Under the Doctrine of Harmonious Construction, any ambiguities found within a deed must be interpreted in a manner that aligns with both the remaining clauses of the document and the original intent of the parties involved : Supreme Court
The Hon’ble Supreme Court in the case of "Shri Nashik Panchavati Panjarpol Trust v. The Chairman which involved a dispute over consent terms recorded by the High Court in a land acquisition matter, the Court applied the doctrine of harmonious construction. This doctrine requires interpreting the document as a whole, resolving any ambiguity, whether obvious or hidden, in a manner consistent with the document's overall content and the intentions of the parties involved.
The case revolved around an appeal against a Bombay High Court judgment that had annulled an entire award and referred the matter back to the Reference Court for reconsideration. The dispute arose when the Agricultural Produce Market Committee (the respondent) acquired lands belonging to the appellants. Consent terms were agreed upon in 1997, following an award made in 1996 under Section 11 of the Land Acquisition Act, 1894. These terms covered various aspects, including compensation and possession transfer. The respondent agreed to pay the awarded compensation and take possession of the disputed lands. Both parties also consented to refer the land valuation to the District Court, with a specific reference date of December 17, 1994.
However, the consent terms and the High Court's order did not establish a clear timeline for the appellant to apply to the respondent for a reference under Section 18 of the Act. The Court noted that the respondent exploited this ambiguity and raised objections about the timing of the appellant's application, which was inconsistent with the spirit of the consent terms.
The Court emphasized that this application was a procedural formality, given that the agreed-upon valuation date was established in the High Court's order. The Court criticized the respondent's plea as not aligning with the consent terms and suggested it was motivated by ulterior motives. It further argued that the High Court had given clear directions based on the consent terms, rendering the limitation issue under Section 18 insignificant.
The Court stated that since the agreed-upon valuation date was December 17, 1994, entrusted to the District Court, Nashik, applying for a reference to the Collector under Section 18 was a mere procedural requirement for the appellant.
In light of these clear agreements between the parties, the Supreme Court held that the respondent could not reasonably claim that the appellant's reference application to the District Court was time-barred under Section 18. The Court concluded that the High Court had erred by interfering with the Reference Court's findings and setting aside the entire award.
The Hon’ble Supreme Court's decision upheld the importance of interpreting consent terms in a manner consistent with the overall agreement and the intentions of the parties involved.