No Prayer, No Compensation: Supreme Court Says Courts Cannot Create New Relief
In a significant ruling reaffirming the limits of judicial discretion in civil litigation, the Supreme Court has held that courts cannot compel a plaintiff to accept monetary compensation when no such relief has been sought in the pleadings. The Court observed that judges are bound by the reliefs claimed by the parties and cannot create an entirely new remedy merely because they consider it equitable or convenient.
The judgment came in a dispute involving alleged encroachments, where the plaintiff had sought a permanent injunction and removal of the encroachment. Instead of granting the relief sought, the High Court directed that compensation be paid to the plaintiff in lieu of the injunction. The Supreme Court found this approach legally unsustainable, emphasizing that an appellate court cannot substitute a relief that the plaintiff never requested.
A Bench comprising Justices S.V.N. Bhatti and Atul S. Chandurkar observed that civil proceedings are governed by the pleadings of the parties. The relief granted by a court must flow from the case presented before it, and any departure from those pleadings would undermine the principles of procedural fairness and natural justice. A litigant cannot be compelled to accept compensation instead of the substantive relief originally sought.
The Supreme Court also criticized the High Court for directing the executing court to determine compensation after setting aside the decree. It held that once the original decree had been interfered with, there remained no legal basis for the executing court to adjudicate issues that did not arise from any subsisting decree. Such directions, the Bench noted, exceeded the permissible jurisdiction of the executing court.
Reiterating a well-established principle of civil jurisprudence, the Court stated that judicial powers, though broad, are not unlimited. Courts exist to adjudicate disputes within the framework established by the parties through their pleadings and evidence. They cannot redesign the litigation by introducing new causes of action or alternative remedies that neither side has sought.
Allowing the appeal, the Supreme Court set aside the Punjab and Haryana High Court’s judgment and restored the legal position that relief must remain confined to the pleadings and prayers made by the litigants. The decision reinforces the doctrine that while courts possess equitable jurisdiction, such powers cannot override the fundamental procedural requirement that justice must be administered within the scope of the case presented before the court.
The ruling is expected to have considerable significance in civil litigation across India. It serves as a reminder that appellate courts cannot replace an injunction with compensation merely because they consider it a more practical solution. Unless a party expressly seeks damages or compensation, courts cannot compel acceptance of such relief, preserving both the autonomy of litigants and the integrity of the adversarial judicial process.
