Alternative Pleadings on Title and Adverse Possession: Mutually Inconsistent or Mutually Destructive?

Saji Koduvath, Advocate, Kottayam.

Abstract

  • The answer is that such claims are mutually destructive and defeat each other.
  • However, in cases involving alternative pleadings of ‘title’ and ‘adverse possession’, it appears that our Apex Court tends to favour the doctrine of ‘mutual inconsistency’ over ‘mutual destructiveness’— perhaps as a pragmatic approach to manage and circumvent the inherent complexities arising from conventional pleading practices in such matters.

Introduction

The plea on claim of title and that on adverse possession are inherently contradictory and cannot logically coexist within the same suit, as they originate from fundamentally different legal premises.

The simultaneous assertion of both claims would be akin to advancing the following two mutually exclusive assertions:

  • (i) “I lawfully own the property.”
  • (ii) “I do not own it lawfully, but I have acquired title by possessing it unlawfully for a sufficient period to attract the doctrine of adverse possession.”

Origin and Nature of Enjoyment Make Certain Dual Pleas Inconsistent

In Kerala State v. Brijit (A. Hariprasad, J.), ILR 2018-2 (Ker) 483; 2018-2 KHC 521; 2018-2 KLT(SN) 53, it is pointed out as under:

  • “53. As we all know, there are certain claims which are mutually inconsistent and exclusive, like
    • easement by prescription and easement of necessity,
    • ownership and easement,
    • lease and license, etc.
  • In the case of easement by prescription and easement of necessity, origin of the rights are entirely different. Easement right by prescription arises by proving the ingredients under Section 15 of the Easements Act, 1882, whereas a claim for easement of necessity, under Section 13, essentially arises out of severance of the tenements by transfer, partition or bequest. It is therefore clear that they cannot be claimed together as they originate from different sources.
  • Likewise, easement and ownership cannot be claimed together for the reason that easement is a right not claimable on one’s own property going by the definition in Section 4 of the Easements Act.
  • Lease and license also cannot be claimed together because a lease is a transfer of property falling within the provisions of the TP Act and a license is in the nature of a permission granted to one person for doing something in or upon the immovable property of the grantor, under the provisions of Section 52 of the Easements Act, which does not involve a transfer of property. Such incompatible rights originate from different sources and, therefore, nature of their enjoyment also would be different.”

The pleas of title and adverse possession are based on fundamentally different legal principles that cannot coincide without inherent contradiction.

  • Government of Kerala v. Joseph, AIR 2023 SC 3988,
  • Karnataka Board of Wakf v. Government of India, AIR 2004 SC 2096; 2004-10 SCC 779,
  • P. T. Munichikkanna Reddy v. Revamma, AIR 2007 SC 1753; 2007-6 SCC 59 (S.B. Sinha, J.);
  • Narasamma v. A. Krishnappa, AIR 2020 SC 4178; 2020-15 SCC 218.

See also:

  • Prabhakar Gones Prabhu Navelkar v. Saradchandra Suria Prabhu Navelkar, 2020-20 SCC 465
  • T. Ravi v. B. Chinna Narasimha, 2017-7 SCC 342,
  • L.N. Aswathama v. V.P. Prakash, 2009-13 SCC 229 (R.V. Raveendran, J.),
  • Arundhati Mishra v. Shri Ram Charita Pandey, (1994) 2 SCC 29.

‘Mutually Destructive‘ Pleas Cannot Co-exist

When these two propositions are presented in a party’s pleadings that contradict or destroy each other, and both cannot be true simultaneously, they are considered “mutually destructive”. Such inconsistency renders both pleas unreliable, and consequently, both are liable to be rejected. Example:

  • 1. Claim of title and adverse possession.
  • 2. Claim of title and benefits under Section 60(b) Easements Act.
  • 3. Easement by prescription and easement of necessity.
  • 4. Ownership and easement.

In Vimal Chand Ghevarchand Jain v. Ramakant Eknath Jajoo, 2009-5 SCC 713 (S.B. Sinha, Dr. Mukundakam Sharma, JJ.), it is held as under:

  •  “Pleadings of the parties, it is trite, are required to be read as a whole. Defendants, although are entitled to raise alternative and inconsistent plea but should not be permitted to raise pleas which are mutually destructive of each other.”

The Supreme Court in Steel Authority of India Ltd v. Union of India, AIR 2006 SC 3229, 2006-12 SCC 233, (S.B. Sinha, Dalveer Bhandari) held as under:

  • “To raise such a mutually destructive plea is impermissible in law. Such mutually destructive plea, in our opinion, should not be allowed to be raised even in an industrial adjudication. Common law principles of estoppel, waiver and acquiescence are applicable in an industrial adjudication.”

In Damodhar Narayan Sawale v. Tejrao Bajirao Mhaske, AIR 2023 SC 3319; it is pointed out as under:

  • “Contextually, it is apposite to state that though in a suit a defendant is entitled to raise alternative inconsistent plea he could not be permitted to raise pleas which are mutually destructive of each other and raising such pleas would only work out to his detriment.”

In Gautam Sarup v. Leela Jetly, 2008-7 SCC 85 (V.S. Sirpurkar, S.B. Sinha, JJ.) it is held as under:

  • “22. What, therefore, emerges from the discussions made hereinbefore is that a categorical admission cannot be resiled from but, in a given case, it may be explained or clarified. Offering explanation in regard to an admission or explaining away the same, however, would depend upon the nature and character thereof. It may be that a defendant is entitled to take an alternative plea. Such alternative pleas, however, cannot be mutually destructive of each other.” (Quoted in: Biswanath Agarwalla v. Sabitri Bera, 2009-15 SCC 693)

In Biswanath Agarwalla v. Sabitri Bera, 2009-15 SCC 693 (Deepak Verma, S.B. Sinha JJ.), pointed out as under:

  • “A defendant, as is well known, may raise inconsistent pleas so long as they are not mutually destructive.“

Following cases also dealt with ‘mutually destructive’ pleas:

  • Steel Authority of India Ltd v. Union of India, AIR 2006 SC 3229, 2006-12 SCC 233
  • Damodhar Narayan Sawale v. Tejrao Bajirao Mhaske, AIR 2023 SC 3319
  • Vimal Chand Ghevarchand Jain v. Ramakant Eknath Jajoo, 2009-5 SCC 713
  • Narayan Sawale v. Tejrao Bajirao Mhaske, AIR 2023 SC 3319
  • Biswanath Agarwalla v. Sabitri Bera, 2009-15 SCC 693
  • Gautam Sarup v. Leela Jetly, 2008-7 SCC 85.

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Time to Choose and Confine to One of the Alternative Pleadings

Different views:

  • 1. Before the commencement of the trial and taking evidence.
  • 2. At least at the time of arguments.
  • 3. During trial.

One thing is definite – the stance on ‘election’ must have reflected in the trial.

The pleas on title and adverse possession are mutually inconsistent, and the latter does not begin to operate until the former is renounced. Therefore, the time to choose and confine to one of the alternative inconsistent pleadings is before the commencement of the trial and taking evidence, so that the opposite party may not be prejudiced (See: P. V. Abdul Majeed Haji v. Shorabi, 2020-4 KerHC 53; 2020-4 KerLT 629).

But, according to the Andhra High Court, as held in Kavitha Goud v. Nookala Sudarshan Reddy, AIR 2004 AP 326; 2004-4 ALD 324; 2004-5 ALT 293, it is ‘at least at the time of arguments‘. In this case, it is said as under:

  • “It is true that a party can take inconsistent pleas, and can adduce evidence in respect of both the inconsistent pleas taken by him. But at least at the time of arguments, he must choose and confine his case to one of those pleas only, but cannot be permitted to urge the inconsistent pleas as grounds of attack or defence till the end of the lis, because the other side should know what exactly is his case.”

The Andhra High Court, in Atluri Prabhakara Rao v. Chalasani Krishna Kumari, 2017-2 ALT 240; 2017 3 ALT 785 (M. Satyanarayana Murthy, J.), observed that the time to confine to any one of the pleas is ‘during trial’. It is said as under:

  • “These two pleas are inconsistent to one another. Forgery is totally distinct from the fabrication. However, the defendant may take inconsistent pleas but she has to confine to any one of the pleas during trial.”

In Kuriakose v. Varkey, 1 August, 2017, (A. Muhamed Mustaque), it is pointed out as under:

  • “It is true that the defendant is entitled to take inconsistent pleas, but at the time of trial, he will have to stick on to one case.”

Plea of Title and Adverse Possession: ‘Mutually Inconsistent’

In Karnataka Board of Wakf v. Government of India, AIR 2004 SC 2096; 2004-10 SCC 779, it is held as under:

  • “The pleas on title and adverse possession are mutually inconsistent, and the latter does not begin to operate until the former is renounced.”
  • (Quoted in: P. T. Munichikkanna Reddy v. Revamma, AIR 2007 SC 1753; 2007-6 SCC 59 (S.B. Sinha, J.); Narasamma v. A. Krishnappa, AIR 2020 SC 4178; 2020-15 SCC 218.)

In L.N. Aswathama v. V.P. Prakash, 2009-13 SCC 229 (R.V. Raveendran, J.) also it was held that the pleas based on title and adverse possession are mutually inconsistent.

RC Lahoti J., opined in Kedar Nath v. Ram Parkash, 1997-2 AD(Del) 761; 1999-1 CLT 1; 1997-67 DLT 106, as under:

  • “However, a party would be better advised to abandon one of the two inconsistent pleas before going to the trial because contradictory inconsistent pleas may lead to effect associated with the peril of Court’s confidence being denied to both. Take the case of a person in possession pleading license and adverse possession in the alternative in an effect to protect his possession.”

In L.N. Aswathama v. V.P. Prakash, 2009-13 SCC 229, it is held as under:

  • “17. … The pleas based on title and adverse possession are mutually inconsistent and the latter does not begin to operate until the former is renounced. Unless the person possessing the property has the requisite animus to possess the property hostile to the title of the true owner, the period for prescription will not commence.
  • 18. …When a person is in possession asserting to be the owner, even if he fails to establish his title, his possession would still be adverse to the true owner. Therefore, the two pleas put forth by the defendant in this case are not inconsistent pleas but alternative pleas available on the same facts. Therefore, the contention of the plaintiffs that the plea of adverse possession is not available to defendant is rejected.”

In Arundhati Mishra v. Shri Ram Charita Pandey, (1994) 2 SCC 29, it is held as under:

  • “4. The question in this case is whether the plea of adverse possession sought to be set up by the respondent could be permitted to be raised. The pleas based on title and adverse possession are mutually inconsistent and the latter does not begin to operate until the former is renounced.”

In Om Prakash v. Bhaurao, 2022, it is held as under:

  • “18. The defendants are certainly entitled to take inconsistent pleas. However, mutually destructive or exclusive pleas stand on a different pedestal. A person who has set a title in himself cannot be permitted to alternatively plea perfection of title by adverse possession. The concept of adverse possession pre-supposes that the claimant accepts the title of the adversary. Adverse possession cannot begin to operate until the claimant renounces title and accepts the title of the adversary.”

In Government of Kerala v. Joseph, AIR 2023 SC 3988, the Supreme Court has affirmed the law as under:

  • “49. Claim of independent title and adverse possession at the same time amount to contradictory pleas.”

In Vidya Shanker v. Suresh Chandra, 2020-4 ADJ 547; 2020-5 AllLJ 290; 2020 142 AllLR 353; 2020 4 AWC 3430 (Sudhir Agarwal, J.) it is said as under:

  • “39. In the matter of plea of adverse possession, mutually inconsistent or mutually destructive pleas must not be taken in the plaint. Whenever the plea of adverse possession is raised, it pre supposes that owner is someone else and the person taking the plea of adverse possession is not the actual owner but has perfected his title by prescription since the real owner failed to initiate any proceeding for restoring the possession within the prescribed period under the statute.”

Sudhir Agarwal, J. then pointed out as under:

  • “40. In P. Periasami v. P.Periathambi, 1995 (6) SCC 523, it was said:
    • “Whenever the plea of adverse possession is projected, inherent in the plea is that someone else was the owner of the property.”
  • 41. In Mohan Lal v. Mirza Abdul Gaffar, (1996) 1SCC 639, the Court said:
    • “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 his title by prescription nec vi, nec clam, nec precario.”
  • 42. In Karnataka Board of Wakf Vs. Government of India, (2004) 10 SCC 779, Court held that whenever the plea of adverse possession is projected, inherent therein is that someone else is the owner of the property. In para 12 it said:
    • “The pleas on title and adverse possession are mutually inconsistent and the latter does not begin to operate until the former is renounced.”

Plea of Title and Adverse Possession: Mutually Destructive

The Kerala High Court, in P. S. George v. Balakrishnan, 2015-1 CivCC 26; ILR 2014-4 (Ker) 966; 2014-4 KHC 725; -2014-4 KLT 788, pointed out as under:

  • “Put it differently, he had been enjoying the disputed property as his own property. So also, there is no pleading either recognising or acknowledging the plaintiffs as the true owners of the property. Needless to say, the element of ‘animus possidendi’ is totally absent. I have already held that alternative plea of adverse possession is unsustainable, mutually destructive and liable to be rejected.”

In Kuriakose v. Varkey, 1 August, 2017, (A. Muhamed Mustaque), it is held as under:

  • “It is settled law that, claiming title in one self and claiming title by adverse possession will not go together and they are mutually exclusive and destructive to each other. It is true that the defendant is entitled to take inconsistent pleas, but at the time of trial, he will have to stick on to one case.”

In Rama Kanta Jain v. M.S. Jain, AIR 1999 (Del) 281, it was held as under:

  • “18. There is another aspect of the matter. The mere fact that the defendants have come forward with a plea of adverse possession, means that they admit the plaintiff to be the true owner. For a plea of ownership on the basis of adverse possession, the first and the foremost condition is, that the property must belong to someone else other than the person pleading his title on the basis of adverse possession, In the instant case the defendants have put forward defences which are irreconcilable’ and mutually destructive and inconsistent with one another.’” (Quoted in: Anu Gupta v. Vijay Gupta, 08 Aug 2022.

In Rattan Lal v. Ragunath, 18 Aug 2023, 2023 Supreme (Del) 3938, quoting Government of Kerala v. Joseph, AIR 2023 SC 3988, it is held as under:

  • “11.2. Therefore, the plea of adverse possession raised by the Appellants as a new plea in first appeal is inconsistent with the case setup in the written statement and the trial. In law, the Appellants are precluded from taking the said plea in view of the decision of the Coordinate Bench of this Court in Bharat Bhushan Jain & Anr. v. UOI & Ors., 2014 SCC OnLine Del 3577, wherein this Court has held that the plea of ownership by title and adverse ownership cannot be raised together being inconsistent and mutually destructive. The plea of adverse possession is a question of fact and cannot be raised in appeal only on the basis of prolonged possession of suit property in the absence of the proof of the other ingredients necessary for proving the said defence including the fact that the possession was hostile to the true owner of the property.”  

No Impediment in ‘Claiming’ Ownership and Adverse Possession

In Kerala State v. Brijit, ILR 2018-2 (Ker) 483; 2018-2 KHC 521; 2018-2 KLT(SN) 53, emphasised that there is no impediment in ‘claiming’ ownership and, in the alternative, a prescriptive title to it by adverse possession. The learned Judge stressed his point as under:

  • “54. … Exclusive possession of the thing owned and the right to exclude others from possession are two essential components in the bundle of rights called “title” or “ownership”. In other words, every owner has a right to possess property in exclusion of all the others. Every person holding property under a claim of adverse possession keeps possession of the same with a hostile animus to exclude all others, including the true owner. Therefore, both in a claim of ownership and adverse possession, assertive possession is an essential component. In the case of a person claiming adverse title by prescription, he must have been holding possession with an open hostile animus for the prescribed period. Therefore, I find no reason to think that there is any impediment in claiming ownership of property and in the alternative, a prescriptive title to it by adverse possession and limitation.”

Mutually Destructive Pleas Cannot be Permitted

In Mrs. Adarsh Kaur Gill v. Smt. Surjit Kaur Gill, FAO(OS) No.634/2009, decided on 15th January, 2009, it is held as under:

  • “13. The plea of ownership by way of adverse possession now sought to be taken is found to be mutually destructive to the plea of possession as co-owner, as a subrogatee-mortgagee in possession and as a tenant. The Supreme Court in L.M. Aswathama v. P. Prakash, MANU/SC/1222/2009 has also held that pleas based on title and adverse possession are mutually destructive; adverse possession does not begin to operate until title is renounced; unless the person possessing the property has the requisite animus to possess the property hostile to the title of the true owner, the period of prescription will not commence.” (Quoted in: Rishi Rathi v. Rishi Rathi, AIR 2022 (Del)(NOC) 585; Kewal Kishan v. Delhi Development Authority, 2013-137 DRJ 267)

In Combi v. K. S.  Ramachandran, 2021-6 KerHC 790; 2021-6 KerLT 379, it is held as under:

  • “3. The contention of tenancy right and adverse possession is mutually destructive and hence cannot be sustained. The tenancy right claimed was rejected by the Land Tribunal on a reference under Section 125 of the KLR Act due to lack of evidence. Nothing was brought to the notice of this court regarding any acceptable proof or evidence showing any existing tenancy right. As discussed earlier, the claim of adverse possession is mutually destructive and inconsistent, hence cannot be sustained.”

In Radheshyam Pathak v. Kanhaiyaa Gond, 2021, it is held as under:

  • “Plea of title and adverse possession, both, are mutually destructive plea and inconsistent as well. Therefore, the defendants cannot be permitted to raise mutually destructive plea.”

In Laxmi Narain v. Kartar Singh, 2021-1 LawHerald 322; 2021-2 RCR(Civ) 780, it is held as under:

  • “In the case titled Rama Kanta Jain v. M.S. Jain. Delhi High Court, 1999(2) RCR (Civil) page 685, it has been laid down that a person who traces his possession to a lawful title can never become an owner by adverse possession. The mere fact that the respondent has come forward with a plea of adverse possession means that he admits the appellant to be true owner. For a plea of ownership on the basis of adverse possession, the first and foremost condition is that the property must belong to someone else other than the person pleading his title. In the instant case, the respondent has put forward the defences which are irreconcilable and mutually destructive and inconsistent with one another.”

In Krishna Chandra v. Sarju Dei 2020-7 ADJ 416; 2020-5 AllLJ 363, it is held as under:

  • “34. Besides, alternative plea may be permissible, but mutually destructive pleas are not permissible. The defendants may raise inconsistent pleas so long as they are not mutually destructive as held in Biswanath Agarwalla v. Sabitri Bera. [JT 2009 (10) SC 538].
  • 35. In Gautam Sarup v. Leela Jetly, [(2008) 7 SCC 85] the Court said that a defendant is entitled to take an alternative plea but such alternative pleas, however, cannot be mutually destructive of each other.”

No Adverse Possession Without Admitting Title of Real Owner

In Nand Ram v.  Jagdish Prasad, AIR 2020 SC 1884; (2020) 9 SCC 393, it was pointed out by the Apex Court :

  • “The question of adverse possession without admitting the title of the real owner is not tenable.”

Our Apex Court, in Ayodhya case Judgment, M Siddiq v. Mahant Suresh Das, 2020-1 SCC 1, it is held as under:

  • “747. A plea of adverse possession is founded on the acceptance that ownership of the property vests in another against whom the claimant asserts a possession adverse to the title of the other.”

This principle is laid down in the following decisions also:

  • The State of Haryana v. Amin Lal, 2024-4 CurCC(SC) 222,
  • Kurella Naga Druva Vudaya Bhaskara Rao v. Galla Jani Kamma, (2008) 15 SCC 150,
  • Uttam Chand v. Nathu Ram, 2020-11 SCC 263, AIR  2020 SC 461.

Conclusion

The law is well settled:

  1. Mutually destructive pleas cannot co-exist.
  2. If a party to the suit raises mutually inconsistent (but not mutually destructive) pleas, he must elect and confine himself to one in the trial.

With respect to alternative pleadings of title and adverse possession, there remains a divergence in judicial opinion on one key issue:

  • whether the alternative pleadings of ‘title and adverse possession’ are to be regarded as ‘mutually inconsistent’ or ‘mutually destructive’.

The fundamental difference in the origin of the rights, the claim of title and adverse possession cannot coexist in the same case. One is destructive to the other, also. Because, it involves two inherently contradictory pleas:

  • (i) “I own the lawful owner of the property”, and
  • (ii) “I do not own it lawfully; the true owner is someone else’’.

Therefore, the simple and clear answer is that such claims are, for obvious reasons, mutually destructive and defeat each other.

  • However, in cases involving alternative pleadings of ‘title’ and ‘adverse possession’, it appears that our Apex Court tends to favour the doctrine of ‘mutual inconsistency’ over ‘mutual destructiveness’— perhaps as a pragmatic approach to manage and circumvent the inherent complexities arising from conventional pleading practices in such matters.

While courts may show some leniency in permitting divergent pleas at the trial stage, appellate courts generally do not entertain a position that contradicts the stance previously ‘elected’ or opted at trial.

End Notes:

Sec. 11 Civil Procedure Code, 1908, reads as under:

  • Res Judicata -No Court shall try any suit or issue in which the matter directly and substantially in issue has been directly and substantially in issue in a former suit between the same parties, or between parties under whom they or any of them claim, litigating under the same title, in a Court competent to try such subsequent suit or the suit in which such issue has been subsequently raised, and has been heard and finally decided by such Court.
  • Explanation I– The expression “former suit” shall denote a suit which has been decided prior to the suit in question whether or not it was instituted prior thereto.
  • Explanation II.- For the purposes of this section, the competence of a Court shall be determined irrespective of any provisions as to a right of appeal from the decision of such Court.
  • Explanation III.- The matter above referred to must in the former suit have been alleged by one party and either denied or admitted, expressly or impliedly, by the other.
  • Explanation IV.- Any matter which might and ought to have been made ground of defence or attack in such former suit shall be deemed to have been a matter directly and substantially in issue in such suit.
  • Explanation V.- Any relief claimed in the plaint, which is not expressly granted by the decree, shall, for the purposes of this section, be deemed to have been refused.
  • Explanation VI– Where persons litigate bona fide in respect of public right or of a private right claimed in common for themselves and others, all persons interested in such right shall, for the purposes of this section, be deemed to claim under the persons so litigating.
  • Explanation VII.- The provisions of this section shall apply to a proceeding for the execution of a decree and reference in this section to any suit, issue or former suit shall be construed as references, respectively, to proceedings for the execution of the decree, question arising in such proceeding and a former proceeding for the execution of that decree.
  • Explanation VIII.-An issue heard and finally decided by a Court of limited jurisdiction, competent to decide such issue, shall operate as res judicata in as subsequent suit, notwithstanding that such Court of limited jurisdiction was not competent to try such subsequent suit or the suit in which such issue has been subsequently raised.

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