On the issue of a sale certificate under Order 21, rule 94, - purchasers title becomes perfected and complete and his right to possession unimpeachable against the parties to the suit as well as those claiming under them.

 1969 (2) MLJ 274 (T.P.Ramaswami Naidu Vs. Margabandu Mandri), it has been held as follows:-

Where a Court auction purchaser of the property in execution of the mortgage decree applies for delivery of possession of the property, he cannot be resisted by the purchaser from the mortgagor as an independent claimant merely because he has been exonerated in the suit. On the issue of a sale certificate to the purchaser in Court auction under Order 21, rule 94, Civil Procedure Code, his title becomes perfected and complete and his right to possession unimpeachable against the parties to the suit as well as those claiming under them......................................

"On the issue of a sale certificate to the purchaser under Order 21, rule 94 the latters title becomes perfected and complete and his right to possession unimpeachable as against the parties to the suit as well as those claiming under them"
M. Rangasamy v. R.C. Ramasamy & Another 

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