Source: Supreme Court 

Why in News? 

A bench of Justice Pankaj Mithal and Justice SVN Bhatti held that when moulding the relief, the Court considers the issues and circumstances established during full-fledged trial, looks at shortening of litigation and then in its perspective render complete justice. 

• The Supreme Court held this in the case of J Ganapatha and others v. N Selvaraj Alou Chetty Trust Rep by its Trustees (2025). 

What was the Background of J Ganapatha and others v. N Selvaraj Alou Chetty Trust Rep by it’s Trustees (2025) Case?   

• In 1929, Somasundaram Chettiar purchased a property of 0.75 cents through a registered sale deed. He was the brother-in-law of N. Selvarajalou Chetty.
• In 1952, Padmini Chandrasekaran (daughter of N. Selvarajalou Chetty) filed a civil suit to resolve the right and title to her father's property. This suit was decreed, leading to appeals by both parties. 
• On 04th May 1962, a court auction sale of properties offered as security by Somasundaram Chettiar was held, and Padmini Chandrasekaran became the auction purchaser. 
• On 30th May 1962, Somasundaram Chettiar executed a will in favor of his adoptive son (Defendant No. 1), and he passed away on 14.06.1962. 
• On 25^th September 1963, the Advocate Commissioner executed a sale deed in favor of Padmini Chandrasekaran for the property in question. 
• On 30^th September 1975, Padmini Chandrasekaran executed a will bequeathing properties to the N. Selvarajalou Chetty Trust and some individuals, specifically mentioning a 0.75 cent land to be sold with proceeds deposited in a fixed deposit for Vinayagamurthy. 
• On 24^th February1992, V. Arumuga Chandran (Defendant No. 2) executed sale deeds on behalf of S. Sarvothaman (Defendant No. 1) in favor of Defendants 3 to 6. 
• On 12th March 1998, the N. Selvarajalou Chetty Trust filed a civil suit (C.S. No. 504 of 1998) against the defendants, seeking: 
  • Declaration that the 1992 sale deeds are void. 
  • Possession of the property. 
  • Permanent injunction against dealing with the property. 
• The Trust's primary argument is that Padmini Chandrasekaran became the absolute owner through the 1962 court auction and 1963 sale deed, and therefore the 1962 will by Somasundaram Chettiar could not transfer ownership to Defendant No. 1. 
• The defendants (particularly Defendants 3-6) argue that they were unaware of previous encumbrances and that the 1963 sale deed did not properly convey title against Defendant No. 1's rights. 

What were the Court’s Observations? 

• The Defendants did not challenge the court's competence to mould relief but argued that moulding relief in favor of the will's executors was illegal. 
• Padmini Chandrasekaran died without children and had divided her property disposition between a trust and specific individuals, bequeathing the specific property to Vinayagamurthy and his children. 
• The original executors of her will, Dr. H.B.N. Shetty and Shri R. Krishnamoorthy, were aged and some had passed away, which influenced the court's decision. 
• The Single Judge found that the first defendant had no title to sell the property to defendants 3-6, and the sale was invalid. 
• The Court considered it unnecessary to make H.B.N. Shetty file another suit, especially given his advanced age (over 80 years) and the 8-year delay. 
• The Court allowed the suit to be decreed in favor of H.B.N. Shetty in his capacity as executor of Padmini Chandrasekaran's will. 
• The Division Bench confirmed the Single Judge's findings, and the Civil Appeal court reviewed whether the moulding of relief was tenable. 
• The Court found that Padmini Chandrasekaran's ownership was established, the trust's declaration was not accepted, and an independent disposition was made to Vinayagamurthy. 
• The Appellate Court emphasized minimal interference in relief moulding, focusing on shortening litigation and preventing further legal complications. 
• Ultimately, the Civil Appeal was dismissed with costs of Rs. 1,00,000 payable to the Legal Aid Services Authority of the Madras High Court. 

When Can the Relief be Moulded? 

• Moulding of relief is a judicial power that allows courts to modify the relief sought by a party based on the specific circumstances and facts established during a trial. 
• The principle enables courts to grant appropriate remedies even when the original relief request is not precise or has been rendered obsolete by changing circumstances. 
• Courts aim to serve justice by maintaining flexibility in relief and exercising equitable jurisdiction, guided by judicial discretion. 
• When moulding relief, courts carefully consider the issues and circumstances established during the trial, with the primary goal of shortening litigation and rendering complete justice. 
• The fundamental principle is that the modified relief should not surprise or prejudice the aggrieved party. 
• Moulding of relief is an exceptional measure, not a standard procedural practice, and is applied sparingly and thoughtfully. 
• The ultimate objective is to provide a just and practical resolution that adapts to the evolving nature of legal proceedings while maintaining fairness to all parties involved.