Sanjay Maruti Jadhav vs. Amit Tatoba Sawant (Supreme Court, 26 April 2024)
Background
The dispute involved Sanjay Maruti Jadhav and another appellant, who were alleged to have forcibly, illegally, and without authorization evicted the respondent, Amit Tatoba Sawant, from the disputed property. The respondent sought relief against this eviction, claiming it was done in violation of his rights under a leave and licence agreement. The trial court, after considering the evidence, ruled in favor of the respondent, finding that the appellants had indeed carried out an unlawful eviction.
Legal Proceedings
The appellants challenged the trial court’s findings before the appellate courts. Both the first appellate court and the High Court upheld the trial court’s decision, concurring with its factual findings regarding the illegal eviction. The matter was then brought before the Supreme Court, where the appellants continued to contest the concurrent findings of fact made by the lower courts.
Supreme Court’s Analysis
The Supreme Court reviewed the evidence and the concurrent findings of the courts below. The Court observed that the findings were based on a thorough appreciation of the evidence on record and constituted findings of fact. The appellants failed to demonstrate any perversity or legal error in the conclusions reached by the courts below.
The Supreme Court reiterated that it does not ordinarily interfere with concurrent findings of fact unless a gross miscarriage of justice or manifest error is shown. In this case, the appellants could not point to any such error. The Court also noted that the eviction was not only unauthorized but also involved the use of force, further justifying the relief granted to the respondent.
Judgment and Outcome
The Supreme Court dismissed the appeal, affirming the decisions of the lower courts. The Court held that the appellants’ actions were illegal and unauthorized, and the respondent was entitled to the relief granted by the trial court and affirmed by the appellate courts. The findings of fact, being well-supported by the evidence, were not open to interference by the Supreme Court.
Significance
This judgment reinforces the principle that the Supreme Court will not disturb concurrent findings of fact by lower courts in the absence of perversity or legal error. It also underscores the protection available to licensees against forcible and unauthorized eviction, and the importance of due process in resolving property disputes.
Citation: Sanjay Maruti Jadhav & Anr. vs. Amit Tatoba Sawant, [2024] 4 Supreme 111; 2024 INSC 345, Supreme Court of India, Judgment dated 26 April 2024.
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