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Supreme Court of India· 21 April 2025

Under the Code of Civil Procedure, 1908, when is a later partition suit barred by Order 2 Rule 2 and by res judicata?

MANJUNATH TIRAKAPPA MALAGI AND ANR v. GURUSIDDAPPA TIRAKAPPA MALAGI (DEAD THROUGH LRS)
2025 INSC 517
Coram: Sudhanshu Dhulia; Ahsanuddin Amanullah
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Answer

Order 2 Rule 2 bars the later suit where it does not include all the properties which were part of the earlier suit. And where the claim concerns property that has already been partitioned as a result of previous litigations, the party cannot re-agitate it, the suit being hit by the principles of res judicata or by constructive res judicata.

Headnote

Code of Civil Procedure, 1908 — Or. 23 rr. 3, 3A — Or. 2 r. 2 — s.96(3) — Compromise decree — Consent decree — Recall application — Res judicata — Joint family property — Code of Civil Procedure, 1908 — Or. 23 r. 3A — Compromise decree — Bar to a fresh suit — Held: No suit lies to set aside a decree on the ground that the compromise on which the decree is based was not lawful; the only remedy is a recall application before the court which recorded the compromise. (¶11, 12) Code of Civil Procedure, 1908 — Or. 23 r. 3 — s.96(3) — Consent decree — Estoppel — Held further: Before passing a decree on a compromise the Court must satisfy itself that the suit has been adjusted by a lawful compromise; a consent decree then operates as an estoppel and is valid and binding until set aside by that court. (¶10, 12) Joint family property — Purchase in the name of a member from family funds — Held further: Property purchased in the name of a member out of family funds is joint family property, and a son whose interest was represented by his father in that partition cannot afterwards call the compromise an act of fraud. (¶7, 8) Code of Civil Procedure, 1908 — Or. 2 r. 2 — Res judicata — Re-agitating a partitioned claim — Held further: A later suit which omits properties that were part of the earlier suit is barred under Order 2 Rule 2, and a claim to property already partitioned cannot be re-agitated; appeal dismissed. (¶14, 15)

In the Court's own words
Paragraph 14In any case, the appellants’ case has no merits. The appellants’ suit is also barred under Order 2 Rule 2 of CPC as it did not include all the properties which were part of their earlier suit. The present suit is also hit by the principles of res judicata or by constructive res judicata as the appellants cannot re-agitate their claim regarding the partition of the suit property, which has already been partitioned as a result of previous litigations. The Trial Court and High Court have dealt with these issues in detail. We are not required to go into the same as we have already given our reasons above for holding that the appellants’ suit is bereft of any merits.
Acts & Sections
Or.23 r.3A Code of Civil Procedure, 1908Or.23 r.3 Code of Civil Procedure, 1908s.96(3) Code of Civil Procedure, 1908Or.2 r.2 Code of Civil Procedure, 1908Or.43 r.1 Code of Civil Procedure, 1908Indian Contract Act, 1872

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Also decided in this judgment
Under the Code of Civil Procedure, 1908, can a compromise decree be challenged by filing a fresh suit?Under the Code of Civil Procedure, 1908, does an appeal lie against a consent decree?Under Order 23 Rule 3 of the Code of Civil Procedure, 1908, what must a court satisfy itself of before passing a compromise decree?Is property bought in the name of one member of a joint family necessarily his separate property?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections