Court ruled that judicial orders must balance individual rights with pressing public interest, particularly in flood mitigation infrastructure projects, as outlined in the Specific Relief Act.

JUDGMENT

(Judgment of the Court was delivered by MOHAMMED SHAFFIQ J.)

The Appeal is directed against the impugned order of "Status Quo" dated 04.07.2025 in O.A.No.401 of 2025 in C.S.No.81 of 2025. Suit in C.S.No.81 of 2025 was instituted by the 1^st Respondent/ Madras Race Club to declare G.O.Ms.No.343 Revenue and Disaster Management Department dated 06.09.2024 terminating the lease dated 08.03.1946 for an extent of 160.86 acres in Venkatapuram, Adyar and Velachery Villages of erstwhile Chengalpattu District now in Chennai District and the consequential letter and notice issued by the Government of Tamil Nadu as null and void. In the said suit an Original Application in O.A.No.401 of 2025 was filed with the prayer not to dispossess Plaintiff/1^st Respondent herein, from the suit scheduled property. An interim order of "Status Quo" was granted by the learned Judge in O.A.No.401 of 2025. Thereafter the said application was finally heard and orders reserved by the learned Judge on 18.08.2025. It was submitted, since it was taking time for pronouncing order in the said application, State filed the present Original Side Appeal, compelled by the impending rains, inasmuch as the order of "Status Quo", if were to continue would adversely impact the works commenced by the State in the suit scheduled property, which inter alia included development/strengthening of four ponds and an Eco Park conceived in larger public interest.

1.1. On hearing both sides this Court vide order dated 22.10.2025 modified the above order of "Status Quo" as under:

“25. Since the interim order of status quo as stated supra would adversely affect public interest, we are inclined to modify the said order and permit the State to carryout all works relating to strengthening/development of pond and any other project of public interest and the respondent club shall co-operate and not obstruct such work. We find support in modifying the order of "Status Quo" in Section 41(ha) of the Specific Relief Act, 1963, which provides that an injunction cannot be granted if it would impede or delay the progress or completion of any infrastructure project. It is not in dispute that the strengthening/development of ponds and Eco Park are infrastructure projects sought to be implemented by the Government in larger public interest, in view thereof the order of "status quo" stands modified as provided supra.”

1.2. Aggrieved, Respondent Race Club filed a Special Leave to Appeal in S.L.A.No(s).31175 of 2025 dated 30.10.2025. The above Special Leave Petition was disposed of with the following observations:

“2. While we are not inclined to interfere with the impugned judgment and order passed by the High Court, we clarify that the portion in paragraph no. 25 which reads, "...permit the State to carryout all works relating to strengthening/development of pond and any other project of public interest and the respondent club shall co-operate and not obstruct such work....." shall entitle the respondent (s)-State only to create what is required for the eco- park, and will be subject to final decision.

3. The Division Bench of the High Court shall endeavour to dispose of the application(s) expeditiously.

4. With these observations, the Special Leave Petition is disposed of.

5. Pending application(s), if any, shall stand disposed of.”

1.3. Thereafter, a Civil Miscellaneous Petition in C.M.P.No.27415 of 2025 c