Supreme Court Restores Injunction, Condemns "Mini-Trials" in Interlocutory Appeals

Case Snapshot

Case Name: Shruti Manav Sharma & Anr. v. Sunanina Singh & Ors.

Citation: 2026 INSC 843

Bench: Justice Pamidighantam Sri Narasimha and Justice Alok Aradhe

Date of Judgment: August 12, 2026

Area of Law: Civil Procedure, Interim Injunctions, Appellate Interference, Discretionary Orders

The Judgment in One Line

Appellate courts cannot substitute their discretion in interim injunction matters unless the Single Judge's order is perverse or arbitrary; mini-trials on merits are impermissible.

Why This Judgment Matters

This landmark judgment is a powerful reaffirmation of the limited scope of appellate interference with discretionary orders granting or refusing temporary injunctions. The Supreme Court restored a Single Judge's injunction that a Division Bench had reversed, holding that the Division Bench conducted an impermissible "mini-trial" on merits. The judgment emphasizes that interlocutory injunctions are "holding operations" to preserve the subject matter of the suit, not final determinations of rights. It also condemns the growing practice of lengthy, merits-laden orders at the interim stage, reminding courts that the three-fold test—prima facie case, balance of convenience, and irreparable injury—must be applied without delving into final merits.

Background

The testator, Devinder Singh Chaudhary, died on December 5, 2009, leaving behind substantial family assets held through companies, partnerships, and LLPs. His widow (original plaintiff) executed a series of gift deeds and LLP transfer agreements between December 2018 and June 2019, transferring shareholding and capital in family entities to her granddaughter (defendant No. 4) and her husband (defendant No. 9). These transfers occurred while the elderly w

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