Dalpat Kumar v Prahlad Singh (1992)

CPC & Limitation Act · Inherent Powers & Interlocutory Orders (ss.148–151, s.94)

Facts.

A dispute over property led to an application for a temporary injunction under Order 39; the lower courts differed on the test to apply.

Issue.

What must an applicant establish to obtain a temporary injunction?

Held.

The Supreme Court restated the settled three-fold test — a prima facie case, the balance of convenience in the applicant’s favour, and irreparable injury not compensable in money — all of which must ordinarily be satisfied together.

Why it matters.

This is the go-to authority for every temporary-injunction answer and problem; naming and applying its three limbs is what scores.

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