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‘Signature only on last page’: Punjab & Haryana HC rejects realtor’s plea over 2007 land deal

Justice Nidhi Gupta of the Punjab and Haryana High Court dismisses the appeal filed by a property dealer, upholds the fraud claim made by three widows, and denies earnest money refund.

4 min readChandigarhDec 17, 2025 03:44 PM IST

In his judgment, Justice Sumeet Goel emphasised that the paramount consideration in all matters relating to the custody of a minor is the welfare and best interests of the child. (File Photo)

The Punjab and Haryana High Court on Wednesday dismissed a second appeal filed by a property dealer seeking the enforcement of an agreement to sell land, holding that the document dated June 23, 2007, was riddled with suspicious features that pointed to fraud on the defendants, three widows.

In her judgment, Justice Nidhi Gupta examined the three-page agreement made at Pataudi in Gurgaon and noted that only the last page bore the signatures of the defendants and the plaintiff, Satish Kumar Saini.

“Admittedly, pages 1 and 2 of the Agreement in question do not bear the signatures of the defendants or the plaintiff. Page 2 of the Agreement contains the most important terms and conditions of the Agreement, such as the total sale consideration, earnest money paid, date of execution of sale deed, etc., which have not been signed by either party,” the court observed.

The judge highlighted further irregularities: overwriting on the date for execution of the sale deed without signatures, handwritten additions of witnesses’ names and the agreement date on page 3, wide spacing suggesting adjustment for pre-obtained signatures, and a visible difference in one defendant’s signature compared to her written statement.

Relying on a recent Supreme Court ruling in Lakha Singh v. Balwinder Singh (2024), Justice Gupta held that the absence of signatures on the first two pages created “a strong inference fortifying the contention” of fraud. The Supreme Court had observed that when only the last page is signed, and earlier pages contain essential terms, it suggests signatures may have been taken on blank stamp paper and contents filled later.

Rs 50-lakh property agreed to be sold for Rs 9 lakh

The court also found the deal unconscionable. The suit land, measuring 5 kanal and 17 marla, was allegedly agreed to be sold for Rs 9 lakh, while the defendants had consistently claimed its market value in 2007 was around Rs 50 lakh. “The alleged Agreement is also suspicious, unconscionable, inequitable and unenforceable as property worth Rs 50 lakhs was allegedly agreed to be sold for only Rs 9 lakhs,” the judgment stated. No explanation was offered for the low price, nor was any financial distress on the defendants’ part pleaded.

The trial court had refused specific performance—a court order directing a party to carry out their obligations as agreed in a contract—but ordered a refund of Rs 3 lakh in earnest money with interest. The first appellate court accepted that the agreement was executed but refused specific performance, citing an earlier sale deed that was later declared void in a separate suit.

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The high court, however, restored the trial court’s finding that the agreement itself was not proved and went further: it rejected even the refund of earnest money because the plaintiff had not sought that relief in the plaint and produced no receipt or proof of the alleged cash payment.

“Plaintiff has produced no proof that such payment was made by him. It is the own case of the plaintiff that the said alleged payment was made in cash… Even no receipt has been produced by the plaintiff to prove the payment,” the court noted, adding that as a property dealer, the plaintiff was expected to obtain a receipt.

Defendants’ vulnerability as widows

The defendants, Laxmi Devi and others, argued that the plaintiff had exploited their vulnerability as widows. They claimed their signatures had been taken on blank paper under the pretext of helping locate their land after their husbands’ death. The court accepted that the cumulative irregularities cast “grave shadow of doubt upon the authenticity of the Agreement”.

Consequently, the high court dismissed regular second appeal No. 3199 of 2013 filed by Satish Kumar Saini, while allowing the cross-appeal of the defendants, leaving the plaintiff with no relief.

Manraj Grewal Sharma

Manraj Grewal Sharma is a senior journalist and the Resident Editor of The Indian Express in Chandigarh, where she leads the newspaper’s coverage of north India’s most politically and institutionally significant regions. From Punjab and Haryana to Himachal Pradesh and the Union Territory of Chandigarh, she oversees reporting at the intersection of governance, law, politics and society. She also reports on the diaspora, especially in Canada and the US. With a career spanning journalism across several countries, academia and international development, Manraj brings a rare depth of perspective to regional reporting. She is widely regarded as a leading chronicler of Punjab’s contemporary history and socio-political evolution, particularly its long shadow of militancy, federal tensions and identity politics. Her book, Dreams after Darkness, remains a definitive account of the militancy years and their enduring aftermath. Professional Background & Expertise A gold medalist in mass communication and a post-graduate in English literature, Manraj has a multifaceted career spanning journalism, academia, and international development. She was also awarded a fellowship by National Foundation of India and did several in-depth pieces on Manipur. Internationally, she has reported from Israel, US, UK, Myanmar, and Mauritius Her key focus areas include: Regional Politics, History, Agriculture, Diaspora, and Security. Of late, she has started focusing on Legal & Judicial Affairs: Much of her recent work involves reporting on high-stakes cases in the Punjab and Haryana High Court, ranging from environmental policy to civil rights. International Consulting: She previously served as a consulting editor for the Asia Pacific Adaptation Network and a publishing consultant for the Asian Development Bank (ADB) in Manila. Academia: For five years, she was the managing editor of Gender, Technology and Development, a peer-reviewed international journal at the Asian Institute of Technology, Bangkok. Recent Notable Articles (Late 2025) Her recent reportage focuses heavily on judicial interventions and regional governance: 1. Environment & Governance "‘NGT can’t test legality of policy’: HC hears challenge to Punjab’s ‘Green Habitat’ plan" (Dec 22, 2025): Covering a critical legal battle over whether the National Green Tribunal has the authority to strike down a state policy regularizing farmhouses on delisted forest land. "High court pulls up Punjab poll panel over audio clip probe" (Dec 10, 2025): Reporting on judicial concerns regarding the transparency and fairness of local body elections. 2. Legal Rights & Social Welfare "HC issues notice to Punjab, Haryana over delay in building old age homes" (Dec 22, 2025): Reporting on a contempt petition against top officials for failing to establish government-run homes for the elderly as promised in 2019. "Victims can appeal acquittals in sessions court without seeking special leave" (Dec 19, 2025): Highlighting a significant procedural shift in criminal law following a Supreme Court ruling. "HC upholds benefits for Punjab FCI officer acquitted in 20-year-old bribery case" (Dec 19, 2025): A report on the concept of "honourable acquittal" and its impact on employee benefits. 3. Human Rights & Identity "As Punjab denies parole to MP Amritpal Singh, HC asks it to submit ‘foundational material’" (Dec 1, 2025): Covering the legal proceedings regarding the radical preacher and sitting MP's request to attend Parliament. "Protecting life paramount: HC backs Muslim woman in live-in after verbal divorce" (Nov 6, 2025): Analyzing judicial protections for personal liberty in the context of traditional practices. Signature Beats Manraj is recognized for her ability to decode complex judicial rulings and relate them to the everyday lives of citizens. Whether it is a 30-year-old land battle in Fazilka or the political implications of Kangana Ranaut’s candidacy in Mandi, her writing provides deep historical and regional context. Contact @grewal_sharma on X manrajgrewalsharma on Instagram ... Read More