Trial Court must consider all registered documents on record before deciding an application for interlocutory injunction.

The property in dispute was originally owned by Mahipatram Dolatram. In 1968, two release deeds were executed: one (No. 1905) for 1565 sq. yards in favor of the father of Defendant No. 1, and another (No. 1906) for 1503 sq. yards in favor of the father of Plaintiff No. 1.

Additionally, 176 sq. yards was allegedly allotted jointly to both.

The Plaintiffs filed a suit for declaration and permanent injunction regarding the joint ownership of this 176 sq. yard parcel.

The Trial Court, vide order dated 16.03.2026, allowed the injunction application (Exhibit-5).

The Appellants (Original Defendants 4-6), who purchased a portion of the land via a registered sale deed in 2023, challenged this order on the grounds that the Trial Court ignored material evidence.

1. Whether the Trial Court committed an error in deciding the injunction application (Exhibit-5) by failing to consider all relevant documentary evidence, specifically Release Deed No. 1905 dated 18.04.1968.

The court exercised its appellate jurisdiction under Order XLIII Rule 1(r) and Rule 2 of the Code of Civil Procedure, 1908, which governs appeals against orders passed under Order XXXIX Rules 1 and 2.

The primary legal principle applied is that a judicial authority, while deciding an application for interim injunction, must consider all material evidence and pleadings placed on record by both parties to determine the existence of a prima facie case, balance of convenience, and irreparable injury.

The High Court observed that the Trial Court’s decision on Exhibit-5 was primarily based on a single document identified as "mark 4/5".

The Court found that despite Release Deed No. 1905 (dated 18.04.1968) being part of the record, the Trial Court failed to discuss or consider its terms and conditions.

The Court reasoned that since the ownership rights of both parties were derived from contemporaneous release deeds, it was mandatory for the Trial Court to evaluate both documents to arrive at a just conclusion regarding the injunction.

The failure to appreciate the entire evidence on record rendered the impugned order unsustainable.

The matter is remanded to the Trial Court with a direction to decide the Exhibit-5 application afresh on its merits after considering all pleadings and evidence produced by both sides. The Trial Court is directed to dispose of the application within 15 days from the receipt of the order.