Hussain Ahmed Choudhury v. Habibur Rahman

Judgment: https://lawyerslibrary.in/books/bknn/
Citation: 2025 INSC 553
Court: Supreme Court of India
Bench: *J.B. Pardiwala, R. Mahadevan; JJ.
Case Number: Civil Appeal No. 5470 of 2025; April 23, 2025
[Arising out of impugned final judgment and order dated 09-10-2015 in RSA No. 3/2007 09-10-2015 in RSA No. 11/2007 passed by the Gauhati High Court]

Statutes

Specific Relief Act, 1963 (Sections 31, 34); Transfer of Property Act, 1882 (Section 7); Muslim Law

Subjects

Gift Deed, Sale Deed, Specific Relief Act, 1963, Section 31, Section 34, Declaration of Title, Cancellation of Instrument, Void Document, Muslim Law, Property Dispute.

Held

The Supreme Court allowed the appeal, setting aside the High Court’s judgment that dismissed the plaintiffs’ suit for declaration of title due to their failure to seek cancellation of a subsequent sale deed. The Court held that under Section 34 of the Specific Relief Act, 1963, a plaintiff, who is not a party to a sale deed executed by persons without title, is not obligated to seek its cancellation under Section 31 to claim a declaration of title. The Court clarified that a suit for declaration of title inherently encompasses challenges to documents denying such title, and the plaintiff’s prior valid Gift Deed from 1958 conferred clear title, rendering the subsequent sale deed void ab initio. The Trial Court’s decree, affirmed by the First Appellate Court, was restored, confirming the plaintiffs’ right, title, and possession over the suit land.

For Petitioner(s) :Mr. Parthiv K. Goswami, Sr. Adv. Ms. Diksha Rai, AOR Ms. Atiga Singh, Adv. Ms. Apurva Sachdev, Adv. Mr. Piyush Vyas, Adv. Ms. Purvat Wali, Adv.

For Respondent(s) : Mr. Avijit Roy, AOR

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Facts

• A registered Gift Deed dated 26.04.1958 was executed by Haji Abdul Aziz Choudhury in favor of his grandson, Siraj Uddin Choudhury (original plaintiff), covering land including the suit land (04 bighas, 05 katha, 06 chatak). The gift was made as Siraj Uddin’s father predeceased Abdul Aziz, rendering him ineligible to inherit under Muslim law.
• The appellants are the legal heirs of Siraj Uddin. Abdul Aziz died in 1971.
• On 05.05.1997, respondent no. 1 (Habibur Rahman) allegedly purchased part of the suit land from original defendants nos. 1 to 6 (siblings of Siraj Uddin’s deceased father), who lacked title.
• The plaintiff filed Title Suit No. 88/1997 for declaration, confirmation of possession, and injunction. After being forcibly dispossessed on 08.05.1999, the plaint was amended to seek recovery of possession.
• The Trial Court (21.05.2001) upheld the validity of the Gift Deed, confirmed the plaintiff’s title, and ruled that defendants nos. 1 to 6 had no saleable interest. The First Appellate Court (17.06.2006) affirmed these findings.
• The High Court (09.10.2015) agreed on the Gift Deed’s validity but allowed the defendants’ second appeals, dismissing the suit for the plaintiff’s failure to seek cancellation of the 1997 sale deed, citing precedents requiring such relief.

Issues

1. Whether the plaintiff was required to seek cancellation of the subsequent sale deed under Section 31 of the Specific Relief Act, 1963, to obtain a declaration of title under Section 34?
2. Whether the High Court erred in dismissing the suit for the plaintiff’s omission to challenge the sale deed, despite concurrent findings on the validity of the Gift Deed?

Contentions

• Appellants (Plaintiffs): The Gift Deed of 1958 validly conferred title, and the subsequent sale deed was void ab initio as the vendors lacked title under Section 7 of the Transfer of Property Act. Cancellation was unnecessary for a stranger to the sale deed, and the Trial Court’s finding that the sale deed covered distinct land supported their claim. Relied on Sk. Golam Lalchand (2024 SCC OnLine SC 2456).
• Respondents (Defendants): The plaintiff’s failure to challenge the sale deed barred relief under Section 34, as it was an obstacle to establishing title. Cited Mohd. Noorul Hoda (1996) 7 SCC 767 and Abdul Rahim (2009) 6 SCC 140, emphasizing the need for cancellation to avoid legal instruments affecting possession.

Cited

The Supreme Court in Hussain Ahmed Choudhury & Ors. v. Habibur Rahman (Dead) Through LRs & Ors. (2025 INSC 553) discussed several case laws to elucidate the scope of Sections 31 and 34 of the Specific Relief Act, 1963, and related legal principles. Below is a comprehensive list of the case laws cited in the judgment, along with the key observations made by the Court in reference to each:

1. Sk. Golam Lalchand v. Nandu Lal Shaw & Ors. (2024 SCC OnLine SC 2456)
   • Context: Cited by the appellants to argue that cancellation of the subsequent sale deed was unnecessary.
   • Observation: The Court noted that Section 31 of the Specific Relief Act, 1963, uses the word “may,” indicating that seeking cancellation of a void instrument is not mandatory, particularly for a person who is not a party to the instrument. The Court clarified that this does not mean a stranger to an instrument falls under “any person” in Section 31, but rather that a plaintiff not bound by the instrument need not seek its cancellation to claim title (para 23-24).
2. Muppudathi Pillai v. Krishnaswami Pillai (1959 SCC OnLine Mad 5)
   • Context: A Full Bench decision of the Madras High Court discussing Sections 39 and 41 of the Specific Relief Act, 1877 (now Sections 31 and 33 of the 1963 Act).
   • Observation: The Court outlined three conditions for cancellation under Section 31: (1) the instrument must be void or voidable against the plaintiff; (2) the plaintiff must reasonably apprehend serious injury if the instrument remains outstanding; and (3) the court must deem it proper to grant preventive relief. The relief is protective, aimed at removing potential mischief from an instrument executed by a party or someone who can bind the plaintiff, not by a stranger asserting a hostile title. The Court emphasized that Section 31 does not apply to instruments executed by third parties unrelated to the plaintiff’s title, as cancellation in such cases would not address the underlying title dispute (paras 20-22).
3. Deccan Paper Mills Company Limited v. Regency Mahavir Properties and Others (2021) 4 SCC 786
   • Context: Cited to clarify the scope of Section 31 proceedings.
   • Observation: The Court held that Section 31 proceedings are in personam, applicable only to parties to the instrument or those claiming through them, not third parties. The expression “any person” in Section 31 is restricted to parties to the instrument or those bound by them (e.g., through derivative title). Relief under Section 31 is to prevent misuse of an instrument against the plaintiff, not to adjudicate competing titles, which is addressed under Section 34. This reinforced that the plaintiff, as a stranger to the sale deed, was not required to seek its cancellation (para 22).
4. Mohd. Noorul Hoda v. Bibi Raifunnisa and Ors. (1996) 7 SCC 767
   • Context: Relied upon by the respondents to argue that the plaintiff must challenge the sale deed to establish title.
   • Observation: The Court distinguished this case, noting it involved a plaintiff seeking to set aside a partition decree through a benamidar, who was a party to the decree. The Court held that when a plaintiff seeks to establish title and an instrument or decree binds them (though not a party, e.g., through a benamidar), they must seek cancellation. The limitation period under Article 59 of the Limitation Act, 1963, applied, as the plaintiff had constructive notice through the benamidar. In the present case, the plaintiff was not bound by the sale deed, as they did not claim through the vendors, making this precedent inapplicable (paras 40-42, 45).
5. Abdul Rahim & Ors. v. Sk. Abdul Zabar & Ors. (2009) 6 SCC 140
   • Context: Cited by the respondents to support the need for cancellation of an instrument affecting title.
   • Observation: The Court distinguished this case, which dealt with the validity of a gift deed under Islamic law and limitation under Article 59. The issue was whether possession was handed over for a valid gift and whether the suit to challenge the gift deed was time-barred. The Court held that constructive possession sufficed for a valid gift and the suit was barred by limitation. The precedent was inapplicable here, as the plaintiff was not challenging an instrument they were bound by, and the Gift Deed’s validity was concurrently upheld without challenge (paras 43-45).
6. Suhrid Singh alias Sardool Singh v. Randhir Singh & Ors. (2010) 12 SCC 112
   • Context: Cited to differentiate between cancellation and declaration suits.
   • Observation: The Court explained that an executant seeking to annul a deed must sue for cancellation under Section 31, but a non-executant seeking to avoid a deed need only seek a declaration under Section 34 that the deed is invalid, non est, or not binding on them. This distinction supported the plaintiff’s position that, as a non-executant of the sale deed, they were not required to seek its cancellation but could seek a declaration of title (para 29).
7. Unni v. Kunchi Amma (1890 SCC OnLine Mad 5)
   • Context: A Madras High Court decision on the treatment of void deeds by non-parties.
   • Observation: The Court held that a person not bound by a deed executed by someone without authority need not sue to set it aside, as it cannot be used against them. Such a deed can be treated as non-existent, and the plaintiff can sue for their rights as if it did not exist. This supported the plaintiff’s argument that the void sale deed required no cancellation for their title claim (para 31).
8. Bijoy Gopal Mukerji v. Krishna Mahishi Debi (1907 SCC OnLine PC 1)
   • Context: A Privy Council decision on the rights of reversionary heirs against voidable alienations.
   • Observation: The Court noted that a Hindu widow’s alienation is voidable by the reversionary heir, who may treat it as a nullity without court intervention. The heir can sue for possession without seeking cancellation, as the deed is not binding on them. This principle was applied to hold that the plaintiff, not bound by the sale deed, could seek a declaration of title without challenging the deed (para 32).
9. Vellayya Konar (Died) & Anr. v. Ramaswami Konar & Anr. (1939 SCC OnLine Mad 149)
   • Context: A Madras High Court decision clarifying the remedies for plaintiffs against third-party deeds.
   • Observation: The Court held that a plaintiff not party to a deed or decree cannot seek its cancellation in toto, as only parties to the instrument or their representatives can do so. Instead, the plaintiff must seek a declaration that the deed is invalid as against them. This reinforced that the plaintiff’s remedy was a declaration under Section 34, not cancellation under Section 31 (para 33).
10. Supreme General Films Exchange Ltd. v. His Highness Maharaja Sir Brijnath Singhji Deo of Maihar and Ors. (1975) 2 SCC 530
    • Context: Cited to emphasize the courts’ discretion in granting declaratory relief.
    • Observation: The Court held that Section 34 is not exhaustive of declaratory relief, and courts have inherent powers to grant declarations outside its strict requirements, depending on the case’s facts. Courts can shape relief to meet justice’s demands, supporting the grant of a declaration based on the plaintiff’s averments that the vendors lacked title, without requiring a specific prayer for cancellation (para 38).
11. Ram Rattan v. State of U.P. (1977) 1 SCC 188
    • Context: Cited by the respondents to argue that a true owner must use legal remedies to dispossess a trespasser with established possession.
    • Observation: The Court noted that a true owner can dispossess a trespasser during the act of trespass but not after the trespasser has established possession, requiring legal recourse. However, this was not directly applied, as the focus was on the plaintiff’s title and the void nature of the sale deed, not possession disputes (para 15).

Summary of Key Legal Principles Derived:

• Section 31 (Cancellation): Applies to parties to an instrument or those claiming through them, not strangers. Cancellation is discretionary (“may”) and not mandatory for void instruments, especially for non-parties.
• Section 34 (Declaration): Allows a plaintiff to seek a declaration of title without seeking cancellation of a void deed executed by strangers, as such deeds are non-binding. The proviso requires “further relief” only if it directly flows from the declaration.
• Void Deeds: A deed executed by persons without title is void ab initio and can be treated as non-existent by those not bound by it, negating the need for cancellation.
• Court’s Discretion: Courts have inherent powers to grant declaratory relief based on the plaint’s averments and evidence, even if specific reliefs like cancellation are not prayed for, to ensure justice.

These observations collectively supported the Court’s conclusion that the plaintiff, not a party to the 1997 sale deed, was not required to seek its cancellation to establish title based on the valid 1958 Gift Deed, leading to the restoration of the Trial Court’s decree.

Decision

• The Supreme Court allowed the appeal, setting aside the High Court’s judgment and restoring the Trial Court’s decree as affirmed by the First Appellate Court.
• Key Findings:
  • Under Section 34 of the Specific Relief Act, a plaintiff not party to a sale deed (executed by persons without title) is not required to seek its cancellation under Section 31 to claim a declaration of title. A suit for declaration inherently addresses documents denying title (Unni v. Kunchi Amma, 1890 SCC OnLine Mad 5; Bijoy Gopal Mukerji v. Krishna Mahishi Debi, 1907 SCC OnLine PC 1).
  • Section 31 applies to parties or those claiming through them, not strangers to the instrument (Muppudathi Pillai v. Krishnaswami Pillai, 1959 SCC OnLine Mad 5; Deccan Paper Mills v. Regency Mahavir Properties, (2021) 4 SCC 786).
  • The proviso to Section 34 requires “further relief” only if it flows directly from the declaration sought. Here, cancellation was not necessary as the sale deed was void ab initio, executed by parties without title.
  • The plaintiff’s averments that defendants nos. 1 to 6 lacked title implied the sale deed was non-binding, sufficient to grant declaratory relief (Supreme General Films Exchange Ltd. v. Brijnath Singhji Deo, (1975) 2 SCC 530).
  • The Trial Court’s finding that the sale deed covered distinct land, not the suit land (Dag Nos. 174/175), further negated the need for cancellation.
  • Precedents like Mohd. Noorul Hoda and Abdul Rahim were distinguished, as they involved plaintiffs bound by or claiming through parties to the disputed instruments, unlike the present case.

Ratio Decidendi

• A plaintiff asserting title based on a prior valid instrument (e.g., a Gift Deed) need not seek cancellation of a subsequent void sale deed executed by strangers to their title. A declaration of title under Section 34 encompasses challenges to such documents, and courts have discretion to grant relief based on the plaint’s averments and evidence.

Obiter Dicta

• Courts have inherent powers to shape declaratory relief to meet justice’s demands, even beyond the strict requirements of Section 34, ensuring effective remedies without compelling plaintiffs to seek unnecessary relief.

Disposition

• Appeal allowed, High Court’s judgment set aside, Trial Court’s decree restored. No order as to costs.

Below are Multiple Choice Questions (MCQs) and Frequently Asked Questions (FAQs) based on the case Hussain Ahmed Choudhury & Ors. v. Habibur Rahman (Dead) Through LRs & Ors. (2025 INSC 553). These are designed to test understanding of the key legal principles, facts, and findings of the case.

Multiple Choice Questions (MCQs)

1. What was the primary legal issue in the case Hussain Ahmed Choudhury & Ors. v. Habibur Rahman?
   a) Validity of a Gift Deed under Muslim law
   b) Whether the plaintiff was required to seek cancellation of a subsequent sale deed to claim a declaration of title
   c) Whether the suit was barred by limitation under Article 59
   d) Whether possession was validly delivered under the Gift Deed
   Answer: b) Whether the plaintiff was required to seek cancellation of a subsequent sale deed to claim a declaration of title
   Explanation: The Supreme Court addressed whether the plaintiff, claiming title via a 1958 Gift Deed, needed to seek cancellation of a 1997 sale deed under Section 31 to obtain a declaration of title under Section 34 of the Specific Relief Act, 1963 (para 18).
2. Under which provision of the Specific Relief Act, 1963, did the plaintiff primarily seek relief in the suit?
   a) Section 31
   b) Section 34
   c) Section 39
   d) Section 41
   Answer: b) Section 34
   Explanation: The plaintiff filed the suit for a declaration of title, confirmation of possession, and recovery of possession, which falls under Section 34, allowing declarations of legal character or property rights (para 25, suit details in para 4).
3. Why did the High Court dismiss the plaintiff’s suit?
   a) The Gift Deed was invalid under Muslim law
   b) The plaintiff failed to challenge the subsequent sale deed or seek its cancellation
   c) The suit was barred by limitation
   d) The plaintiff did not prove possession of the suit land
   Answer: b) The plaintiff failed to challenge the subsequent sale deed or seek its cancellation
   Explanation: The High Court dismissed the suit because the plaintiff did not seek cancellation of the 1997 sale deed, deeming it necessary to clear title, despite agreeing on the Gift Deed’s validity (para 14, 34-37).
4. What was the Supreme Court’s key holding regarding the need to cancel the sale deed?
   a) Cancellation under Section 31 is mandatory for all title disputes
   b) A plaintiff not party to a sale deed need not seek its cancellation to claim title under Section 34
   c) The sale deed was valid and binding on the plaintiff
   d) The plaintiff must seek cancellation if possession has been transferred
   Answer: b) A plaintiff not party to a sale deed need not seek its cancellation to claim title under Section 34
   Explanation: The Court held that a plaintiff, as a stranger to the sale deed executed by persons without title, was not required to seek its cancellation under Section 31 to obtain a declaration of title under Section 34, as the deed was void ab initio (para 34, 36).
5. Which precedent clarified that a non-executant of a deed need only seek a declaration, not cancellation?
   a) Mohd. Noorul Hoda v. Bibi Raifunnisa
   b) Suhrid Singh alias Sardool Singh v. Randhir Singh
   c) Abdul Rahim v. Sk. Abdul Zabar
   d) Deccan Paper Mills v. Regency Mahavir Properties
   Answer: b) Suhrid Singh alias Sardool Singh v. Randhir Singh
   Explanation: The Court cited Suhrid Singh (2010) 12 SCC 112 to distinguish that an executant must seek cancellation under Section 31, but a non-executant, like the plaintiff, need only seek a declaration under Section 34 that the deed is not binding (para 29).
6. What did the Supreme Court restore in its final disposition?
   a) The High Court’s judgment dismissing the suit
   b) The Trial Court’s decree as affirmed by the First Appellate Court
   c) The sale deed’s validity
   d) The plaintiff’s possession without a decree
   Answer: b) The Trial Court’s decree as affirmed by the First Appellate Court
   Explanation: The Supreme Court set aside the High Court’s judgment and restored the Trial Court’s decree, as affirmed by the First Appellate Court, confirming the plaintiff’s title and possession (para 46).
7. Why was Mohd. Noorul Hoda v. Bibi Raifunnisa distinguished by the Supreme Court?
   a) It involved a benamidar claiming through a party to the instrument
   b) It addressed the validity of a Gift Deed under Muslim law
   c) It did not involve a sale deed
   d) It was decided under the Specific Relief Act, 1877
   Answer: a) It involved a benamidar claiming through a party to the instrument
   Explanation: The Court distinguished Mohd. Noorul Hoda (1996) 7 SCC 767 because it involved a plaintiff bound by a partition decree through a benamidar, unlike the present plaintiff, who was not claiming through the sale deed’s vendors (para 42, 45).
8. What role did the Trial Court’s finding about the sale deed’s land play in the Supreme Court’s reasoning?
   a) It proved the sale deed was valid
   b) It showed the sale deed covered distinct land, not the suit land
   c) It established the plaintiff’s possession
   d) It negated the Gift Deed’s validity
   Answer: b) It showed the sale deed covered distinct land, not the suit land
   Explanation: The Trial Court found that the land in the sale deed was distinct from the suit land (Dag Nos. 174/175), supporting the conclusion that the sale deed did not affect the plaintiff’s title, further negating the need for cancellation (para 9, 11).
9. Which case clarified that courts have inherent powers to grant declaratory relief beyond Section 34?
   a) Unni v. Kunchi Amma
   b) Supreme General Films Exchange Ltd. v. Brijnath Singhji Deo
   c) Bijoy Gopal Mukerji v. Krishna Mahishi Debi
   d) Vellayya Konar v. Ramaswami Konar
   Answer: b) Supreme General Films Exchange Ltd. v. Brijnath Singhji Deo
   Explanation: The Court cited Supreme General Films (1975) 2 SCC 530 to hold that Section 34 is not exhaustive, and courts can grant declaratory relief based on the plaint’s averments to meet justice’s demands, even without a specific prayer for cancellation (para 38).
10. What principle did Unni v. Kunchi Amma establish?
    a) A void deed must always be cancelled
    b) A deed by a person without authority can be treated as non-existent by those not bound by it
    c) Possession is essential for a valid gift under Muslim law
    d) Limitation bars all title suits after three years
    Answer: b) A deed by a person without authority can be treated as non-existent by those not bound by it
    Explanation: Unni v. Kunchi Amma (1890 SCC OnLine Mad 5) held that a deed executed by someone without authority is non-binding on others, who can treat it as non-existent and sue for their rights without seeking cancellation (para 31).

Frequently Asked Questions (FAQs)

1. What was the factual background of the case?
   The case involved a dispute over land gifted by Haji Abdul Aziz Choudhury to his grandson, Siraj Uddin Choudhury, via a 1958 Gift Deed, as Siraj’s father predeceased Aziz, affecting inheritance under Muslim law. In 1997, defendants (siblings of Siraj’s father) sold part of the suit land to Habibur Rahman, who allegedly had no title. The plaintiff (Siraj’s heirs) filed a suit for declaration of title and possession, which was granted by the Trial and First Appellate Courts but dismissed by the High Court for not seeking cancellation of the sale deed. The Supreme Court restored the Trial Court’s decree (paras 4-5).
2. Why did the High Court dismiss the plaintiff’s suit despite upholding the Gift Deed’s validity?
   The High Court agreed that the 1958 Gift Deed was validly executed and possession was delivered but dismissed the suit because the plaintiff did not challenge or seek cancellation of the 1997 sale deed. It relied on precedents like Mohd. Noorul Hoda and Abdul Rahim, holding that without cancelling the sale deed, the plaintiff could not obtain a declaration of title, as it posed an obstacle (paras 14, 34-37).
3. What was the Supreme Court’s main reasoning for allowing the appeal?
   The Supreme Court held that a plaintiff not party to a sale deed executed by persons without title (void ab initio) need not seek its cancellation under Section 31 to claim a declaration of title under Section 34. The plaintiff’s valid 1958 Gift Deed established title, and the sale deed, executed by defendants without saleable interest, was non-binding. A declaration of title inherently addresses such void deeds, and the plaintiff’s averments implied the sale deed’s invalidity (paras 34-36).
4. How did the Court interpret Sections 31 and 34 of the Specific Relief Act, 1963?
   • Section 31: Applies to parties to an instrument or those claiming through them (e.g., via derivative title), allowing cancellation if the instrument is void/voidable and poses serious injury. It does not apply to strangers to the instrument, like the plaintiff (paras 19-22).
   • Section 34: Permits a declaration of title or legal character without requiring further relief (e.g., cancellation) unless it directly flows from the declaration. A non-executant can seek a declaration that a deed is not binding without cancelling it (paras 25-28).
5. Why was the sale deed considered void ab initio?
   The sale deed was void ab initio because it was executed by defendants nos. 1 to 6, who had no title or saleable interest in the suit land, as the land was validly gifted to the plaintiff in 1958. Under Section 7 of the Transfer of Property Act, 1882, a vendor cannot transfer better title than they possess. Additionally, the Trial Court found the sale deed covered distinct land, not the suit land (paras 6-7, 9).
6. How did the Court address the respondents’ reliance on Mohd. Noorul Hoda and Abdul Rahim?
   The Court distinguished these cases:
   • Mohd. Noorul Hoda involved a plaintiff bound by a partition decree through a benamidar, requiring cancellation due to derivative title. The plaintiff here was not claiming through the sale deed’s vendors (para 42).
   • Abdul Rahim dealt with a gift deed’s validity and limitation, not a stranger’s deed. The plaintiff here was not bound by the sale deed, and the Gift Deed’s validity was unchallenged (para 45).
7. What role did the Trial Court’s findings play in the Supreme Court’s decision?
   The Trial Court’s findings were pivotal:
   • The 1958 Gift Deed was validly executed, with possession delivered, conferring title to the plaintiff.
   • Defendants nos. 1 to 6 had no saleable interest.
   • The 1997 sale deed covered distinct land, not the suit land (Dag Nos. 174/175), as per the settlement map. These findings, affirmed by the First Appellate Court, supported the plaintiff’s title and negated the need to challenge the sale deed (paras 8-10).
8. What principle did the Court derive from Unni v. Kunchi Amma and Bijoy Gopal Mukerji?
   • Unni v. Kunchi Amma (1890 SCC OnLine Mad 5): A deed executed by someone without authority is non-binding on others, who can treat it as non-existent and sue for their rights without cancellation (para 31).
   • Bijoy Gopal Mukerji (1907 SCC OnLine PC 1): A voidable alienation (e.g., by a Hindu widow) can be treated as a nullity by a reversionary heir without court intervention, supporting the plaintiff’s right to seek a declaration without cancelling the sale deed (para 32).
9. How did the Court view the plaintiff’s averments in the plaint?
   The Court held that a plaint must be read holistically. The plaintiff’s averment that defendants nos. 1 to 6 had no title or saleable rights implied that the sale deed was not binding on the plaintiff. This was sufficient to grant declaratory relief, even without a specific prayer for cancellation, as courts can shape relief based on evidence and justice’s demands (paras 37-38).
10. What broader legal implication does this case have for title disputes?
    The case establishes that in title disputes, a plaintiff with a prior valid title (e.g., via a Gift Deed) need not seek cancellation of a subsequent void deed executed by strangers to their title. A declaration of title under Section 34 encompasses challenges to such deeds, and courts have discretion to grant relief based on the plaint’s intent and evidence, promoting efficient resolution of property disputes without unnecessary procedural hurdles (paras 36-38).

These MCQs and FAQs encapsulate the core legal issues, factual matrix, and judicial reasoning of the case, making them useful for students, legal practitioners, and those studying property law or the Specific Relief Act, 1963.