Court case(1992) 1 SCC 719

Property of the respondents' family had been sold in execution of a decree and the appellants, as purchasers, were about to be put in possession. The respondents filed a suit challenging the sale and applied for a temporary injunction to restrain delivery of possession. The trial court refused it; the High Court granted it. The purchasers appealed to the Supreme Court.

The Supreme Court set aside the injunction and laid down the governing principles. The court must be satisfied of three things: (1) a prima facie case, meaning a serious question to be tried with a probability of the plaintiff being entitled to relief, which is not the same as a prima facie title to be proved at the trial; (2) that the balance of convenience lies in favour of granting the injunction, the court weighing the comparative mischief or inconvenience to each side; and (3) that the plaintiff would otherwise suffer irreparable injury, which means not that there must be no physical possibility of repairing the injury but that it must be a material one that cannot be adequately compensated in money. The grant is discretionary and the three conditions must co-exist.