JAGDISH PRASAD vs SHIV NATH

The Supreme Court clarified that a suit for specific performance of contract is governed by Section 19(b) of the Specific Relief Act, 1963, which allows a subsequent purchaser for value, without notice, to be impleaded as a party if the transaction is bona fide. The Court found that the lower court erred in treating the suit as one under Section 77 of the Registration Act, leading to the rejection of the appellant's prayer to be impleaded. Consequently, the impugned judgment was set aside, and the appeal was allowed.