In the intricate tapestry of Indian civil litigation, the concept of limitation serves as a gatekeeper, ensuring that claims are pursued within a reasonable timeframe to promote finality and prevent stale disputes. The case of R. Nagraj (Dead) Through LRs. v. Rajmani and Others stands as a testament to the judiciary’s unwavering commitment to this principle. Decided by the Supreme Court of India in 2025, this case unravels a complex saga of familial disputes, property auctions, and legal procrastination, culminating in a definitive ruling on the application of limitation laws. This case study delves into the factual and procedural intricacies, the legal issues at stake, the arguments advanced by the parties, the judicial reasoning, and the law settled, offering a comprehensive analysis of a landmark decision that reinforces the sanctity of timely legal action.

Detailed Factual Background
The origins of this litigation lie in a joint Hindu family comprising Rangappa Gowdar and his sons, Dasappa Gowdar and Samiappan. The dispute traces back to a suit filed in 1965 (O.S. No. 851 of 1965) by Samiappan’s wife, Sunderammal, and daughter, Vennila (Respondent Nos. 6 and 7), seeking maintenance from Samiappan, his father Rangappa Gowdar, and his brother Dasappa Gowdar. The suit was decreed on August 26, 1965, and the suit properties were attached to secure the maintenance amount during execution proceedings.

Following the deaths of Rangappa and Dasappa, their legal heirs were impleaded in these proceedings. The suit’s ‘A’ schedule property was auctioned in court and purchased by Karivarada Gowdar, with the sale confirmed on September 25, 1970, via a certificate issued in E.P. No. 424 of 1969. Possession was handed over to Karivarada Gowdar on December 22, 1970, and a patta book was issued in his favor.

Subsequent attempts by Samiappan to encroach on the ‘A’ schedule property led Karivarada Gowdar to file a suit (O.S. No. 1978 of 1972) for a permanent injunction, which was decreed on June 11, 1973. The property was later sold to Respondent Nos. 8 to 10, who also secured a decree for permanent injunction in O.S. No. 3390 of 1981 on July 24, 1982. The property then passed to Respondent No. 11 and eventually to the appellants, R. Nagraj and another, who were subsequent purchasers.

In 1982, Respondent Nos. 1 to 3—Dasappa Gowdar’s wife, Madammal, and daughters, Rajmani and Santhamani—filed a suit (O.S. No. 257 of 1982) seeking to set aside the 1965 decree, partition the ‘A’ and ‘C’ schedule properties into 12 equal parts, allot 5/12 shares to themselves, and obtain a permanent injunction against the subsequent purchasers. They alleged fraud and collusion in the 1965 decree and claimed ignorance of the earlier proceedings, asserting continuous possession of the suit properties and mental distress following Dasappa’s death.

Detailed Procedural Background

• The trial court, the II Additional District Munsif, Coimbatore, dismissed O.S. No. 257 of 1982 on September 8, 1994, holding that the suit was barred by limitation under Article 59 of the Limitation Act, 1963.
  • The court found Respondent Nos. 1 to 3 were aware of the 1965 decree and execution proceedings, having been impleaded as legal heirs, and had failed to act within the stipulated time, filing the suit 17 years later.
  • The dismissal was also based on merits, as the court found no entitlement to the reliefs sought.
• Respondent Nos. 1 to 3 appealed to the Additional District Judge, Coimbatore, in Appeal Suit No. 207 of 1994, which was dismissed on January 28, 1997, affirming the trial court’s findings on limitation and merits.
  • They then filed a second appeal (S.A. No. 406 of 1998) before the High Court of Judicature at Madras.
  • On March 30, 1998, the High Court admitted the appeal, framing substantial questions of law regarding:
    • Propriety of selling the entire ‘A’ schedule property to satisfy the decree when only a 1/3rd share was held by Samiappan.
    • Whether the suit was barred by limitation given their claim of unawareness until 1981.
• On February 17, 2020, the High Court allowed the second appeal, set aside the lower courts’ judgments, and remitted the case for a fresh trial.
  • It directed the trial court to frame a specific issue on limitation, admit evidence, and decide within six months.
• Aggrieved, the appellants (subsequent purchasers) approached the Supreme Court via Civil Appeal No. 5131 of 2025.
  • The Supreme Court issued notice and stayed further proceedings on January 25, 2021.
  • During the appeal, Respondent Nos. 1 and 2 passed away; their legal heirs were impleaded, and several respondents were deleted as proforma parties.

Issues Involved in the Case

• Whether the High Court was justified in remanding the case despite concurrent findings by the lower courts, under Section 100 CPC.
• Whether the suit was barred by limitation under Article 59 of the Limitation Act.
• Whether the failure to frame a specific issue on limitation was fatal to the judgments.
• Whether Respondent Nos. 1 to 3’s claims of ignorance and fraud held merit.

Detailed Submission of Parties

Appellants’ Submissions

• Respondent Nos. 1 to 3 were aware of the 1965 decree and sale long before filing O.S. No. 257 of 1982.
• The 17-year delay rendered the suit hopelessly barred by limitation under Article 59.
• The ‘A’ schedule property ceased to be joint family property after its auction and confirmation of sale.
• Respondent Nos. 1 to 3’s attempt to set aside the 1965 decree demonstrated abuse of process.
• Lower courts had thoroughly analyzed the limitation issue, supported by documentary evidence (Ex.B1, Ex.B5).
• The High Court should have decided the substantial questions of law instead of remanding after two decades.

Respondent Nos. 1 to 3’s Submissions

• Limitation was a mixed question of fact and law requiring specific framing of issues.
• Lower courts' failure to frame an issue on limitation rendered their findings unsustainable.
• Cited Vaish Aggarwal Panchayat v. Inder Kumar & Others (2020) 12 SCC 809 emphasizing necessity of specific pleadings and evidence.
• Alleged fraud and collusion in the 1965 decree.
• Claimed unawareness until 1981 based on notice under Ex.A6.
• Sought to set aside the decree, partition properties, and secure an injunction asserting continuous possession.

Detailed Discussion on Judgments and Citations

• Vaish Aggarwal Panchayat v. Inder Kumar & Others (2020) 12 SCC 809: Limitation is a mixed question of fact and law; requires evidence. Supreme Court found prior knowledge was established.
• Ramesh B. Desai & Ors. v. Bipin Vadilal Mehta & Others (2006) 5 SCC 638: Courts must frame material issues. Supreme Court found broader issues encompassed limitation.
• Santosh Hazari v. Purushottam Tiwari (2001) 3 SCC 179: Section 100 CPC requires formulation and decision of substantial questions of law.
• Surat Singh (Dead) v. Siri Bhagwan & Others (2018) 4 SCC 562: High Court must follow mandatory procedure under Section 100 CPC.
• Mehboob-Ur-Rehman v. Ahsanul Ghani (2019) 19 SCC 413: Additional substantial questions under Section 100(5) require recorded reasons.
• Vijay Arjun Bhagat v. Nana Laxman Tapkire (2018) 6 SCC 727: High Court's failure to follow Section 100 CPC procedure criticized.
• Ramakrishnan Kadinhipally v. P.T. Karunakaran Nambiar 2023 SCC OnLine SC 323: Remand unwarranted without justification against concurrent findings.
• Bharat Barrel & Drum Mfg. Co. Ltd. v. ESI Corporation AIR 1972 SC 1935: Limitation Act prevents stale claims, not extinguishment of substantive rights.
• N. Balakrishnan v. M. Krishnamurthy (1998) 7 SCC 123: Limitation promotes timely remedies and general welfare.
• V.M. Salgaocar and Bros. v. Board of Trustees of Port of Mormugao (2005) 4 SCC 613: Courts must dismiss suits ex facie barred by limitation.
• Manindra Land & Building Corp. Ltd. v. Bhutnath Banerjee (1964) 3 SCR 495: Courts obligated to dismiss time-barred suits.
• Sardar Amarjit Singh Kalra v. Pramod Gupta (2003) 3 SCC 272: Procedural laws are handmaids of justice, not obstacles.
• Kailash v. Nanhku and Ors. (2005) 4 SCC 480: Procedural rules should advance justice; broader issues covered limitation.
• Sugandhi v. P. Rajkumar (2020) 10 SCC 706: Procedural violations should be overlooked if no prejudice caused.

Case Details
Case Title: R. Nagraj (Dead) Through LRs. and Another v. Rajmani and Others
Date of Order: April 9, 2025
Case No.: Civil Appeal No. 5131 of 2025 
Name of Court: Supreme Court of India
Name of Hon'ble Judges: J. B. Pardiwala, R. Mahadevan

Disclaimer:
The information shared here is intended to serve the public interest by offering insights and perspectives. However, readers are advised to exercise their own discretion when interpreting and applying this information. The content herein is subjective and may contain errors in perception, interpretation, and presentation.

Written By: Advocate Ajay Amitabh Suman, IP Adjutor - Patent and Trademark Attorney
Email: ajayamitabhsuman@gmail.com, Ph no: 9990389539