The Supreme Court has reinforced that quasi-judicial bodies are bound by the principle of res judicata, which prevents the same issue from being relitigated once a decision has attained finality. In a recent judgment, the Apex Court set aside an order by the Rajasthan High Court that had upheld a second ruling from a quasi-judicial body, despite a prior unchallenged and final order on the same matter.
A bench comprising Justices Vikram Nath and Prasanna B. Varale heard the case, where a quasi-judicial body had revisited a matter that was previously settled. The authority had reviewed its own earlier decision while adjudicating a fresh application, leading to a dispute over the validity of the second order.
The High Court, while considering the second order, justified its stance despite the first order having attained finality and remaining unchallenged. This led to an appeal before the Supreme Court, arguing that even quasi-judicial bodies are bound by res judicata and cannot reopen a decided matter through subsequent applications.
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Setting aside the Rajasthan High Court’s ruling, the Supreme Court emphasized that the quasi-judicial authority lacked jurisdiction to entertain a second application when the first order was final and accepted by the parties.
"Once the said order has been accepted by the parties and has attained finality, the Competent Authority would not have jurisdiction to entertain a second application contrary to the findings and directions given by the Competent Authority in the first order," the court stated.
The Court also relied on legal precedents, affirming that quasi-judicial bodies must adhere to the principles of res judicata. Referring to the case Ujjam Bai vs. State of U.P., the Court reiterated:
"The principle of res judicata applies to and binds quasi-judicial authorities. Whenever a judicial or quasi-judicial tribunal gives a finding on law or fact, its findings cannot be impeached collaterally or in a second round and are binding until reversed in appeal or revision or by way of writ proceedings."
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Additionally, the Court cited Abdul Kuddus vs. Union of India & Others, (2019) 6 SCC 604, where it was held:
"It would be incorrect to hold that the opinion of the Tribunal and/or the consequential order passed by the Registering Authority would not operate as res judicata."
The judgment further stressed that no quasi-judicial body has the unilateral authority to overturn the decision of a coordinate or predecessor authority unless duly set aside through legal avenues.
Case Title: M/S FAIME MAKERS PVT. LTD. VERSUS DISTRICT DEPUTY REGISTRAR, CO-OPERATIVE SOCIETIES (3), MUMBAI & ORS.
Appearance:
For Petitioner(s) Mr. Dama Seshadri Naidu, Sr. Adv. Mr. Aman Vachher, Adv. Mr. Amar Khanna, Adv. Mr. Dhiraj, Adv. Mr. Ashutosh Dubey, Adv. Mrs. Anshu Vachher, Adv. Ms. Abhiti Vachher, Adv. Mr. Akshat Vachher, Adv. Ms. Nandni Sharma, Adv. Mr. Amit Kumar, Adv. Mr. Jasvinder Choudhary, Adv. M/S. Vachher And Agrud, AOR
For Respondent(s) Mr. Piyush Dwivedi, AOR Mr. Nipun Katyal, Adv. Mr. Aditya Lele, Adv. Mr. Puneet Pathak, Adv. Mr. Dhananjai Shekhawat, Adv. Mr. Dhananjay Kumar, Adv. Mr. Archit Jain, Adv. Mr. Bharat Bagla, Adv. Mr. Siddharth Dharmadhikari, Adv. Mr. Aaditya Aniruddha Pande, AOR Mr. Abhikalp Pratap Singh, AOR Ms. Aagam Kaur, Adv. Mr. Utkarsh Kumar, Adv. Ms. Shubhangi Agarwal, Adv. Mr. Kartikey, Adv. Ms. Gayatri Agarwal, Adv. Mr. Aditya Bharat Manubarwala, Adv. Mrs. Sarvagnya P Trivedi, Adv. Mr. Naman Maheshwari, Adv. Mrs. Akriti Aditya Manubarwala, Adv. Mrs. Tanishka Grover, Adv. Mr. Bharat Thakorlal Manubarwala, AOR
