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As per case facts, Jagannath, a benamidar, purchased properties from the appellants for his employer. He later relinquished his rights via a registered release deed. Despite appellants paying the decretal
...amount, Jagannath filed a partition suit, concealing this deed, and obtained a preliminary decree. Appellants discovered the release deed during the final decree hearing and challenged the preliminary decree as fraudulent. The High Court, however, ruled non-disclosure wasn't extrinsic fraud. The question arose whether a preliminary decree obtained by deliberately concealing a vital document constitutes fraud on the court, rendering the decree a nullity. Finally, the Supreme Court held that Jagannath's non-production and non-mentioning of the release deed unequivocally amounted to playing fraud on the court. It emphasized that litigants must approach with clean hands and disclose all relevant documents; withholding a vital document for advantage constitutes fraud on both the court and the opposing party. A case based on falsehood has no right to proceed and can be summarily dismissed at any stage. Therefore, the Supreme Court allowed the appeal, setting aside the High Court's judgment, and restoring the trial court's order, affirming that fraud vitiates all judicial acts.
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