Interim Relief Resembling Final Relief Is Not Absolutely Barred: Allahabad High Court

An appellate court's removal of a temporary injunction protecting the claimed chairman of a charitable trust

Dr. Amod Kumar Sachan challenged allegedly fabricated trust minutes removing him as chairman and restructuring Hind Charitable Trust. The trial court restrained interference until a fresh election. The appellate court discharged the injunction, invoking final-relief and res judicata reasoning.

Issue and applicable law

The central question was an appellate court's removal of a temporary injunction protecting the claimed chairman of a charitable trust.

A first appellate court has co-extensive power but must address the trial court's reasons and apply the three injunction tests without conducting a mini-trial. Legal propositions cannot be applied in isolation from the factual record.

Court's reasoning

The Court held that similarity between interim and final relief creates no absolute jurisdictional bar, though the prima facie threshold becomes stricter. Its principal reason was that the appellate court failed to engage with the trial court's findings on disputed meeting minutes, notice, balance of convenience and irreparable injury.

Decision and practical effect

The abstract approach to final relief was rejected and the appellate order was interfered with under Article 227.

The ruling is significant because it clarifies how the stated legal standard should be applied to comparable disputes without extending the decision beyond the facts reported by the source.

Case details

• Case: Proceedings arising from Regular Suit No. 455 of 2026 concerning Hind Charitable Trust
• Court: Allahabad High Court
• Judges: Justice Jaspreet Singh
• Source: https://www.livelaw.in/high-court/allahabad-high-court/allahabad-high-court-orderxxxix-cpc-grant-final-relief-interim-stage-549293