Supreme Court Disposes of Punjab National Bank Appeal Based on Settlement: Satinder Kapur & Anr. (27 March 2018)

Date of the Judgment: 27 March 2018
Citation: (2018) INSC 218
Judges: Kurian Joseph J., Mohan M. Shantanagoudar J., Navin Sinha J.

Can a pending appeal be resolved through a settlement between the parties involved? The Supreme Court of India addressed this question in a recent civil appeal, where the parties reached a settlement during the pendency of the case. This judgment highlights the court’s willingness to acknowledge and incorporate settlements to resolve disputes. The bench consisted of Justices Kurian Joseph, Mohan M. Shantanagoudar, and Navin Sinha.

Case Background

Punjab National Bank (the appellant) had filed appeals against the judgment(s) and order(s) of the High Court of Delhi at New Delhi. The High Court orders were dated 20.03.2013 passed in W.P.(C) No.8432/2011 and 27.11.2015 passed in Review Petition No.245/2013. While the appeals were pending before the Supreme Court, the parties, Punjab National Bank and Satinder Kapur & Anr. (the respondents), arrived at a settlement.

Timeline:

Course of Proceedings

The appellant, Punjab National Bank, initially filed a writ petition (W.P.(C) No.8432/2011) before the High Court of Delhi, which was decided on 20.03.2013. Subsequently, a review petition (Review Petition No.245/2013) was filed, which was decided on 27.11.2015. Aggrieved by these orders, the bank appealed to the Supreme Court of India. During the pendency of the appeals, the parties reached a settlement.

Legal Framework

The judgment primarily focuses on the procedural aspect of disposing of a case based on a settlement between the parties. The Supreme Court acknowledged the settlement deed filed by the parties and made it a part of the judgment. There is no specific statute or provision discussed in the judgment.

Arguments

The judgment does not detail any specific arguments made by the parties, as the case was disposed of based on a settlement. The primary submission was the Deed of Settlement itself.

Issues Framed by the Supreme Court

The Supreme Court did not frame any specific issues for determination, as the matter was resolved based on the settlement between the parties.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The judgment does not rely on any specific case laws or legal provisions. The decision is based on the settlement between the parties.

Judgment

The Court did not discuss any authorities in this case, as the matter was resolved based on the settlement agreement between the parties.

What weighed in the mind of the Court?

The primary sentiment of the court was to facilitate the resolution of disputes through mutual agreement of the parties. The court’s willingness to accept the settlement indicates a preference for amicable resolutions over prolonged litigation. The court’s decision highlights the importance of party autonomy in resolving disputes.

The court’s decision was solely based on the fact that the parties had reached a settlement, and the court deemed it appropriate to dispose of the appeals based on this agreement.

The court stated, “The terms of the said Deed of Settlement shall form part of this judgment.” and “Accordingly, these appeals are disposed of in terms of the Deed of Settlement with a further direction to the parties to strictly abide by the terms of settlement.” and “Pending applications, if any, shall stand disposed of.”

Key Takeaways

• ✓ The Supreme Court prioritizes the settlement of disputes between parties.
• ✓ A settlement deed, once filed and accepted, becomes a part of the court’s judgment.
• ✓ Parties are expected to strictly adhere to the terms of the settlement.

Directions

The Supreme Court directed the parties to strictly abide by the terms of the settlement.

Development of Law

The judgment reinforces the principle that parties can resolve their disputes through settlements, and the courts will uphold such agreements. There is no change in the previous position of law.

Conclusion

The Supreme Court disposed of the appeals filed by Punjab National Bank based on a settlement reached between the parties. The Deed of Settlement was made part of the judgment, and the parties were directed to strictly adhere to its terms. This case highlights the court’s inclination towards resolving disputes amicably through mutual agreements.