Quasi-Judicial Bodies Bound By Principles Of Res Judicata : Supreme Court Reiterates

Observing that the quasi-judicial bodies are also bound by the principles of res-judicata to prevent re-litigation on the same issue, the Supreme Court set aside the Rajasthan High Court's order which had upheld the second order passed by the quasi-judicial body despite the first order passed by the quasi-judicial body was not followed and remained unchallenged.

The bench comprising Justices Vikram Nath and Prasanna B Varale heard the case where the quasi-judicial body had relitigated the same issue which was decided in an earlier application filed before it. The quasi-judicial authority had reviewed an earlier order passed by it while adjudicating a second application.

The High Court justified the second order of the quasi-judicial authority despite the earlier being not followed and remained unchallenged thereby attaining finality.

Challenging the High Court's decision, an appeal was preferred before the Supreme Court contending that even the quasi-judicial bodies are bound by the principle of res-judicata, and the issue decided by the quasi-judicial body via its initial order cannot be relitigated upon subsequent filing of application.

Setting aside the High Court's decision, the judgment authored by Justice Nath noted that the High Court erred in validating the second order passed by the quasi-judicial body even when the first attained finality.

“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 observed.

“It has been settled by this Court that the principle of res judicata applies to and binds quasi-judicial authorities. This Court in Ujjam Bai vs. State of U.P. has taken the view that principles of res judicata equally apply to quasi-judicial bodies. 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. The characteristic attribute of a judicial act or decision is that it binds, whether right or wrong. Thus, any error, either of fact or law, committed by such bodies cannot be controverted otherwise by way of an appeal or revision or a writ unless the erroneous determination relates to the jurisdictional matter of that body.”, the court added.

Also, reliance was placed on the case of Abdul Kuddus vs. Union of India and others, (2019) 6 SCC 604 where the court held that “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 Court added that “any quasi-judicial Authority would not ordinarily have the power to unilaterally take a contrary view taken by a coordinate or predecessor authority at an early point in time.”

Applying the aforesaid law to the present case, the Court observed that “it is evident that once a Competent Authority (quasi-judicial in nature) settles an issue, that determination attains finality unless it is set aside in accordance with law.”

Accordingly, the Court said that the second application filed before the quasi-judicial authority deserved to be dismissed, and subsequently set aside the High Court's order upholding the quasi-judicial body's second order.

In terms of the aforesaid, the Court allowed the appeal.

Case Title: M/S FAIME MAKERS PVT. LTD. VERSUS DISTRICT DEPUTY REGISTRAR, CO-OPERATIVE SOCIETIES (3), MUMBAI & ORS.

Citation : 2025 LiveLaw (SC) 379

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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