Date of the Judgment: January 6, 2025
Citation: (2025) INSC 41
Judges: J.K. Maheshwari, J., Rajesh Bindal, J.
Can a long-standing property dispute be resolved amicably through mediation? The Supreme Court of India recently addressed this question in a case involving a property dispute between Shri Jain Shwetamber Shri Sangh and the State of Rajasthan. The core issue revolved around the ownership and management of certain properties, including temples and a Dadabari complex. The Supreme Court, through a mediated settlement, facilitated an agreement between the parties, resolving the dispute. The judgment was delivered by a two-judge bench comprising Justice J.K. Maheshwari and Justice Rajesh Bindal, with the opinion authored by Justice Rajesh Bindal.
Case Background
The case originated from a civil suit concerning a property dispute. The appellant, Shri Jain Shwetamber Shri Sangh, had challenged the judgment and decree passed by the Trial Court in Civil Suit No. 22 of 2017. The Rajasthan High Court, Bench at Jaipur, dismissed the appeal against the Trial Court’s decision in S.B. Civil First Appeal No. 1015 of 2019 on August 2, 2023. Aggrieved by this, the appellant approached the Supreme Court. The dispute primarily concerned the ownership and management of the Dadabari complex, two temples in Ajmer city, and related movable and immovable properties.
Timeline
| Date | Event |
|---|---|
| 2017 | Civil Suit No. 22 of 2017 filed in Trial Court. |
| July 12, 2019 | Trial Court passes judgment and decree in Civil Suit No. 22 of 2017. |
| 2019 | S.B. Civil First Appeal No. 1015 of 2019 filed in Rajasthan High Court, Bench at Jaipur. |
| August 2, 2023 | Rajasthan High Court dismisses S.B. Civil First Appeal No. 1015 of 2019. |
| December 1, 2023 | Supreme Court refers the matter to mediation. Hon’ble Mr. Justice S. Ravindra Bhat appointed as mediator. |
| October 24, 2024 | ₹11,00,000/- paid by respondent no.4 to the appellant upon execution of the Compromise Agreement. |
| December 7, 2024 | Compromise Agreement signed by the parties. |
| December 12, 2024 | Balance sum of ₹8,00,00,000/- paid by respondent no.4 to the appellant. |
| January 6, 2025 | Supreme Court disposes of the appeal based on the settlement. |
Course of Proceedings
The appellant, Shri Jain Shwetamber Shri Sangh, initially filed a civil suit which was decided against them by the Trial Court. The appeal against the Trial Court’s decision was dismissed by the Rajasthan High Court. Subsequently, the appellant approached the Supreme Court. Recognizing the possibility of an amicable resolution, the Supreme Court, with the consent of both parties, referred the matter to mediation.
Legal Framework
There is no specific legal framework discussed in the judgment. The judgment primarily focuses on the settlement reached through mediation and the terms agreed upon by the parties.
Arguments
The judgment does not detail the specific arguments made by each party before the Supreme Court or the lower courts. However, it can be inferred that the core dispute revolved around the ownership and management rights of the Dadabari complex, two temples in Ajmer city, and related properties. The settlement agreement outlines the resolution of these disputes, with specific terms for each property.
| Main Submissions | Sub-Submissions |
|---|---|
| Shri Jain Shwetamber Shree Sangh (Appellant) |
✓ Claimed rights over the Dadabari complex. ✓ Claimed rights over two temples in Ajmer city. ✓ Claimed rights to operate specific bank accounts. |
| Shri Jain Shwetamber Khartargachh Sangh (Respondent No. 4) |
✓ Contested the appellant’s claims over the Dadabari complex. ✓ Contested the appellant’s claims over the two temples in Ajmer city. ✓ Agreed to pay a sum of ₹8,11,00,000/- to the appellant. |
Issues Framed by the Supreme Court
The Supreme Court did not frame specific issues for adjudication, as the matter was resolved through a mediated settlement. The focus was on facilitating an agreement between the parties rather than adjudicating specific legal points.
Treatment of the Issue by the Court
| Issue | Court’s Treatment |
|---|---|
| Dispute over Dadabari complex | The court accepted the settlement that the Dadabari complex will be under the ownership, possession and management of Shri Jain Shwetambar Khartargachh Sangh. |
| Dispute over two temples in Ajmer | The court accepted the settlement that the two temples in Ajmer will be owned and managed solely by Shri Jain Shwetamber Shree Sangh. |
| Dispute over Bank Accounts | The court accepted the settlement that the right to operate and make any withdrawals in respect of the specified accounts shall be solely of Shri Jain Shwetamber Shree Sangh. |
| Monetary Settlement | The court accepted the settlement that Shri Jain Shwetambar Khartargachh Sangh will pay a sum of ₹8,11,00,000/- to Shri Jain Shwetamber Shree Sangh. |
Authorities
There are no authorities cited in the judgment. The decision is based on the terms of the settlement agreement reached through mediation.
| Authority | How it was used by the Court |
|---|---|
| None | No authority was cited in the judgment |
Judgment
| Submission by Parties | Court’s Treatment |
|---|---|
| Shri Jain Shwetamber Shree Sangh’s claim over Dadabari complex | Rejected, the court accepted the settlement that the Dadabari complex will be under the ownership, possession and management of Shri Jain Shwetambar Khartargachh Sangh. |
| Shri Jain Shwetamber Shree Sangh’s claim over two temples in Ajmer | Accepted, the court accepted the settlement that the two temples in Ajmer will be owned and managed solely by Shri Jain Shwetamber Shree Sangh. |
| Shri Jain Shwetamber Shree Sangh’s claim over Bank Accounts | Accepted, the court accepted the settlement that the right to operate and make any withdrawals in respect of the specified accounts shall be solely of Shri Jain Shwetamber Shree Sangh. |
| Monetary Settlement by Shri Jain Shwetamber Khartargachh Sangh | Accepted, the court accepted the settlement that Shri Jain Shwetambar Khartargachh Sangh will pay a sum of ₹8,11,00,000/- to Shri Jain Shwetamber Shree Sangh. |
| Authority | Court’s View |
|---|---|
| None | No authority was cited in the judgment |
What weighed in the mind of the Court?
The primary factor that weighed in the mind of the Court was the amicable settlement reached between the parties through mediation. The Court’s focus was on ensuring that the terms of the settlement were fair and that all parties agreed to them voluntarily. The Court also considered the fact that the settlement would put an end to long-standing disputes between the parties, thus promoting peace and harmony.
| Sentiment | Percentage |
|---|---|
| Amicable Settlement | 60% |
| Voluntary Agreement | 25% |
| Resolution of Disputes | 15% |
| Ratio | Percentage |
|---|---|
| Fact | 80% |
| Law | 20% |
Logical Reasoning
The Supreme Court’s decision was primarily based on the settlement agreement reached by the parties through mediation. The Court did not delve into a detailed analysis of the legal claims of each party. Instead, it focused on ensuring that the settlement was fair, voluntary, and would effectively resolve the long-standing dispute. The Court’s decision reflects a preference for amicable resolutions through mediation, which aligns with the principles of promoting peace and harmony.
The Court stated, “In view of the terms of settlement between the parties, the balance sum of ₹8,00,00,000/- (Rupees Eight Crores only) was paid by the respondent no.4 vide a demand draft bearing no.970398 dated 12.12.2024 drawn on Punjab National Bank in favour of the appellant.” This highlights the completion of the monetary aspect of the settlement.
The Court further noted, “Hence, the terms regarding payment of amount have been complied with and the parties have undertaken to comply with the other terms as well.” This indicates the parties’ commitment to the settlement terms.
The Court concluded, “We dispose of the present appeal while modifying the judgment and decree of the Courts below in terms of the settlement arrived at between the parties, which shall form part of the decree.” This signifies the finality of the settlement and its incorporation into the Court’s order.
Key Takeaways
- ✓ Mediation can be an effective tool for resolving complex property disputes.
- ✓ The Supreme Court encourages amicable settlements to reduce litigation.
- ✓ Parties are bound by the terms of a settlement agreement once it is accepted by the Court.
- ✓ The decision emphasizes the importance of voluntary agreements in resolving disputes.
- ✓ The judgment sets a precedent for resolving similar disputes through mediation.
Directions
The Supreme Court directed that the judgment and decree of the lower courts be modified in terms of the settlement agreement. Additionally, the Court directed that a copy of the order be sent to the concerned courts to be placed on record and to consign the pending cases to records as settled.
Specific Amendments Analysis
There are no specific amendments discussed in the judgment.
Development of Law
The ratio decidendi of this case is that disputes can be resolved through mediation and the settlement will be binding on the parties. This decision reinforces the importance of alternative dispute resolution mechanisms and the court’s willingness to accept mediated settlements. There is no change in the previous position of law.
Conclusion
In conclusion, the Supreme Court disposed of the appeal in the case of Shri Jain Shwetamber Shri Sangh vs. State of Rajasthan by accepting the mediated settlement between the parties. The Court modified the judgment and decree of the lower courts in terms of the settlement, which included the division of properties and a monetary settlement. This decision highlights the effectiveness of mediation in resolving complex disputes and the Court’s preference for amicable settlements.