Case of Dr Amit Arya vs Kamlesh Kumari, SC Judgement Dated 19th December 2025. The apex court ruled that a decree for specific performance is not rendered inexecutable merely due to the decree-holder’s delay in depositing the balance consideration after a successful appeal. Applying the doctrine of merger, it held that time limits in a Trial Court’s decree do not survive once it merges with an Appellate Court’s decree that is silent on time. The court restored the execution, noting that delay alone, without a positive refusal to perform, cannot defeat the equitable remedy of specific performance.