Caretaker possession cannot defeat true ownership where no independent right, lease, or licence is proved.

A caretaker or gratuitous occupant cannot maintain an injunction suit against the true owner where the owner's title is established on the documentary record and the occupant shows no independent right, lease, licence, or valid family arrangement. Possession held as a caretaker, agent, servant, or watchman is possession on behalf of the owner and does not create any proprietary interest or entitlement to resist recovery of possession under Section 6 of the Specific Relief Act, 1963. The Court stressed careful scrutiny of pleadings and documents in injunction matters and held that due process is satisfied when rights are adjudicated by a competent court. The respondent's injunction claim was therefore not maintainable.

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Issues: Whether a person shown to be only a caretaker or gratuitous occupant can maintain a suit for injunction against the true owner, and whether the courts below erred in protecting such possession.

Analysis: The title to the suit property stood established in favour of the appellant on the documentary record, while the respondent did not assert any independent title. The reasoning proceeded on the principle that possession of a caretaker, agent, servant, watchman, or other person allowed to stay gratuitously is possession on behalf of the owner and does not create any right or interest in the property. A person in such custody cannot resist the claim of the true owner by invoking Section 6 of the Specific Relief Act, 1963, and the Court also stressed that protection by injunction is unavailable where the claimant cannot show a valid subsisting rent, lease, or licence arrangement. The material on record did not establish the alleged family arrangement, and the respondent's continued occupation could not displace the appellant's ownership and right to recover possession. The Court also emphasized that pleadings and documents must be scrutinised carefully in injunction matters, and that due process of law is satisfied when the rights of the parties are adjudicated by a competent court.

Conclusion: The respondent's injunction suit was not maintainable against the true owner, and the judgments of the courts below were set aside in favour of the appellant.

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