Summary and Analysis of Vishnu Vardhan @ Vishnu Pradhan vs. The State of Uttar Pradesh & Ors

1. Heading of the Judgment

Case Title: Vishnu Vardhan @ Vishnu Pradhan vs. The State of Uttar Pradesh & Ors.
Court: Supreme Court of India
Civil Appeal No.: 7777/2023
Bench: Justices Surya Kant, Dipankar Datta, and Ujjal Bhuyan
Date of Judgment: July 23, 2025

2. Relevant Laws and Sections Discussed

The judgment extensively discusses the following legal principles and statutory provisions:

• Fraud and Judicial Proceedings:
  Doctrine: "Fraud unravels everything" (Lord Denning in Lazarus Estates Ltd. v. Beasley).
  Legal Precedents: Nidhi Kaim v. State of Madhya Pradesh, S.P. Chengalvaraya Naidu v. Jagannath, A.V. Papayya Sastry v. Govt. of A.P.
  Order VI Rule 4, CPC: Necessity of pleading fraud with specificity.

• Doctrine of Merger:
  Examined in Kunhayammed v. State of Kerala – Limits of merger when fraud vitiates judicial orders.
  Exception: Fraud nullifies merger (A.V. Papayya Sastry).

• Maintainability of Proceedings:
  Article 32 (Constitution): Scope of writ jurisdiction for Fundamental Rights violations.
  Article 226: High Court’s broader writ powers compared to Article 32.
  Order XIV Rule 2, CPC: Mixed issues of law and fact cannot be decided as preliminary issues.

• Land Acquisition & Compensation:
  Land Acquisition Act, 1894 (Sections 4, 6, 18, 30): Rights of co-owners in compensation disputes.
  Article 300-A (Constitution): Right to property.

3. Basic Details of the Judgment

• Parties:
  Appellant: Vishnu Vardhan (alleged fraud by Reddy Veeranna).
  Respondents: State of UP, NOIDA, and Reddy Veeranna.

• Core Dispute:
  Ownership of land in Sector 18, NOIDA, jointly purchased by Vishnu, Reddy, and Sudhakar in 1997.
  Reddy fraudulently obtained sole ownership via compromised decrees and suppressed facts in litigation.
  High Court’s 2021 order (impugned) declared Reddy the sole owner, awarding him enhanced compensation.

• Key Issues:
  Whether Reddy committed fraud to secure judicial orders.
  Maintainability of Vishnu’s appeal and writ petition.
  Applicability of the doctrine of merger to fraud-tainted orders.

4. Explanation of the Judgment

Fraud Vitiates Judicial Orders

• Fraud by Reddy:
  Consistently claimed joint ownership in earlier suits but later asserted sole ownership in collusive proceedings.
  Obtained a compromise decree (2006) via a cancelled Power of Attorney (Venkataramana, Reddy’s partner).
  Suppressed pending litigation (Vishnu’s 2020 suit) from the High Court.

• Legal Principle:
  Fraud nullifies all judicial acts ("Fraud avoids all judicial acts" – Coke).
  The Supreme Court held Reddy’s actions as deliberate deception, rendering the High Court’s order and its own 2022 decision (Reddy Veerana) void ab initio.

Maintainability of Vishnu’s Proceedings

• Writ Petition (Article 32):
  Dismissed as Vishnu failed to prove Fundamental Rights violation (no infringement of Articles 14, 19(1)(g), or 21).
  Relief sought (declaration of co-ownership) fell under Article 226, not Article 32.

• Civil Appeal:
  Allowed. The doctrine of merger does not apply when fraud is proven.
  The High Court’s 2021 order and SC’s 2022 decision were set aside.

Remand and Directions

1. High Court to Re-adjudicate:
   WP 2272/2019 restored with Vishnu and Sudhakar impleaded as parties.
   Fresh determination of compensation and ownership rights.

2. Interim Measures:
   Reddy’s securities (title deeds) to remain with SC.
   Restraints on Reddy from alienating assets pending High Court’s decision.

3. Review Petition:
   Vishnu permitted to cure defects for review of SC’s 2022 order.

Key Observations

• Public Interest: Fraudulent claims drain public funds (NOIDA’s Rs. 300 crore compensation).

• Judicial Caution: Courts must scrutinize collusive litigations to prevent abuse of process.

Conclusion

The Supreme Court quashed all fraud-tainted orders, emphasizing that fraud vitiates even final judicial decisions. The case was remanded to the High Court for fresh adjudication, ensuring all co-owners are heard. The judgment reinforces:

1. Zero tolerance for fraud in judicial proceedings.

2. Procedural flexibility to serve justice over technicalities.

3. Doctrine of merger is inapplicable to fraudulent orders.

Final Outcome:

• Civil Appeal allowed; Writ Petition dismissed.

• High Court to decide afresh with all parties.

• Fraudulent litigants (Reddy) subjected to stringent safeguards.