Arjan Singh vs Punit Ahluwalia & Ors

The Supreme Court analyzed the application of Order 23 Rule 3 of the Code of Civil Procedure in the context of a consent decree executed in favor of a third party, Puneet Ahluwalia, by Dr. Bawa. The Court held that the High Court erred in its interpretation of the rule, emphasizing that the deed of sale was invalid due to the violation of an interim injunction that had not been extended. The Court reinstated the trial court's order, affirming that a party cannot suffer due to the fault of the court, thus upholding the appellant's rights under the specific performance claim.