The Himachal Pradesh High Court on Tuesday set aside a lower court order that had refused to club four related civil suits involving land and ownership disputes between Hardeep Singh and Manohar Lal. The hearing took place before Justice Ajay Mohan Goel, who noted that the trial court had “completely misdirected” itself by assuming that Indian law does not allow consolidation of similar cases.
Background
The dispute involves multiple civil suits filed by both sides over alleged overlapping land claims. Hardeep Singh had sought to consolidate four suits being heard separately, arguing that all of them deal with overlapping issues and parties. Singh’s counsel told the court that handling them separately would lead to repetition of witness statements, unnecessary delays, and possibly contradictory outcomes.
However, the trial court rejected the request on April 25, 2023. The judge at the lower level had said that the Civil Procedure Code (CPC) does not provide any provision for “clubbing” of suits, and Section 10 of the CPC, which deals with halting a later suit when another on the same issue is already pending, cannot be used to merge cases.
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Court’s Observations
Justice Goel disagreed strongly with this reasoning. The bench observed, “The learned Trial Court has completely misdirected itself by returning the findings that there is no concept of consolidation or clubbing of cases.”
He clarified that Section 10 CPC deals only with preventing parallel proceedings on the same matter - it does not block courts from consolidating suits where issues are connected. The judge explained that consolidation is routinely allowed when it helps avoid conflicting judgments and reduces unnecessary repetition of evidence.
The bench also noted that the purpose of consolidation is practical efficiency, not legal technicality.“In order to avoid multiplicity of recording of evidence and adjudication in isolation of one lis which may have bearing on the other lis, cases are clubbed and consolidated,” the Court noted.
However, the judge was careful to state that consolidation is not automatic. Whether the suits should actually be merged must depend on the specific facts, including the similarity of claims and reliefs sought.
Decision
Declaring the lower court’s ruling “not sustainable in the eyes of law,” Justice Goel quashed the impugned order and revived the consolidation application. The trial court has now been directed to reconsider the request afresh, based strictly on the contents of the application and replies filed by both sides.
The High Court also clarified that it was not expressing any view on the merits of whether consolidation should happen, leaving that decision to the trial court.
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The parties have been directed to appear before the trial court on 17 November 2025.
The matter ends at the High Court’s direction to re-decide the application.
Case Title: Hardeep Singh vs. Manohar Lal & Others
Court: High Court of Himachal Pradesh, Shimla
Case Number: CMPMO No. 325 of 2023
Decision Date: 28 October 2025
