In a detailed order dated 30 October 2025, the Jharkhand High Court at Ranchi, presided over by Justice Anubha Rawat Choudhary, declined to entertain a separate second appeal filed by Kumari Ratnakar, holding that her interests were already safeguarded through a prior intervention order in an ongoing property dispute that traces back to two sale deeds from 1970.
The judgment arose in a series of second appeals - S.A. Nos. 94, 99, and 114 of 2019 - filed by multiple parties contesting ownership and procedural validity concerning land located in Dhanbad district, Jharkhand.
Background
The case involves a complex tangle of ownership claims dating back more than five decades. The main controversy centers around two sale deeds - No. 24951 dated 1 October 1970 and No. 25097 dated 6 October 1970 - which several parties, including the intervenor, allege were executed fraudulently.
The State of Jharkhand, along with several private parties, approached the High Court challenging the findings of lower courts. The appeals raised multiple questions - ranging from limitation (delay in filing suits), notice under Section 80 of the Civil Procedure Code, and the maintainability of the revenue suit - to the binding nature of an earlier decision in Suit No. 544 of 2001.
Kumari Ratnakar, who had purchased a portion of the disputed land, had earlier been allowed to intervene in one of the pending appeals (S.A. No. 94 of 2019). However, she also filed a separate appeal (S.A. No. 99 of 2019) as a precautionary measure, fearing her rights might not be fully represented.
Court's Observations
Justice Choudhary took note of the fact that the intervenor’s application had already been accepted in 2023. The court had then specifically recorded that Ratnakar’s rights "stand protected by virtue of the order passed in S.A. No. 94 of 2019." Therefore, there was no necessity for her to pursue a separate second appeal.
Her counsel argued that since she had later filed Title Suit No. 201 of 2018 alleging fraud in the two sale deeds, her independent appeal should be entertained. But the bench found that this suit, along with another earlier one (Title Suit No. 119 of 2014), was already pending before competent civil courts. Any findings on the same issue by the High Court could interfere with those proceedings.
The bench observed,
"Once the intervenor’s right is protected in the earlier appeal, there is no point in allowing a separate second appeal. Her interests are already secured."
The court also discussed procedural issues such as condonation of delay, abatement due to the death of several respondents, and service of notice validity, concluding that procedural lapses had been addressed properly in connected cases.
Regarding a separate petition (I.A. No. 4941 of 2024) filed by the intervenor seeking a judicial inquiry into the 1970 deeds, Justice Choudhary declined to interfere.
"When allegations of fraud are already the subject matter of two title suits, this court will not order another inquiry," she remarked, stressing that fraud allegations must be proven through evidence at trial.
Decision
In the concluding part of her order, Justice Choudhary dismissed the application seeking leave to appeal (I.A. No. 819 of 2020) and consequently disposed of S.A. No. 99 of 2019, ruling that Kumari Ratnakar’s rights remain bound by the outcome of S.A. No. 94 of 2019.
Similarly, the court dismissed the application for a separate inquiry into the old sale deeds, reiterating that the matter is sub judice in civil courts. Other related appeals - S.A. Nos. 94 and 114 of 2019 - were listed for further hearing on 3 November 2025.
The order effectively narrows the litigation field, ensuring that the long-standing property dispute continues under one consolidated umbrella rather than multiple overlapping appeals.
