Supreme Court Dismisses Appeal in Property Dispute After Settlement: Rajeev Kumar Upadhyay vs. Prakash Chand Rawat (2017)

Date of the Judgment: April 24, 2017
Citation: 2017 INSC 380
Judges: Kurian Joseph, J. and R. Banumathi, J.
Can a pending appeal be dismissed if the parties reach a settlement? The Supreme Court of India addressed this question in a recent case where the parties resolved their property dispute out of court. This judgment highlights the importance of amicable settlements in resolving legal conflicts. The bench consisted of Justice Kurian Joseph and Justice R. Banumathi.

Case Background

The case involves a property dispute between Rajeev Kumar Upadhyay (the appellant) and Prakash Chand Rawat (the respondent). The specifics of the original dispute are not detailed in the judgment. However, during the pendency of the appeal before the Supreme Court, the parties reached a settlement. This settlement included a cancellation deed of the agreement to sell and a bank draft payment.

Course of Proceedings

The Supreme Court, upon receiving an application from the respondent regarding the settlement, directed the District Judge, Agra, to conduct an inquiry. This inquiry was to verify the genuineness of the cancellation deed and the receipt of the bank draft by the appellant. The District Judge submitted a report confirming the settlement. Consequently, the Supreme Court took the appeal on board and dismissed it as infructuous.

Legal Framework

The judgment does not explicitly cite specific sections or statutes. However, the legal framework is based on the principle that if parties settle a dispute outside of court, the court can dismiss the case as infructuous. This is a common practice aimed at reducing the burden on the judiciary and promoting amicable resolutions.

Arguments

The respondent filed an application to bring on record the settlement documents, specifically the cancellation deed and the bank draft. The respondent argued that the appeal had become infructuous due to the settlement. The appellant’s counsel stated that he had informed the appellant about the application and the settlement, but had not received a response.

Issues Framed by the Supreme Court

The Supreme Court did not frame specific issues in this case. The primary concern was whether the settlement between the parties was genuine and if the appeal had become infructuous as a result.

Treatment of the Issue by the Court

Authorities

The Supreme Court did not rely on any specific case laws or legal provisions in this judgment. The decision was based on the factual finding of a settlement between the parties.

Judgment

The Supreme Court allowed I.A. No. 3, which pertained to the settlement. The court then took up C.A. No. 3232/2015 and dismissed the appeal as infructuous. The court also disposed of any pending applications and did not impose any costs on either party.

What weighed in the mind of the Court?

The primary factor that weighed in the mind of the Court was the confirmation of a genuine settlement between the parties by the District Judge, Agra. The court’s decision was driven by the principle of giving effect to settlements reached by the parties, thereby reducing the burden on the judicial system.

The court’s reasoning was straightforward: a settlement had been reached, and the court should respect the parties’ decision to resolve the matter amicably. The court did not delve into the merits of the original dispute.

The court quoted: “In these two applications, the prayer is to the following effect: (a)allow the respondent/applicant to file additional documents i.e. Annexure A-1, Cancellation Deed dated 31.08.2016 and Annexure A-2 Bank Draft dated 22.08.2016 drawn on Indian Oversea Bank in favour of the appellant in order to bring on record the subsequent events; (b) and accordingly dismissal of the appeal as infructuous in view of subsequent events as pointed out above; and (c) pass such other and further order(s) as this Hon’ble Court may deem fit in the interest of justice.”

The court also noted: “The District Judge, Agra, to whom this Court had directed to verify, has in the Report dated 27.2.2017 submitted that there is a genuine settlement between the parties.”

Finally the court concluded: “The appeal is dismissed as having become infructuous, in view of the settlement between the parties.”

Key Takeaways

• ✓ Amicable settlements are encouraged by the Supreme Court.
• ✓ When parties settle a dispute, the court may dismiss the appeal as infructuous.
• ✓ District court reports can be relied upon as evidence for settlement.

Directions

The Supreme Court did not issue any specific directions in this case. The dismissal of the appeal was the final order.

Development of Law

The ratio decidendi of this case is that when parties to an appeal settle their dispute out of court, the appeal becomes infructuous and can be dismissed by the court. This reinforces the principle of encouraging settlements and reducing the burden on the judiciary. There is no change in the previous positions of law.

Conclusion

The Supreme Court dismissed the appeal in Rajeev Kumar Upadhyay vs. Prakash Chand Rawat after the parties reached a settlement. This decision underscores the court’s support for amicable dispute resolutions and highlights the procedural aspects of dismissing cases when settlements occur during appeals.