Interim injunctions against transferees require hearing, reasons, and settled relief tests before restraining alienation or construction.

Interim injunctions restraining alienation and construction on suit land were set aside because affected owners and transferees were not given an effective hearing, and the orders were made without recorded reasons. The Court emphasised that interlocutory relief must satisfy the settled tests of prima facie case, balance of convenience and inconvenience, and irreparable injury. It also noted the plaintiff's prolonged silence and the equitable position of transferees, while recognising only limited protection under lis pendens. The restraint against third-party transferees could not be maintained, and the earlier order was restored.

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Issues: Whether the interim injunction orders restraining alienation and construction on the suit land, including against transferees who were not parties to the appeal, were sustainable in law.

Analysis: The interim orders were passed without affording an effective opportunity of hearing to the owners and transferees whose rights were directly affected. The order restraining further construction on the transferred plots was made in haste and without recording reasons, even though the transfers had been made when no restraint order was operating. In granting interlocutory relief, the settled requirements of a prima facie case, balance of convenience and inconvenience, and irreparable loss and injury had to be considered. The Court also took into account the long silence of the plaintiff for nearly 19 years, the equities arising from the transferees' position, and the limited protection available under the principle of lis pendens.

Conclusion: The interim injunction orders dated 22 April 2008 and 7 May 2008 were unsustainable and were set aside. The restraint against the transferees could not be maintained, and the original order dated 29 February 2008 was restored.

Ratio Decidendi: An interlocutory injunction affecting owners and third-party transferees cannot be sustained unless the Court applies the settled tests for interim relief, gives affected parties a fair opportunity of hearing, and records reasons showing why the equitable balance justifies restraint.

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