Conditional compromise decree is executable once funds received are sufficient to satisfy the decreetal amount.

The petitioners filed Special Civil Suit No. 50 of 2017 challenging a 2010 Sale Deed for ancestral land

During the suit's pendency, the land was acquired for a National Highway, and compensation was made payable to Respondent No. 1

On 25.04.2023, the parties entered into a Compromise Decree wherein Respondent No. 1 agreed to pay the petitioners Rs. 1,31,50,000/- with 9% interest p.a.

The decree stipulated that compensation would first be deposited into Respondent No. 1’s account, who would then pay the petitioners

Despite receiving approximately Rs. 22.91 crores in 2023, Respondent No. 1 failed to pay

The petitioners filed Execution Application No. 18 of 2023. The Executing Court rejected the application on 09.09.2025, labeling it "premature" because the entire compensation amount had not yet been received

1. Whether the Executing Court erred in interpreting the compromise decree as "premature" and conditional upon the receipt of the entire compensation amount

2. Whether the Executing Court failed to exercise its jurisdiction by going behind the decree and preventing the judgment creditors from receiving the fruits of the decree

The Court observed that a compromise decree has the force of a contract with the seal of the Court and is fully executable like any other decree

Under the principles governing execution, an Executing Court cannot go behind the decree or modify its effect

The primary duty of the Executing Court is to ensure that the judgment creditor receives the fruits of the decree

Furthermore, when a decree links payment to the receipt of funds, the obligation to pay crystallizes as soon as sufficient funds (even if partial) are received to satisfy the decretal amount

The High Court found that the Executing Court committed a jurisdictional error by misinterpreting the Compromise Decree

The lower court’s reasoning—that execution was premature until all compensation was received—was deemed an error of fact and law

The High Court noted that Respondent No. 1 had already received Rs. 22.91 crores, which was significantly higher than the decretal amount of Rs. 1.31 crores owed to the petitioners

Therefore, the condition for payment had effectively been met.

The Court reasoned that the lower court failed to properly examine the nature of the decree and the extent of compliance, resulting in a failure to exercise the jurisdiction vested in it

It held that the execution was not premature since the respondent had received sufficient funds to satisfy the decree

The matter was remanded to the Executing Court for adjudication afresh on merits

The High Court directed the Executing Court to dispose of the application as expeditiously as possible and ordered both parties to cooperate without seeking unnecessary adjournments

Interim relief was vacated