Author Details:-

Aastha Sameer Chawan 2nd Year BLS LLB  Shriman Bhagojiseth Keer Law College  SBKLC,Ratnagiri, Maharashtra.

Introduction 

“Res judicata,” the Latin term meaning “a matter already judged,” refers to cases where one party has had a chance to plead their case before a competent court. Once a given dispute is finally settled, neither of the parties can bring this identical case back to court again. This doctrine is one of the very important pledges for the attainment of efficiency and fairness in the legal system. The main purpose of res judicata fundamentally is to stop the insistent recurrence of an issue in a case that has undergone a thorough examination and adjudication. 

In the interests of providing res judicata in order to deter people from again seeking a final judgement on the same issue or matter, it protects both the courts and the parties involved against wasting time and resources adjudicating the same dispute.

Key Elements 

Two main parameters

1. Final Judgement on the Merits: 

 Res judicata can only be used if the previous judgement is final and concerns the substantive issues of the case and not merely technical points such as want of jurisdiction. It should be a judgement on the actual rights and claims of the parties. For example, the court stated in [Sheodan Singh v. Daryao Kunwar](AIR 1966 SC 1332) that only judgments relevant to the merits would hold the requisite weight within the realm of res judicata.

2. Same Parties or Their Representatives:  

For res judicata To apply, the parties in the suit must either be the same persons as those of the previous case or those having some legal connection to the original parties, like representatives or heirs. The Supreme Court in [S.P.A. Annamalay Chettiar v. B.A. Thornhill] (AIR 1931 PC 263),laid great stress on the fact that the parties (or, their legal representatives) were the same.

Common Principles

Res judicata means “it has been decided. It keeps the same problems from being litigated repeatedly by establishing a fair and efficient legal system. So why is that  with a breakdown:

1. Improving the Efficiency of Courts:

This applies especially in judicial proceedings, which also have their own form of res judicata where they will not be overburdened by the same case that has been settled but rather offer the courts to conduct new business. Whatever ends up being decided will be final, but it makes the practice a win-win for both sides in terms of time and expense.In Lal Chand v. Radha Kishan (AIR 1977 SC 789), the Supreme Court observed that it saves vexation to the courts.

2. Anyone who wants to avoid being embroiled in litigation for years

It protects individuals from being dragged to court multiple times on the same issue. Unless there has been an ‘onslaught of litigation’, people can soon move on after a subject remains resolved

Analysis:

The practical application, raises several issues relating to scope and exceptions.

1. Constructive Res Judicata:

It bars parties from raising an issue in the later suit which could have been raised in the former. Constructive res judicata is provided under Explanation IV to Section 11 of the Code of Civil Procedure. In the case of State of U.P. v. Nawab Hussain(AIR 1977 SC 1680), where it was held that in a subsequent proceeding, a party cannot set up new claims if they could have been presented as part of the initial case . It avoids strategic litigation and gets all complaints answered in one go. 

2. Res Judicata in PILs

While res judicata in general applies to PILs, Indian courts realise the flexibility needed in matters of public interest. In Forward Construction Co. v. Prabhat Mandal, (AIR 1986 SC 391), Supreme Court held that while res judicata does apply to the extent of applicability, it would not be a barred fresh filing based on matters of significant public interest.

3. Exceptions to Res Judicata

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Fraud: No judgement obtained by fraud can ever attain any status of legal sanctity, and is thus open to attack even if it is barred due to the doctrine of res judicata(Hazel-Atlas Glass Co. v. Hartford-Empire Co.)

Judgement not in rem: Where the former court was without jurisdiction over either the subject matter or the parties, judgement does not raise res judicata and parties remain free to seek relief from a proper forum (Kalb v. Feuerstein)

Subsequent Changes in Law: Where there has been a marked change in relevant legal principles, courts may open new cases even after judgments are rendered. This was the exception used in L. Chandra Kumar v. Union of India, where the Supreme Court permitted reopening based on a constitutional change of interpretation.

The Doctrine of Res Judicata: still holds relevance in India. Balancing efficiency and fairness in the judgments of Indian courts, its application brings finality in judgments; exhorts respect for courts; thus builds public confidence in the judicial system. In doing so, by avoiding interminable litigation over identical issues, it allows the judiciary and litigants to close their doors to it and free them to better use the resources of the judicial apparatus in relation to unsettled and new disputes.

End Notes

1. Legal Structure of Res Judicata in India:

The res judicata in India is a statutory provision under Section 11 of the Code of Civil Procedure, 1908. According to Section 11 of the Code of Civil Procedure, 1908, no court shall reexamine any matter directly and substantially being heard on a prior suit between the same parties and no court shall try any suit or issue which should be substantially reached if directly or indirectly brought forward for examination.

2. Daryao v. State of U.P., the Case of Landmark:

The Indian Supreme Court gave a more effective turn of the point to the constitutional import of the doctrine by holding that the res judicata applies even to writ petitions under Article 32 of the Constitution of India by preventing abuse of process and judicial consistency in Daryao v. State of U.P.AIR 1961 SC 1457.