K.S. Manjunath v. Moorasavirappa| Specific Performance | Bona Fide Purchaser |₹5 Crore Equity Relief

In this video, we break down the Supreme Court of India's important judgment in Civil Appeal Nos. 13507–13508 of 2025, where the Court upheld the High Court’s decree of specific performance for a 2000 Agreement to Sell (ATS) but imposed a unique balancing-equity condition requiring the original vendees to pay ₹5 Crores to the subsequent purchasers.

This case is crucial for understanding:
✅ When a suit for specific performance is maintainable
✅ What makes a contract “determinable” under the Specific Relief Act
✅ Legal standards for a bona fide purchaser without notice
✅ How the Supreme Court balances equities in long-pending property disputes

🧾 Key Highlights of the Judgment

1️⃣ Maintainability of Suit
The Supreme Court held that a separate prayer challenging termination is not mandatory when the termination itself is unilateral, arbitrary, and not contractually permissible.

2️⃣ Determinable Contract (Section 14 Specific Relief Act)
A contract is “determinable” only if it can be terminated at the sweet will of a party. Since the ATS here could be terminated only for specific reasons, it was not determinable.

3️⃣ Bona Fide Purchaser Test (Section 19(b))
The subsequent purchasers were not bona fide, as they had actual notice of the ATS and failed to make basic due-diligence inquiries—amounting to “wilful abstention”.

4️⃣ Balancing Equity
Although specific performance was granted, the Court directed payment of ₹5,00,00,000/- + interest + balance consideration to compensate for 18 years of elapsed time.

📚 Chapters (Timestamps)

00:00 – Introduction
01:05 – Case Background & Timeline
04:40 – Issues Before Supreme Court
05:20 – Maintainability of Suit
07:15 – Determinable Contract Explained
09:30 – Bona Fide Purchaser Analysis
12:10 – Readiness & Willingness of Vendees
13:45 – Supreme Court’s Final Directions
15:20 – Practical Impact of This Judgment
17:00 – Conclusion

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