The doctrine Res Judicata has evolved from the English Common Law. It plays a crucial role in Administrative law. This maxim is used to prevent the re-judgment of matters which have already been decided upon. This doctrine is also known as the “Rule of Conclusiveness of Judgment” is covered under Section 11 of the Civil Procedure Code.
This doctrine has been explained in the famous landmark case – Satyadhyan Ghosal v. Deorjin Debi. In the above-mentioned case, the judgment was given by Hon’ble Justice Das Gupta in which he said that “The principle of Res Judicata is based on the need of giving finality to the judicial decisions”, it was then established that in Doctrine of Res Judicata, no person could be disputed twice for the same reason, secondly it is the State that decides whether there should be an end to litigation and lastly that a judicial decision must be accepted as the correct decision.
In Daryao v. State of UttarPradesh the doctrine’s universal application established that under Article 226 of the Indian Constitution if a Writ Petition is dismissed by the High Court on its merits, it would be treated Res Judicata if a similar case is filed in the Supreme Court under Article 32 of the Indian Constitution. Similarly, in Devilal Modi v. Sales Tax Officer, it was concluded that since the petition filed in the supreme court was similar to that which was filed in the High Court consisting of the same parties and the High Court had already passed an order which was not challenged, the case filed under Article 32 was dismissed by the Hon’ble Judges. In the unusual case of Avtar Singh v. Jagjit Singh when the case was filed in the Civil Court, it was held that the case did not fall under the purview of its jurisdiction thereby dismissing it. When the same case was filed under the Revenue Court same decision was passed and lastly when again the case was presented before the Civil Court, this time it was dismissed on the basis of Res Judicata. On appeal to the High Court, it was held that if the defendant did not appear and the court by itself dismisses the plaint on the grounds of lack of jurisdiction the order may not be Res Judicata however if the defendant appeared after which the question of jurisdiction was raised it would appear to be Res Judicata if the suit was filed again in the same court. In Mathura Prasad v. Dossabai N.B. Jeejeebhoy, it was held that if the cause of action is different or the law is different although the decision is already made by the authority, the decision will be declared as valid but Res Judicata would not operate in the subsequent proceedings.