Delhi High Court

Finality of partition decree bars reopening of consensus-based proposals during execution to delay auction.

Suchitra Ray & Anr. vs Sumitra Sarkar & Ors.

Delhi High CourtJUDGMENT: July 07, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The parties are siblings involved in a partition suit regarding property No. J-1982, C.R. Park, New Delhi.

Source reference: no citation

A preliminary decree was passed on 13.12.2023, granting each party a 1/6th share

Source reference: p. 4, para. 6

On 03.04.2024, a final decree was passed directing the sale of the property through auction as physical partition was not permissible under municipal by-laws and no inter se consensus was reached

Source reference: p. 4, para. 7

The appellants unsuccessfully challenged this via RFA (OS) 28/2024 and a review petition

Source reference: p. 8, para. 20

In execution proceedings (EX.P. 58/2025), the Single Judge ordered the possession of the property be taken from the appellants for auction on 29.04.2026

Source reference: p. 1, para. 1

In the present appeal, the Court had initially stayed execution on 29.05.2026 based on a consent order where one Mr. Bharat Chetal was to purchase the property for ₹21 crores and deposit ₹10 lakhs as bona fides

Source reference: p. 2, para. 2-3

The appellants subsequently moved CM APPL. 39318/2026 to substitute the purchaser with Mr. Gurleen Singh Makkar and seek an extension of time

Source reference: p. 3, para. 4
02

Issues

1. Whether the appellants are entitled to an extension of time or modification of the consent order dated 29.05.2026 when they failed to comply with the personal undertaking of the named purchaser, Mr. Bharat Chetal

Source reference: p. 6, para. 13

2. Whether the Execute Court's order dated 29.04.2026, directing the takeover of possession for auction, suffered from any legal infirmity

Source reference: p. 11, para. 26
03

Law Applied

The Court applied Section 148 and Section 151 of the Code of Civil Procedure, 1908, governing the enlargement of time and the inherent powers of the Court

Source reference: p. 1, para. 1

The principle that an undertaking given to the Court is personal to the party making it and cannot be unilaterally substituted by a third party without judicial leave

Source reference: p. 6, para. 11-12

Affirmed that once a final decree for partition through sale (due to the impossibility of physical division) attains finality, the Executing Court is duty-bound to enforce it by auctioning the property

Source reference: p. 11, para. 26
04

Reasoning

The Court found that the appellants breached the foundational condition of the interim stay order dated 29.05.2026.

Source reference: no citation

Specifically, the deposit of ₹10 lakhs was required to be made by Mr. Bharat Chetal to show his bona fides, but was instead made by a third party, Mr. Gurleen Singh Makkar, without the Court's permission

Source reference: p. 5-6, para. 10-11

The Court characterized the appellants’ conduct—shifting from a "builder proposal" to "prospective buyer A" and then "prospective buyer B"—as a calculated attempt to protract proceedings and delay the execution of a final decree that had already attained finality

Source reference: p. 9-10, para. 22-23

Since the preliminary and final decrees were no longer under challenge and the property was legally incapable of physical partition, the Court reasoned that the Single Judge’s order to take possession for auction was the only viable method to satisfy the decree

Source reference: p. 11, para. 26
05

Holding

The Court dismissed the application for modification (CM APPL. 39318/2026), holding that a party in breach of an interim protection's conditions cannot seek further equitable indulgence

It directed the Registry to refund the unauthorized deposits made by Mr. Gurleen Singh Makkar

Source reference: p. 7, para. 16

The Court dismissed the main appeal (EFA(OS) 5/2026), vacated the interim stay, and affirmed the Single Judge's order dated 29.04.2026, holding that it correctly gave effect to the final decree for property auction

Source reference: p. 11, para. 27
Delhi High Court

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Suchitra Ray & Anr.vsSumitra Sarkar & Ors.

Delhi High Court · July 07, 2026

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