The Supreme Court of India reiterated that a fraudulent document must first be classified as void or voidable to determine the applicable limitation period. Where fraud affects the very character of the document, the transaction is void ab initio and Article 65 of the Limitation Act, 1963 applies. Article 59, which prescribes three years for cancellation, applies to voidable documents. The Court clarified that a void document is a nullity in law, so a separate suit for cancellation is unnecessary. The Court further held that a sale without consideration falls within the principle under Section 54 of the Transfer of Property Act. A claimant can therefore seek possession on the basis of title without first obtaining cancellation of a void deed. The case is important for Article 59, Article 65, void ab initio transactions, fraud, limitation and Section 54 TPA.