The Supreme Court of India clarified the distinction between void and voidable documents under the Limitation Act, 1963. It held that Article 59, providing a three-year limitation period, applies to cancellation of voidable instruments, while Article 65, providing twelve years for possession based on title, applies where the document is void ab initio. Fraud relating to the very character of a document makes it void, whereas fraud concerning its contents may make it voidable. The Court further held that a void document is a nullity and does not require a separate cancellation decree. Under Section 54 of the Transfer of Property Act, a sale without consideration is legally ineffective. Therefore, a plaintiff can seek possession under Article 65 without first seeking cancellation of the void document. The ruling is significant for limitation, fraudulent sale deeds, void transactions, Article 59, Article 65 and Section 54 TPA.