Supreme Court Restores Interim Application, Modifies Status Quo Order, Appoints Receiver to Administer Disputed Land

Case Snapshot

• Case Name: Parbatsinh Dolatsang Dodiya and Others v. Rameshbhai Harjibhai Makwana and Others

• Citation: 2026 INSC 898

• Bench: Justice S.V.N. Bhatti and Justice N.V. Anjaria

• Date of Judgment: August 20, 2026

• Area of Law: Civil Law, Execution of Decree, Appointment of Receiver, Tenancy Law

The Judgment in One Line

Supreme Court sets aside findings beyond appellate scope, restores interim application, and appoints Advocate Receiver for disputed land.

Why This Judgment Matters

This judgment is significant as it clarifies the limits of appellate jurisdiction—an appellate court cannot traverse beyond the scope of the subject matter of the appeal. The Supreme Court set aside findings that went beyond the scope of the appellate proceedings and restored the interim application for adjudication on merits. The judgment also demonstrates the Court's pragmatic approach in land disputes by appointing an Advocate Receiver to administer the property during pendency of proceedings, ensuring that neither party gains an unfair advantage and the property is preserved. This will guide courts in execution proceedings and interim applications.

Background

The dispute concerns agricultural land measurin

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