ATMA RAM vs CHARANJIT SINGH

The Supreme Court addressed the issue of maintainability of a suit for mandatory injunction in the context of a specific performance agreement under the Specific Relief Act. The Court held that a suit for mandatory injunction can be treated as one for specific performance when the plaintiff seeks to enforce an agreement to sell immovable property, thus allowing the suit to proceed despite the respondent's claims of limitation and maintainability. The Court ultimately set aside the High Court's decision, reinstating the Trial Court's decree in favor of the petitioner.