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Desh Bandhu Gupta vs N.L.Anand & Rajinder Singh on 17 September, 1993

No doubt, the procedural requirement is mandatory. The court is obliged under the rule to examine whether the whole of the attached property of the judgment-debtor or a portion alone is to be sold to satisfy the decree. The question whether the property is one or more is not of much significance. Even if there is only one property, on enquiry, if the court is satisfied that a portion thereof alone is sufficient to satisfy the decree, only such portion should be sold. The mandate under the above rule is not a matter of discretion but an obligation cast upon the court and, so much so, any violation of the rule would be illegal. The jurisdiction of the court to conduct the sale to satisfy the decree debt extend only up to the point at which decree is satisfied and that being so, it has an obligation to ensure that only such property or portion of the property of the judgment-debtor as may be necessary to satisfy the decree is sold. The apex court in Desh Bandhu Gupta v. N.L.Anand & Rajinder Singh [ (1994) 1 S.C.C. 131] has held in that regard as follows:
Supreme Court of India Cites 16 - Cited by 181 - K Ramaswamy - Full Document

Ambati Narasayya vs M. Subba Rao & Anr on 6 October, 1989

11. The obligation cast on the executing court to examine whether the whole property attached or a portion thereof as may be necessary to satisfy the decree debt has been highlighted earlier also by the apex court in Ambati Narasayya v. M.Subba Rao (AIR 1990 S.C. 119) and other decisions referred to by the learned counsel for the appellant which have been referred to earlier. The decisions of the apex court on that point leave no room for any doubt that if the sale is proceeded without examining that question and substantial injury thereof is resulted, then such sale could be attacked as one without jurisdiction since the procedural mandate under Order 21 Rule 64 C.P.C. had been infringed. Bearing in mind the legislative mandate FAO 315/08 16 under Order 21 Rule 64 C.P.C. and the decisions of the apex court, the sale impugned in the present case has to be examined with reference to the materials involved.
Supreme Court of India Cites 2 - Cited by 132 - K J Shetty - Full Document

Shyamlal Purohit And Anr. vs Jagannath Ray And Anr. on 3 December, 1968

So long as the company exists, i.e., before its dissolution a shareholder cannot claim any interest in the assets of the company is reiterated by the apex court in Shyamlal Purohit v. Jagannath Ray [ (1970) 40 Comp. Cases 138] wherein the competency of a shareholder to impeach the sale of the property of the company under Order 21 Rule 90 C.P.C. as in the present case arose for consideration. The apex court held in categorical terms that such an application by a shareholder of the company to impeach the sale of its property is not entertainable and he has no locus standi to maintain an application under Order 21 Rule 90 C.P.C. The apex court has held thus:
Calcutta High Court Cites 12 - Cited by 8 - A K Mukherjea - Full Document

Bacha F. Guzdar vs Commissioner Of Income-Tax, Bombay on 28 October, 1954

6. Point No.1 :- Order 21 Rule 90 C.P.C. deals with an application for setting aside sale of an immovable property sold in execution of a decree on the ground of material irregularity or fraud. However, such an application is entertainable only at the instance of a decree-holder, or the purchaser, or any other person entitled to share in a rateable distribution of assets, or whose interests are affected by the sale. The appellant, a shareholder of the judgment-debtor- company can maintain his application only if he is able to satisfy that his interest is affected by the sale. The primary question then emerges for consideration is whether the appellant, a shareholder of the judgment-debtor- company, which is sui juris, has got any interest in the assets of the company. A shareholder, no doubt, acquires the right to participate in the profits of the company, but it is not possible to hold that he has any interest in the assets of the company. Position of a shareholder with respect to the company's assets is explained by the apex court in Bacha F. Guzdar v. Commissioner of I.T., Bombay (AIR 1955 S.C. 74) and the same is as follows:
Supreme Court of India Cites 12 - Cited by 349 - M C Mahajan - Full Document
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