Supreme Court Stresses Strict Adherence to Clear Language in Interpreting Legal Instruments

In a notable case of Kamal Kishore Sehgal v. Murti Devi, (2024 SCC OnLine SC 2582), dated September 19, 2024, regarding interpretation of sale deeds, the Hon’ble Supreme Court of India ruled that when the language in a legal instrument or document is clear and unequivocal, the interpretation should rely solely on the explicit wording, without considering external factors or circumstances.

The dispute arose from the interpretation of sale deeds related to a piece of land divided into two portions, A and B, sold to the plaintiff (respondents) and defendants (appellants), respectively. The sale deed for portion A, included a provision stipulating that a 15-foot-wide common passage on its side would be left for the common use of both parties.  However, the sale deed for Portion B did not include any such stipulation.

The plaintiffs sought a permanent injunction, asserting that the common passage included not only the one adjacent to portion A but also extended to the passage running across portion B. Initially, the Hon’ble Trial Court, Delhi, dismissed the plaintiffs’ suit. However, the Hon’ble High Court of Delhi later reversed this decision, ruling in favor of the plaintiffs.

The Hon’ble Supreme Court of India ruled in favor of the defendants, reinstating the original judgement of the Hon’ble Trial Court, Delhi. It reaffirmed that when the language of a legal instrument is clear and unambiguous, the interpretation should follow its ordinary and common meaning. External circumstances or presumed intentions should not alter the literal construction of the document.

The Hon’ble Supreme Court of India found that the Hon’ble High Court of Delhi had erred by extending the interpretation of the common passage to include the entire alignment from X-Z1, which was not supported by the language of the sale deeds or the attached map. The map attached to the sale deeds and the explicit language clearly indicated that the common passage was limited to X-Y, which was intended for shared use by both parties, without extending into portion B owned by the defendants.