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47.1. In Celir LLP [2024 SCC OnLine SC 3727], the Apex
Court reiterated that the 'Henderson Principle' is a core
component of the broader doctrine of abuse of process,
aimed at enthusing in the parties a sense of sanctity towards
judicial adjudications and determinations. It ensures that
litigants are not subjected to repetitive and vexatious legal
challenges. At its core, the principle stipulates that all claims
and issues that could and should have been raised in an
earlier proceeding are barred from being raised in
subsequent litigation, except in exceptional circumstances.
This rule not only supports the finality of judgments but also
underscores the ideals of judicial propriety and fairness.
47.2. In Celir LLP [2024 SCC OnLine SC 3727], the Apex
Court noticed that there are four situations where, in second
proceedings between the same parties, doctrine res judicata
as a corollary of the principle of abuse of process may be
2025:KER:98698
invoked; (i) cause of action estoppel, where the entirety of
a decided cause of action is sought to be relitigated; (ii)
issue estoppel or, 'decided issue estoppel', where an issue is
sought to be relitigated, which has been raised and decided
as a fundamental step in arriving at the earlier judicial
decision; (iii) extended or constructive res judicata, i.e.,
'unraised issue estoppel', where an issue is sought to be
litigated which could, and should, have been raised in a
previous action but was not raised; (iv) a further extension
of the aforesaid to points not raised in relation to an issue
in the earlier decision, as opposed to issues not raised in
relation to the decision itself. As part of the broader rule
against abuse of process, the 'Henderson Principle' is rooted
in the idea of preventing the judicial process from being
exploited in any manner that tends to undermine its
integrity. This idea of preventing abuse of judicial process is
not confined to specific procedure rules, but rather aligned
to a broader purport of giving quietus to litigation and
finality to judicial decisions. The essence of this rule is that
litigation must be conducted in good faith, and parties
should not engage in procedural tactics that fragment
disputes, prolong litigation, or undermine the outcomes of
such litigation. It is not a rigid rule but rather a flexible
principle to prevent oppressive, unfair, or detrimental
litigation.
47.4. In Celir LLP [2024 SCC OnLine SC 3727], the Apex
Court held that the 'Henderson Principle' operates on the
broader contours of judicial propriety and fairness, ensuring
that the judicial system remains an instrument of justice
rather than a platform for procedural manipulation. Judicial
propriety demands that courts maintain the finality and
integrity of their decisions, preventing repeated challenges
to settled matters. Once a matter has been adjudicated, it
should not be revisited unless exceptional circumstances
warrant such reconsideration. Repeated litigation of the
same issue not only wastes judicial resources but also
subjects the opposing party to unnecessary expense and
harassment. judicial processes are not merely technical
mechanisms but are rooted in principles of equity and
justice.
49. As reiterated by the Apex Court in Celir LLP [2024 SCC
OnLine SC 3727], the 'Henderson Principle' is a core
component of the broader doctrine of abuse of process,
aimed at enthusing in the parties a sense of sanctity towards
judicial adjudications and determinations. It ensures that
litigants are not subjected to repetitive and vexatious legal
challenges. At its core, the principle stipulates that all claims
and issues that could and should have been raised in an
earlier proceeding are barred from being raised in
subsequent litigation, except in exceptional circumstances.
This rule not only supports the finality of judgments but also
underscores the ideals of judicial propriety and fairness.
50. The 'Henderson Principle' operates on the broader
contours of judicial propriety and fairness, ensuring that the
judicial system remains an instrument of justice rather than
a platform for procedural manipulation. Judicial propriety
demands that courts maintain the finality and integrity of
their decisions, preventing repeated challenges to settled
2025:KER:98698
matters. Once a matter has been adjudicated, it should not
be revisited unless exceptional circumstances warrant such
reconsideration. Repeated litigation of the same issue not
only wastes judicial resources but also subjects the opposing
party to unnecessary expense and harassment. judicial
processes are not merely technical mechanisms but are
rooted in principles of equity and justice.