Dr. Amod Kumar Sachan v. Richa Mishra and 6 Others, 2026

Dr. Amod Kumar Sachan instituted Regular Suit No. 455 of 2026 before the Civil Judge (Senior Division), Lucknow.

The dispute concerned the management and administration of the Hind Charitable Trust, a public charitable trust created through a registered trust deed dated 9 December 2004.

The trust had seven founder trustees, and the petitioner claimed to have continuously served as its Chairman.

The petitioner alleged that while he was in Delhi, certain trustees and other persons broke open the locks of the Trust's administrative offices and removed important records.

He further alleged that minutes dated 3 February 2026 had been fabricated to remove him as Chairman.

According to the petitioner, those minutes were also intended to take away his executive, administrative and financial powers and transfer management of the hospitals to respondent No. 1.

He additionally challenged minutes dated 16 January 2026, through which resignations allegedly accepted by the Board in 2004 were purportedly revoked and Smt. Sarojini Verma was inducted as a founder trustee.

The petitioner sought a declaration that both sets of minutes were void ab initio.

He also filed an application under Order XXXIX Rules 1 and 2 CPC seeking temporary injunction.

On 2 April 2026, the Trial Court restrained the defendants from interfering with the petitioner's functioning as Chairman until a fresh election was conducted in accordance with the trust deed.

Two appeals were thereafter filed under Order XLIII Rule 1(r) CPC against the injunction order.

The First Appellate Court allowed the appeals on 8 July 2026 and discharged the injunction.

The Appellate Court took the view that the Trial Court had effectively granted final relief at the interim stage.

It also relied upon observations contained in its earlier interim order dated 10 April 2026 and treated them as having a res judicata effect.

The Appellate Court further considered discrepancies concerning the meeting agenda and proceedings to be an “accidental omission” under the trust deed.

It also held that the petitioner had allegedly not approached the court with clean hands and had failed to correct the array of parties as directed.

The petitioner challenged the Appellate Court's order before the Allahabad High Court under Article 227 of the Constitution.

The respondents argued that an injunction is an equitable and discretionary relief and that the petitioner had allegedly withheld material facts.

They further alleged that the petitioner had opened bank accounts on the basis of a fabricated trust deed through which Trust funds had allegedly been siphoned.

The High Court examined whether the First Appellate Court had correctly interfered with the Trial Court's injunction order.

The Allahabad High Court allowed the petitions and set aside the First Appellate Court's order dated 8 July 2026.

The Court held that the proposition that an interim relief resembling the final relief can never be granted is legally incorrect.

The Court explained that whether such an injunction should be granted depends upon the facts and circumstances of each case.

The Trial Court had considered the three traditional requirements for temporary injunction: prima facie case, balance of convenience and irreparable injury.

The Trial Court had also identified discrepancies in the minutes dated 3 February 2026, which raised doubts concerning the authenticity of the meeting.

The Trial Court had noted the absence of an agenda for the relevant meetings and the removal of the petitioner allegedly on the basis of an FIR without providing show-cause notice or conducting an inquiry.

The High Court held that the First Appellate Court possessed powers co-extensive with those of the Trial Court while examining the injunction.

However, it was required to properly consider the findings and reasons recorded by the Trial Court before arriving at a contrary conclusion.

The Appellate Court could not simply substitute its own view without demonstrating why the Trial Court's reasoning was erroneous.

The High Court rejected the Appellate Court's reliance upon its earlier interim observations as creating a form of res judicata.

The Court clarified that observations made while entertaining an appeal or granting interim relief are generally tentative in nature and do not bind the court at the stage of final adjudication.

The Court also rejected the approach concerning the alleged “accidental omission”.

It held that such a plea should ordinarily be properly pleaded and established by evidence, rather than being conclusively determined at the interim stage.

Regarding the clean hands principle, the High Court held that the Appellate Court should have established a nexus between the alleged non-disclosure and the petitioner's entitlement to injunction.

The High Court reiterated that Article 227 is supervisory, and it does not ordinarily permit the High Court to re-appreciate evidence or substitute its own factual findings.

However, the High Court could intervene where the subordinate court had failed to apply the correct legal principles.

The First Appellate Court's order dated 8 July 2026 was therefore set aside.

The two appeals were restored to the First Appellate Court for fresh consideration.

The parties were directed to appear before the First Appellate Court on 9 September 2026.

The appeals were directed to be decided afresh, preferably within three weeks.

Since restoration of the appeals revived the Trial Court's injunction, the High Court issued interim safeguards concerning the Trust's bank accounts.

The accounts were directed not to be operated singly or jointly by the petitioner and respondent No. 1.

Instead, they were to be operated jointly by the petitioner and Shri Vikram Singh, a founder trustee.

Withdrawals were restricted to salaries, statutory dues and similar necessary payments.

Details of such withdrawals were directed to be placed before the First Appellate Court.

The petitions were accordingly allowed.

The judgment clarifies an important principle concerning interim injunctions: similarity between interim and final relief does not automatically make the interim order impermissible.

Courts must examine whether extraordinary interim protection is justified by the factual circumstances and urgency of the dispute.

The decision reinforces the traditional three-fold test of prima facie case, balance of convenience and irreparable injury.

The judgment places significant emphasis on the duty of an appellate court to engage with the reasoning of the Trial Court.

An appellate court may disagree with the Trial Court, but it must explain why the findings are legally or factually unsustainable.

The ruling also cautions against treating interim observations as final findings.

Courts frequently make tentative observations while deciding interlocutory applications; treating such observations as binding at the final stage could improperly restrict subsequent adjudication.

The Court's discussion of res judicata therefore reinforces the distinction between provisional findings and final determinations.

The ruling also highlights the importance of pleadings in civil litigation.

A party seeking to rely on a contractual or trust-deed exception such as an “accidental omission” should ordinarily plead the factual basis for that contention and establish it through appropriate evidence.

The judgment further demonstrates that the clean hands doctrine cannot be invoked mechanically.

The alleged suppression must have a meaningful connection with the relief sought before it can justify denial of equitable relief.

The Court's approach under Article 227 is also significant: supervisory jurisdiction is not intended to function as a second appeal for re-appreciation of evidence.

Nevertheless, supervisory intervention is justified where the subordinate court has proceeded on an incorrect legal principle or failed to exercise jurisdiction properly.

The temporary restrictions on the Trust's bank accounts demonstrate the Court's attempt to preserve the subject matter of the dispute while the injunction appeals are reconsidered.

Overall, the judgment seeks to balance judicial restraint, procedural fairness, equitable relief and effective protection of disputed trust assets.