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Introduction In this 2025 judgment, the Supreme Court reiterated that a compromise decree passed under Order 23 Rule 3 of the Code of Civil Procedure (CPC) can only be challenged by filing a recall application before the same court. A separate suit challenging the validity of the compromise on the ground of coercion or fraud is barred under Order 23 Rule 3A CPC. Order 23 Rule 3 CPC – Compromise of suit. Order 23 Rule 3A CPC – Bar to....
Read MoreRatlam, a princely state that eventually joined the Indian Union, was governed by Sajjan Singh. Sajjan Singh and the Indian government entered into a contract in 1949 that gave him a number of rights and privileges, including the ability to receive a yearly privy purse. The Constitution (26th Amendment) Act, which was passed in 1954, removed the rulers of the former princely states' privy privileges and privy funds. In the Supreme Court, Sajjan Singh contested the legality of the 26th....
Read MoreThe claimant, Hadley, owned a mill featuring a broken crankshaft. The claimant engaged Baxendale, the defendant, to transport the crankshaft to the location at which it would be repaired and then subsequently transport it back. The defendant then made an error causing the crankshaft to be returned to the claimant a week later than agreed, during which time the claimant’s mill was out of operation. The claimant contended that the defendant had displayed professional negligence and attempted to claim for....
Read MoreBench of Justices Manoj Misra and Manmohan Introduction The Supreme Court, in this matrimonial dispute, quashed criminal proceedings under Section 498A IPC against the parents-in-law of the complainant-wife. The Court emphasized the need for courts to be cautious while accepting allegations at face value, especially when made after years of marriage and in the backdrop of divorce litigation. It held that generic and delayed allegations against relatives should not result in criminal trials unless supported by specific instances of cruelty....
Read MoreBench: Justice Pankaj Mithal and Justice Prashant Kumar Mishra Introduction: The Supreme Court in this case reaffirmed that the principle of res judicata applies to criminal proceedings, especially when findings of fact have been recorded by a criminal court in a prior adjudication on merits. The Court held that re-litigation of the same issue in subsequent criminal proceedings is barred, and continuing such proceedings amounts to abuse of the process of law. Section 11, Code of Civil Procedure, 1908....
Read MoreThe Plaintiff had taken a shop on rent from the Defendant. Later, both parties entered into a sale agreement where the Plaintiff agreed to buy the same shop. At the time of the agreement, the Plaintiff paid part of the purchase amount and promised to pay the remaining balance when the official sale deed would be signed. However, after six months, the Defendant sold the shop to another person (a third party) for ₹20,000. In response, the Plaintiff filed a....
Read MoreBench: Justices Surya Kant, Dipankar Datta, and Ujjal Bhuyan Introduction The Supreme Court reiterated that a writ petition under Article 32 of the Constitution cannot be used to challenge the final judgment of the Supreme Court itself. The judgment emphasized the importance of judicial finality, the doctrine of res judicata, and the structured remedies of review and curative petition provided under the Constitution. Facts of the Case The petitioners were retired government employees who were denied pensionary benefits under....
Read MoreIn R.K. Dalmia vs. Delhi Administration (1962), R.K. Dalmia, a prominent businessman, was accused of publishing controversial and sharply critical articles in The Hindustan Times. These articles were said to contain disrespectful language against the government and allegations that were considered potentially harmful to public order and national security. As a result, Dalmia was charged by the Delhi Administration under Section 153A of the Indian Penal Code for promoting enmity between different groups, and under Section 124A for sedition. The....
Read MoreIn this case, Mr. Powell, the plaintiff, was a candidate for the headmaster position at a school. His application was forwarded by the school manager to the appointing authority, which later passed a resolution that basically confirmed Powell’s selection for the role. However, this decision was never officially communicated to him, and everything was still being handled internally. One of the board members overheard discussions about the final decision and informed Powell that he had been chosen. Thinking he had....
Read Morethe Bench Comprising Justices Pankaj Mithal and SVN Bhatti Introduction This Supreme Court judgment deals with the interpretation of Article 58 of the Limitation Act, 1963, focusing on when the limitation period begins in suits for declaration. The Court clarified that limitation begins when the cause of action first arises, not when the plaintiff acquires “full knowledge” of the dispute. The judgment also reiterates the principle that a time-barred suit is liable to be dismissed under Order VII Rule 11(d) CPC,....
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