Sukhbiri Devi and Others v. Union of India and Others

The Hon’ble Supreme Court in Sukhbiri Devi and Others v. Union of India and Others (2022) reaffirmed the significance of limitation in property disputes, especially those involving registered relinquishment deeds. The case stemmed from a challenge to a relinquishment deed executed in 1991 by legal heirs in favour of one Dhan Singh, who secured allotment of alternate land under a Government scheme. Over two decades later, the widow and children of another heir (who passed away in 1993) initiated a suit in 2000, alleging fraud and misrepresentation.

The Hon’ble Court held that even though allegations of fraud were made, the plaintiffs had failed to seek cancellation of the deed within the statutory limitation period. The Court emphasized that a registered document carries a presumption of validity, and such presumption cannot be defeated by mere unsubstantiated claims of fraud raised after an inordinate delay. Importantly, the Court clarified that the issue of limitation must be addressed even if the deed is under challenge on the ground of fraud.

Dismissing the appeal, the Court concluded that the suit was clearly time-barred under Article 59 of the Limitation Act, 1963, which requires actions for cancellation of instruments to be filed within three years from the date the alleged fraud became known.

This decision underlines the judiciary’s consistent view that parties cannot sleep over their rights and later challenge registered conveyances after long delays. It also reinforces both the sanctity of registered deeds and the strict application of limitation laws in civil property disputes.

Source

https://indiankanoon.org/doc/170980716/