3 Review(s)

In Santosh Devi v. Sunder (2025), the Supreme Court ruled that mere allegations of fraud are not enough. The plaintiff must show that the fraud concealed their right to sue to invoke Section 17 of the Limitation Act, 1963, which postpones limitation until discovery. Courts also weigh reasonable diligence—not just actual discovery. In Rajeev Gupta & Ors. v. Prashant Garg & Ors. (2025), the Supreme Court clarified that where cancellation of a sale deed is the primary relief, Article 59 (3-year period) applies instead of Article 65’s 12-year period for possession–even when both reliefs are sought. This prevents litigants from framing suits in a way that masks the true nature of their claim to evade shorter limitation periods. The Kerala High Court, in M/S National Collateral Management Service Ltd. v. Valiyaparambil Traders (2025), reaffirmed stringent requirements under Section 14 of the Limitation Act. To benefit, litigants must have: