Legal Review and Analysis of Kapadam Sangalappa and Others vs Kamatam Sangalappa and Others 2025 INSC 1307

In-Short

Case: Kapadam Sangalappa & Ors. vs Kamatam Sangalappa & Ors. (2025 INSC 1307): A Supreme Court judgment emphasizing that a decree-holder must prove a violation with cogent evidence to execute a decree; it dismissed an execution petition for the custody of idols as the appellants failed to discharge this burden of proof, with evidence indicating the underlying compromise was never acted upon.

1. Name and Citation of the Judgment

Kapadam Sangalappa and Others vs Kamatam Sangalappa and Others
Civil Appeal Nos. 281-282 of 2015
Supreme Court of India
Decided on: November 11, 2025
Citation: 2025 INSC 1307

2. Related Laws and Statutes

The judgment revolves primarily around procedural and evidentiary aspects of civil law, referencing:

• The Code of Civil Procedure, 1908 (CPC): The core of the execution proceedings. Key provisions involved are Section 9 (Jurisdiction of Civil Courts), Section 47 (Questions to be determined by the court executing a decree), Section 115 (Revision by the High Court), and Order XXI, Rule 31 (Execution of decrees for specific movable property).

• The Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1987: The judgment notes that the High Court had earlier held that this Act did not oust the jurisdiction of the civil court to execute the 1933 decree.

3. Basic Details of the Judgment

• Court: Supreme Court of India

• Bench: Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi

• Nature of Case: Civil Appeals arising from execution proceedings of a compromise decree.

• Parties: The Appellants (Kapadam families of Gungulakunta village) and the Respondents (Kamatam families of Yerrayapalli village), both from the Kuruba community in Anantapur, Andhra Pradesh.

• Core Subject: The executability of a century-old compromise decree concerning the custody and worship of idols of the deity Lord Sangalappa Swamy.

4. Core Principles, Issues, and Judicial Analysis

This judgment is a classic illustration of the legal principles governing the execution of a decree, emphasizing that a decree's existence does not automatically guarantee its enforcement without proof of its violation.

A. The Central Dispute and Historical Context

The core issue was whether the Appellants (decree-holders) could successfully execute a compromise decree dated November 1, 1933, which mandated the alternating custody of sacred idols between the two villages every six months and the rotation of worship rights every three months.

• Origin of the Dispute: The litigation traces back to 1927, with the 1933 compromise decree intended to settle the feud.

• Alleged Breach: The Appellants filed an execution petition in 2000, alleging that the Respondents had, since 1999, refused to rotate the idols as per the decree.

• The Legal Journey: The matter traveled from the Executing Court, which allowed the execution, to the Andhra Pradesh High Court, which set aside the execution order, leading to the present appeal in the Supreme Court. (Paragraphs 1-14)

B. The Supreme Court's Analysis: The Paramountcy of Evidence

The Supreme Court confined its analysis to the singular, pivotal question: whether the Appellants had discharged their burden of proof to establish that the Respondents had violated the terms of the 1933 decree.

i. The Burden of Proof in Execution Proceedings

The Court reaffirmed a fundamental legal principle: the burden of proving that a judgment-debtor has willfully disobeyed a decree rests squarely on the decree-holder. The Appellants, as the parties seeking enforcement, were obligated to lead cogent evidence to prove that the Respondents were in possession of the original idols and had refused to hand them over. (Paragraph 26)

ii. Scrutiny and Rejection of the Evidence

The Supreme Court conducted a thorough review of the evidence and found it wholly insufficient.

• Presumption Cannot Replace Proof: The Court strongly criticized the Executing Court for allowing the execution based on a "mere presumption" that since there was no dispute for decades, the arrangement must have been operational and the Respondents must be in possession. The Supreme Court held such an inference, without factual proof, is "impermissible." (Paragraph 24)

• Unreliable Testimony: The testimonies of the sole witnesses from both sides (PW-1 and RW-1) were dismissed as consisting of "bare assertions, unsupported by any independent witnesses or documentary proof." Crucially, neither witness was a party to the original 1933 suit. (Paragraph 24)

• Admissions Undermining the Case: The Court highlighted damning admissions by the Appellants' own witness (PW-1). He admitted that there were no accounts maintained for the temple, no sharing of income, and that his family had continuously been performing the puja, repairing old articles, and purchasing new ones over the past 60 years. Most critically, he admitted he was unaware if the Respondents had ever paid the Rs. 2,000 stipulated in the 1933 decree, a condition precedent for their right to participate. (Paragraphs 25-26)

• Non-compliance with Other Decree Terms: The Court noted the complete absence of evidence to show that the other key term of the decree—the appointment of four trustees (two from each sect) to manage the endowment—was ever implemented. This further indicated that the compromise decree had remained largely on paper. (Paragraph 27)

iii. Inference of the Decree Being Inoperative

Based on the lack of evidence, the Supreme Court found the Respondents' contention to be "highly probable"—that the compromise decree was never acted upon. The failure of the Respondents to pay the Rs. 2,000 meant their rights under the decree never crystallized, and the Appellants continued in possession and management of the idols, making the question of "returning" them a factual impossibility. (Paragraphs 25-26)

5. Final Outcome and Directions

The Supreme Court dismissed the appeals, upholding the judgment of the High Court. The Court found no reason to interfere, concluding that the Appellants had failed to discharge the burden of proving that the Respondents had violated the terms of the 1933 compromise decree. The execution petition was, therefore, rightly set aside by the High Court. (Paragraphs 28-29)

6. MCQs Based on the Judgment

Question 1: In the case of Kapadam Sangalappa vs Kamatam Sangalappa (2025 INSC 1307), on whom did the Supreme Court place the burden of proving the violation of the 1933 compromise decree?
a) On the Executing Court to investigate the facts suo motu.
b) On the Respondents (judgment-debtors) to prove they had complied with the decree.
c) On the Appellants (decree-holders) to prove the Respondents had willfully disobeyed the decree.
d) Equally on both parties to establish their respective claims.

Question 2: The Supreme Court, in its analysis, heavily relied on the admission of the Appellants' witness (PW-1) to conclude that a key condition of the 1933 decree was likely never fulfilled. What was that condition?
a) The condition to maintain detailed accounts of temple income and expenditure.
b) The condition to appoint two trustees from each sect to manage the endowment.
c) The condition for the Respondents to pay a sum of Rs. 2,000 to the Appellants.
d) The condition to build a new temple for the deity in a neutral location.