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Pattam Khader Khan vs Pattam Sardar Khan & Anr on 9 July, 1996

''13.The limitation for the purpose of Article 134 starts from the date of confirmation of sale. (See Ganpat Singh v. Kailash Shankar [(1987) 3 SCC 146]) In Pattam Khader Khan v. Pattam Sardar Khan [(1996) 5 SCC 48] this Court held that it is not from the date when sale certificate is issued that the limitation starts running. The sale becomes absolute on confirmation under Order 21 Rule 92 of the Code effectively passing title. It cannot be said to attain finality only when sale certificate is issued under Order 21 Rule 94. There can be variety of factors conceivable for which delay can be caused in issuing a sale certificate. The period of one-year limitation now prescribed under Article 134 of the Limitation Act in substitution of a three-year period prescribed under Article 180 of the Limitation Act, 1908 is reflective of the legislative policy of finalising proceedings in execution as quickly as possible by providing a quick https://www.mhc.tn.gov.in/judis 25/35 C.R.P(MD).No.171 of 2023 forum to the auction-purchaser to ask for the delivery of possession of the property purchased within that period from the date of the sale becoming absolute rather than from the date of issuance of the sale certificate. On his failure to avail such a quick remedy the law relegates him to the remedy of a regular suit for possession based on title, subject again to limitation.''
Supreme Court of India Cites 7 - Cited by 49 - M M Punchhi - Full Document

Ganpat Singh (Dead) By Lrs vs Kailash Shankar & Ors on 8 May, 1987

''13.The limitation for the purpose of Article 134 starts from the date of confirmation of sale. (See Ganpat Singh v. Kailash Shankar [(1987) 3 SCC 146]) In Pattam Khader Khan v. Pattam Sardar Khan [(1996) 5 SCC 48] this Court held that it is not from the date when sale certificate is issued that the limitation starts running. The sale becomes absolute on confirmation under Order 21 Rule 92 of the Code effectively passing title. It cannot be said to attain finality only when sale certificate is issued under Order 21 Rule 94. There can be variety of factors conceivable for which delay can be caused in issuing a sale certificate. The period of one-year limitation now prescribed under Article 134 of the Limitation Act in substitution of a three-year period prescribed under Article 180 of the Limitation Act, 1908 is reflective of the legislative policy of finalising proceedings in execution as quickly as possible by providing a quick https://www.mhc.tn.gov.in/judis 25/35 C.R.P(MD).No.171 of 2023 forum to the auction-purchaser to ask for the delivery of possession of the property purchased within that period from the date of the sale becoming absolute rather than from the date of issuance of the sale certificate. On his failure to avail such a quick remedy the law relegates him to the remedy of a regular suit for possession based on title, subject again to limitation.''
Supreme Court of India Cites 16 - Cited by 49 - M M Dutt - Full Document
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