ARJAN SINGH vs PUNIT AHLUWALIA .

The Supreme Court addressed the validity of a consent decree under Order 23 Rule 3 of the Code of Civil Procedure, emphasizing that the decree was invalid as it was executed in violation of an interim injunction that had not been extended. The Court held that the High Court erred in applying the first part of Order 23 Rule 3, as the appellant's rights were compromised due to the non-extension of the injunction. Consequently, the Court reinstated the trial court's decision declaring the deed of sale invalid.