SMT. LAXMI DEVI vs SETHANI MUKAND KANWAR & TWO OTHERS

The Supreme Court held that under Section 2(d) of the Transfer of Property Act, 1882, the provisions of the Act do not affect transfers in execution of decrees, and thus Section 100 applies to auction sales. The Court found that the 1st respondent could not enforce a charge against the property purchased by the appellant due to a material irregularity in the sale proclamation. However, the application to set aside the auction sale was dismissed as the injury claimed by the 1st respondent was not substantial, given that other properties were available to satisfy her maintenance claim.