SHANTI DEVI (SINCE DECEASED) THROUGH LRS. GORAN VS JAGAN DEVI ORS . . . In State of Maharashtra vs Pravin Jethalal Kamdar, 2000 SCC Online SC 522, it was held that, in case of void and non-est documents, it is enough to file a suit for possession to which Article 65 of Limitation Act, 1963 would apply
SHANTI DEVI (SINCE DECEASED) THROUGH LRS . GORAN v. JAGAN DEVI Clarifies the distinction between void and voidable documents regarding limitation and the necessity of seeking cancellation Limitation Act, 1963: The judgment extensively discusses the applicability of Article 59 and Article 65 of the Limitation Act, 1963
Void sale deeds and limitation: Supreme Court holds Article . . . - CaseMine Mutation presumption: Revenue entries (mutation) do not validate a void transaction nor alter the limitation analysis applicable to judicial vindication of title Conclusion Shanti Devi v Jagan Devi is a careful restatement and consolidation of a vital slice of limitation law in property disputes The Court clarifies that:
2025 INSC 1105 REPORTABLE In my view, limitation would not come in the way of the plaintiff-respondents, for, the suit can be filed from the date of the knowledge as per the provisions of Article 59 of the Limitation Act, which reads thus:- 59
Shanti Devi v. Jagan Devi, 2025 INSC 1105; Accamma Sam Jacob v. The . . . In Shanti Devi v Jagan Devi, 2025 INSC 1105, on 12 September 2025, made it clear – when a deed is fraudulent or a sham and bogus one, ‘it is not necessary for the plaintiff to claim any separate declaration that a document is void‘