eCourtsIndia

Sunny Khurana vs. Girdhari Lal

Final Order
Court:High Court, Delhi
Judge:Hon'ble Vibhu Bakhru
Case Status:Unknown Status
Order Date:17 May 2019
CNR:DLHC010135182019

AI Summary

The Delhi High Court granted a transfer petition to shift a property dispute suit from East District to West District courts, consolidating related litigation over a property in Ramesh Nagar, New Delhi. The court found it appropriate to transfer the case considering the interrelated nature of multiple suits and the property's location within West District jurisdiction.

Ratio Decidendi:
When multiple related suits involving the same immovable property are pending in different district courts, and the property is located in one of those districts, the High Court may exercise its inherent jurisdiction to transfer a suit from one district court to another district court where related suits are pending, in order to consolidate the litigation and promote judicial efficiency, provided the petitioner has a legitimate interest in the matter.
Obiter Dicta:
The court noted that the petitioner's readiness to be impleaded as a defendant without contesting the application and the interrelated nature of the multiple suits were significant factors in granting the transfer petition.

Case Identifiers

Primary Case No:TR.P.(C.) 23/2019
Case Type:Transfer Petition (Civil)
Case Sub-Type:Transfer Petition - Other Matters Relating to Specific Performance
Secondary Case Numbers:CM Nos. 10999/2019, CM Nos. 11000/2019, CNR: DLHC010135182019
Order Date:2019-05-17
Filing Year:2019
Court:High Court of Delhi at New Delhi
Bench:Single Judge
Judges:Hon'ble Vinod Goel, Hon'ble Vibhu Bakhru

Petitioner's Counsel

Praveen Suri
Advocate - Appeared
Jessica Jacob
Advocate - Appeared

eCourtsIndia AITM

Brief Facts Summary

The dispute concerns a double storey property bearing No. 38/1 & 2, Ramesh Nagar, New Delhi. An Agreement to Sell was entered into on 21.05.1997 between Girdhari Lal (defendant no. 1) and Kishan Chand. Sunny Khurana claims to have acquired the property through Kishan Chand. Girdhari Lal filed Civil Suit No. 1763/2016 in East District court seeking cancellation of the Agreement to Sell and recovery of the property. Sunny Khurana, though not originally a party, sought to be impleaded as a defendant. Additionally, Girdhari Lal filed two other suits (Civil Suit Nos. 1166/2018 and 1167/2018) in West District court for recovery and possession of the same property against different defendants. Sunny Khurana filed a transfer petition seeking to consolidate all related suits in West District court.

Timeline of Events

1997-05-21

Agreement to Sell entered into between Girdhari Lal and Kishan Chand for the property at Ramesh Nagar, New Delhi

Before 2016

Sunny Khurana claims to have acquired the property through Kishan Chand

2016

Girdhari Lal filed Civil Suit No. 1763/2016 in East District court seeking cancellation of Agreement to Sell and recovery of property

2018

Girdhari Lal filed Civil Suit No. 1166/2018 and Civil Suit No. 1167/2018 in West District court for recovery and possession of the property

2019-03-06

Sunny Khurana filed Transfer Petition TR.P.(C.) 23/2019 in Delhi High Court

2019-03-08

First hearing before Justice Vinod Goel; notice issued to respondents returnable on 01.04.2019

2019-05-17

Final order passed by Justice Vibhu Bakhru granting the transfer petition

2019-06-03

Parties directed to appear before West District court

Key Factual Findings

Sunny Khurana claims to have acquired the property through Kishan Chand

Source: Recited from Petitioner Pleading

An Application under Order 1 Rule 10 CPC has been filed seeking to implead the petitioner as a defendant

Source: Recited from Petitioner Pleading

The petitioner is not contesting the application for impleading and readily concedes to be impleaded as a defendant

Source: Recited from Petitioner Pleading

Two other suits have been filed for recovery and possession of the property, being Civil Suit No. 1166/2018 and Civil Suit No. 1167/2018

Source: Recited from Petitioner Pleading

The said suits are pending before the Court of learned ADJ, West District, Tis Hazari Court Complex

Source: Recited from Petitioner Pleading

The property falls within the West District

Source: Current Court Finding

The controversy involved in the suits may be interrelated

Source: Current Court Finding

Primary Legal Issues

1.Whether a transfer petition under the High Court's inherent jurisdiction is maintainable for transferring a suit from one district court to another district court
2.Whether the suit should be transferred from East District court to West District court based on the location of the property and consolidation of related litigation
3.Whether the petitioner, who is not a party to the original suit, has standing to file a transfer petition

Secondary Legal Issues

1.Proper procedure for impleading a new defendant under Order 1 Rule 10 CPC
2.Jurisdiction of courts in property disputes based on location of immovable property
3.Consolidation of related suits involving the same property

Questions of Law

Is it appropriate to transfer a suit from one district court to another when the property is located in the latter district and related suits are pending there?

Statutes Applied

Code of Civil Procedure, 1908
Order 1 Rule 10
Procedure for impleading a new defendant in a pending suit; the petitioner sought to be impleaded as a defendant in the original suit

Petitioner's Arguments

The petitioner Sunny Khurana argued that: (1) The petitioner has acquired the property through Kishan Chand and has a legitimate interest in the suit; (2) The petitioner is willing to be impleaded as a defendant in the original suit without contesting the application; (3) Multiple related suits involving the same property are pending in West District court; (4) The property is located in West District; (5) Consolidation of all related suits in one court would be more efficient and avoid conflicting judgments; (6) The transfer would serve the interests of justice.

Respondent's Arguments

The respondent Girdhari Lal did not appear in court despite service of notice and did not present any arguments against the transfer petition.

Court's Reasoning

The court found that: (1) The petitioner, though not originally a party to the suit, has a legitimate interest as the property is claimed to have been acquired through Kishan Chand; (2) The petitioner's willingness to be impleaded as a defendant without contesting the application demonstrates good faith; (3) Multiple related suits (Civil Suit Nos. 1166/2018 and 1167/2018) are already pending in West District court for recovery and possession of the same property; (4) The property is located in West District; (5) The controversy involved in the suits may be interrelated; (6) Consolidation of related suits in one court would promote judicial efficiency and prevent conflicting decisions; (7) It is appropriate to transfer the suit from East District court to West District court.

Statutory Interpretation Method:
Purposive Interpretation - The court interpreted the transfer jurisdiction purposively to promote judicial efficiency and consolidation of related litigation
Judicial Philosophy Indicators:
  • Emphasis on Judicial Efficiency - The court prioritized consolidation of related suits to avoid conflicting decisions
  • Pragmatic Approach - The court considered the practical implications of having related suits in different courts
  • Fairness and Natural Justice - The court ensured that the petitioner's legitimate interest was protected
Order Nature:Substantive
Disposition Status:Disposed
Disposition Outcome:Allowed

Impugned Orders

Court of Learned ADJ, East District, Karkardooma Court
Case: Civil Suit No. 1763/2016
Date:

Specific Directions

  1. 1.Civil Suit No. 1763/2016 captioned 'Girdhari Lal and Others v. Sh. Ashok Kumar and Others' is transferred from the Court of learned ADJ, East District, Karkardooma to the West District, Tis Hazari Court
  2. 2.Parties are directed to appear before the concerned Court on 03.06.2019
  3. 3.Order dasti under signature of Court Master

Precedential Assessment

Persuasive (Other High Court)

This is a single judge order of the Delhi High Court dealing with transfer of suits between district courts. While not binding on other courts, it provides persuasive guidance on the principles governing transfer of suits based on property location and consolidation of related litigation. The order does not establish new law but applies established principles of judicial efficiency and jurisdiction.

Tips for Legal Practice

1.When multiple related suits involving the same immovable property are pending in different district courts, practitioners should consider filing a transfer petition in the High Court to consolidate the litigation in the court where the property is located or where related suits are already pending.
2.A party not originally named in a suit but having a legitimate interest in the property can file a transfer petition and seek to be impleaded as a defendant, provided the party demonstrates willingness to cooperate with the court process.
3.The High Court will exercise its inherent jurisdiction to transfer suits when consolidation would promote judicial efficiency and prevent conflicting decisions on the same property.

Legal Tags

Transfer of suit between district courts High Court jurisdictionConsolidation of related property disputes judicial efficiencyImmovable property location basis for court jurisdictionImpleading new defendant Order 1 Rule 10 CPC procedureInterrelated litigation consolidation High Court inherent powersProperty recovery and possession suits Delhi courtsAgreement to Sell cancellation property dispute resolutionMultiple suits same property different courts consolidationJudicial efficiency and conflict avoidance property disputesTransfer petition grounds related suits same property

Disclaimer: eCourtsIndia (ECI) is not a lawyer and this analysis is generated by ECI AI, it might make mistakes. This is not a legal advice. Please consult with a qualified legal professional for matters requiring legal expertise.

Order Issued After Hearing

Purpose:

First Hearing

Listed On:

8 Mar 2019

Order Text

* IN THE HIGH COURT OF DELHI AT NEW DELHI

+ TR.P.(C.) 23/2019 and CM Nos. 10999/2019 & 11000/2019

SUNNY KHURANA & ANR ..... Petitioners Through: Mr Praveen Suri with Ms Jessica Jacob, Advocates. versus

GIRDHARI LAL & ANR ..... Respondents Through: None. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU O R D E R

% 17.05.2019

  1. None appears for the respondents despite service of notice.

  2. The petitioners have filed the present petition, inter alia, praying that the Civil Suit bearing No. 1763/2016 captioned "Girdhari Lal & Others v. Sh. Ashok Kumar & Others", which is pending before the Court of Learned ADJ, East District, Karkardooma Court be transferred to the concerned Court in West District.

  3. The plaintiffs in the said suit had sought cancellation of an Agreement to Sell dated 21.05.1997 entered into between defendant no.1 and one Sh. Kishan Chand, in respect of the suit property bearing No. 38/1 & 2, Double Storey, Ramesh Nagar, New Delhi (hereafter 'the said property'). The petitioner claims to have acquired the said property through Kishan Chand. Although, the petitioner is not a party to the said suit, it is stated that an application under Order 1 Rule 10, CPC, has been filed seeking to implead the petitioner and the learned counsel appearing for the petitioner states that the petitioner is not contesting the said application and readily concedes to

$~6

implead the defendant in the said suit. It is further stated that two other suits have been filed for the recovery and possession of the said property, being Civil Suit No. 1166/2018 captioned "Girdhari Lal Tolani v. Narender Kumar and Anr." and Civil Suit No. 1167/2018 captioned "Girdhari Lal Tolani v. Jagdish Lal & Another". The said suits are pending before the Court of learned ADJ, West District, Tis Hazari Court Complex.

  1. Since the controversy involved in the suits may be interrelated and also considering that the said property falls within the West District, this Court considers it apposite to allow the present petition.

  2. Accordingly, Suit No. 1763 of 2016 captioned "Girdhari Lal and Others v. Sh. Ashok Kumar and Others" is transferred from the Court of learned ADJ, West District, Karkardooma to the West District, Tis Hazari Court. The parties are directed to appear before the concerned Court on 03.06.2019.

  3. The applications also stand disposed of.

  4. Order dasti under signature of Court Master.

VIBHU BAKHRU, J

MAY 17, 2019 RK

Original Order Copy

Get a certified copy of this order

Share This Order

Case History of Orders

Order(3) - 3 Aug 2019

Final Order

Click to view

Order(2) - 17 May 2019

Final Order

Viewing

Order(1) - 8 Mar 2019

Interim Order

Click to view
Similar Case Search

Similar Case Searches