A plaintiff must establish title before obtaining a declaratory decree, even by compromise.

The petitioners challenged the Trial Court’s refusal to accept a compromise petition filed by the parties in O.S. No. 824/2024, a suit seeking a declaration of ownership over the suit properties.

The Trial Court considered that the claim rested on revenue documents, which do not by themselves establish title, and declined to grant a declaration solely on the basis of the compromise

The petitioners sought supervisory relief under Article 227 of the Constitution; the respondents supported the compromise, stating that they admitted the petitioners’ title and the alienation in their favour

Whether the Trial Court could reject a compromise petition seeking a declaration of title because the plaintiff had not produced prima facie material establishing title

Whether the Trial Court’s refusal to accept the compromise warranted interference under Article 227 of the Constitution

Order XXIII Rule 3 of the Code of Civil Procedure, 1908, permits a court to record a lawful compromise; Section 151 CPC preserves the court’s inherent powers.

A court considering a compromise must assess the issues, the terms and nature of the compromise, and its consequences, and may decline to act on it if it does not provide a lawful basis for the relief sought

In a suit for declaration of title, the plaintiff must establish title before the court can grant declaratory relief; the burden remains on the plaintiff even if the defendants do not oppose the claim

Revenue documents, by themselves, are not documents of title

No precedent was cited.

The Court held that the requested compromise decree would declare ownership, so the parties’ consent alone could not supply the necessary basis for that relief.

The plaintiff still had to establish title, and the Court found no prima facie material sufficient to do so; revenue documents alone were inadequate

The Trial Court was therefore justified in refusing to accept the compromise.

The parties remained free to establish their respective cases at trial

Finding no ground for interference under Article 227, it dismissed the writ petition and left the parties to prove their respective cases at trial