The judgment clarifies that the title of a court auction purchaser becomes complete upon the confirmation of the sale, which occurs under Order 21, Rule 92 of the Civil Procedure Code. Once the sale is confirmed, the property vests in the purchaser from the date of sale, and this is the point at which the sale becomes absolute. The issuance of a sale certificate is considered a formal, ministerial act that merely evidences this already completed transfer of title, and not a necessary condition for the sale to be deemed absolute or for limitation periods to commence.

The Court emphasizes that the starting point for limitation for applications seeking delivery of possession, under relevant procedural rules and limitations law, is the date when the sale becomes absolute, not the date when the sale certificate is issued. The delay or failure in issuing the sale certificate does not affect the limitation period, which is based on the date the sale is confirmed and the title passes. Therefore, an application for possession filed within the limitation period should not be barred solely because the sale certificate has not yet been issued.

The judgment further states that the issuance of the sale certificate is a ministerial act and does not create or alter the title; it is merely evidence of the transfer. The law aims to finalize proceedings swiftly, and the limitation period is designed to provide a quick remedy for the purchaser to seek possession, starting from the date the sale becomes absolute. If the limitation period expires, the purchaser's remedy is to file a suit for possession, not to seek possession through proceedings that are barred by limitation.

In conclusion, the Court set aside the orders of the High Court that delayed limitation from the date of issuance of the sale certificate and restored the order of the lower court, affirming that limitation begins from the date the sale becomes absolute, not from the date of the sale certificate issuance.