Oral evidence on sale-document execution circumstances may be admitted without varying written terms, preventing manifest injustice through supervisory review.

Oral evidence may be admitted to establish special or compelling circumstances surrounding execution of a registered sale document where it does not contradict or vary its written terms, including the recorded consideration. Sections 91 and 92 of the Indian Evidence Act restrict variation of documentary terms but permit evidence relevant to the circumstances of execution, subject to assessment of its probative value by the reference court. Supervisory jurisdiction under Article 227 may be exercised not only against perverse subordinate-court orders but also to prevent manifest injustice. The evidentiary opportunity concerning valuation-related circumstances therefore remains available for the reference court's evaluation.

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Issues: (i) Whether oral evidence could be permitted to establish the special or compelling circumstances in which a registered sale document was executed; (ii) Whether supervisory jurisdiction under Article 227 of the Constitution of India could be exercised to avert manifest injustice.

Issue (i): Whether oral evidence could be permitted to establish the special or compelling circumstances in which a registered sale document was executed.

Analysis: Sections 91 and 92 of the Indian Evidence Act, 1872 preclude oral evidence that contradicts or varies the written terms of a document, subject to their exceptions, explanations and provisos. Evidence concerning the circumstances that compelled a sale at the stated consideration does not necessarily seek to alter the consideration recorded in the document. An attestor or another person closely acquainted with the execution may be examined where competent to speak to facts relevant to those circumstances; the evidentiary weight of that testimony remains for the reference court to assess.

Conclusion: Oral evidence regarding the circumstances of execution was permissibly allowed; this issue is in favour of the respondent.

Issue (ii): Whether supervisory jurisdiction under Article 227 of the Constitution of India could be exercised to avert manifest injustice.

Analysis: The supervisory jurisdiction is narrow and may be invoked not only where an inferior court's order is perverse, but also where intervention is necessary to prevent manifest injustice. The permission to adduce the relevant evidence was considered necessary to avoid gross injustice, without characterising the subordinate court's order as perverse.

Conclusion: Exercise of supervisory jurisdiction to grant the evidentiary opportunity was justified; this issue is in favour of the respondent.

Final Conclusion: The evidentiary opportunity granted to establish circumstances relevant to valuation remains effective, with its probative value to be determined by the reference court.

Ratio Decidendi: Oral evidence that does not vary the written terms of a document but addresses relevant circumstances of its execution may be admitted, and Article 227 jurisdiction may be exercised to prevent manifest injustice.

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