Mandatory interim injunctions need a strong case, irreparable injury and favourable balance of convenience; appellate interference is limited.

A suit under Section 6 of the Specific Relief Act is a summary remedy limited to prior possession and illegal dispossession, and it does not determine title or better possessory rights. Mandatory interim relief is an exceptional equitable measure, available only on a strong prima facie case, irreparable injury, and a balance of convenience in favour of the applicant. An appellate court should interfere with a trial court's discretionary refusal or grant of interim relief only if the decision is arbitrary, capricious, perverse, or contrary to settled principles. Where the trial court has taken a possible judicial view on the material, appellate substitution is unwarranted.

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Issues: Whether the appellate court could interfere with the trial court's refusal to grant mandatory interim relief in a suit under Section 6 of the Specific Relief Act, 1963, and whether the standards governing interlocutory mandatory injunctions were satisfied.

Analysis: A suit under Section 6 is a summary remedy confined to the question of prior possession and illegal dispossession, and it is not meant to decide title or better rights of possession. Mandatory interim relief is an exceptional equitable remedy that requires a strong case for trial, irreparable or serious injury, and a balance of convenience in favour of the applicant. In an appeal against a discretionary order, the appellate court may interfere only if the trial court's view is arbitrary, capricious, perverse, or contrary to settled principles. If the trial court has taken a possible and judicial view on the materials before it, the appellate court should not substitute its own assessment merely because another view is possible.

Conclusion: The appellate court was not justified in reversing the trial court's refusal of mandatory interim relief. The order of the trial court was restored and the interim relief granted by the appellate court was set aside.

Final Conclusion: The decision reaffirms that discretionary interim orders will not be interfered with in appeal unless the lower court's exercise of discretion is shown to be legally unsustainable, and that mandatory interim injunctions require a distinctly higher threshold than ordinary interlocutory relief.

Ratio Decidendi: An appellate court cannot interfere with a trial court's discretionary refusal or grant of interim relief unless the discretion was exercised perversely, arbitrarily, or in disregard of settled principles, and mandatory interim injunctions may be granted only on a strong case, irreparable injury, and favourable balance of convenience.

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