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Delhi High Court
Smt Uma Devi vs Satula Devi & Ors on 17 December, 2025
$~
* IN THE HIGH COURT OF DELHI AT NEW DELHI
% Order reserved on: 04.12.2025
Order pronounced on: 17.12.2025
+ LPA 209/2021
SMT UMA DEVI .....Appellant
Through: Mr. Trideep Pais, Sr. Adv. with
Mr. B. Shravanth Shanker,
Adv.
versus
SATULA DEVI & ORS. .....Respondents
Through: Mr. Vikas Singh, Sr. Adv. with
Mr. Varun Singh, Ms. Alankriti
Dwivedi, Ms. Deepeika Kalia,
Mr. Sudeep Chandra &
Ms. Bhumi Sharma, Advocates
for R-2A.
Mr. Ravi Sharma, Mr. Anjani
Kumar Rai, Advs. for R-2
Mr. Sandeep Sethi, Sr. Adv.
with Mr. D. Abhinav Rao, Adv.
for R-4.
Mr. K.K. Rai, Sr. Adv. with
Mr. Anshul Rai, Mr. S.K.
Pandey, Mr. Awanish Kumar,
Mr. Chandrashekhar A.
Chakalabbi, Ms. Sreoshi
Chatterjee, Ms. Basabi Pandey
& Ms. Mallika Ranjan,
Advocates for Respondents
(Aditya Sharma & Akshunya
Sharma).
+ LPA 52/2022
KANCHANA RAI .....Appellant
Through: Mr. Sandeep Sethi, Sr. Adv.
with Mr. D. Abhinav Rao, Adv.
versus
Signature Not Verified
Signed By:JAI
NARAYAN
Signing Date:17.12.2025LPA 209/2021 and connected matter Page 1 of 4
11:58:10
SATULA DEVI & ORS. .....Respondents
Through: Mr. Vikas Singh, Senior
Advocate with Mr. Varun
Singh, Ms. Alankriti Dwivedi,
Ms. Deepeika Kalia,
Mr. Sudeep Chandra &
Ms. Bhumi Sharma, Advocates
for R-2A
Mr. Ravi Sharma, Mr. Anjani
Kumar Rai, Advs. for R-2.
Mr. Trideep Pais, Senior
Advocate along with
Mr. B. Shravanth Shanker,
Advocate for R-4.
Mr. K.K. Rai, Senior Advocate
with Mr. Anshul Rai, Mr. S.K.
Pandey, Mr. Awanish Kumar,
Mr. Chandrashekhar A.
Chakalabbi, Ms. Sreoshi
Chatterjee, Ms. Basabi Pandey
& Ms. Mallika Ranjan,
Advocates for Respondents
(Aditya Sharma & Akshunya
Sharma)
CORAM:
HON'BLE MR. JUSTICE ANIL KSHETARPAL
HON'BLE MR. JUSTICE HARISH VAIDYANATHAN
SHANKAR
ORDER
ANIL KSHETARPAL, J
CM APPL. 74934/2025[For clarification of judgment dated
CM APPL. 69765/2025 and CM APPL. 73989/2025 [For
clarification of judgment dated 16.09.2025] in LPA 52/2022
1. By way of the present Applications, the Applicants are seeking
clarification of the detailed common judgment passed by this Bench
on 16.09.2025, wherein as many as 11 Letter Patent Appeals (LPAs),
one Regular First Appeal (RFA) and one First Appeal against the
order (FAO), were finally disposed of, while issuing certain
directions.
2. In the aforestated 11 LPAs, the orders dated 02.06.2021,
23.07.2021, 19.07.2021, 04.06.2021, 29.10.2021, 06.01.2022,
11.07.2022, were challenged, whereas the RFA and FAO assail the
validity of judgments dated 10.04.2023 and 20.11.2023, respectively.
3. The present applications seeking clarification have been filed
by Smt. Uma Devi and Smt. Kanchana Rai. It has been argued that the
alleged factual narrations and objections recorded in the interim orders
passed by the learned Single Judge [hereinafter referred to as 'LSJ']
from time to time, insofar as they relate to the parties including the
Applicant, should not affect the various proceedings pending before
the Court. It is further contended that none of the parties should be
allowed to use such interim observations recorded in those orders to
the prejudice of the Applicant.
4. It is submitted that unless such clarification issued, the rights of
the Applicant may be gravely prejudiced. According to the Applicant,
said clarification if not issued, would result in an inconsistency with
the intention of this Court to relegate the matter back to the Probate
Court to adjudicate the Probate Petition independently.
5. This Court has considered the submissions; however, we are of
the view that there is in fact no requirement to issue any clarification
with respect to the judgment dated 16.09.2025. It is well settled that
the interim orders passed by a Court from time to time during the
pendency of the petitions, and the final judgment passed at the time of
their disposal, merge into the final Appellate Order/Judgment passed
by the Appellate Court/Forum. It is for this reason that the interim
orders cease to exist in law, once the final judgment is delivered.
6. In other words, all the orders either interim or not passed by the
Court during the pendency of the writ petition, probate petition or suit
stood merged in the one final judgment delivered by this Bench on
16.09.2025.
7. Accordingly, once the aforesaid orders have merged in the final
judgment by this Bench on 16.09.2025, we do not find it appropriate
to issue any clarification.
8. With these observations, the present applications are disposed
of.
ANIL KSHETARPAL, J.
HARISH VAIDYANATHAN SHANKAR, J.
DECEMBER 17, 2025/sp/hr
