एस.पी. चेंगलवराय नायडू बनाम जगन्नाथ
| Citation | (1994) 1 SCC 1 |
| Court | Supreme Court of India |
| Date | 18 November 1993 |
| Year | 1994 |
| Bench | S. Mohan, M.M. Punchhi JJ. |
| Acts/Articles | CPC Section 151, Transfer of Property Act |
| Category | Constitutional Law, Property & Land Law |
Key Principle Established
A judgment or decree obtained by fraud is a nullity. Courts will not permit a party to benefit from fraud, suppression of facts, or misrepresentation. Fraud vitiates all transactions.
A party obtained a property decree by suppressing a prior release deed that was crucial to the case. The opponent discovered this suppression and sought to set aside the decree.
The Supreme Court held that fraud vitiates everything — “fraus omnia corrumpit”. A judgment or decree obtained by fraud is a nullity and can be set aside at any time. The Court will not allow a person to retain any advantage obtained through fraud, suppression of material facts, or misrepresentation.
This is the most cited authority on fraud in property litigation. The principle “fraud vitiates all transactions” is applied across all branches of law.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.