has not properly

appreciated the fact and/or considered the fact that as such, by granting such an

amendment and permitting the plaintiffs to amend the plaints incorporating

the prayer clause to declare the respective charges/mortgages void ab initio, the

nature of the suits will be changed. As per the settled proposition of law, if,

by permitting the plaintiffs to amend the plaint including a prayer clause

nature of the suit is likely to be changed, in that case, the Court would not

be justified in allowing the amendment. It would also result in misjoinder

of causes of action.

37. From the impugned order [Alok Kumar Lodha v. Asian Hotels (North) Ltd.,

2021 SCC OnLine Del 4370] passed by the High Court, it appears that what has

weighed with the High Court is that the plaintiffs, is the dominus litus and

heavy reliance is placed in Kasturi [Kasturi v. Iyyamperumal, (2005) 6 SCC 733].

However, the principle that the plaintiffs is the dominus litus shall be

applicable only in a case where parties sought to be added as defendants

are necessary and/or proper parties. The plaintiffs cannot be permitted to

join any party as a defendant who may not be necessary and/or proper

parties at all on the ground that the plaintiff is the dominus litus.

(emphasis added)

33) Mr. Sharma has sought to complain that the Petitioners are

being rendered remediless qua their rights in respect of land bearing

Survey No.151A. He submits that though Defendant No.1 has filed Suit

No. 8031 of 1984 challenging the alienation made in favour of the BCT,

Plaintiffs apprehend that Defendant No.1 may settle the said suit

regarding rights of the Trust and that therefore Plaintiffs attempted to

intervene and get themselves impleaded in Suit No. 8031 of 1984. That they were allowed to be impleaded in the suit. However, their

impleadment was challenged before the Hon’ble Apex Court inter alia by

Atul Builders and by order dated 8 August 2017, the Hon’ble Apex Court

has set aside the impleadment order entertaining the objection of Atul

Builders. He has placed on record copy of order dated 8 August 2017

passed by the Hon’ble Apex Court. Having gone through the order, it

appears that the Hon’ble Apex Court has directed that a call on

impleadment can be taken afresh by the Trial Court after decision is

rendered by this Court in the present Petition. This is clear from the

following findings recorded by the Hon’ble Apex Court in the order dated

8 August 2017:

In our opinion, in case the impleaded party interest is comfined to the said land

and if ultimately the same stand deleted from the purview of the litigation due

to which the impleadment has been ordered, in that case there would be no

requirement of continuance of impleaded respondents as party to the suit. In

case they succeed in partly maintaining interest even in any of the aforesaid

survey numbers or otherwise their impleament will hold good. In case the newly

added respondents are able to show that their interest would be finally affected,

even otherwise by the litigation, after deletion also impleadment will hold good.

A call on impleadment can be taken afresh by the trial court after the decision is

rendered in the pending writ application in the High Court at Bombay in which

deletion of the aforesaid survey numbers appears to have been questioned.

34) It would therefore be for the Plaintiff to reapply for their

impleadment in Suit No. 8031 of 1984 and mere factum of their nonimpleadment

in that suit cannot be a ground for allowing them to enlarge

the scope of enquiry in the present suit by incorporating amendments

which are hopelessly time barred and outside the scope of inquiry in the present suit.


35) Considering the overall conspectus of the case I am of the

view that the City Civil Court has rightly rejected the application for

amendment. No interference is warranted in the impugned order. the

Writ Petition is accordingly dismissed.

[SANDEEP V. MARNE, J.]

27 August 2026


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