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2026 Supreme(Mad) 259

IN THE HIGH COURT OF JUDICATURE AT MADRAS
P.B.BALAJI, J.
R.S. Sathvi – Appellant
Versus
K. Poorna Gurunath – Respondent
A.S. Nos. 594, 595, 596, 597, 598, 599 of 2024, C.M.P. Nos. 18455, 18459, 18465, 18466, 18467, 18478, 18479, 18480, 18482 of 2024
Decided On : 06-02-2026

Advocates Appeared:
For the Appellants : A. Gunaseelan, R. Mohan
For the Respondent: M. Balasubramanian

Settlement deeds executed without valid ownership rights are invalid and cannot confer any title, rendering subsequent deeds likewise unenforceable.

Headnote:(A) Code of Civil Procedure, 1908 - Section 96 - Family law - Disputes regarding land settlement deeds - Appeals against decree on grounds of invalidity of settlement deeds and claims barred by limitation were upheld; validity of subsequent deeds executed by Lakshmi Kanthamma on basis of invalid antecedent deeds was also rejected. The relationship of parties and the intention behind the deeds were significant in the court’s reasoning. (Paras 19 to 29)

(B) Limitation - The appellant’s claims were challenged based on the issue of limitation under Article 58, and the court held that the disputes arose after the demise of the ancestors leading to a fresh cause of action. The suits filed by both parties were not barred by limitation. (Paras 26 to 28)

Facts of the case:
The property originally belonged to K.P.Chandra Rao, who executed settlement deeds in favor of his children. Subsequent deeds were argued to be invalid or sham, leading to conflicting ownership claims among heirs after the death of the original owners.

Findings of Court:
The trial court's dismissal of some suits and decree in others was upheld as valid, ruling that invalid deeds could not confer any rights, and the long-standing ownership claims were acknowledged.

Issues: The primary issues addressed were the validity of various settlement deeds, claims of limitation, and the true intention of property allocation among family members.

Ratio Decidendi: The court found that the execution of settlement deeds by the original owner was invalid post his previous transactions, affirming that family arrangements must be adhered to in accordance with legal interpretations rather than mere familial intention.

Result: Appeals dismissed, with no order as to costs.

Table of Content
1. overview of appeal suits and original suits details. (Para 1 , 2 , 3 , 4 , 5)
2. legal counsel arguments for appellants. (Para 15 , 16 , 17)
3. points for consideration formation by the court. (Para 18 , 19)
4. assessment of rights in settled property and invalidation of certain deeds. (Para 20 , 21 , 22)
5. evaluation of evidentiary failures and relationships impacting decisions. (Para 23 , 24 , 25 , 26 , 27 , 28)
6. final judgment and dismissal of appeals. (Para 29)

JUDGMENT :

P.B. BALAJI, J.

1. A.S.No.598 of 2024 has been preferred by the plaintiff in O.S.Nos.2048 of 2014, for declaring settlement deeds in Doc. Nos.1785 & 1786 of 2005, dated 03.08.2005, executed by K.P.Chandra Rao, in favour of Lakshmi Kanthamma as sham and nominal and not binding on the plaintiff and for consequential permanent injunction, aggrieved by the dismissal of the suit by the Trial Court.

2. A.S.Nos.595 & 599 of 2024 have been preferred against judgment and decree in O.S.Nos.2242 & 2243 of 2014, being suits for declaration to declare the settlement deeds executed by Lakshmi Kanthamma in favour of K.P.Chandra Rao and a defendant in O.S.No.2242 of 2014, R.V.S.Sathvi and the defendant in O.S.No.2243 of 2014, R.V.S. Kiran, as sham and nominal and not binding on the plaintiff and for a permanent injunction, the Defendants have filed these appeals.

3. AS.No.597 of 2024 has been preferred, challenging the dismissal of O.S.No.3355 of 2014, where the appellant as plaintiff sought for declaration that settlement deed dated 12.01.2006, executed by Lakshmi Kanthamma and settlement deed dated 05.06.2002, as null and void and similarly, revocation deeds dated 26.09.2008 in Doc.Nos.1974 & 1975 of 2008 as null and void and also judgment and decree dated 06.04.2009 in O.S. No.5764 of 2007 as null and void and for the relief of permanent injunction, the present appeal has been filed.

4. A.S.No.594 of 2024 has been preferred, challenging the dismissal of suit filed by the Appellant as plaintiff in O.S.No.3354 of 2014, where the appellant has sought for declaration that the settlement deed dated 23.01.2006 executed by Lakshmi Kanthamma, Settlement deed dated 05.06.2002 in Doc.Nos.1055 & 1056, as null and void and revocation deeds dated 26.09.2006, the present appeal has been filed;

5. A.S.No.596 of 2024 has been preferred, challenging the dismissal of the suit filed by the Appellant as plaintiff in O.S.No.3100 of 2014, where the relief of declaration of title was sought for along with reliefs seeking declaration that settlement deed dated 07.12.2006, executed by Lakshmi Kanthamma and settlement deed dated 05.06.2002, as null and void and similarly, revocation deeds dated 26.09.2008 in Doc.Nos.1974 & 1975 of 2008 as null and void and also judgment and decree dated 06.04.2009 in O.S.No.5764 of 2007 as null and void and for the relief of permanent injunction, the present appeal has been filed.

6. I have heard Mr.A.Gunaseelan, learned counsel for the appellants in all the First Appeals and Mr.N.Balasubramanian, learned counsel for the contesting respondents 1 to 4 in A.S. Nos.594, 596 & 597 of 2024 and respondents in A.S.Nos.595, 598 & 599 of 2024.

7. In order to appreciate the facts of the various cases referred herein above, it would be appropriate to cull out the pleadings briefly:-

8. For the sake of brevity, the case of the appellant is culled out in common and similarly, the case of the respondents 1 to 4 in common.

9. Plaints in brief:

(a) The property measuring 5162 sq.ft, situated in Door No.268, Sydenhams Road, Choolai, Chennai, comprised in RS. Nos.1319/1990 part and 1319/1991 part was originally belonging to one K.P.Chandra Rao, he having purchased the same in and by a registered sale deed dated 10.09.1958 in Doc. No.2223 of 1958. On 05.06.2002, the said K.P.Chandra Rao, executed a settlement deed in favour of S.P.Jayalakshmi, the first plaintiff in O.S.No.2048 of 2014, 2242 of 2014, 2243 of 2014. Third defendant in O.S.Nos.3100 of 2014 and 3354 of 2014. Th

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