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Teja Singh vs Union Territory Of Chandigarh And Ors. on 30 September, 1983

This rule provides that where issues both of law and fact arise in the same suit and the Court is of the opinion that the suit can be disposed of an issue of law only then the same can be tried as a preliminary issue provided it relates to the jurisdiction of the Court or a bar to the suit created by any law for the time being in force. In this case, plea of the petitioner is that the suit would be barred by a bar to the suit created by the principle of res judicata. Principle of res judicata is that where a Court of competent jurisdiction has determined the controversy after hearing the parties or the parties claiming through them the subsequent on the same cause of action between the parties is barred. Respondent had filed a civil writ petition in this Court which had been dismissed. Case of the petitioner is that the relief claimed in the writ petition filed in this Court was directly and substantially the same which has been claimed in the suit. Teja Singh's case (Supra) provides that where a writ petition has been dismissed after hearing the parties then the subsequent suit in the same cause of action would be barred. The evidence required on such an issue would be minimal i.e. a certified copy of the pleadings of the parties in the writ petition can be placed on record by way of an affidavit and the trial Court after going through the pleadings of the parties and the order passed by the High Court can determine as to whether the suit is barred by the principle of res judicata or not. No useful purpose would be served by postponing this issue and tried with the other issues as it might prolong the litigation unnecessarily.
Supreme Court of India Cites 5 - Cited by 33 - Full Document

Ram Kali And Anr. vs Sohan Lal on 23 August, 1984

8. No doubt the question of res judicata is a mixed question of law and fact which may necessitate taking of evidence also in the given facts of a case. It would depend on the facts and circumstances of each case as to whether the issue of res judicata tried as a preliminary issue or not. I am reframing myself from making any comments on the merits of the controversy as to whether the suit would be barred by res judicata or not because the observations made by me may prejudice either of the parties to the suit. The facts in Smt. Ram Kali's case (Supra) were different from the present case. In this case, the pleadings in the writ petition and the order passed by the High Court in the writ petition has to be examined as to whether the suit is barred by the principle of res judicata or not. Certified copies of the pleadings and the order passed by the High Court can be produced by the parties through affidavits which can be taken as evidence which would decide as to whether the suit is barred by the principle of res judicata or not. The evidence which is to be recorded under the circumstances would be minimal and save a lot of botheration of the parties in the given facts and circumstances of the present case.
Punjab-Haryana High Court Cites 3 - Cited by 7 - Full Document
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