V. RAVIKUMAR V. S. KUMAR 2025 INSC 343:

DATE: 03/03/2025

BENCH: Justice Sudhanshu Dhulia and Justice K. Vinod Chandran

FACTS:

The plaintiff filed a suit seeking a declaration that multiple sale deeds executed based on a power of attorney were null and void. Additionally, the plaintiff sought a permanent injunction to prevent the first defendant from interfering with the peaceful possession and enjoyment of the suit properties. In response, the first defendant, acting as the power holder, filed an application under Order VII Rule 11 of the Civil Procedure Code (CPC), along with Sections 10, 11, and 150, contending that the suit was barred by limitation. The Trial Court, considering the averments in the plaint, found that the facts clearly indicated that the suit was time-barred and accordingly rejected the plaint.

On appeal, the High Court took a different view, holding that since the power of attorney was formally revoked only on September 22, 2015, the limitation period should be calculated from that date. As a result, the High Court ruled that the suit was not time-barred and directed its restoration before the Trial Court for adjudication on merits. Aggrieved by this decision, the defendant-appellant challenged the High Court’s ruling before the Supreme Court.

ISSUES:

The main issue in this case was the whether the order made by the High Court on the assessment made regarding the limitation period of the power of attorney was wrong or not. 

JUDGEMENT WITH REASONING:

The Supreme Court set aside the High Court's order and upheld the Trial Court’s decision to reject the plaint. The Court ruled that the suit was barred by limitation, as the power of attorney was executed in 2004, and the contested conveyances occurred between 2004 and 2009. The cancellation of the power of attorney in 2015 did not impact transactions lawfully executed before that date. Accordingly, the appeal was allowed, and the rejection of the plaint was affirmed.

The Court emphasized that the plaintiff never disputed the execution of the power of attorney in 2004 or the fact that the conveyances were made under its authority. There was no allegation of fraud or coercion in granting the power of attorney, nor any claim that it did not confer the power to execute sale deeds. Since the power holder had legally transferred the properties based on the authority given, the later cancellation of the power of attorney had no bearing on the validity of those transactions.

Additionally, the Court held that the High Court erred in considering the cancellation date as the starting point for the limitation period. The limitation should have been calculated from the dates of the conveyances, which occurred between 2004 and 2009. As the suit was filed over a decade later, it was clearly time-barred. Therefore, the Supreme Court upheld the rejection of the plaint by the Trial Court.

ANALYSIS:

The Supreme Court’s ruling reinforces the principle that limitation periods must be strictly adhered to in legal proceedings, particularly in matters concerning property transactions. By affirming that the limitation period should commence from the date of the conveyances rather than the later cancellation of the power of attorney, the Court upheld the sanctity of legally executed transactions. This decision prevents the misuse of legal provisions by parties attempting to challenge settled transactions long after they have been completed. If the High Court’s reasoning had been upheld, it could have set a precedent allowing individuals to retroactively invalidate property transfers merely by cancelling a power of attorney years after its execution, leading to uncertainty in property rights and commercial dealings.

Furthermore, the Court's judgment highlights the importance of distinguishing between the validity of a transaction and the subsequent cancellation of the authority under which it was executed. The Supreme Court rightly pointed out that once a power of attorney is lawfully granted, any conveyances made under its authority remain valid, even if the power is later revoked. The decision ensures that subsequent cancellations cannot create fresh causes of action to reopen settled matters, thereby upholding legal certainty and protecting bona fide purchasers. By setting aside the High Court’s ruling, the Supreme Court reaffirmed the necessity of finality in legal transactions and the need to prevent unnecessary litigation based on belated claims.