Prescriptive Rights in Easements and Adverse Possession – Inchoate until Upheld by a Competent Court

Jojy George Koduvath, Kottayam

Contents

  • Introduction
  • PART I – Easement in Law
  • PART II – Adverse Possession
  • PART III – Prescriptive Rights – Inchoate until upheld by courts

Introduction

  • Application of ‘Prescriptive Rights’ arise in two main branches of law-
    • 1. In ‘easement by prescription’ and
    • 2. In claims on ‘adverse possession’.
  • Prescriptive Rights are Inchoate until Title thereof is Upheld by a Competent Court.
  • Declaration is necessary for claiming rights on Adverse Possession; but, a declaration is not necessary for claiming rights on easement.

PART I

“An Easement is a Right”

  • Easement is a right possessed by the owner of a land (dominant land),
    • to use the land of another (servient land),
    • for the beneficial enjoyment of the (dominant) land.

Easement Does Not Confer Ownership or Possession

  • No Ownership is bestowed in the (servient) land (AIR 2004 All 359; AIR 1925 Bom 335).
  • No Possession obtained in the (servient) land. (2011 (2) KLT 605; AIR 1925 Bom 335).  
  • No Interest is created in the (servient) land. (2003 (1) KLT 320; AIR 1954 All 393).

Easement (सुखाधिकार) is Well Recognised; And Circumscribed by Law

  • Easement is a limited right to ‘use’or ‘enjoy‘ another’s land.
  • It is to do, or to prevent to do, some specific thing.
  • It is to be exercised in a way least onerous to ‘another’s land’.
  • It is not a right to build and enjoy.
  • The right gained cannot be enlarged or increased.
    • That is, an easement of way to a particular (dominant) property cannot be extended to another property by the dominant owner; an easement for residential purpose cannot be enlarged (or increased) for an industrial purpose.
  • Servient owner can use his land in any manner (without disturbing enjoyment of the easement).

According to ‘Katiyar on Easements’:                                                                   

  • Easement is not a right to land or exclude owner.
  • It is not a right to permanent occupation. 
  • It does not confer exclusive right of user/enjoyment.
  • And, it is not a corporeal interest in land.

Easement – Definition under the Indian Easements Act

SECTION 4 of the Indian Easements Act defines Easements as under:

  • “An easement is a right
  • which the owner or occupier of certain land possesses,
    • as such,
  • for the beneficial enjoyment of that land 
  • to do and continue to do something, or to prevent and continue to prevent something being done,
  • in or upon, or in respect of, certain other land not his own.”

Acquisition of Easements – “Basis of Every Right of Easement is Grant”

The Indian Easements Act, 1882 refers to the different methods by which easements are acquired. They are pointed out (Ramkanya Bai v. Jagdish, AIR 2011 SC 3258) to be the following:

  1. easements by grant: express grant by the owner of the servient heritage
  2. easements of necessity: based on implied grants or reservations made by the owner of a servient heritage at the time of transfers or partitions
  3. easements by prescription: it is presumed that it is acquired by peaceable and open enjoyment, without interruption for twenty years and
  4. customary easements: it is inferred that it is acquired by virtue of a local custom.

For easement by prescription, it is not necessary that the user should be exclusive, but the claimant should exercise it under some claim existing in his own favour independently of all others.

The origin of all easements is, theoretically, grant by the servient owner. It may be express or implied. It may also be presumed from long user. It is observed in Sree Swayam Prakash Ashramam v. G. Anandavally Amma, AIR 2010 SC 622, as under:

  • “Theoretically all easements have their origin in some sort of grant by the servient owner. The grant may be express or it may be implied from the surrounding attendant circumstances and conduct of the parties or it may even be presumed from long user. In the case of an express grant of easement the limit thereof depends on the words used.”

In Lachhi v. Ghansara Singh, AIR 1972 HP 89, it is held as under:

The basis of every right of easement is theoretically a ‘grant’ from the servient-owner.

  • It may be expressed, as in Sections 8 to 12 of the Act; or
  • it may be implied from the circumstances as in Section 13 of the Act; or
  • it may be presumed from long and continued user for a certain period as in Section 15 of the Act; or
  • it may be inferred from a long and continued practice of user by a certain class of the public in certain locality.

For easement by prescription, it is not necessary that the user should be exclusive, but the claimant should exercise it under some claim existing in his own favour independently of all others.

Salient Limitations of Easement under the Indian Easements Act

  • The owner of a land only ‘uses’or ‘enjoys‘ another’s land (Sec. 31)
  • Only ‘enjoyment’ of soil or things ‘subsisting’ (Explanation in Sec. 4).
  • Limited enjoyment of (a) land & (b) advantages from its situation: S. 7
  • Right be exercised in a way least onerous to ‘another’s land’: Sec. 22
  • Secure full enjoyment; cause as little inconvenience: S. 24: 2017-2 KLT 63

It is Not a right to:                                            

  • tend to total destruction of servient tenement: S. 17 (2003 (1) KLT320)
  • make additional burden: S. 23
  • make constructions in, or cultivate upon: (2003 (1) KLT 320).
  • prevent servient owner to use: S. 27 : 2003 (1) KLT 320
  • enlarge purpose of, or accustomed, user: S. 28
  • substantially increase an easement: S. 29
  • prevent servient owner from obstructing excessive  ‘user’ of servient land – as ‘enjoyment of easement’: S. 31
  • increase burden by making permanent change in do. tent: S. 43
  • capable of forming grant – No easement, if Not capable of forming grant (without document or registration): 1987 (2) KLT 1037.

No easement if:

  • right claimed is incidents of ownership.
  • servient property belongs to him. Easement is a right with conscious knowledge that the servient property does not belong to him. AIR 1966 Raj 265. It must also be with proper animus as to easement: AIR 1973 Mad 173.

Read Blog: Easement Simplified

Easement by Prescription is Acquired; not arise out of ‘Express Permission’

Sec. 12, Easements Act states that an easement is acquired by the owner of an immovable property. It is observed by the Apex Court in Bachhaj Nahar Vs. Nilima Mandal, AIR 2009 SC 1103, that the claimant of easement (by prescription) should plead and prove that the right claimed was enjoyed independent of any agreement with the owner of the property over which the right is claimed, as any user with the express permission of the owner will be a licence and not an easement. 

PART II

Adverse Possession – ‘Evolving’ Concept

Adverse possession being essentially a judge-made law, and not exhaustively defined in any statute, the concept of adverse possession has been ‘evolving’. It is interesting to note that there were divergent views even with respect to the very fundamentals of ‘adverse possession’.

Earlier view – Inaction of true-owner matters (not overt-acts of trespasser) 

At one time it was considered that inaction/acquiescence of the true owner for 12 years brings-in adverse possession. Because,

  • Article 65, which speaks of as to limitation of suits (to be filed by the plaintiffs) does not specifically speak as to (i)  intention to dispossess title owner or (ii) knowledge on the part of trespasser as to who is the true owner.
  • “Nec vi, nec clam, nec precario” does not refer to (or speak as to) ‘hostile’ possession
  • “Animus possidendi” also does not say – hostile possession.
  • Inaction, acquiescence etc. of true owner are the material considerations – to become a ‘possession’ adverse to plaintiff.
  • Therefore, to attract adverse possession the trespasser need not know the true owner.

Philosophy of the earlier view can be seen from Amrendra Pratap Singh v. Tej Behadur (Para 22 – AIR 2004 SC 3782)

  • “What is adverse possession? ………The process of acquisition of title by adverse possession springs into action essentially by default or inaction of the owner. ……… The law does not intend to confer any premium on the wrong doing of a person in wrongful possession; it pronounces the penalty of extinction of title on the person who though entitled to assert his right and remove the wrong doer and re-enter into possession, has defaulted and remained inactive for a period of 12 years, which the law considers reasonable for attracting the said penalty. ………..”

Present view – Give prominence to overt and adverse acts of trespasser. 

Following are the important decisions to see the present view on adverse possession:

  1. Karnataka Board of Wakaf v. Govt of India, AIR 2004 SC 2096
  2. T. Anjanappa v. Somalingappa, (2006) 7 SCC 570]
  3. PT Munichikkanna Reddy v. Revamma, AIR 2007 SC 1753
  4. Ravinder Kaur Grewal v. Manjit Kaur,AIR 2019 SC 3827: (2019) 8 SCC 729

PT Munichikkanna Reddy v. Revamma, AIR 2007 SC 1753, is the latest decision of the Supreme Court that discussed various views on adverse possession. It is observed in this decision as under:

  • “Adverse possession in one sense is based on the theory or presumption that the owner has abandoned#* the property to the adverse possessor on the acquiescence of the owner to the hostile acts and claims of the person in possession. It follows that sound qualities of a typical adverse possession lie in it being open, continuous and hostile.”
  • “Thus, there must be intention to dispossess. And it needs to be open and hostile enough to bring the same to the knowledge and plaintiff has an opportunity to object.“

Thereafter it was emphasised as under:

  • “Therefore, to assess a claim of adverse possession, two-pronged enquiry is required:
  • 1. Application of limitation provision thereby jurisprudentially “willful neglect” element on part of the owner established. Successful application in this regard distances the title of the land from the paper-owner.
  • 2. Specific Positive intention to dispossess on the part of the adverse possessor effectively shifts the title already distanced from the paper owner, to the adverse possessor. Right thereby accrues in favour of adverse possessor as intent to dispossess is an express statement of urgency and intention in the upkeep of the property.”

Read Blog: Adverse Possession: An Evolving Concept

U.N. Mitra, in the “Law of Limitation and Prescription” (Tagore Law Lectures – 12th Edition, Vol.2, Page 1430) it is stated as under:

  • “A squatter is one who settles on land without title or with a view to acquiring title. He is a person who settles or locate on land enclosed or unenclosed with no bona fide claim or colour of title and without consent of the owner. He is merely an intruder and no matter how long he may continue there, no right in law vests in him. A squatter who does not set up a claim of right cannot plead adverse possession. No length of squatting possession would operate as a good or valid defence in a suit for possession by the true owner. A mere squatter or intruder who does not deny the title of the true owner or set up any right in himself cannot claim to be in adverse possession. ………” (Quoted in: K.J. Abraham v. Mrs. Mariamma Itty, ILR 2016-3 Ker 98)

In a nutshell, adverse possession arises from:

  1. acquiescence of the owner to the hostile acts; and
  2. hostile acts of the trespasser.

PART III

Prescriptive Rights – Inchoate until the title is upheld by a competent court

No doubt, it is true, one can acquire right of easement or adverse possession by prescription. But, prescriptive rights are said to be inchoate (started; but, not full-blown) until the such title is declared or upheld by a competent court.

It was observed in Sultan Ahmad v. Valiullah (1912) 10 ALJ 227, that the result of the Easements Act and the similar provisions of the Limitation Act was that a right of easement could not be said to be perfected until the right was declared by a decree of court.

  • Sultan Ahmad v. Valiullah (1912) 10 ALJ 227 is referred to in:
  • Nachiparayan v. Narayana Goundan, (1920): 60 Ind Cas 171, (1920) 39 MLJ 574;
  • Arjuna Udayar v. Manuswamy Naicker, 1999-1 CurCC 97.
  • See also: Tradesh and Miners, Ltd v. Dhirendra Nath Banerjee, AIR 1944 Pat 261.

In Siti Kantapal v. Radha Gobindaen, AIR 1929 Cal 542, it was held as under:

  • “It has been authoritatively held that a tie to easement is not complete merely upon the effluxion of the period mentioned in the Statute viz., 20 years and that however long the period of actual enjoyment may be, no absolute or indefeasible right can be acquired until the right is brought in question in some suit, and until it is so brought in question, the right is inchoate only and in order to establish it when brought in question, the enjoyment relied on, must be an enjoyment for 20 years up to within 2 years of the institution of the suit.” (Quoted in – D. Ramanatha Gupta vs S. Razaack, AIR 1982 Kant 314.)

In Ramanunni Vaidyar v. Govindankutty Nair, 1998(2) Ker LT 47, it is found that a person who has not acquired or perfected a right cannot maintain an action against the owner of the land over which the right is claimed. It is held as under:

  • In my view, on the basis of an inchoate right or a right which has not ripened into an easement by prescription, but is merely one of user, no relief can be granted to the user of them as against the owner of that land. In other words, a right, properietory or otherwise, has to be shown for obtaining relief (Krishna Pillai v.Kunju Pillai 1990 (1) KLT 136, referred to).

S. 27,  Lim. Act Gives Substantive Right – One Can Seek Declaration and Recovery

Generally speaking, the Limitation Act only bars the remedy but doesn’t destroy the right to which the remedy relates to. The exception to the general rule is contained in Section 27 of the Limitation Act, 1963.

Sec. 27 of the Limitation Act speaks that at the determination of the period “hereby limited to any person for instituting a suit for possession of any property”, his right to such property shall be extinguished.

The Limitation Act is an Act of repose. “Adverse possession statutes, like other statutes of limitation, rest on a public policy that do not promote litigation and aim at the repose of conditions that the parties have suffered to remain unquestioned long enough to indicate their acquiescence.” (See: PT Munichikkanna Reddy and others v. Revamma, (2007) 6 SCC 59: AIR 2007 SC 1753)

Adverse possession confers title under Sec. 27 (by necessary implication, because extinguished title of real owner comes to vest in wrongdoer – because, rights thereon had already been lost to the true owner, and passed over to the ‘possessory/adverse’ owner).

Therefore it is clear that Sec. 27 is a provision in the Limitation Act that gives a substantial right to a party. In view of Sec. 27 one can seek declaration of title by adverse possession and consequential injunction or recovery. That is why it is held in Ravinder Kaur Grewal v. Manjit Kaur,  AIR 2019 SC 3827: (2019) 8 SCC 729, that the person acquiring title by adverse possession can use it as a sword.

Plea of title and adverse possession – Whether Mutually Contradictory?

In Government of Kerala v. Joseph, AIR 2023 SC 3988, it is held as under: 

  • “21.9 Claim of independent title and adverse possession at the same time amount to contradictory pleas. The case of Annasaheb Bapusaheb Patil v. Balwant, (1995) 2 SCC 543 elaborated this principle as:
  • “15. Where possession can be referred to a lawful title, it will not be considered to be adverse. The reason being that a person whose possession can be referred to a lawful title will not be permitted to show that his possession was hostile to another’s title. One who holds possession on behalf of another, does not by mere denial of that other’s title make his possession adverse so as to give himself the benefit of the statute of limitation. Therefore, a person who enters into possession having a lawful title, cannot divest another of that title by pretending that he had no title at all.”
  • This principle was upheld in the case of Mohan Lal v. Mirza Abdul Gaffar (AIR 1996 SC 910, 1996 1 SCC 639 – two Judge Bench) –
  • “4. As regards the first plea, it is inconsistent with the second plea. Having come into possession under the agreement, he must disclaim his right thereunder and plead and prove assertion of his independent hostile adverse possession to the knowledge of the transferor or his successor in title or interest and that the latter had acquiesced to his illegal possession during the entire period of 12 years, i.e., up to completing the period of his title by prescription nec vi, nec clam, nec precario. Since the appellant’s claim is founded on Section 53-A, it goes without saying that he admits by implication that he came into possession of the land lawfully under the agreement and continued to remain in possession till date of the suit. Thereby the plea of adverse possession is not available to the appellant.”
  • The Court in Uttam Chand (Sri Uttam Chand v.  Nathu Ram AIR 2020 SC 461) has reiterated this principle of adverse possession.”

(Note: Mutually destructive plea is impermissible: (2006) 12  SCC 233, AIR 2009 SC 2355).

Is declaration necessary for claiming Easement?

No.

Sec. 35 Easement Act allows to file a suit if the easement is disturbed (without making ground thereof by establishing the right by a ‘declaration’). See: Unnikrishnan v. Ponnu Ammal: AIR 1999 Ker 405.

Sec. 35 Easement Act reads as under:

  • 35. Injunction to restrain disturbance – Subject to the provisions of the Specific Relief Act, 1877 (1 of 1877)1, sections 52 to 57 (both inclusive), an injunction may be granted to restrain the disturbance of an easement–
    • if the easement is actually disturbed – when compensation for such disturbance might be recovered under this Chapter;
    • if the disturbance is only threatened or intended – when the act threatened or intended must necessarily, if performed, disturb the easement.

Is declaration necessary for claiming Adverse Possession?

Yes.

Declaration is, mainly, to make clear what is doubtful – as to legal character and title. ILR 1970-2 (Del) 433: Eg. Suit by trespasser claiming adverse possession: Darshan Kumari v. Kaushalya Devi: 1990 JKLR 208; 1991 Kash LJ 1 (R.P. Sethi, J) for dispelling cloud: AIR 1953 (Gau) 162.

Declaration is held to be needed in the following circumstances:

  1. For establishing or restoring the deprived rights or as introductory/ preliminary to grant (1) Injunction or (2) Recovery (Mohd. Manjural Haque v. Bisseswara Banerjee, AIR 1943 Cal 361; Unnikrishnan v. Ponnu Ammal: 1999-1 KLT 298: AIR 1999 Ker 405)
  2. When serious denial or cloud on title (or right): Anathula: AIR 2008 SC 2033
  3. Asserted title or civil right is not clear, simple and straight-forward; or, not well-established (lawful possession). Make clear what is doubtful – as to legal character and title. ILR 1970-2 (Del) 433: Eg. Suit by trespasser claiming adverse possession: Darshan Kumari v. Kaushalya Devi: 1990 JKLR 208; 1991 Kash LJ 1 (R.P. Sethi, J) for dispelling cloud: AIR 1953 (Gau) 162.
  4. Complicated or complex questions of fact and law to be ‘adjudicated’ (Anathula: 2008 SC 2033)
  5. Insurmountable obstacle – Md. Noorul Hoda v. Bibi Raifunnisa : (1996) 7 SCC 767; Chellakannuv. Kolanji (R. Banumathi, J.), AIR 2005 Mad 405.
  6. When the defendant raises a genuine dispute with regard to title and when he raises a cloud over the title of the plaintiff: Jharkhand State Housing Board v. Didar Singh , (2019) 17 SCC 692 . Referred to in: Padhiyar Prahladji Chenaji vs Maniben Jagmalbhai: 2022 SCC OnLine SC 258.
  7. When a title dispute exists; and plaintiff himself elaborated the same in the plaint. A. Subramanian v. R. Pannerselvam, AIR 2021 SC 821.
  8. In Sudhakara Reddy v. Lakshmamma, 2014 (4) ALT 404, 2011 (4) ALD 325 (DB), the High Court found fault with the lower courts for framing an issue so as to embrace a declaration (as to cancellation of a deed) in the suit seeking injunction simpliciter.

Should Date of Beginning of 20 Years be pleaded?

In Justiniano Antao v. Bernadette B. Pereira, (2005) 1 SCC 471, it was pointed out as follows:

  • “In order to establish a right by way of prescription to the detriment of the other party, one has to show that the incumbent has been using the land as of right peacefully and openly and without any interruption for the last 20 years. There should be specific pleadings and categorical evidence in general and specifically that since what date to which date one is using the access for the last 20 years.”

Kerala High Court, in Soman Nair v. Manoj Kumar, 2014 (P. Bhavadasan, J.) distinguished the decision Justiniano Antao v. Bernadette B. Pereira, observing as under:

  • “12. A reading of the decision reported in Justiniano Antao’s case (cited supra) would reveal that the dictum has to be read in the context of facts of the case. That was a case where the Apex Court found that till 1984, the claimant was using another way and only thereafter the claim over the way through servient tenement was made. A vague assertion had been made in the said case that the pathway has been used for a long time. It was under those circumstances, the Apex Court had occasion to hold as mentioned above.
  • 13. In the case on hand, the definite pleading as could be culled out from the written statement and counter claim is that defendants as well as their predecessors-in-interest have been using the pathway in question for a long time in fact for more than 30 years and this is only means of access  to their property.”

Pappachan v. Alex, ILR 2023-3 Ker 523; 2023-5 KHC 10, distinguished the decision Justiniano Antao v. Bernadette B. Pereira, observing as under:

  • “24. In Justiniano Antao (supra) there was no pleading by the plaintiff that she used the pathway in question for a period of 20 years. Holding that in the absence of such a pleading which is elementary and essential to claim a prescriptive easement right, the Apex Court held that the date from which the right of way was started to use should have been pleaded. The pleadings set forth by the appellants in this case certainly constitute sufficient pleadings to claim easement by prescription. It is true that they did not plead as to from which date they started using that pathway. They, however, pleaded that for the last more than 35 years they have been using that pathway. In the light of such a specific pleadings the law laid down in Justiniano Antao [(2005) 1 SCC 471] does not disentitle the appellants from claiming the relief.”

Read Blogs:

End Notes:

When Injunction granted Without Declaration

  • Where title claimed by the defendant is Nullity, or Ab-initio void.
  • No serious cloud, but trespasser without any claim to title or an interloper without any apparent title, merely denies the plaintiff’s title. 
  • Established custom/customary-rights (Eg. Village pathway, Marumakkathayam) and suits on  settled common law propositions (right of access to the adjoining land from the highways).
  • By virtue of enacted provisions of law (Sp. Relief Act, Easements Act, Contract Act etc.)

Persons having clear title and possession suing for injunction, should not be driven to the costlier and more cumbersome remedy of a suit for declaration. (Anathula: 2008 SC 2033).

When Injunction is granted without declaration:

Relevant ActWhen Injunction or Recovery Granted Without Declaration
Sp. Relief Act
Sec. 34		1. Title: well established; clear,simple and straight-forward; or settled right (lawful possession) or Well established possession
2. No Substantial questions of fact and law exists (2017 -7 MLJ 627; 2005-4 MLJ 258): Unnikrishnan v. Ponnu Ammal: AIR 1999 Ker 405.
3. No serious denial or cloud(not any apparent defect) on title (or right):   Anathula: AIR 2008 SC 2033. (Such as settled or lawful possession: Anathula: AIR 2008 SC 2033; infringement of trade mark or copyright: 2004-3 SCC 90).
4. Void acts: 2000 SC 1099; 2009-4 KLT 840; (2002) 9 SCC 28; AIR 1977 SC 1718; 2013 SC 1226
5. Fraud on character of a document (not contents): Premsingh v. Birbal: (2006) 5 SCC 353
Sp. Relief Act
Sec. 38		Particular instances specified in Sec. 38 (2) & (3) of the Sp. Rlf. Act
1. Breach of Contractual obligations(including Bylaw provisions)
2. Trustee invades plaintiff’s right.                
3. No standard for ascertaining damages.
4. Compensation in money would not be adequate relief.
5. Necessary to prevent multiplicity of judicial proceedings.
SR Act: Sec. 41(h)Fiduciary obligation (attached to trust): 41(h).
..No lis (no dispute for defendant): 2010-168 DLT 132
Evd. Act, S. 57Facts judicially noticeable: Evd. Act, S. 57
Ease-ments
Act
Sec. 35		35. Injunction to restrain disturbance – Subject to the provisions of the Specific Relief Act, 1877 (1 of 1877)1, sections 52 to 57 (both inclusive), an injunction may be granted to restrain the disturbance of an easement-
(a) if the easement is actually disturbed – when compensation for such disturbance might be recovered under this Chapter;
(b) if the disturbance is only threatened or intended – when the act threatened or intended must necessarily, if performed, disturb the easement. (See: Unnikrishnan v. Ponnu Ammal: AIR 1999 Ker 405)
Contract Act
Sec. 74		Law confers a right; or, Right arises under an Act. (Eg. with expression “shall be void”):(2015)7 SCC 601; 2003 SC 4102 Sec. 74 Contract Act: while resisting a claim of return of advance or to support forfeiture of earnest money, the defendant can resist it without a counter claim. In Kailash Nath Associates v. Delhi Development Authority (2015) 4 SCC 136, it is held: “The Section applies whether a person is a plaintiff or a defendant in a suit.”
Common LawEstablished custom/customary-rights. Eg. Village pathway, Marumakkathayam. It is pointed out in KVK Janardhanan v. State of TN, AIR 1995 Mad 179, that it is a settled proposition –
“In a case of a public road or a cart track every public has got a right of access to the adjoining land. There is no need to ask for a declaration and if there is any obstruction they can ask for the relief of a mandatory injunction.”
Consti-tutionConstitutional right: Art. 19, 21, 300A etc.
Evd. ActEstoppel against defendant S. 115, 116 (tenant), 117 (licencee) Evd. Act
..Acquiescence against defendant
..Already declared (in earlier civil case).

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