LawforAll

Tuesday, July 1, 2025

Property Law – Partition – Memorandum vs. Partition Deed – Registrability: The crucial distinction between a document merely recording an already completed oral partition (memorandum of partition) and a document that itself effects a partition lies in its registrability. A memorandum of an already effected oral partition may not require compulsory registration under Section 17 of the Registration Act, whereas a document that creates, declares, assigns, limits, or extinguishes rights in immovable property by itself as a partition deed would be compulsorily registrable. The binding nature of an oral family settlement needs to be assessed based on the specific facts and evidence presented, particularly when daughters (also legal heirs) were not parties to the documented settlement.


2025: JHHC:16513

IN THE HIGH COURT OF JHARKHAND AT RANCHI

S.A. No. 157 of 2019

Appellant: Shyamlal Poddar @ Shyam Poddar

Respondent: Sukhdeo Mandal

CORAM: HON’BLE MRS. JUSTICE ANUBHA RAWAT CHOUDHARY

C.A.V. on 04.03.2025 Pronounced on 23.06.2025

1. Transfer of Property – Gift Deed – Registration: A deed of gift purporting to transfer immovable property is invalid and ineffective if it is an unregistered instrument. The fact that stamp paper was purchased for the deed and it was attested by a Notary and witnesses does not cure the defect of non-registration as mandated by law for transfer of immovable property.

2. Adverse Possession – Proof: A claim of adverse possession requires proof of actual, open, notorious, exclusive, and continuous possession hostile to the true owner for the statutory period. Mere assertion of possession is insufficient; evidence contradicting continuous residence (e.g., voter registration in another village) can defeat such a claim.

3. Civil Procedure – Non-Joinder of Necessary Parties: A suit for declaration of right, title, and interest and for possession over a portion of property inherited by co-heirs is not necessarily bad for non-joinder of all legal heirs of the original owner if the party claiming a share has acquired it through a valid transfer from some of the recognized co-heirs, and the alleged missing parties are not deemed "necessary parties" whose absence would prevent the court from passing an effective decree.

4. Property Law – Partition – Memorandum vs. Partition Deed – Registrability: The crucial distinction between a document merely recording an already completed oral partition (memorandum of partition) and a document that itself effects a partition lies in its registrability. A memorandum of an already effected oral partition may not require compulsory registration under Section 17 of the Registration Act, whereas a document that creates, declares, assigns, limits, or extinguishes rights in immovable property by itself as a partition deed would be compulsorily registrable. The binding nature of an oral family settlement needs to be assessed based on the specific facts and evidence presented, particularly when daughters (also legal heirs) were not parties to the documented settlement.

5. Sale Deed – Challenge to Execution/Validity: A registered sale deed for immovable property, duly proved, creates right, title, and interest in favour of the purchaser. If the execution of such a deed is challenged, but the challenging party does not seek its cancellation or raise a counter-claim in any court of law, the sale deed can be considered a valid piece of document for the transfer of the suit land.

2025: JHHC:16513

IN THE HIGH COURT OF JHARKHAND AT RANCHI

S.A. No. 157 of 2019

Shyamlal Poddar @ Shyam Poddar, aged about 80 years son of

Late Narsingh Poddar, resident of village Posta, P.O. Patrodih as

well as village- Karmatanr, P.O. and P.S. Karmatanr, District

Jamtara. … … Defendant no.1/Appellant no.1/Appellant

Versus

1. Sukhdeo Mandal, son of Late Budhu Mandal, resident of village

Het Karmatanr, P.O. and P.S. Karmatanr, District Jamtara

… … Plaintiff/Respondent no.1/Respondent

2. Smt. Thakri Devi wife of late Moti Poddar

3. Kashi Poddar son of Late Moti Poddar,

nos. 2 and 3 are resident of village Posta, P.O. Patrodih, P.S.

Narayanpur, District Jamtara

4. Meena Devi, daughter of late Moti Poddar and wife of Laxmi

Verma, resident of village Karmatanr, P.O. and P.S. Karmatanr,

District Jamtara

5. Asha Devi, daughter of late Moti Poddar and wife of Mohan

Poddar, resident of village Dhakuri, P.O. Tapoban, P.S. Kunda,

District- Deoghar

… … Proforma Defendant Nos. 2 to 5/ Profmrma

Resp. Nos. 2 to 5/ Proforma Respondents

6. Lilabati Devi aged about 65 years, wife of Shyam Lal Poddar, R/o

village + P.O.+P.S.- Karmatanr, District Jamtara

(Substituted vide order dated 29.09.2022)

6(a) Mahadeo Poddar

6(b) Manoj Kumar Poddar

Both S/o Shyam Lal Poddar r/o Village- Posta, P.O. Patrodih, P.S.

Narayanpur, District Jamtara as well as Village - Karmatanr, P.O. &

P.S.- Karmatanr, District Jamtara

6(c) Usha Devi, w/o Indra Swarnakar, r/o Vill- Kurmipara, Mihijam,

near Shiv Mandir, P.O. & P.S.- Mihijam, District- Jamtara.

6(d) Santoshi Devi Burma, w/o- Shekhar Burma, r/o village –

Joraphatak, Dhanbad (Gandhi Road), P.O. & P.S. – Dhanbad, DistrictDhanbad.

… … Defendant No.1(a)/Appellant no. 2/Respondents

---

CORAM: HON’BLE MRS. JUSTICE ANUBHA RAWAT CHOUDHARY

---

For the Appellant : Mr. Amar Kr. Sinha, Advocate

: Mr. Ashutosh Pd. Joshi, Advocate

For the Resp. Nos. 1 to 5 : Mr. Kaushik Sarkhel, Advocate

---

C.A.V. on 04.03.2025 Pronounced on 23.06.2025 

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1. This appeal has been filed challenging the judgment and decree

dated 26.02.2019 (decree signed on 06.03.2019) passed by learned

District Judge I, Jamtara dismissing Civil Appeal No.14 of 2017 and

confirming the judgement and decree dated 31.03.2017 (decree signed

on 11.04.2017) passed by learned Civil Judge (Senior Division) I,

Jamtara in Title Suit No.9 of 2009. The appellant was the defendant

no.1 in Title Suit No.9 of 2009.

2. This appeal has been admitted for hearing on the following

substantial questions of law:

i. Whether exhibit -4 was effecting partition and

compulsorily registrable as per section 17 and 49 of

the Registration Act or it was just a memorandum of

earlier partition?

ii. Whether Oral Family Settlement (Exhibit-4) entered

into between the sons with respect to the property

acquired by their father during his lifetime without

making daughters as party to the said deed is binding

upon the parties and whether the finding of the learned

appellate court is perverse and against the mandate of

law?

3. Case of the plaintiff

I. The plaintiff Sukhdeo Mandal filed the suit for declaration of

right, title and interest over the suit properties in his favour and

against the defendant and prayed for delivery of possession over

the suit properties in his favour through the process of the court

and permanent injunction against the defendants restraining

them from disturbing his possession.

II. The land involved in the present case has been described in the

schedule to the plaint as under: -

“In the district of Jamtara, Subdivision Jamtara, Police

Station Jamtara, Out Post-Karmatarn, Anchal Jamtara,

in mouza Karmatarn No. II appertaining to A.K.J. No.

106/4115, plot No. 1206/A area 1/2 decimal and plot No.

1206/2305/A area 1/2 decimal total measuring an area

of 1 decimal of land alongwith one pucca constructed

house shown in red colour in the annexed trace map.”

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III. As per the plaint, Narsingh Poddar, Son of Late Raghu Poddar

purchased 2 decimals of land from plot No. 1206 and

1206/2305 of mauza Karmatanr from the descendants of

Khartar Shaw and Ramdhani Shaw by registered deed of sale;

Narsingh Poddar entered into possession of the property in the

year 1997 and constructed house over the property having

transferrable basauri rights. The genealogy has been given in

paragraph 4 of the plaint. Narsingh Poddar had two sons,

namely, Moti Poddar and Shyam Poddar. The proforma

defendants were the descendants/legal heirs of Moti Poddar.

IV. It is the case of the plaintiff that Narsingh Poddar died in the

year 1999 and Moti Poddar died in the year 1987 and thus he

left behind only one son, namely, Shyam Poddar. The wife of

Moti Poddar is Thakuri Devi who was defendant No. 2. It was

the case of the plaintiff that after death of Narsingh Poddar, both

the brothers or their legal heirs had succeeded the property

purchased by Narsingh Poddar. It was his further case that after

death of Moti Poddar, Shyam Poddar had started creating

disturbance and ultimately the aforesaid two decimals property

was amicably divided half and half; northern one decimal of

land was allotted to Shyam Poddar whereas Southern one

decimal of land was allotted to the heirs of Moti Poddar. To

this, a memorandum of partition was created for future

reference on 20.11.2005 only.

V. It is further case of the plaintiff that after death of Moti Poddar,

the widow and the children started living at village Posta, P.S.

Narayanpur and taking advantage of the death of Moti Poddar,

defendant No. 1 Shyam Poddar made up his mind to grab the

entire 2 decimals of land. Upon being informed, the legal heirs

and successors of Moti Poddar took several preventive measures

but they failed. It is alleged in the plaint that the principal

defendant Shyam Poddar had anti-dated several papers to grab 

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the entire 2 decimals of land and ultimately several litigations

started between the parties.

VI. The plaintiff’s further case is that the proforma defendants i.e.

legal heirs and successors of Moti Poddar being in need of

money sold their allotted one decimal of land towards the

southern side to the plaintiff by a registered deed of sale bearing

No. 493 dated 20.10.2008 and consequently, the plaintiff

became the rightful owner to the extent of one decimal of land

with structure thereon. The principal defendant i.e. Shyam

Poddar started creating trouble and on 25.01.2009, the plaintiff

along with the legal heirs and successors of Moti Poddar (the

proforma defendants) approached the principal defendant

Shyam Poddar to give vacant possession of the purchased land

as described in the schedule but the principal defendant flatly

denied and asked the plaintiff to move the competent court of

law. Consequently, the suit was filed on 25.02.2009.

4. Case of the contesting defendant i.e. defendant No.1

The defendant No. 1 Shyam Lal Poddar filed his written

statement before the learned trial Court and the case of the

defendant no. 1 was as under:

a. There was no cause of action for the suit and the suit was

not maintainable. It was the case of the defendant no. 1 that the

plaintiff had a jewelry shop at Karmatanr where defendant no. 3

Kashi Poddar (S/o Moti Poddar) worked under him as his

employee and he got the illegal sale deed executed by the

proforma defendant without any consideration only to commit

mischief.

b. The suit was bad for non-joinder of necessary parties as

all the heirs of Narsingh Poddar- the original owner of suit land,

were not made party. Narsingh Poddar had three daughters

namely Amli Devi, Bhumi Devi and Shanti Devi, the first of

whom died on 01.10.2008 leaving behind her five sons namely 

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Amardeep, Raju, Tuntun, Ashok and Pappu and a daughter

Munni Devi. Bhumi Devi died in or about 2000 leaving six sons

namely Tarani, Dhananjay, Nandu, Mahesh, Pancham and

Kamlesh and one daughter Beena Devi. It was asserted that

Shanti Devi was still alive and the plaintiff deliberately omitted

her name and the names of the others and had furnished an

incorrect genealogy. The defendant no.1 further averred that the

actual owner of the suit land was wife of defendant no.1, which

was fully known to the vendors of the plaintiff and also the

plaintiff of the suit, but with ulterior motive she was not made

party in the suit and the suit was liable to be dismissed for

willful non-joinder of necessary parties.

c. It was also case of the defendant no.1 that Narsingh

Poddar did not die in 1999 but he died on 26.05.1998 and left

behind two sons and three daughters as his next heirs. Before

and after the death of Moti Poddar, the proforma defendants

always lived at Posta and they had no occasion to live at

Karmatanr.

d. It was also pleaded on behalf of defendant Shyam Lal

Poddar that the proforma defendants were never the owner of

one decimal of land towards southern side and their alleged sale

of land to the plaintiff was mala fide. As per this defendant, the

proforma defendants contested several cases under sections 144

and 107 of Code of Criminal Procedure with him for the suit

land and got such proceeding drawn up by making false

allegations. It was asserted that in all those cases, the defendant

no. 1 had clearly asserted in his show-cause that the proforma

defendants did not have any right, title, interest in the suit land

nor they were in possession of the same. As per the contesting

defendant, the fact was that the 2 decimals of land was

purchased by Narsingh Poddar who built a tide roof house and

was living on the property with his younger daughter-in-law i.e.,

W/o Shyam Poddar who used to nurse and look after Narsingh 

2025: JHHC:16513

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Poddar at his old age. Out of special love and affection for her,

Narsingh Poddar gifted and transferred the entire two decimals

of land along with house in her favour on 07.12.1995 and the

defendant no. 1(a) (wife of defendant no.1) accepted the sale

gift and entered into possession on 07.12.1995 itself and

continued to reside over the property along with her sons on her

own right. Narsingh Poddar got himself divested of the said

property by such transfer through gift. It was asserted that

Narsingh Poddar had also executed a deed of gift in favour of

defendant no. 1(a) on 07.12.1995 which was certified by Notary

and attested by witnesses and he also sworn an affidavit

confirming the contents of the deed. Defendant no. 1(a) had

undertaken some construction work over the property soon after

the death of Narsingh Poddar but in March 2008, the proforma

defendants started filing cases to stop the construction. So, the

specific case of the defendant No. 1 was that by virtue of gift

defendant no. 1(a) became the absolute owner of the suit land

and she is in exclusive owner of the suit property. Alternatively,

the defendant No. 1 submitted that defendant no. 1(a) had

acquired indefensible perspective title to the entire 2 decimal of

land and remained in peaceful possession for more than 12

years beginning from 07.12.1995 adversely to Narsingh Poddar

and his heirs.

5. Case of the proforma defendants i.e. defendant Nos. 2 to 5

i. The defendant nos. 2, 3, 4 and 5 appeared and filed their

written statement pleading therein that after the sudden demise

of Moti Poddar i.e. husband of defendant no.2, these

defendants became helpless and as such the defendant no.1

Shyam Lal Poddar decided to grab the entire two decimals of

land illegally by practicing fraud and undue influence and as

such he prepared ante-dated forged document.

ii. It was the case of these defendants that on 03.07.2004 a

panchayati was held at Karmatanr in which the panch after 

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hearing both parties held equal share of both sets of defendants

and the original panchnama was given to Shyam Lal Poddar

and a photo copy was supplied to the defendant no. 2 Thakri

Devi. In the year 2008, once again the defendant Shayam Lal

Poddar tried to occupy the suit property and on being informed

to the police, a proceeding u/s 144 of Cr. P.C was started

between the defendants inter se, registered as Crl. Misc. Case

No. 145/2008 in which vide order dated 02.06.2008 the

proceeding was dropped with observation that it was a civil

dispute and the parties should knock at the door of civil court

for proper relief.

iii. It was also the case of these defendants that again in the month

of September, 2008, the defendant no.1 Shayam Lal Poddar

started a proceeding u/s 144 of Cr.P.C in which the then SDM

Jamtara was pleased to declare and confirm the possession of

Shyam Lal Poddar over the suit properties. Being aggrieved

and dissatisfied with the aforesaid order, the defendant no.2

Thakuri Devi and her son Kashi Nath Poddar preferred a

Criminal Revision before the Learned Sessions Judge, Jamtara

bearing Crl. Rev. Case no. 26/2008, in which vide order dated

02.01.2009 the learned revisional court was pleased to allow

the revision modifying the order of SDM, Jamtara and the

operative portion of order regarding finding of possession

given by SDM Jamtara was expunged.

6. Case of defendant No. 1(a)

A. Addition of Leelavati Devi, W/o of Defendant No. 1 as

defendant No. 1(a). - The records of the case reveal that upon

filing of written statement by defendant No. 1 who asserted that

the property belonged to his wife, the plaintiff filed a petition to

add her as a party which was allowed vide order dated

10.11.2009 and consequently, wife of defendant no. 1 was made

defendant No. 1(a) and thereafter she filed a separate written

statement.

2025: JHHC:16513

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B. The defendant no. 1(a) asserted that the suit was bad for nonjoinder of necessary parties, since all the heirs of Narsingh

Poddar had not been made party in this suit. It was also pleaded

that Narsingh Poddar had purchased the suit land in the year

1977 and not in the year 1997 as alleged by the plaintiff, and

constructed a tiled roof house on about 1 decimal of land and

started living there with the defendant no. 1(a), who used to

nurse and look him after in his old age. It was further pleaded

that her husband also assisted in managing the household of

Narsingh Poddar, but the other son and the son's family as well

as the daughters of Narsingh Poddar never cared for welfare and

needs. It was also her case that due to her continuous service to

her father-in-law, the latter developed special affection for her

and on 07.12.1995 he gifted the two decimals of purchased land

and the house standing thereon to her, which she accepted and

entered into possession on the same day. By such gift, Narsingh

Poddar was divested of his right in the land in question and

defendant no. 1(a) started possessing the same as of her own

right and still she was in possession thereof.

C. It was also case of this defendant that on 07.12.1995 Narsingh

Poddar had executed a Written Deed of Gift in her favour,

attested by Notary and supported by witnesses and also an

affidavit sworn by Narsingh Poddar himself. She further

asserted that when she was undertaking some construction work

on the suit land, the proforma defendants tried to stop

construction of the pucca house and septic latrine being made

by her and in that process, they also filed a case u/s 144 of

Cr.P.C for stopping construction, but failed to accomplish

success. The defendant no. 1(a) further averred that she had

acquired a prescriptive title to the entire two decimals of

purchased land of Narsingh Poddar and structures standing

thereon by remaining in continuous possession of the same 

2025: JHHC:16513

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adversely to Narsingh Poddar and subsequently his all the heirs

to their knowledge and knowledge of all other persons.

D. It was further pleaded by her that the sale of one decimal of

land alongwith pucca constructed house by the proforma

defendants in favour of the plaintiff was entirely illegal, void

and fraudulent and no title accrued to the plaintiff by virtue of

the fake sale deed. It was also case of this defendant that under

no circumstances the proforma defendants would sell half of the

properties of Narsingh Poddar, who had died leaving behind

five branches of sons and daughters and each of them had only

1/5th share therein and as such the proforma defendants who

represented only one son of Narsingh Poddar could not have

more than 1/5th share and their fake sale of half share of

Narsingh Poddar's properties did not confer any title to the

extent of half share and plaintiff could not have asked for any

decree for half share.

E. The defendant no. 1(a) further averred that the alleged sale deed

was replete with false averments. It was pleaded that the

plaintiff had brought the sale deed in question in existence with

the mala fide object of grabbing the suit land by his muscle

power being a dada of the locality, who also gained over the

proforma defendants.

7. On the basis of pleadings of the parties, the learned trial court

framed the following issues for consideration: -

(1) Is the suit as framed maintainable?

(2) Is there any cause of action for the suit?

(3) Is the suit bad for non-joinder of necessary

parties?

(4) Has the plaintiff right, title and interest over the

suit properties?

(5) Is the deed of gift executed by Narsingh Poddar

in favour of the wife of Shyam Poddar is valid

and effective?

(6) Are the plaintiffs entitled to the reliefs claimed?

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(7) Has Lilavati Devi acquired right, title and

interest on the basis of adverse possession

against Narsingh Poddar and others?

Findings of the trial Court

8. Before the learned trial Court, the plaintiff examined altogether

11 witnesses in support of his case. PW-1 Sukhdev Mandal, PW-2

Shankar Sao, PW-3 Md. Sultan, PW-4 Subeshwar Mandal, PW-5

Ghafoor Mian, PW-6 Pramod Kumar Sah, PW-7 Jai Prakash

Ambastha, PW-8 Dhananjay Biswas, PW-9 Mahendra Mandal, PW10 Sattar Mian @ Ahamad Hussan and PW-11 Pradeep Mandal. The

plaintiff also adduced some documents which were marked exhibits as

under:

(i) Deed of Sale dated 20.10.2008 - Ext. -1

(ii) Original Trace Map dated 20.10.2008 – Ext. -2

(iii) Signature of Dhananjay Biswas on the Sale Deed - Ext. 3

(iv) Signature of Mahendra Mandal on the Sale Deed–Ext.3/1

(v) Signature of Ahamad Hussain on the sale Deed – Ext. 3/2

(vi) Letter of direction for mutual oral partition of family -Ext- 4

(vii) Certified Copy of voter list of Shyam lal Poddar - Ext. -5

(viii) Certified Copy of Voter List of Lila Devi - Ext. -5/1

(ix) Certified Copy of order dated 02.01.2009 of Crl. Rev. No

26/2008 - Ext. 6

9. On behalf of the contesting defendant, seven witnesses namely

DW-1 Tulsi Das, DW-2 Tarni Poddar, DW-3 Shyam Lal Poddar

(defendant no. 1 himself), DW-4 Lilawati Devi, DW-5 Pancham @

Panchanand Poddar, DW-6 Baidyalal Turi and DW-7 Pawan Kumar

Poddar were examined. The defendant exhibited following

documents:

(i) Deed of gift dtd. 07.12.1995 – Ext. A

(ii) Signature of Lila Devi on the deed of gift – Ext. A/1

(iii) Signature of Narsingh Poddar on the deed of gift –

Ext. A/2

(iv) Affidavit of Narsingh Poddar sworn on 07.12.1995 –

Ext. B

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(v) Rent Receipt No. 533010 – Ext. C

(vi) Rent Receipt No. 1735101 – Ext. C/1

(vii) Rent Receipt No. 1939210 – Ext. C/2

10. The learned trial Court first considered issue no. (4) i.e. as to

whether the plaintiff had right, title and interest over the suit

properties. After considering the evidences, in particular deed of sale

executed on 20th October 2008 (exhibit- 1), the learned Court found

the exhibit-1 to be a valid piece of document showing transfer of the

suit land in favour of the plaintiff and thus creating right, title and

interest in his favour. The learned trial court recorded that the

registered sale deed was not specifically challenged by the contesting

defendants nor any counter claim was filed and on the strength of the

registered deed which was not challenged, the issue was decided in

favour of the plaintiff. The findings are as follows:-

“In the course of trial the deed of sale executed on 20th

October 2008 by Thakari Devi, Kashi Poddar and Meena

Devi have been proved as Ext.-1 without objection.

Although the contesting defendants have challenged the

execution of this deed in the course of trial, they have

admitted at the time of their cross-examination that they

have never challenged the same in any court of law nor

prayed for its cancellation. Besides, neither they have

alleged that the heirs of Moti Poddar had got no title to

the properties sold by them nor they have filed any

counter claim.

In view of the above the sale deed prove vide Ext. 1 is

found to be a valid piece of document showing transfer of

the suit land in favour of the plaintiff and thus creating

right, title and interest in his favour. Thus, this issue is

decided in favour of the plaintiff and against the

defendants.”

11. The issue no. 5 was also decided against the defendant no. 1

and 1(a) as the gift deed was an unregistered document. The findings

are as follows:-

“The Deed of Gift has been proved as Ext.A by the

defendant no.1. This document is an unregistered

instrument. It reflects that stamp for this deed was 

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purchased two months ago prior to its registration in

December 1995. DW4 Lilawati Devi has admitted in

para 13 of her cross-examination that the deed of gift

was prepared in registry office. Further para 23 of her

cross- examination shows that her father-in-law died in

the year 1998 and in para 24 that prior to that he was

bed-ridden for the last 5-6 years and was not in a

position to attend nature's call. This piece of evidence

creates physical impossibility regarding presence of the

executant of the deed proved vide Ext. A, and said to be

executed in the year 1995. The trace map annexed

thereto further creates suspicion and doubts regarding

the genuineness of this document. Needless to say that no

immovable property can be transferred through an

unregistered instrument.

In view of the above this issue is decided in

favour of the plaintiff and against the defendants.”

12. Thus, issue no. 5 was decided in favour of the plaintiff and

against the contesting defendants.

13. While deciding issue no. 7, the learned trial Court held as

under:

“As per para-12 of the written statement of defendant

Lilavati Devi she is in peaceful continuous possession of

the 2 decimals of land, but as per the plaintiff the death

of Narsingh Poddar had occurred in the year 1999,

which is slightly contracted by defendant no. 1 of para-9

of W.S. Be that as it may, in both the cases, which refutes

the claim of adverse position made by her from the year

1995. She herself has admitted in para-14, 16 and 17

about having no knowledge about the sating aside of

the order of 144 of Cr. P.C passed in her favour and

also about issuance of rent receipt and mutation of that

land. Besides the document proved vide Ext. 5 and Ext.

5/1 clearly establish that her husband and she are the

enrolled voters of village Posta, even till the year 2014.

In that view of matter the plea of adverse position

taken by her is found to be shattered. Needless to say

that it is established law that to claim adverse position

there must a denial of title of the owner and for a

possession to be adverse it has to be actual, open,

notorious, exclusive and continuous. In the instant

suit the possession of Lilavati is found to be neither

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against the true owner nor continuous.

 In view of these discussions this issue is decided in

favour of the plaintiff and against the defendants.”

14. With regard to issue no. 3 i.e., as to whether the suit was bad

for non-joinder of necessary parties, the learned trial Court held in

paragraph 16 of its judgment as under:

“16. Issue No. (3) i.e. “Is the suit bad for non- joinder of

necessary parties?” The contesting defendant Shaymlal

Poddar taken the plea that suit is bad for non-joinder of

necessary parties as all the heirs of Narsingh Poddar , the

original owner of the suit land has not been made party. He

has pleaded that Narshinhg Poddar had three daughters,

Amli Devi, Bomi Devi and Shanti Devi but the plaintiff had

deliberately omitted their names.

The other contesting defendant Lilavati Devi

has pleaded similarly in para-4 of her W.S that all the heirs

of Narsingh Poddar have not been made in the party in the

suit, although the W.S filed by her does not mention the

names of the heirs of Narsingh Poddar, in absence of

whom, the suit is bad for non-joinder.

On consideration of the pleading of the parties

and taking into consideration the facts of this suit, this court

finds that Leelavati Devi has already been made a party in

this suit vide order dtd 10/11/2009 and the pleading of the

defendant regarding the non- joinder of a few others i.e.,

the three daughters of Narsingh Poddar is not tenable,

since they are not necessary parties, this issues has become

redundant. Hence, it stands decided in favour of the

plaintiff.”

15. While deciding issue nos. 1, 2 and 6, the learned trial Court

held as under:

“17. Now the issue no. (2) i.e. “Is there any cause of

action for the suit?” is taken for discussion.

As per para 21 of the plaint the cause of action for the

suit arose on and from 25.01.2009, a Sunday, when the

defendant no. 1 refused the give vacant possession of the

suit properties to the plaintiff. Vide para-17 of the plaint the

plaintiff has alleged that on 25.01.2009 he had approached

the principal defendant Shyam Lal Poddar alongwith the

proforma defendant to give vacant possession of the suit 

2025: JHHC:16513

14

land and structure as per schedule but he flatly denied and

suggested him to move the competent court of law.

The plaintiff examined as PW1 has supported his

pleading in regard with this issue in para 13 of his

affidavited examination-in-chief which shows that there is

cause of action for the suit in his favour. Hence, this issue is

decided in favour of the plaintiff and against the

defendants.

18. Since the core issues have been decided in favour of the

plaintiff and against the defendants the remaining two

issues no. (1) and (6), which are related to maintainability

of the suit and entitlement of the reliefs claimed by the

plaintiff are decided in favour of the plaintiff and against

the defendants.”

16. After giving the aforesaid findings, the learned trial Court

decreed the suit in favour of the plaintiff and against the defendants.

The defendants were directed to give delivery of possession to the

plaintiff within 30 days failing which he was at liberty for recovery of

possession through the process of the court.

Findings of the 1st appellate Court

17. The contesting defendants were appellants before the learned 1

st

appellate Court. The learned appellate Court framed following points

for determination: -

“A. Whether the learned lower court has wrongly decided

the issue that plaintiff has got right, title and interest over

the suit property without considering the fact of all the legal

heirs of Late Narsingh Poddar and the fact of alleged

partition between Shyamlal Poddar and the legal heirs of

Motilal Poddar?

B. Whether the impugned judgment and decree of the

learned Trial Court are justified and it calls for any

interference?”

18. The learned 1

st appellate Court considered the aforesaid points

jointly as both were related to each other. After discussing the

arguments of the parties, the learned 1st appellate court recorded its

findings at paragraph 12 as under: -

“12. Both points are related with each other, hence, they

are taken jointly for discussion. I have perused the 

2025: JHHC:16513

15

pleadings and evidences available on record and

considered the submissions of learned counsels for the

parties. It is admitted fact that two decimals land from Plot

No. 1206 and 1206/2305 of Mouza Karmatanr was

purchased by one Narsingh Poddar, S/o Late Raghu

Poddar of village Posta. It is also admitted fact that said

Narsingh Poddar died in the year 1999 leaving behind the

legal heirs of his one son Motilal Poddar, who are

Proforma Defendants and another son Shyamlal Poddar,

who is Contesting Defendant and Appellant here. It

appears that the case of plaintiff is that the Proforma

Defendants, who are the legal heirs of said Motilal Poddar

were allotted the half share in the said purchased land of

Narsingh Poddar and they have sold the one decimal of

land to the plaintiff through registered Sale Deed No. 493

dated 20.10.2008. It is further case of plaintiff that after the

death of Narsingh Poddar, his son Shyamlal Poddar and

the legal heirs of the another son Motilal Poddar succeeded

the purchased portion and the said land was amicably

divided half and half by them in equal share and 1 decimals

of southern side land and structure was allotted to the legal

heirs of Moti Poddar and in this respect, Memorandum of

Partition was created on 20.11.2005, which has been

proved as Ext. 4. Further case of plaintiff is that the legal

heirs of Moti Poddar are the Proforma Defendants and they

have sold the said 1 decimal land and structure thereon

allotted to them in Southern side to the plaintiff through

registered Sale Deed and the said Sale Deed has not been

challenged till date by the contesting defendants and thus

plaintiff has got right and title over the suit land. On the

other hand, contesting Defendant Shyamlal Poddar has

pleaded that the entire two decimals lands purchased by his

father, has been gifted to his wife Lilabati Devi by his father

in the year 1995 through a Notary Affidavit and he and his

wife Lilabati Devi are in possession over the suit land and

his wife Lilabati Devi has perfected her title over the suit

land by way of adverse possession also. He has further

pleaded that the plaintiff has suppressed the fact by not

impleading the three daughters of the said Narsingh

Poddar as the two sons of Narsingh Poddar exclusively

never succeeded to the purchased portion of the land and

these three daughters were necessary party and these

daughters were the legal heirs of Narsingh Poddar but

plaintiff has shown that the alleged plot was divided in 

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16

equal share between the heirs of Motilal Poddar and Shyam

Poddar. Contesting defendants have pleaded that the

alleged partition document is forged and spurious and

proforma defendants have no right to sell 1 decimal land to

plaintiff and the alleged Sale Deed does not confer the title

to the plaintiff, as the contesting defendants, who are

husband and wife and the legal heirs of Narsingh Poddar,

are in possession over the same and the said contesting

defendant Lilabati Devi has obtained the suit land by way

of Gift Deed and also perfected her title by way of adverse

possession.

In view of pleadings of both the sides and evidences, it is

apparent that plaintiff/respondent has purchased one

decimal land of the aforesaid Plot No. 1206 and

1206/2305 of Mouza Karmatanr through registered Sale

Deed (Ext. 1) from the legal heirs of Motilal Poddar, the

son of Narsingh Poddar. The said legal heirs of Motilal

Poddar have been made party as proforma Defendant and

they have also filed their written statement, in which they

have admitted the execution of Sale Deed (Ext. 1) of the suit

property in favour of plaintiff and they have not objected

the claim of plaintiff in their written statement. The plaintiff

and his witnesses have also proved the execution of Sale

Deed of the suit property in favour of plaintiff. The plaintiff

has brought a document as “Parvarik Apsi Mokhik

Batwara Ka Nideshan Patra” between the legal heirs of

Moti Poddar and Shyam Poddar, which have been proved

as Ext. 4. Although it does not bear the signature of scribe

but P.W. 11 Pradeep Mandal has stated that his father had

written the said Batwara Patra and P.W.6 has also proved

the creation of the said Batwara Patra and even the

Contesting Defendant Shyamlal Poddar, who has

examined himself as D.W.3, has also admitted in para 31

that his paternal house is in village Posta and during the

lifetime of Narsingh Poddar, he and his brother Motilal

got separated and the entire properties were divided by his

father in two equal shares. It further appears that

contesting Defendant Shyamlal Poddar has not

challenged his signature over the alleged Deed of

Partition. It further appears that contesting defendants

Shyamlal Poddar and his wife have claimed the entire two

decimals of lands, purchased by the said Narsingh Poddar,

on the basis of a gift deed alleged to be sworn before

Notary. These contesting defendant Shyamlal Poddar has 

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17

admitted in para 5 of his W.S. that the daughters of

Narsingh Poddar namely Amli Devi died on 0.10.2008 and

Bhumi Devi died on or about 2000, which shows that they

were died prior to filing of this suit and these contesting

defendants have nowhere stated that these daughters have

ever claimed any right in the suit land rather these

defendants have claimed the said two decimals of lands

including suit land to be their own. The plaintiff has

purchased 1 decimal land and since the contesting

defendants had obstructed in taking possession, he has filed

the suit against contesting defendants for declaration of his

right, title and recovery of possession. Certainly it is a

declaratory suit and not a Partition Suit and further it

appears that daughters of said Narsingh Poddar or their

heirs have never claimed any title and even contesting

defendants have examined D.W. 5, who is the son of alleged

daughter Bhumi Devi and in spite of having knowledge of

the suit,, he has not claimed any right, title over the suit

land rather he has stated that his maternal uncle Shyamal

Poddar and his wife had obtained the suit land on the basis

of gift and by way of adverse possession. It appears that the

contesting defendants have claimed the suit land on the

basis of unregistered Deed of Gift alleged to be executed by

Narsingh Poddar in the year 1995 and the said Lilavati

Devi entered into possession and continued to reside there

but the said Deed of Gift, which has been marked as Ext. A,

is an unregistered instrument and on perusal it appears that

stamp for this deed was purchased two months prior to its

alleged creation on 07.12.1995. At the same time, it also

cannot be denied that the said Narsingh Poddar was

bedridden for the last 5-6 years and he was not in position

to attend nature's call and he died in the year 1998, hence,

his physical presence at the time of executing the said Deed,

creates serious doubt about the execution and preparation

of Ext. A and moreover this is an unregistered instrument,

which cannot create right and title in favour of contesting

defendants. Further the alternative plea of adverse

possession by contesting defendant Lilavati Devi is also not

tenable, as in order to establish the claim of adverse

possession, there must be a denial of title of the owner and

for a possession to be adverse, it has to be actual, open,

notorious, exclusive and continuous but here in this case, it

is admitted fact that the Proforma Defendants contested

several cases u/s 144 and 107 Cr. P.C. with contesting 

2025: JHHC:16513

18

defendant in the year 2008 for the suit properties, which

clearly reveal that Defendant Lilavati Devi had no peaceful

continuous possession and it cannot be said in the facts and

circumstances of the case that she has perfected her title

over the suit land by way of adverse possession. Further it

also appears that contesting defendant has pleaded the

ownership over suit properties by way of alleged Gift Deed

as well as of adverse possession. The plea of ownership and

acquisition of rights by adverse possession are mutually

destructive and are inconsistent with each other and the

Defendants/Appellants have not established their defence of

ownership as well as acquisition of right by way of adverse

possession with support of cogent and reliable evidences.

On the other hand, plaintiff/respondent has proved that he

had acquired the suit land by way of registered Deed (Ext.

1) executed by the legal heirs of Motilal Poddar and his

registered Deed of Sale regarding suit properties is still in

existence and thus he holds a better title over the suit

land than the contesting defendants and the learned

lower court has rightly appreciated all the issues and has

rightly decreed the suit of plaintiff directing the contesting

defendants to give delivery of possession to the plaintiff and

considering entire facts and circumstances of the case, I do

not find any illegally and infirmity in the impugned

judgment and decree and the same are liable to be

sustained.”

Arguments on behalf of the appellant (defendant no.1)

19. The learned counsel for the appellant has placed Exhibit – 4 and

submitted that Exhibit – 4 is the family settlement as claimed by the

plaintiff and as per Exhibit – 4 which is dated 20.11.2005, Exhibit-4 is

between wife, son and daughter of late Moti Poddar on the one hand

and Shyam Poddar on the other. He has submitted that Moti Poddar

and Shyam Poddar were the sons of Narsingh Poddar, in whose name

the property was standing. He has further submitted that the document

dated 20.11.2005 (exhibit-4) reveals that there was a settlement

between the legal heirs of Moti Poddar on one hand and Shyam

Poddar on the other and the said document reveals that the document

by itself is a document of partition and not a memorandum of

partition. He has further submitted that the partition deed [the so-

2025: JHHC:16513

19

called family settlement] was compulsorily registrable and

consequently the same could not have been admitted in evidence. He

has further submitted that on account of non-registration of the

document of family settlement which was essentially a deed of

partition between the legal heirs of Moti Poddar and Shyam Poddar,

the first substantial question of law is fit to be answered in favour of

the appellant and against the respondents.

20. He has further submitted that in the said partition, the daughters

of Narsingh Poddar have not been made party, and therefore, on

account of non-joinder of the daughters to the deed of partition, the 2nd

substantial question of law is also fit to be answered in favour of the

appellant. He has further submitted that if these two issues are decided

in favour of the appellant, then the natural consequence would be the

sale deed executed by the legal heirs of Moti Poddar in favour of the

plaintiff in the year 2008 would be null and void and consequently the

plaintiff cannot claim any right, title, interest and possession with

respect to the property. He has submitted that there is no need to

separately challenge the said sale deed and adverse inference has been

drawn by the learned courts for not challenging the said sale deed.

21. He further referred to the impugned judgements and submitted

that the contesting defendants were claiming the property by referring

to a gift deed executed by Narsingh Poddar during his lifetime in

favour of wife of Shyam Poddar but the said gift deed has been

disbelieved by both the courts and there is no substantial question of

law in connection with the gift deed, but irrespective of the gift deed,

Shyam Poddar, the defendant no.1, was legal heir and successor of the

property belonging to Narsingh Poddar and the daughters having not

been made party to the family arrangement or settlement, the case of

the plaintiff based on the sale deed executed in 2008 by the legal heirs

and successors of Moti Poddar is of no consequence. He has relied

upon the judgement passed by Hon’ble Supreme Court reported in

(2015) 16 SCC 787 (Yellapu Uma Maheshwari and Anr. Vs. Buddha

Jagadheeswararao and Ors.) (paragraph 12.2) and section 49 of the 

2025: JHHC:16513

20

Registration Act, 1908 which deals with the effect of non-registration

of documents and also the judgement reported in (2018) 15 SCC 130

(Sita Ram Bhama Vs. Ramvatar Bhama) (paragraph 14) to submit

that the document of partition was inadmissible in evidence and could

be looked into for collateral purpose.

Arguments of the Respondents

22. The learned counsel for the respondent - plaintiff has submitted

that on the face of Exhibit 4, it is relating to oral partition and the

decision arrived thereto and it is a recital of the oral partition which

has already taken place, and therefore, it was not compulsorily

registrable. He submits that both the courts have rightly referred to

Exhibit 4. The learned counsel has further submitted that as per the

written statement filed by the defendant, who is the appellant before

this Court, his specific case was that the property was belonging to his

wife namely, defendant no. 1(a) and he claimed the property in favour

of defendant no. 1(a) on the basis of a gift deed which was disbelieved

by both the courts and no substantial question of law in that

connection has been framed, and therefore, finding in connection with

the gift deed has already become final. He has submitted that the

plaintiff was claiming the property on the basis of registered sale deed

of the year 2008 which was never challenged by defendant no. 1(a) or

any of the defendants and the defendants were claiming the property

by stating that the property belongs to defendant no. 1(a) by virtue of

gift deed. He has also submitted that the case of the defendants as set

up in the written statement has been disbelieved.

23. The learned counsel has submitted that the present suit is not

the partition suit so as to ensure that all the legal heirs and successors

of Narsingh Poddar were required to be made party and the plaintiff

had only claimed a declaratory suit on the basis of a registered sale

deed which was executed by the legal heirs of Moti Poddar, who

claimed to have exclusive possession over the property on the basis of

oral partition recorded duly on 20.11.2005 and otherwise also they had

the right over the property and therefore it cannot be said that the sale 

2025: JHHC:16513

21

deed was null and void. Had the sale deed been challenged, then under

such circumstances, the legality and validity of Exhibit - 4 was

required to be examined and under such circumstances, the right of the

daughters also could have been adjudicated upon, but in a case where

the sale deed has not been challenged, there is no question of

adjudication of the right of the daughters and the sale deed by no

stretch of imagination can be said to be void ab initio.

24. The learned counsel has relied upon the judgement passed by

Hon’ble Supreme Court reported in 1963 SCC Online SC 197 (Tek

Bahadur Bhujil Vs. Debt Singh Bhujil and Ors.) (paragraph 13) to

submit that family arrangement can be arrived orally and its terms

may be put in writing and such a written instrument will not be

compulsorily registrable under Section 17 of the Registration Act and

therefore it is submitted that reliance on Exhibit 4 was not hit by

section 49 of the Registration Act. The learned counsel has also relied

upon the judgement passed by the Hon’ble Supreme Court reported in

(2020) 9 SCC 706 (Ravinder Kaur Grewal and Ors. Vs. Manjit Kaur

and Ors.) (paragraph 17) and submitted that this judgement stands on

similar facts as that of the facts involved in the present case.

Findings of this Court

25. The suit was filed for declaration of right, title and interest with

respect to Schedule-A property on the strength of deed of sale dated

20.10.2008 (Exhibit-1) executed by the proforma defendants in favour

of the plaintiff. The proforma defendants were representing the legal

heirs and successors of the Moti Poddar S/o Late Narsingh Poddar and

the principal defendants/contesting defendants were defendant no. 1

and 1(a) i.e., Shyam Poddar, son of Narsingh Poddar and the wife of

Shyam Poddar respectively.

26. The specific case of the plaintiff was that Narsingh Poddar had

purchased two decimals of land by registered sale deed. He died in the

year 1999 leaving behind Shyam Poddar and heirs of late Moti Poddar

and after the death of Narsingh Poddar, Shyam Poddar and legal heirs 

2025: JHHC:16513

22

and successors of Moti Poddar remained in possession of the aforesaid

property of two decimals but Shyam Poddar started creating some

disturbance and the two decimals of property was divided half and

half ; one decimal towards the north was allotted to Shyam Poddar and

remaining one decimal towards the south was allotted to legal heirs

and successors of Moti Poddar and a memorandum of partition to that

effect was created for future reference on 20.11.2005 (exhibit-4).

Thereafter the legal heirs and successors of Moti Poddar started living

in another place and Shyam Poddar tried to grab the entire property

and the legal heirs and successors of Moti Poddar were unable to meet

the litigation expenses and therefore they sold their 1 decimal share to

the plaintiff vide registered deed dated 20.10.2008 (exhibit-1) and

consequently the plaintiff became the rightful owner of the suit

property comprising of 1 decimal. The cause of action arose on

25.01.2009 when the defendant no. 1 namely, Shyam Poddar

(appellant herein) refused to hand over the property to the plaintiff.

27. The defendant no. 1 opposed the prayer and asserted that the

owner of the property is his wife as Narsingh Poddar had gifted the

property to the wife of defendant no. 1 and was in peaceful possession

by constructing a pucca house. It was his further case that Narsingh

Poddar did not die in 1999 but he died on 26.05.1998 leaving behind

his two sons and three daughters. It was asserted that the sale deed

dated 20.10.2008 executed by the proforma defendants in favour of

the plaintiff was an illegal document. It was also his case that

Narsingh Poddar had three daughters namely Amli Devi, Bhumi Devi

and Shanti Devi out of them Amli Devi died on 01.10.2008 leaving

behind her five sons whose name was mentioned and Bhumi Devi

died sometimes in the year 2000 leaving behind his six sons/daughters

whose name was also mentioned and that Shanti Devi was still alive

but the plaintiff deliberately omitted to include her name and the name

of others and had furnished incorrect genealogy.

28. Consequently, defendant no. 1(a) was added as defendant no.

1(a) who claimed the suit property by virtue of a deed of gift said to 

2025: JHHC:16513

23

have been executed by Narsingh Poddar on 07.12.1995 which was an

un-registered document and was certified by the Notary and attested

by the witnesses. The principal defendant also claimed that they have

acquired indefeasible prescriptive title to the entire two decimal of

land by remaining in peaceful possession for more than 12 years

beginning from 07.12.1995 adversely to Narsingh Poddar and his

heirs.

29. The proforma defendants who are the legal heirs and successors

of Moti Poddar and were arrayed as defendant nos. 2,3,4 and 5

asserted in their written statement that on 03.07.2004 a Panchayati

was held in which Panch after hearing both the parties held equal

share of both sets of defendants and the original punchnama was given

to defendant no. 1 and a photocopy was supplied to the defendant no.

2 Thakri Devi; in the year 2008 once again the defendant no. 1 tried to

occupy the suit property for which a proceeding under Section 144 of

Cr.P.C. was also initiated and by order dated 02.06.2008, the

proceeding was dropped with an observation that it was a civil

dispute. The defendant no. 1 again started a proceeding under Section

144 Cr.P.C. in which the possession of the defendant no. 1 was

confirmed against which a Criminal Revision was preferred and by

order dated 02.01.2009 the operative portion regarding finding of

possession given by SDJM, Jamtara was expunged.

30. The learned Trial Court while deciding issue no. 5 with regard

to claim of gift by Narsingh Poddar in favour of defendant no. 1(a)

decided the issue in favour of the plaintiff and against the contesting

defendants on the ground that gift deed (Ext. A) was an un-registered

document and on the basis of materials on record it was held that it

was physically impossible for the executant of the gift deed i.e.

Narsingh Poddar to execute the same in the year 1995 as he was bed

ridden. The gift deed was rejected as suspicious document. It was also

observed that no immovable property can be transferred through an

un-registered document. The said finding with regard to the gift deed

has attained finality. 

2025: JHHC:16513

24

31. It further transpires that before the learned Trial Court a specific

argument on behalf of the contesting defendants was advanced that the

genealogy given by the plaintiff was not correct as it showed only two

sons but the plaintiff had admitted during his cross examination who

was examined as P.W. 1 that Narsingh Poddar had three daughters

also. However, the plea of non-joinder of necessary party was rejected

by the learned trial court by considering the pleadings and by

observing that defendant no. 1(a) was already made party in the

proceedings. The learned 1st appellate court also rejected the plea of

non-joinder of daughters/their legal heirs as necessary party by

observing that two daughters died prior to filing of the suit and the

contesting defendants had nowhere stated that those daughters had

ever claimed any portion of the suit property. The learned court also

observed that the suit was for a declaratory decree and not a partition

suit and that one of the defendant witnesses D.W-1 was son of one of

the daughters, but he did not claim any right, title or interest over the

suit property and had supported the case of the defendant no.1 and

1(a). This Court finds that the plea of non-joinder of daughters/their

legal heirs as necessary party was rejected without considering the fact

that the entire claim of the plaintiff was rooted in the memorandum of

partition (exhibit-4) followed by registered sale deed of the year 2008

(exhibit-1) executed by the proforma defendants in favour of the

plaintiff and in the memorandum of partition (exhibit-4) also the

daughters/their legal heirs were not parties/signatories.

32. An argument was also advanced by the contesting defendants

while assailing the document of partition (Exhibit-4) that it was an

illegal and inadmissible document which was not proved by the

plaintiff, rather it was filed by Pradeep Mandal P.W. 11. The

admissibility of the said document was seriously disputed. It was also

asserted that the plaintiff never came in possession of the property as

the vendors of the plaintiff (i.e. proforma defendants) did not put the

plaintiff in possession of the suit property, rather the suit property was

in possession of the contesting defendants on which they have 

2025: JHHC:16513

25

constructed a house. It was also argued that the contesting defendants

and also the proforma defendants were the legal heirs of the recorded

holder i.e. Narsingh Poddar and therefore in order to claim possession

through the process of the court, the plaintiff must prove that they

have a better title. It was also asserted that the only issue which was to

be decided was whether there was a lawful and valid partition amongst

the legal heirs and successors of Narsingh Poddar; whether the

proforma defendants i.e. legal heirs and successors of Late Moti

Poddar came in possession of the suit premises on the basis of

partition and whether execution of sale deed by proforma defendants

was lawful.

33. The learned Trial Court while considering the point as to

whether the plaintiff had right, title and interest over the suit

properties on the strength of Exhibit-1 [i.e. the Sale deed executed by

the legal heirs and successors of Moti Poddar in favour of the plaintiff

on 20.10.2008] observed that the same was marked as exhibit-1

without objection and the contesting defendants never challenged the

execution of this deed nor the deed was challenged in any court of law

nor any prayer was made for its cancellation nor they alleged that the

legal heirs of Moti Poddar had no title to the properties sold by them

nor they had filed any counter claim and consequently, the learned

trial court decided the issue by holding that the sale deed [exhibit-1]

was a valid document showing transfer of suit land in favour of

plaintiff and thus creating right, title and interest in his favour. The

learned Trial Court ultimately held that the plaintiff was entitled to get

vacant possession of the suit property.

34. The learned Trial Court did not touch upon the core issue as to

whether the legal heirs and successors of Moti Poddar acquired any

exclusive right, title and interest over the suit property by virtue of

partition read with the so called memorandum of partition (exhibit-4)

although the entire case of the plaintiff was based on the averment that

there was a partition between Shyam Poddar and legal heirs of Moti

Poddar and consequently the legal heirs of Moti Poddar acquired title 

2025: JHHC:16513

26

over the suit property which was sold to the plaintiff by registered

deed in the year 2008 (exhibit-1) .

35. So far as the 1

st substantial question of law is concerned, upon

perusal of Exhibit-4, this court finds that admittedly the same is an unregistered document. The parties whose names have been mentioned

in Exhibit-4 dated 20.11.2005 are wife of Moti Poddar, his sons and

daughters in first part and Shyam Poddar in the second part. Exhibit-4

refers to some compromise between the parties on 20.11.2005 and the

terms of compromise has been mentioned in exhibit-4. As per the

terms of compromise, the property belonged to Narsingh Poddar; one

of the sons of Narsingh Poddar namely Moti Poddar had suddenly

expired; as long as Narsingh Poddar was alive, the legal heirs of

Narsingh Poddar were jointly possessing the property but after his

death there was dispute in the family and consequently both, Shyam

Poddar and legal heirs and successors of Moti Poddar decided to

divide the property equally and one decimal towards north was given

to the 2nd party and one decimal towards south was given to the 1st

party; Wife of Moti Poddar could sell the property allotted to the share

of late Moti Poddar.

36. The memorandum of partition does not give any detail of the

date of previous partition nor does it refer to any separate possession

with respect to the share of each brother. This is over and above the

fact that the said document refers to a compromise between the parties

which was arrived on 20.11.2005 and the document (exhibit-4) was to

give effect to the said compromise. Thus, on perusal of Exhibit-4

dated 20.11.2005, this Court finds that the said document by itself is

dividing the share between Shyam Poddar on one hand and legal heirs

and successors of Moti Poddar on the other hand through a

compromise recorded in the document of partition which was said to

be arrived at on 20.11.2005.

37. Considering the nature of Exhibit-4, this court is of the

considered view that the same was compulsorily registrable and no

reliance can be placed on Exhibit-4 to give exclusive title of the suit 

2025: JHHC:16513

27

property to the legal heirs of Moti Poddar so as to enable them to

transfer exclusive title of their share of property to the plaintiff.

Admittedly, the vendors of the plaintiff were not in possession of the

property and consequently plaintiff was never handed over the

possession of the property by his vendors. There is no evidence much

less any document showing mutation with respect to the suit property

showing the suit property in exclusive possession of legal heirs of

Moti Poddar arising out of any partition. The sheet anchor of the claim

of the plaintiff was the partition between Shyam Poddar and legal

heirs of Moti Poddar. Exhibit-4 being an unregistered document could

not have been relied upon.

38. In the judgment passed by the Hon'ble Supreme Court in the

case of “Kale Vs. Direction of Consolidation” reported in (1976) 3

SCC 119, the proposition with regard to family settlement through a

memorandum and its necessity of registration has been settled and the

proposition has been laid down in paragraphs 10 and 11 of the said

judgment. In another judgment passed by the Hon'ble Supreme Court

in the case of “Yellapu Uma Maheswari Vs. Buddha

Jagadheeswararao” reported in (2015) 16 SCC 787, it was held that

the nomenclature given to a document is not decisive factor but the

nature and substance of the transaction has to be determined with

reference to the terms of the document and admissibility of a

document is entirely dependent upon the recitals contained in that

document, but not on the basis of the pleadings set-up by the party

who seeks to introduce the document in question. In the said case,

after holding that the document involved in the case was inadmissible

for want of registration, the Court proceeded to consider the question

as to whether the document could be used for any collateral purpose

and the Court accepted the submission of the appellant of that case

that the document can be looked into for collateral purpose provided

the appellant – defendant paid the stamp duty together with penalty

and got the document impounded. 

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28

39. Aforesaid two judgments have been followed by the Hon'ble

Supreme Court in the judgment reported in (2018) 15 SCC 130 (Sita

Ram Bhama Vs. Ramvatar Bhama) wherein the foundational fact

was that the plaintiff and the respondent were real brothers and their

father decided to divide his self-acquired movable and immovable

property between the plaintiff and the defendant. However, the father

did not execute any settlement deed. The father died and thereafter the

plaintiff and the defendant recorded a memorandum of settlement as

decided by their father which was signed by the mother of the parties

and also two sisters had signed as witness. However, a suit was filed

seeking partition of the property and the defendant filed a petition

under Order VII Rule 11 of Code of Civil Procedure taking the plea

that during the lifetime of father, the plaintiff and the defendant had

partitioned the property and southern portion came in the share of the

plaintiff and the northern portion came in the share of the defendant

and in confirmation of the earlier partition the family settlement was

executed which was signed by the plaintiff and the defendant along

with both the sisters and the mother. Thus, it was pleaded that there

was no cause of action to file the partition suit. The trial court allowed

the said petition filed under Order VII Rule 11 of CPC and dismissed

the suit for want of cause of action. Subsequently, another civil suit

was filed by the plaintiff claiming that after dismissal of the earlier

suit of the plaintiff, the defendant broke open the lock of the house

and took possession of the house. The plaintiff prayed for decree of

possession against the defendant. In the suit, the plaintiff filed the

document evidencing family settlement which was claimed by the

plaintiff as a memorandum of settlement. An application was filed by

the defendant under Order 13 Rule 3 of CPC and Article 45 and

section 35 of the Stamp Act and sections 17 and 49 of the Registration

Act, claiming that the memorandum of partition being not a registered

document and not being properly stamped, was not admissible in

evidence. The trial court allowed the application of the defendant

holding that the document of family settlement was not admissible 

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29

being inadequately stamped and not registered. The judgment of the

trial court was upheld by the High Court. The High Court also took

the view that so-called family settlement took away the share of the

sisters and the mother, therefore, the same was compulsorily

registrable. The plaintiff, being aggrieved by the judgment, was in

appeal before the Hon'ble Supreme Court.

40. In paragraph 10 of the judgment, the Hon'ble Supreme Court

observed that the only question needed consideration was as to

whether the document of family settlement could have been accepted

by the trial court in evidence or the trial court had rightly held that

the said document was inadmissible. The Hon'ble Supreme Court

observed that neither the plaintiff nor the defendant had any share in

the property on the date when it was said to have been partitioned by

their father who ultimately died and after his death, the plaintiff, the

defendant and their mother as well as the sisters became the legal heirs

under Hindu Succession Act, 1956 and they inherited the property as

Class-I heir. The document divided the entire property between the

plaintiff and the defendant which was also claimed to have been

signed by their mother as well as sisters. The Hon'ble Supreme Court

observed that there was relinquishment of rights of other heirs of the

property, hence the learned courts were right in their conclusion that

there being relinquishment, the document was compulsorily

registrable under section 17 of the Registration Act. In this context,

the Hon'ble Supreme Court in paragraph 11 of its judgment has

referred to the judgment passed in the case of Kale Vs. Direction of

Consolidation (Supra) and has observed as under:

“11. Pertaining to family settlement, a memorandum of family

settlement and its necessity of registration, the law has been

settled by this Court. It is sufficient to refer to the judgment of

this Court in Kale v. Director of Consolidation. The

propositions with regard to family settlement, its registration

were laid down by this Court in paras 10 and 11:

“10. In other words to put the binding effect and the

essentials of a family settlement in a concretised form, 

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30

the matter may be reduced into the form of the

following propositions:

(1) The family settlement must be a bona fide one so as

to resolve family disputes and rival claims by a fair and

equitable division or allotment of properties between

the various members of the family;

(2) The said settlement must be voluntary and should

not be induced by fraud, coercion or undue influence;

(3) The family arrangement may be even oral in which

case no registration is necessary;

(4) It is well settled that registration would be

necessary only if the terms of the family arrangement

are reduced into writing. Here also, a distinction should

be made between a document containing the terms and

recitals of a family arrangement made under the

document and a mere memorandum prepared after the

family arrangement had already been made either for

the purpose of the record or for information of the court

for making necessary mutation. In such a case the

memorandum itself does not create or extinguish any

rights in immovable properties and therefore does not

fall within the mischief of Section 17(2) of the

Registration Act and is, therefore, not compulsorily

registrable;

(5) The members who may be parties to the family

arrangement must have some antecedent title, claim or

interest even a possible claim in the property which is

acknowledged by the parties to the settlement. Even if

one of the parties to the settlement has no title but

under the arrangement the other party relinquishes all

its claims or titles in favour of such a person and

acknowledges him to be the sole owner, then the

antecedent title must be assumed and the family

arrangement will be upheld and the courts will find no

difficulty in giving assent to the same;

(6) Even if bona fide disputes, present or possible,

which may not involve legal claims are settled by a

bona fide family arrangement which is fair and

equitable the family arrangement is final and binding

on the parties to the settlement.

11. The principles indicated above have been clearly

enunciated and adroitly adumbrated in a long course of

decisions of this Court as also those of the Privy 

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31

Council and other High Courts, which we shall discuss

presently.” (emphasis in original)

41. The Hon'ble Supreme Court further went on to examine as to

whether the document being unstamped, could be accepted in

evidence for collateral purpose. In that context, the Hon'ble apex

Court referred to the judgment passed in the case of Yellapu Uma

Maheswari (Supra) wherein a reference was made to the Larger

Bench judgment of Hon'ble Andhra Pradesh High Court in the case of

“Chinnappareddigari Peda Mutyala Reddy Vs. Chinnappareddigari

Venkata Reddy” reported in AIR 1969 AP 242 wherein it was held

that whole process of partition contemplates 3 phases i.e., severancy of

status, division of joint property by metes and bounds and nature of

possession of various shares and it was held that in a suit for partition,

an unregistered document can be relied upon for collateral purposes

i.e. severancy of title, nature of possession of various shares but not

for the primary purpose i.e., division of joint properties by metes and

bounds. As recorded by the Hon'ble Supreme Court, the Hon’ble

Andhra Pradesh High Court further held that an unstamped instrument

was not admissible in evidence even for collateral purpose, until the

same is impounded. Paragraph 14 of the aforesaid judgment in the

case of Sita Ram Bhama (Supra) is quoted as under:

“14. After holding the said documents as inadmissible, this

Court in Yellapu Uma Maheswari case further proceeded to

consider the question as to whether the documents B-21 and B22 can be used for any collateral purpose. In the above context,

the Court accepted the submission of the appellant that the

documents can be looked into for collateral purpose provided

the appellant-defendant to pay the stamp duty together with

penalty and get the document impounded. In paras 16 and 17,

the following has been laid down: (SCC p. 794)

“16. Then the next question that falls for consideration

is whether these can be used for any collateral purpose.

The larger Bench of the Andhra Pradesh High Court in

Chinnappareddigari Peda Mutyala Reddy v.

Chinnappareddigari Venkata Reddy has held that the

whole process of partition contemplates three phases

i.e. severancy of status, division of joint property by 

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32

metes and bounds and nature of possession of various

shares. In a suit for partition, an unregistered document

can be relied upon for collateral purpose i.e. severancy

of title, nature of possession of various shares but not

for the primary purpose i.e. division of joint properties

by metes and bounds. An unstamped instrument is not

admissible in evidence even for collateral purpose, until

the same is impounded. Hence, if the appellantdefendant want to mark these documents for collateral

purpose it is open for them to pay the stamp duty

together with penalty and get the document impounded

and the trial court is at liberty to mark Exts. B-21 and

B-22 for collateral purpose subject to proof and

relevance.

17. Accordingly, the civil appeal is partly allowed

holding that Exts. B-21 and B-22 are admissible in

evidence for collateral purpose subject to payment of

stamp duty, penalty, proof and relevancy.”

42. Having gone through the aforesaid judgment and considering

the substantial questions of law involved in this case, this Court has

gone through the Exhibit- 4 which has been termed as the

memorandum of family settlement. The perusal of exhibit-4 clearly

reveals that the same was entered into between the legal heirs and

successors of Moti Poddar, son of Late Narsingh Poddar on the one

hand and Shyam Poddar, son of Late Narsingh Poddar on the other,

being the 2nd party. This Court finds that the daughters of Late

Narsingh Poddar and/or their legal heirs have been completely

excluded. They have neither signed as witness nor they are party to the

memorandum of settlement nor the genealogy of Late Narsingh

Poddar has been completely mentioned. The memorandum of partition

(exhibit-4) dated 20.11.2005 is based on compromise entered on

20.11.2005 itself and it incorporates the terms and conditions of

compromise and the said compromise completely excludes the

daughters of the family, although the property was said to have been

acquired by Late Narsingh Poddar -the common ancestor. On the date

of memorandum of partition, the amendment to Hindu Succession Act

had come into force and therefore, the daughters of the family could 

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33

not have been excluded. The family settlement does not reflect

relinquishment of any right by the three daughters/their legal heirs

although they were the necessary party. Merely because the daughters

of the family have not lodged any claim with respect to the property,

that by itself will not validate the memorandum of partition (exhibit-4)

dated 20.11.2005. Further, memorandum of partition (exhibit-4) dated

20.11.2005 by itself is recording the terms of compromise dated

20.11.2005 and through this document only, the property is sought to

be partitioned between the legal heirs and successors of Moti Poddar

on the one hand and Shyam Poddar on the other. Exhibit- 4 is not a

memorandum of earlier partition. Accordingly, this court is of the

considered view that exhibit-4 is not admissible in evidence for want

of registration.

43. This Court finds that both the learned courts have not at all

considered the contents, true impact and import of so-called

memorandum of partition (exhibit-4) dated 20.11.2005 and the learned

courts have also not considered the consequence of its non-registration

and non-inclusion of the daughters of the family in the said

memorandum of partition.

44. So far as 2

nd substantial question of law is concerned,

admittedly none of the daughters/their legal heirs were party to the socalled memorandum of partition (exhibit-4) dated 20.11.2005 which

was recording the terms of compromise dated 20.11.2005 entered into

between Shyam Poddar and legal heirs and successors of Moti Poddar

without including the daughters of Narsingh Poddar – the common

ancestor/their legal heirs. Moreover, the compromise as recorded in

exhibit-4 is dated 20.11.2005 and by this time the amendment in

Hindu Succession Act, dated 09.11.2005 giving coparcenary status to

the daughters of the family had come into force and therefore the

Exhibit-4/compromise having not been joined by other daughters of

the family cannot be said to be a document of recording partition by

metes and bounds nor exhibit-4 can be said to be memorandum of

partition amongst the family members of Narsingh Poddar-the 

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34

common ancestor . The finding of the learned 1st appellate court that

the daughters have not made any claim over the property by itself is

perverse, inasmuch as, out of the 3 daughters, 2 daughters had expired

prior to the so-called memorandum of partition (exhibit-4) and one

daughter was still alive but daughters/her legal heirs were neither

party to the so-called memorandum of partition (exhibit-4) nor party

to the suit. Examination of the son of one of the daughters Bhumi

Devi as D.W. 5 who had not claimed any right and title over the suit

property, but stated that his maternal uncle Shyam Poddar and his wife

had obtained the suit land on the basis of gift and by way of adverse

possession is not sufficient to conclude that the daughters/their legal

heirs have given up their claim over the suit property. The learned

Court recorded that the contesting defendants had nowhere stated that

daughters had ever claimed any right in the suit land, rather the

defendants claimed that the entire land of 2 decimals which included

the suit land of 1 decimal was their property on the basis of gift. Such

finding is also perverse, inasmuch as, it were the daughters/their legal

heirs who could have come forward, if made party to exhibit-4 or to

the suit, to state as to whether they had relinquished their rights over

the property and merely because contesting defendants have not made

any objection on this point, the same has no bearing in the claim/rights

of daughters/their legal heirs.

45. As a consequence of the aforesaid findings, the substantial

questions of law are answered as follows: -

A. With respect to the 1st substantial question of law, it is held that

exhibit- 4 was effecting partition and was compulsorily

registrable as per sections 17 and 49 of the Registration Act and

was inadmissible in evidence. Exhibit- 4 dated 20.11.2005 was

not a memorandum of partition but it records terms and

conditions of compromise dated 20.11.2005 entered into

between legal heirs and successors of Moti Poddar in 1st part

and Shyam Poddar in 2

nd part. 

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35

B. So far as 2nd substantial question of law is concerned, the socalled oral family settlement (exhibit-4) entered into between

legal heirs and successors of Moti Poddar on the one hand and

Shyam Poddar on the other without making daughters as party

to the exhibit-4, was not binding on the parties. The finding of

the learned 1st appellate court is perverse and is against the

mandate of law.

46. Both the substantial questions of law are decided in favour of

the appellant (defendant no.1) and against the respondent nos. 1 to 5

(plaintiff and the proforma defendants).

47. This Court also finds that the entire claim of the plaintiff is

based on a registered deed of sale dated 20.10.2008 executed by the

legal heirs and successors of Moti Poddar although at no point of time,

the exclusive possession of legal heirs and successors of Moti Poddar

with respect to the suit property has been proved. Admittedly, the

plaintiff was never handed over physical possession of the suit

property and the property was in possession of the contesting

defendants i.e. defendant no. 1 and defendant no. 1(a) and further, the

sale deed of the year 2008 (exhibit-1) itself was based on so called

amicable partition in two equal shares between legal heirs of Moti

Poddar on the one hand and Shyam Poddar on the other. Thus, the

entire basis of the title of the vendors of the plaintiff was the amicable

partition recorded in the so-called memorandum of partition (exhibit4) which has been held to be inadmissible in evidence and also held to

be not valid in law on account of non-inclusion of the daughters/their

legal heirs. Consequently, neither the proforma defendants (legal heirs

and successors of Moti Poddar) had the exclusive right, title and

possession with respect to the suit property nor the plaintiff acquired

exclusive right, title and interest over the suit property by virtue of

registered sale deed of the year 2008 (exhibit-1).

48. The law is well-settled that the vendor cannot pass any better

title than what he actually possesses. Therefore, the exhibit- 1 which is

a registered sale-deed dated 20.10.2008 executed by the legal heirs 

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36

and successors of Moti Poddar in favour of the plaintiff is in effect

sale of undivided portion of joint family property in which vendors of

the plaintiff also had share and accordingly, the learned courts were

not justified in decreeing the suit and directing the defendant no. 1 and

1(a) to hand over the possession of the suit property to the plaintiff.

Accordingly, the impugned judgement passed by learned District

Judge- I, Jamtara in Civil Appeal No.14 of 2017 upholding the

judgement and decree passed by learned Civil Judge (Senior

Division)- I, Jamtara in Title Suit No.9 of 2009 is hereby set-aside and

the suit is dismissed.

49. This second appeal is accordingly allowed.

50. Pending I.A., if any, stands closed.

51. Let this judgment be communicated to the learned court

concerned through FAX/e-mail.

(Anubha Rawat Choudhary, J.)

Pankaj