Introduction:

In the case of S.C. Gupta v. Union of India & Anr. (W.P.(C) 4462/2025), the Delhi High Court addressed the applicability of the doctrine of constructive res judicata to writ proceedings. The petitioner, S.C. Gupta, challenged Clause 3.3 of the “Guidelines for Grant of Reward to Informers and Government Servants, 2015,” asserting that the clause was unconstitutional and violated Articles 14 and 21 of the Indian Constitution. The clause in question allows the competent authority discretion in determining rewards on a case-by-case basis. Previously, the petitioner had contested the quantum of reward granted under these guidelines, but not the constitutionality of Clause 3.3 itself.

Arguments:

Petitioner’s Arguments:

The petitioner argued that Clause 3.3 was arbitrary and lacked clear criteria, leading to unequal treatment of informers. He contended that the discretionary power vested in the authorities resulted in inconsistent and unfair reward allocations, thereby violating the principles of equality and fairness enshrined in the Constitution. The petitioner emphasized that the clause’s vagueness allowed for potential misuse and discrimination.

Respondents’ Arguments:

The Union of India, represented by the Additional Solicitor General, contended that the petition was barred by the principle of constructive res judicata. They argued that the petitioner had the opportunity to challenge Clause 3.3 in the earlier litigation concerning the quantum of reward but failed to do so. Allowing the current petition would undermine the finality of judicial decisions and lead to repetitive litigation. The respondents maintained that the discretionary nature of Clause 3.3 was necessary to assess rewards based on the specifics of each case.

Court’s Judgment:

The Delhi High Court, comprising Chief Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela, held that the doctrine of constructive res judicata applies to writ proceedings. The court emphasized that while Section 11 of the Civil Procedure Code (CPC) pertains to suits, the underlying principles, including constructive res judicata, are rooted in public policy and aim to prevent multiplicity of litigation. The court cited the Supreme Court’s decision in Devilal Modi v. Sales Tax Officer, Ratlam (1964), which affirmed the applicability of res judicata to writ petitions.

The court noted that the petitioner had previously challenged the quantum of reward but did not contest the validity of Clause 3.3. Since the petitioner could have raised this issue in the earlier proceedings, the current petition was barred by constructive res judicata. The court underscored that permitting successive petitions on issues that could have been addressed earlier would lead to endless litigation and contravene the principles of finality and judicial efficiency.

Consequently, the court dismissed the writ petition, reaffirming the importance of raising all pertinent issues in the initial litigation to uphold the integrity of the judicial process.