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As per case facts, the Respondent-Plaintiff mortgaged a house and later executed a registered Sale Deed and Rental Agreement with the Appellant-Defendant. When the Appellants sought eviction for non-payment of
...rent, the Respondent-Plaintiff filed a suit to declare the Sale Deed sham, alleging it was a mortgage. The Trial Court agreed, but the First Appellate Court reversed, finding it a genuine sale. The High Court then set aside the First Appellate Court's decision, restoring the Trial Court's judgment. This led the Appellants to appeal to the Supreme Court. The question arose regarding the rigorous standard and material particulars required to declare a registered Sale Deed a sham, considering the strong presumption of its validity and genuineness under Section 92 of the Indian Evidence Act. Finally, the Supreme Court ruled that a registered Sale Deed has a formidable presumption of validity, and the burden of proof to displace it rests heavily on the challenger with cogent evidence. It found the Respondent-Plaintiff's pleadings and evidence inadequate, the Sale Deed unambiguous, and the transaction genuinely a sale, not a mortgage. The Court allowed the appeal, setting aside the High Court's judgment and restoring the First Appellate Court's decision, dismissing the original suit.
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