Specific Performance: Proving Financial Readiness and the Fatal Impact of Unexplained Delay
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Case: MOHAMMED KHALEEL (D) THR. LRS. v. JAYAMMA
Court: Supreme Court of India
Date: 23-06-2026
Law: Specific Relief Act, Limitation Act.
Highlights of the Judgment:
- Interpretation of Section 16(c) of the Specific Relief Act, 1963, on the continuous nature of readiness and willingness.
- The legal distinction between "readiness" as financial capacity and "willingness" as conduct and intention.
- Evidentiary rules requiring proof of financial capacity at the relevant time rather than through post-suit financial documents.
- The impact of unexplained delay and laches on discretionary equitable relief, notwithstanding the statutory limitation period.
- Apportionment of party obligations for obtaining statutory clearances under the Urban Land (Ceiling and Regulation) Act, 1976.
- Application of landmark precedents including "N.P. Thirugnanam" and "Man Kaur" to specific performance suits.