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2025 Supreme(SC) 1819

J. B. PARDIWALA, MANOJ MISRA
Karam Singh – Appellant
Versus
Amarjit Singh – Respondent


Advocates appeared:
For the Petitioner(s): Mr. Subhasish Bhowmick, AOR
For the Respondent(s): Mr. Ajay Pal, AOR

Table of Content
1. factual background of the suit and parties involved. (Para 2 , 3 , 4)
2. arguments for and against the limitation of the suit. (Para 11 , 12 , 13)
3. court's analysis of plaint rejection under limitations. (Para 15 , 16 , 17 , 18 , 19 , 21)
4. use of limitation laws in judgment ruling. (Para 20 , 22)
5. conclusion overturned high court's ruling. (Para 23 , 24)

JUDGMENT :

1. Leave granted.

3. The appellant along with Dilbag Singh (i.e., proforma respondent no. 9) instituted Suit No.424 of 2019 against Amarjit Singh (i.e., respondent no.1), Shamsher Singh (i.e., respondent no.2), Jagdish Singh (i.e., respondent no.3), Smt. Nachhattar Kaur (i.e., respondent no.4), Kuldeep Kaur (i.e., respondent no.5), Sukhdeep Kaur (i.e., respondent no.8), Sandeep Singh (i.e., respondent no.6) and Major Singh (i.e., respondent no.7) for:

4. The plaint case in a nutshell was that the original owner of the suit land was Ronak Singh alias Ronaki who died intestate on 05.10.1924, leaving behind his widow Kartar Kaur. A dispute arose regarding succession to the estate of Ronak Singh between Kartar Kaur (i.e. Ronak Singh’s widow) and Chinki and Nikki (i.e. sisters of Ronak Singh), predecessor-in

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Judicial Analysis

None of the listed cases explicitly indicate that they have been overruled, reversed, or treated as bad law based solely on the language provided. There are no phrases such as "overruled," "reversed," "criticized," or "abrogated" in the case summaries. Therefore, based on the information available, no cases are identified as bad law.

Followed / Consistent Treatment:

All cases appear to be standalone legal principles or clarifications without any indication of being overruled or criticized in the provided data.

For example, case Vinod Infra Developers Ltd. VS Mahaveer Lunia - 2025 6 Supreme 457 discusses rejection of plaint and jurisdiction, which is a standard legal principle; similarly, JITENDRA SINGH VS STATE OF MADHYA PRADESH - 2021 6 Supreme 185 and Suraj Bhan VS Financial Commr. - 2007 3 Supreme 539 clarify the limited nature of revenue records, which are well-established legal positions.

The cases concerning the validity of mutation entries, revenue records, and agreements (e.g., Balwant Singh VS Daulat Singh - 1997 6 Supreme 385, Suraj Bhan VS Financial Commr. - 2007 3 Supreme 539, JITENDRA SINGH VS STATE OF MADHYA PRADESH - 2021 6 Supreme 185) reflect consistent legal principles about property rights and revenue record entries, with no indication of subsequent disapproval.

Rejection and Procedural Principles:

Cases Vinod Infra Developers Ltd. VS Mahaveer Lunia - 2025 6 Supreme 457 and Ramisetty Venkatanna VS Nasyam Jamal Saheb - 2023 4 Supreme 519 deal with procedural aspects of plaint rejection under CPC, which are standard procedural principles and do not show signs of being overruled or criticized.

These cases reinforce existing procedural law without indication of negative treatment.

Partnership and Property Rights:

Case Rajendra Bajoria VS Hemant Kumar Jalan - 2021 6 Supreme 705 discusses partnership upon death of a partner, which appears to be a straightforward statement of law, with no subsequent treatment indicating criticism or overruling.

Overall, the treatment pattern across these cases suggests they are consistent with established legal principles and have not been marked as bad law in the provided summaries.

The treatment of these cases in subsequent jurisprudence is not specified in the provided data, so their status as good law, overruled, or criticized cannot be conclusively determined.

Without references to subsequent decisions or judicial comments, the treatment remains ambiguous regarding whether any of these cases have been questioned or criticized later.

Specifically, the absence of explicit treatment language means we cannot definitively categorize any case as overruled or bad law based solely on this data.

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