The Supreme Court has re-iterated that Execution Petitions must be disposed off within six months. If courts are unable to do so, they must record reasons behind it.

In Bhoj Raj Garg v. Goyal Education and Welfare Society and Ors., the Petitioner approached the Apex Court in appeal contending that the Execution Court is not abiding by the directions issued in Rahul S. Shah v. Jinendra Kumar Gandhi (2021) 6 SCC 418. The execution proceedings were pending for over 14 years.

In Rahul S. Shah, the Apex Court had issued a direction that Executing Courts must dispose of Execution Proceedings within 6 months from the date of filing, which may only be extended by recording reasons in writing for such delay. It also included directions, some of which are:

1. In suits relating to delivery of possession, the court must examine the parties to the suit under Order X in relation to third party interest and further exercise the power under Order XI Rule 14 asking parties to disclose and produce documents, upon oath, which are in possession of the parties including declaration pertaining to third party interest in such properties.
2. In appropriate cases, where the possession is not in dispute and not a question of fact for adjudication before the Court, the Court may appoint Commissioner to assess the accurate description and status of the property.
3. After examination of parties under Order X or production of documents under Order XI or receipt of commission report, the Court must add all necessary or proper parties to the suit, so as to avoid multiplicity of proceedings and also make such joinder of cause of action in the same suit.
4. Under Order XL Rule 1 of CPC, a Court Receiver can be appointed to monitor the status of the property in question as custodia legis for proper adjudication of the matter.