Topic

sham agreement

1 articleLatest March 2026
Clean Hands Doctrine | Concealed Loan Agreement in Sale Deed Bars Specific Performance Relief : SC
Case Law Analysis
|Supreme Court of India

Clean Hands Doctrine | Concealed Loan Agreement in Sale Deed Bars Specific Performance Relief : SC

The Supreme Court ruled that a plaintiff seeking specific performance must disclose all material agreements, including hidden loan arrangements, to satisfy the 'clean hands' doctrine. Failure to reveal a Memorandum of Understanding (MoU) showing the transaction as a loan-security deal rather than a genuine sale agreement disentitles the plaintiff from equitable relief under contract law.