Compromise decree challenge fails where undue influence is unparticularised and no disputed fact warrants trial

A compromise decree carries judicial imprimatur and cannot be set aside on vague or general allegations of undue influence. A party seeking such relief must plead full particulars and disclose material showing that the compromise was not voluntary or lawful. Here, the applicant had earlier executed a registered relinquishment deed, lacked subsisting title when the suit was filed, personally supported the compromise in court, and later relied on the decree in other proceedings. Those facts, taken with the deficient pleadings, did not raise a disputed question requiring trial or evidence, so the application was rightly rejected without recording evidence.

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Issues: Whether the application to set aside the compromise decree on the ground of undue influence disclosed a case requiring trial and evidence.

Analysis: A compromise decree carries the court's imprimatur, and a challenge to it cannot rest on vague or general allegations. The applicant had earlier executed a registered relinquishment deed, had no subsisting title when the suit was filed, had personally appeared in court to support the compromise, and had subsequently relied on the decree in other proceedings. The pleadings did not contain the full particulars required for a plea of undue influence, nor did they disclose material showing that the compromise was not voluntary or lawful. In these circumstances, no disputed question of fact warranting trial arose, and the court below was justified in rejecting the application without recording evidence.

Conclusion: The challenge to the compromise decree failed, and no opportunity to lead evidence was required.

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